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IHM Myth Busters
The regulatory environment around the Inventory of Hazardous Materials (IHM) is entering a critical phase, and shipowners – especially those operating under the Liberian flag – need to get their facts straight if they want to avoid hefty costs and severe setbacks. There are a few key misconceptions. Let’s take the top five in turn and set the record straight.
The Hong Kong Convention is now active, meaning nearly 6,000 Liberia-flagged vessels must already carry a certified IHM Part I. Ships flagged by other Registries have until 26 June 2030, but compliance is necessary for vessels entering EU waters under EU SRR, or sailing in territories that have implemented the Convention, including Liberia.
Delaying is risky. During the EU SRR rollout, service costs rose sharply, and class societies and flag authorities faced an overload of files to approve, delaying certification. The same backlogs are expected as 2030 approaches, so shipowners should act early to avoid cost inflation, approval delays and compliance issues.
Carrying a certified and up-to-date IHM Part I is not optional. Port State Control authorities have issued fines of €50,000–€60,000 for non-compliance, and in some ports, ships have even been detained until hazardous materials sampling is completed, creating costly operational disruptions.
Certain regions require IHM documentation before a vessel enters territorial waters. If asbestos is detected, authorities may expect an additional asbestos-free certificate, adding time and cost.
Australian authorities, for example, do not require a certified IHM to be onboard but mandate independent verification surveys for certain hazardous materials, such as asbestos. If a vessel has an IHM, they use that document to fulfil the independent survey requirement. A vessel will be allowed in Australian waters even if it does not have an IHM Part-I onboard, provided it has an asbestos survey report.
In China, the UAE, and many EU countries, asbestos rules are already enforced at drydocks, and in European facilities, work may be refused entirely unless hazardous materials are removed by certified professionals.
An approved IHM Part I must be continuously maintained to keep certificates valid. Flag and Class bodies require evidence of maintenance at renewal, so shipowners need a formal procedure integrated into their Safety Management System and a designated IHM Responsible Person.
Service suppliers like Normec Verifavia must regularly review procurement orders and collect Material Declarations (MDs) and Supplier Declarations of Conformity (SDoCs) for all relevant item, even when no hazardous materials are present. All paints and coatings, equipment and machinery, and structure and hull falling under the scope of the regulation require documentation, and with suppliers charging €15–€20 per declaration, errors can be expensive.
The EU SRR and the Hong Kong Convention operate independently, each requiring its own certificate. Vessels trading exclusively in EU waters need only EU SRR certification, while ships sailing internationally must also hold an HKC certificate.
Although an EU SRR certificate can make obtaining the HKC certificate easier, the process is not automatic. Owners must submit their approved Statement of Compliance and maintenance records.
Conversely, HKC-certified ships can obtain EU SRR approval by demonstrating sampling and testing for additional restricted materials (PFOS and HBCDD), although the latter primarily applies to newbuilds.
IHM Part I divides hazardous materials into two categories: Table A, which lists materials that must be removed, and Table B, whose materials may remain but must be recorded.
Table A substances such as asbestos, PCBs, and ozone-depleting materials fall under strict international rules including SOLAS, the Stockholm Convention, and the Montreal Protocol.
While the overall structure is consistent between the HKC’s Tables A and B and the EU SRR’s Annex I and Annex II, the exact substances listed differ slightly in, making accurate documentation essential for compliance under both regimes.
