IHM approval and survey process

INSB Class may offer shipowners certification according to the Hong Kong Convention and/or to the EU Regulation irrespective of the current ships class, but only if and when INSB Class is so authorized by the Administration as its recognized organization.


  • INSB Class shall review and approve the IHM and shall issue an IHM approval letter;.
  • After successful approval, ship owner shall apply for an IHM initial survey on board ship to be carried out by an INSB Class surveyor;
  • After successful completion of the IHM initial survey, IHM certificate or Statement of Compliance will be issued by the surveyor with maximum 5 years validity in harmonization with the ship’s main class renewal date.

Engineering Review

Development of Part I of the Inventory for New Vessels

IHM submitted to INSB Class will be reviewed for compliance based on the following:

  1. The Inventory was prepared at the design and construction stage in the standard format set out in appendix 2 of Resolution MEPC.269(68). However, in this format there should be a reference stating tht the IHM has been developed to cover also the requirements of the EUSRR.
  2. Hazardous Materials listed in Appendices 1 and 2 meeting Regulation 4 and 5.1 of HKC and/or Annexes I and II meeting Article 5 of EUSRR.
  3. The Inventory corresponds to the information indicated on the Material Declaration and Supplier’s Declaration of Conformity.
  4. The Inventory identifies hazardous materials contained in ship structure, equipment and coating, along with the location and approximate quantity.
  5. Hazardous materials listed Table A-Materials listed in appendix 1 of the Annex to the Convention (and/or Annex I of EUSRR) are not used onboard the vessel above their threshold values, unless permitted by the Convention / Regulation.
  6. Hazardous materials listed in Table B -Materials listed in appendix 2 of the Annex to the Convention (and/or Annex II of EUSRR), when used onboard the ship above their threshold values, are reported in the Inventory.
  7. The Inventory contains diagrams showing the locations of materials listed in Table A - Materials listed in appendix 1 of the Annex to the Convention (and/or Annex I of EUSRR),
  8. A quality management system is established ensuring the quality and continuity of the IHM which includes the identity of the designated person, a system for maintaining and updating of the Inventory, records of new installations, repairs, maintenance and modifications to a ship or ship’s IHM designated person and records of changes to the Inventory. Proper maintenance of an archive of all the associated documentation should also be included and it should include that new installations of equipment, repairs and refittings are accompanied by a Material Declaration and the Supplier’s Declaration of Conformity, as provided by the suppliers of parts and equipment delivered.

Documents to be submitted for the review/approval of Part I of the Inventory for NEW VESSELS

Development of Part I of the Inventory for Existing Vessels

IHM submitted to INSB will be reviewed for compliance based on the following:

  1. The Inventory was prepared in the standard format set out in Appendix 2 of Resolution MEPC.269(68). However, in this format there should be a reference stating that the IHM has been developed to cover also the requirements of the EU SRR.
  2. Hazardous Materials listed in Appendices 1 and 2 meeting Regulation 4 and 5.2 of HKC and/or Annexes I and II meeting Article 5 of EUSRR
  3. The Inventory was prepared by/with the assistance of a HAZMART/expert accepted/approved by INSB Class (the /expert engaged has signed off on the visual/sampling check plan and the report of visual/sampling check)
  4. The Inventory corresponds with the visual/sampling check report.
  5. The Inventory identifies hazardous materials contained in ship structure, equipment and coating, along with the location and approximate quantity.
  6. The classification of items as “potentially containing hazardous material (PCHM)” are noted in the remarks column of the Inventory where applicable.
  7. Hazardous materials listed in Table A - Materials listed in appendix 1 of the Annex to the Convention (and/or Annex I of EUSRR), where present in quantities above the respective threshold values, are reported in the Inventory.
  8. Hazardous materials listed in Table B -Materials listed in appendix 2 of the Annex to the Convention (and/or Annex II of EUSRR), when used onboard the ship above their threshold values, are reported in the Inventory, as far as practicable
  9. The Inventory contains diagrams showing the locations of materials listed in Table A - Materials listed in appendix 1 of the Annex to the Convention (and/or Annex I of EUSRR),
  10. A quality management system is established ensuring the quality and continuity of the IHM which includes the identity of the designated person, a system for maintaining and updating of the Inventory, records of new installations, repairs, maintenance and modifications to a ship or ship’s IHM designated person and records of changes to the Inventory.

Documents to be submitted for the review/approval of Part I of the Inventory for EXISTING VESSELS

EU SRR IHM SoC for non EU flagged Ships with HKC IHM

For the vessels, which are flying the flag of a third country, and already have a Hong Kong Convention (HKC) compliant IHM, to get the EU SRR SoC, following is required:

  1. Up to date IHM must be submitted for approval in case the hazardous material situation of the vessel has changed

  2. IHM maintenance procedure of the vessel with supporting documents such as Material Declarations (MD) from suppliers

  3. Owners to confirm
    -  If the vessel has undergone any repairs or conversions and /or replaced any equipment or machinery or hull coating is renewed, etc. If yes, to submit the Material Declaration (MD) or Supplier’s Declaration of Conformity (SDoC) for that equipment or machinery etc. for review to verify that it does not contain Hazardous Materials listed in Table A and B of MEPC 269 (68)
    -  that the Material Declarations (MDs) & Supplier’s Declaration of Conformity (SDoC) for all the materials obtained during new construction of the vessel, based on which the IHM document was prepared, are readily available onboard

  4. Owners to state in their report that after the EU SRR SoC issuance, the maintenance of this IHM shall be done according to EU SRR. That means for the new installations the shipowner shall collect MDs with hazardous materials, including HBCDD. PFOS is not a requirement for non-EU flagged ships however it is strongly recommend the MD form with 15 hazardous materials to be used, including PFOS and HBCDD for future maintenance

  5. An IHM initial survey is required to verify the content. EU SRR Statement of Compliance can be issued after successful completion of the initial survey with maximum validity of 5 years in harmonization with the ship’s main class renewal date

In case IHM Part I has been prepared according to the IMO Resolution MEPC.197(62), since same has been superseded by the MEPC.269(68) the owners should use the currently valid guidelines for the threshold values of the Hazardous Materials and also for reference when preparing the maintenance procedure.