Materials to be listed in the IHM (as per HKC and EUSRR provisions)


  • Part I – hazardous materials inherent in the ship’s structure and fitted equipment;
  • Part II – operationally generated wastes;
  • Part III – stores.

The IHM Part I shall be prepared and certified for new ships and ships in operation and shall be maintained and kept up to date during the operational life of the ship, while the IHM Part II & III are only required to be prepared when the ship is decided to be sent for recycling. For the preparation of IHM Part I, hazardous materials set out in appendix 1 and 2 of the HKC or Annex I and II of the EUSRR shall be investigated.

In general, the IMO guidelines (MEPC.269(68) provide sufficient information for the development of the IHM in relation to the HazMats included in Appendices 1 and 2 of the HKC as well as an indicative list of these HazMats with CAS numbers and respective specific test methods. Therefore, for information on the HazMats included in Appendices 1 and 2 of the HKC and in Annexes I and II of the EUSRR reference should be made to the IMO guidelines.

The standard format of IHM

The inventory should be developed on the basis on the standard format set out in Appendix 2 of the IMO guidelines (MEPC.Res.269(68)). 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 new ships all the hazardous materials listed in Appendix 1 & 2 or Annex I & II shall be investigated, while for ships in operation, Appendix 1 / Annex I is a must and Appendix 2 / Annex II is to be investigated as far as practicable.

HM classified under tables A, B, C or D

MEPC.269(68)/Appendix 1 : -Items to be listed in the Inventory of Hazardous Materials-, provides information on the hazardous materials that may be found on board a ship. Materials set out in MEPC.269(68)/Appendix 1 should be listed in the Inventory. Each item in Appendix 1 is classified under Tables A, B, C or D, according to its properties:

  1. Table A Hazardous materials to be prohibited;
  2. Table B Hazardous materials to be controlled;
  3. Table C (Potentially hazardous items) comprises items which are potentially hazardous to the environment and human health at ship recycling facilities; and
  4. Table D (Regular consumable goods potentially containing hazardous materials) comprises goods which are not integral to a ship and are unlikely to be dismantled or treated at a ship recycling facility.

Tables A and B correspond to Part I of the Inventory. Table C corresponds to Parts II and III and Table D corresponds to Part III

For loosely fitted equipment, there is no need to list this in Part I of the Inventory. Such equipment which remains on board when the ship is recycled should be listed in Part III.

Those batteries containing lead acid or other hazardous materials that are fixed in place should be listed in Part I of the Inventory. Batteries that are loosely fitted, which includes consumer batteries and batteries in stores, should be listed in Part III of the Inventory.

Similar materials or items that contain hazardous materials that potentially exceed the threshold value can be listed together (not individually) on the IHM with their general location and approximate amount specified there (hereinafter referred to as "bulk listing").

Materials not required to be listed in the Inventory

Materials listed in Table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.

Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.

Threshold values of HM included in the IHM Part I

HM should be reported in the IHM when the material is present in the product above the applicable threshold value. However, when there is no specified threshold value for a HM (i.e.: Ozone Depleting Substances or Radioactive substances) then it should be reported in the IHM when deliberately used in the formulation of a product where its continued presence is desired to provide a specific characteristic, appearance, property, attribute or quality regardless of quantity. Suppliers should report such substances when they have knowledge (or with reasonable inquiry should have knowledge) of their presence.

As a general principle, unless expressly provided otherwise in the relevant legislation, revised threshold values for the materials to be listed in the IHM Part I, should be used for IHM developed or updated after the adoption of the revised values and need not be applied to existing IHM and IHM under development. However, when materials are added to the IHM, such as during maintenance, the revised threshold values should be applied and recorded in the IHM.

Annex B of "EMSA's best practice guidance on the inventory of hazardous materials" provides information on the HM that should be listed in the IHM Part I, the relevant threshold values and the referenced EU legislation which may be of relevance to the respective HM.