For standard format of IHM refer to Appendix 2 of IMO Res. MEPC.269(68) "2015 Guidelines for the development of the inventory of hazardous materials". However, in this format, there should be a reference stating that the IHM has been developed to cover also the requirements of EUSRR. This would entail that the Inventory would keep the classification of Materials according to the IMO guidelines with the addition of two HM (PFOS and HBCDD) as appropriate.
For materials to be listed in the IHM Part I refer to Annex B of "EMSA's best practice guidance on the inventory of hazardous materials" or Appendix 1 of Hong Kong Convention, if applicable.
Supplier is a company which provides products; which may be a manufacturer, trader or agency. Supply chain means the series of entities involved in the supply and purchase of materials and goods, from raw materials to final product.
The suppliers are responsible to identify and declare whether or not their equipment, products, materials and systems contain hazardous materials by providing Declaration of Conformity (SDoC) and Material Declarations (MD) .
In some cases supplier should request their companies from the supplier chain the relevant information if the supplier itself cannot develop the MDs based on the information available.
Every MD shall be accompanied by a SDoC.
Supplier’s Declaration of Conformity (SDoC) and Material Declarations (MD)
Suppliers should identify and declare the presence of a HM included in the Annex II of the EUSRR if it exceeds the threshold value specified in Annex B of "EMSA's best practice guidance on the inventory of hazardous materials" (or table B of Appendix I of IMO Res. MEPC.269(68)). However, this provision does not apply to chemicals which do not constitute a part of the finished product.
Suppliers should provide their customers with Supplier’s Declarations of Conformity and Material Declarations in any case even when no HM are contained above the applicable threshold values.
However, due regard should be given to include in the IMO/MD form a supplement with a reference to the presence (or absence) of the two additional HM (PFOS22 and HBCDD) included only in Annexes I and II of the EUSRR. (PFOS is not applicable for ships flying the flag of a third country).
For standard format of MD refer to Appendix 6 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials".
For standard format of SDoC refer to Appendix 7 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials".
Sampling and analysis
The overall objective of any sampling activity is to obtain a sample which can be used for the targeted purpose i.e. to identify the presence or absence of HM contained in the equipment, systems, and/or areas on board a ship by suitable and generally accepted methods such as laboratory analysis.
Sampling and analysis should comply with specific national legislation where it exists and with international standards. The whole process should be in accordance with the provisions of this guidance and the IMO guidelines.
Due diligence should be exercised when undertaking any work on sampling and analysis. The sampling activity involves certain risks to personnel involved or to other persons on board. Therefore, sampling should only be undertaken by competent personnel i.e. IHM experts, with the proper use of suitable equipment. Furthermore, analysis of the samples should only be carried out by suitably accredited laboratories using qualified and trained personnel, suitable testing methods and the necessary equipment.
Sampling should be carried out in accordance with a pre-decided methodology and supported by an appropriate check plan.
Standard working procedures for sampling (sampling methodology) should be established and agreed upon before the start of the sampling campaign. The sampling methodology should include the following:Determine on a ‘targeted’ or ‘random’ sampling campaign or both
Targeted sampling should be applied where
the presence of prohibited and restricted Hazardous
Materials is assumed but cannot be recognized by analysis of
the available documentation or visual maintenance Part l
Random sampling may be applied where the
presence of prohibited and restricted Hazardous Materials
has been excluded by document analysis but either there are
suspicions of existence of HM or there is a policy for
performing random checks as a quality assurance procedure.
Targeted sampling should take place during the preparation of the IHM of an existing ship in accordance with the relevant procedure of the IMO guidelines and should include any equipment, system and/or area which cannot be specified regarding the presence of HM by document or visual analysis except those which shall be classed as ‘Potentially Containing HM’ (PCHM).
Random sampling may be used as a quality assurance process and may take place for new ships during the design and construction stage, on existing ships during the initial preparation of the IHM along with targeted sampling or on any ship after the initial preparation of the Inventory.
Identity of the sampler/IHM expert
Preparation of a ‘visual/sampling check plan’ (VSCP) or of ‘random checking plan’ (RCP) as appropriate.
The estimated number of samples to be taken, the types of samples to be chosen and a description of or reference to the sampling method. As a general rule, the samples should be representative of the materials being checked and in sufficient numbers. As guidance the rule of 10% may be established meaning that roughly 10% of the components of any system identified for a sampling check should be sampled. However, taking of samples and the number of samples to be taken should always be determined according to the professional judgement of the entity carrying out the HM survey and proper/pragmatic ceilings in the number of samples should be established per each product or system. Materials of the same kind may be sampled in a representative manner.
Selection of location (checkpoints), date of sample-taking and the overall duration of the sampling campaign. It should be noted that the sampling campaign may be adjusted and other sampling points may be identified during the survey according to the actual conditions on-board and in accordance with the professional judgement of the IHM expert.
A risk assessment for the HM survey using all the information available before the sampling (MD, SDoC, certificates, plans, diagrams, manuals, other information etc). This assessment should determine the existing risks (e.g. chemical hazards, electrical hazards, working in closed spaces, at heights or on operable machinery, noise, disturbing sampling, necessary PPE, decontamination and disposal arrangements etc). The risk assessment should then identify the necessary precautions and safety procedures to be followed during the HM survey and sampling.
Labelling which gives detailed information or a specific sample code that cannot be removed easily. The sampling position on board may also be labelled with the same identifier. Marked-up ship plans and photographic records should be kept showing the location and extent of the sample.
Preservation of the integrity of samples during transport and storage (before analysis).
Close cooperation between the sampler and the accredited laboratory and establishment of quality assurance and quality control (QA/QC) procedures (e.g. appropriate sampling containers, blank samples, blind Samples etc). It is essential to consult with the accredited laboratory before sampling to ensure that the measurement methods available can meet the defined sampling needs.
Development of Part I of the Inventory for Newbuild ships
The builder/fabricator is responsible for the IHM compilation throughout the design and construction process using information obtained from collected Material Declarations (MD) and Supplier Declarations of Conformity (SDoC).
According to the Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials, the ‘MD and SDoC for products from [direct] suppliers (tier 1 suppliers) should be requested and collected by the shipbuilding yard. Tier 1 suppliers may request from their suppliers (tier 2 suppliers) the relevant information if they cannot develop the MD based on the information available. Thus the collection of data on hazardous materials may involve the entire shipbuilding supply chain’ (see below Figure “Process of MD (and SDoC) collection showing involvement of supply chain”), taken from Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials.
Process of MD (and SDoC) collection showing involvement of supply chain
For the example of the development process for the IHM Part I for new ships refer to Appendix 3 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials", requiring the steps to be followed by the shipyard:
However, the order of these steps is flexible and can be changed depending on the schedule of shipbuilding.
The shipyard is to complete the development of Part I of the Inventory based on the information provided by the supplier or other supporting documents collected according to the following categorization:
- Paints and coating systems;
- Equipment and machinery; and
- Structure and hull
The location plan can be presented, either as list, or as a drawing enabling clear identification of the location of hazardous materials.
The equipment, machinery, structural element or coatings for which the SDoC and MD indicate they do not contain hazardous material are not to be listed in the IHM Part I.
IHM must cover the whole ship structure and equipment. There should be no items specified as “unknown”.
If one or more materials listed in Table A (IMO) / Annex I (EUSRR), of Annex 1/Appendix I, are found in concentrations above the specified threshold value according to the MD provided by the supplier, the shipyard is to refuse the use of the product and inform the supplier to replace it with the one complies with the specifications and provide the updated MD and SDoC. However, if the materials are used in a product in accordance with an exemption specified by the Convention (e.g., new installations containing hydrochlorofluorocarbons(HCFCs) before 1 January 2020), the quantity and location of the product on the ship are to be listed in the Inventory.
If materials listed in Table B (IMO) / Annex II (EUSRR), of Annex 1/Appendix I are present in products above the threshold values provided in Table B, the quantity and location of the products and the contents of the materials present in them are to be listed in the Inventory.
The shipyard is to establish written procedures for purchasing and controlling the supply of asbestos free material, equipment and components.
INSB Class Certification for Newbuild ships
The shipyard is responsible to submit the IHM Part I, with pertinent SDoCs and MDs and results of the random sampling to INSB Class and to formally confirm correctness of the final IHM.
INSB Class shall review submitted documents and, if found satisfactorily, shall assign approval status. Review should be based on sampling verification of the submitted documents.
Upon approval of the documents, Initial survey should be conducted on-board ship by INSB Class surveyors, by verifying that the IHM, especially the location of hazardous materials, is consistent with the arrangements, structure and equipment of the ship, before Certificate / Statement can be issued.
Also, the survey shall verify that the IHM Part I, as submitted, reflects the actual state on-board and that it is actually placed on-board.
The Initial survey of a new ship shall be conducted before the ship is put in service, or before the inventory certificate is issued. In the case that no suitable documents are available for particular item of equipment of material, supplementary sampling and testing may also be requested.
Development of Part I of the Inventory for existing ships
The shipowner is responsible for the compilation of the IHM who may draw upon expert assistance.
According to Resolution MEPC.269(68) "2015 Guidelines for the Development of the Inventory of Hazardous Materials", the following process (summarised in below Figure “Flow diagram for developing Part I of the IHM for existing ships” taken from Resolution MEPC.269(68) should be followed to compile the IHM for an existing ship:
Step 1: collection of necessary information
Step 2: assessment of collected information
Step 3: preparation of visual / sampling check plan
Step 4: on-board visual checking and sampling check
Step 5: preparation of the IHM Part I and related documentation
Flow diagram for developing Part I of the IHM for existing ships
Below chart is EMSA's Guidance, with red are the difference approaches from IMO
For the example of the development process for the IHM Part I for existing ships refer to Appendix 5 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials".
For EUSRR compliance for EU/EEA flagged vessels, PFOS must be investigated and HBCDD shall be investigated as far as practicable.
Step 1: Collection of necessary information
Requirements stated in para. 4.2.5 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials" should be followed.
The shipowner is to collect all documentation regarding the ship, including maintenance, conversion, and repair documents; certificates, manuals, ship’s plans, drawings, and technical specifications; product information data sheets (such as MD and SDoC); and hazardous material inventories or recycling information from sister ships from all sources of information such as shipyard, classification society, previous shipowner and Ship Recycling Facility.
The reasonably available documentation and information include but not limited to:
- Ship's specification
- General Arrangement
- Machinery Arrangement
- Spare Parts and Tools List
- Piping Arrangement
- Accommodation Plan
- Fire Control Plan
- Fire Protection Plan
- Insulation Plan (Hull and Machinery)
- International Anti-Fouling System Certificate
- Related manuals and drawings
- Information from other inventories and/or sister or similar ships, machinery, equipment, materials and coatings
- Results of previous visual/sampling checks and other analysis
If the ship has undergone conversions or major repair work, it is necessary to identify as far as possible the modifications from the initial design and specification of the ship.
As it will not be feasible to check all the equipment, system and/or areas on-board to determine presence of hazardous materials an indicative list should be prepared by the shipowner identifying equipment, system and/or areas that are presumed to contain hazardous materials.
Step 2: Assessment of collected information
Requirements stated in para. 4.2.6 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials" should be followed.
The assessment is to cover all materials listed in Table A (IMO) / (Annex I (EU).-PFOS is not applicable for ships flying the flag of a third country-. The assessment of the materials listed in Table B (IMO) / (Annex II (EU), is not mandatory, but they are to be listed as far as practicable.
Information collected in step 1 above should be assessed. Preparation of a checklist may be an efficient method for developing the IHM Part I in order to clarify results for each step.
Each listed equipment, system, and/or area on board is to be analysed and assessed for its Hazardous Materials content.
The existence and volume of Hazardous Materials may be judged and calculated from the Spare parts and tools list and the Maker’s drawings. The existence of asbestos contained in floors, ceilings and walls may be identified from Fire Protection Plans, while the existence of TBT in coatings can be identified from the International Anti-Fouling System Certificate, Coating scheme and the History of Paint.
The results of the assessment should be reflected in the VSCP which is to be developed.
Step 3: Preparation of visual / sampling check plan (VSPC)
Requirements stated in para. 4.2.7 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials" should be followed.
VSPC is intended for targeted sampling and visual checking aiming at locating and identifying equipment,machinery, systems and areas on-board ship containing or potentially containing hazardous materials.
VSPC should be based on the following three lists:
- list of any equipment, system and/or area, -specified regarding the presence of the materials listed in Appendix 1 / Annex I by document analysis-, for visual check;
- list of equipment, system and/or area -which cannot be specified regarding the presence of the materials listed in Appendix 1 / Annex I by document or visual analysis- for sampling check; and
- list of equipment, system and/or area, (any equipment, system and/or area which cannot be specified regarding the presence of the materials listed in Appendix 1 / Annex I by document analysis, classed as "potentially" containing hazardous materials. The prerequisite for this classification is a comprehensible justification such as the impossibility of conducting sampling without compromising the safety of the ship and its operational efficiency
Each list should contain the indication of the location of listed equipment, machinery, systems and areas.
A sampling check is taking of samples to identify the presence or absence of hazardous material contained in the equipment, systems, and/or areas, by suitable and generally accepted methods such as laboratory analysis by the accredited laboratory.
Visual / sampling checkpoints should be all points where the presence of the materials to be considered for the IHM Part I, as listed in Appendix 1 of IMO Res. MEPC.269(68) / listed in Annex B of "EMSA's best practice guidance on the inventory of hazardous materials", is likely, the documentation is not specific or materials of uncertain composition were used.
To prevent any incidents during the visual/sampling check, a schedule is to be established to eliminate interference with other ongoing work on board. To prevent potential exposure to Hazardous Materials during the visual/sampling check, safety precautions are to be in place on board. For example, sampling of potential asbestos containing materials could release fibres into the atmosphere. Therefore, appropriate personnel safety and containment procedures are to be implemented prior to sampling.
Items listed in the visual/sampling check should be arranged in sequence so that the onboard check is conducted in a structured manner (e.g. from a lower level to an upper level and from a fore part to an aft part).
To preclude the introduction of non-compliant components into a vessel’s structure or equipment after the inventory for the ship is prepared, the visual/sampling check plan is to include checking of spare parts onboard the ship that may be used for the vessel’s structure or equipment.
If any of the spare parts for the vessel’s structure or equipment onboard the ship are found to contain materials listed in Appendix 1, Table A or B (EMSA Annex B) above their respective threshold values, these spare parts are to be documented in an appendix to Part I of the IHM. When these spare parts are used, Part I of the IHM is to be updated accordingly.
Step 4: On-board visual checking and sampling check
Requirements stated in para. 4.2.8 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials" should be followed.
Visual / sampling check should be carried out according to VSPC. Visual / sampling check should be performed by IHM expert.
Any uncertainty regarding the presence of hazardous materials should be clarified by visual / sampling check. Checkpoints should be documented in the ship’s plan and may be supported by photographs.
When sampling check is carried out, samples should be taken and sample points should be clearly marked on the ships plan and the sample plan should be referenced.
If the equipment, system and/or area of the ship are not accessible for a visual check or sampling check, they should be classified as "potentially containing hazardous material". The prerequisite for such classification should be the same prerequisite as above. Any equipment, system and/or area classed as "potentially containing hazardous material" may be investigated or subjected to a sampling check at the request of the shipowner during a later survey (e.g. during repair, refit or conversion).
The results of visual / sampling checks should be recorded in the checklist.
A person taking samples is to be protected by the appropriate safety equipment. Appropriate safety precautions are also to be in place for passengers, crew members and other persons on board, to minimize the potential exposure to hazardous materials. Safety precautions could include the posting of signs or other verbal or written notification for personnel to avoid such areas during sampling. The personnel taking samples is to ensure compliance with relevant national regulations.
Samples may be tested by a variety of methods when it is suspected that one or more hazardous materials listed in Table A (IMO) / (Annex I (EUSRR) ) are present in the product “Indicative” or “field tests” may be used when the likelihood of a hazard is high, the test is expected to indicate that the hazard exists and the sample is being tested by “specific testing” to show that the hazard is present. Indicative or field tests are quick, inexpensive and useful on board the ship or on site, but they cannot be accurately reproduced or repeated, and cannot identify the hazard specifically,and therefore cannot be relied upon except as “indicators”. In all other cases, and in order to avoid dispute, “specific testing” is to be used. Specific tests are repeatable, reliable and can demonstrate definitively whether a hazard exists or not. They will also provide a known type of the hazard. Specific tests are to be carried out by a recognized testing organization accepted by INSB.
Step 5: Preparation of the IHM Part I
Requirements stated para. 4.2.9 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials" should be followed.
For standard format of IHM refer to Appendix 2 of IMO Res. MEPC.269(68), "2015 Guidelines for the development of the inventory of hazardous materials".
For materials to be listed in the IHM Part I refer to Annex B of "EMSA's best practice guidance on the inventory of hazardous materials" (or to Hong Kong Convention, if applicable).
The IHM Part I should be prepared by the shipowner from:
- VSPC; and
- results of visual / sampling check
The IHM Part I should list all equipment, systems and/or areas or coatings for which:
- a document analysis has indicated that they contain hazardous materials
- a sampling analysis has indicated that they contain hazardous materials; and
- no document analysis and no sampling analysis could be carried out
The following information should be included for all equipment, systems and/or areas or coatings listed in the IHM Part I:
- location on-board the ship (the location plan can be presented, either as list, or as a drawing enabling clear identification of the location of hazardous materials);
- laboratory report, if any, with testing results of samples; and
- the approximate quantity of hazardous materials estimated from the document analysis or sampling analysis or, where no document and sampling analysis could be carried out, the approximate quantity or volume of the equipment, systems, structural elements or coatings and the indication of "potentially containing hazardous material"
Example of location diagram of hazardous materials
Once the IHM and IHM inspection report is ready, shipowner shall submit the IHM report to INSB for approval and verification.
INSB Certification for existing ships
Once the IHM and IHM inspection report is ready, shipowner shall submit the IHM report and relevant documentation to INSB for approval and verification (click here for the required documents)
INSB shall review submitted documents and, if found satisfactorily, shall assign approval status. Review should be based on sampling verification of the submitted documents.
Upon approval of the documents, Initial survey should be conducted on-board ship by INSB surveyors, by verifying that the IHM, especially the location of hazardous materials, is consistent with the arrangements, structure and equipment of the ship, before Certificate / Statement can be issued.
Also, the survey shall verify that the IHM Part I, as submitted, reflects the actual state on-board and that it is actually placed on-board.
In the case that no suitable documents are available for particular item of equipment of material, supplementary sampling and testing may also be requested.
Maintenance of IHM Part I
Shipowner's responsibility and IHM Designated person
It is the owner's responsibility to keep the Inventory of Hazardous Materials Part I up to date. Part I of the Inventory shall be appropriately maintained and updated especially after any repair or conversion of a ship. An IHM maintenance procedure shall be implemented including the assignment of a designated person, by keeping records of changes.
According to Resolution MEPC.269(68) – 2015 "Guidelines for the Development of the Inventory of Hazardous Materials”, shipowners should implement the following measures in order to ensure the conformity of Part I of the Inventory:
- to designate a person as responsible for maintaining and updating the Inventory (the designated person may be employed ashore or on board);
- the designated person should establish and supervise a system to ensure the necessary updating of the Inventory in the event of new installation;
- to maintain the Inventory including dates of changes or new deleted entries and the signature of the designated person;
- to provide related documents as required for the survey or sale of the ship;
According to the EUSRR, the designated person must be qualified.
Quality Management System
The duties of the designated person should be incorporated in the shipowner’s quality/safety management system and should be clearly described in writing taking into account that keeping an updated IHM may be a simplified process but it might also become quite demanding e.g. if a major conversion or extensive repair works are undertaken.
The shipowner is also to establish written procedures for purchasing and controlling the supply of asbestos free material and components for repairs, modifications and maintenance.
Moreover, the quality management system should identify the procedures to safeguard the proper updating of the IHM during scheduled or unscheduled works involving changes, replacements or repairs to the structure, equipment, systems, fittings, arrangements and material, which has an impact on the Inventory.
If any machinery or equipment or component is added to, removed or replaced or the hull coating is renewed, the MD/SDoC forms provided by the suppliers shall be properly filed and Part I of the IHM shall be updated. Updating is not required if identical parts or coatings are installed or applied.
During the IHM renewal survey updated IHM together with maintenance records will be checked by the surveyors.
A procurement policy should request any items supplied to the ship are accompanied by a completed MD and SDoC as per Resolution MEPC. 269(68) and the EMSA best practice guidance if inclusion of EU SRR hazards is required.
Material Declarations and Supplier Declarations of Conformity
MDs and SDoCs are required to be collected for all items brought on board the ship that will or could be part of the ships structure and fitted equipment – even if they contain no hazardous materials.
Unique MD and SDoC should be requested for each individual equipment type brought on board the ship.
Multiple units of the same piece of equipment can be covered under a single MD and SDoC.
IHM Surveys / Certificate (SOC) / PSC
Any relevant changes in ship structure and equipment, especially after any repair or conversion or sale of a ship, should be recorded by the shipowner and reported to INSB Class.
If there are any amendments to the IHM Part I due to the mentioned above changes, the revised IHM Part I, together with MD & SDoC shall be re-approved by INSB Class prior to an additional survey (or periodical survey) for endorsement of the Certificate (or Statement of Compliance), as applicable.
In case of where such changes have no impact on the IHM Part I*, it is required to keep the relevant MD and SDoC onboard a ship without re-approval.
* When one or more hazardous materials are found to be present in concentration below the specified threshold value according to the MD
The IHM Certificate (or Statement of Compliance), shall cease to be valid if the condition of the vessel does not correspond substantially with the particulars of that IHM certificate/SoC, including where IHM Part I materials has not been properly maintained and updated, reflecting changes in ship structure and equipment, taking into account the relevant IMO guidelines.
If a PSC officer has clear grounds to believe that there is no procedure implemented on board the ship for the maintenance of IHM Part I, a detailed inspection may be carried out.
Continuity of Part I of the Inventory
Part I of the Inventory should belong to the ship and the continuity and conformity of the information it contains should be confirmed, especially if the flag, owner or operator of the ship changes.
It is standard international practice and a provision of IMO international instruments that the relevant certificates cease to be valid upon transfer of the ship to the flag of another State.
See detailed requirement in subsections 4.1.2 to 4.1.4 of the IHM Guidelines (Resolution MEPC.269(68)) and Article 5 in EUSRR 1257/2013.
Shipowners may have implemented the procedure based on HKC and it is suggested to review and advance the procedure to EUSRR.