IHM Service

In order to protect human health and the environment from the risks posed by hazardous substances on board ships, the International Maritime Organization (IMO) and the European Union (EU) have introduced regulatory frameworks governing ship recycling, notably the International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention) and the EU Ship Recycling Regulation. Both instruments require ships to carry an Inventory of Hazardous Materials (IHM) identifying the location and approximate quantities of hazardous materials contained in the vessel’s structure and equipment.

The EU Ship Recycling Regulation has been fully applicable since 31 December 2020, while the Hong Kong Convention entered into force on 26 June 2025, establishing mandatory global requirements for safe and environmentally sound ship recycling.

Beyond its initial preparation and certification, the IHM must be properly maintained throughout the ship’s operational life. Shipowners are required to update Part I of the IHM whenever hazardous materials are added, removed, or replaced, including during repairs, retrofits, or coating renewals. This requires appropriate procurement controls to obtain Material Declarations and Supplier’s Declarations of Conformity from suppliers and to ensure that any changes are reflected in the IHM documentation.

Following the Convention’s entry into force, the IMO updated the Guidelines for the Development of the IHM (Resolution MEPC.379(80), as amended by Resolution MEPC.405(83)) to include additional substances of concern. In particular, cybutryne — a biocidal compound used in certain anti-fouling systems — must now be identified and recorded in the IHM where present, further underscoring the importance of continuous and accurate IHM maintenance.