Earlier this year, IMO adopted a resolution including the 2023 Guidelines for the development of the Inventory of Hazardous Materials (IHM) to ensure compliance with regulation 5 of the Hong Kong Convention.
To remind, on 26 June 2023, Liberia ratified the Hong Kong Convention, thereby fulfilling the criteria for entry into force of the Convention. Upon entry into force on 26 June 2025, the Hong Kong Convention will require new ships and existing ships of 500 GT and above no later than 5 years after the entry into force of the Convention, or before going for recycling, if this is earlier, to have onboard a valid International Certificate on IHM.
The objectives of the IHM under the Hong Kong Convention is to document ship-specific information on the actual hazardous materials present on board in order to protect health and safety of the crew, and to protect health and safety of workers at ship recycling facilities and avoid environmental pollution when the ship is going for recycling.
According to the IMO Circular the following five (5) steps are important for IHM:
Step #1 : Collection of necessary information
The shipowner should identify, research, request and procure all reasonably available documentation regarding the ship. Information that will be useful includes maintenance, conversion and repair documents; certificates, manuals, ship’s plans, drawings and technical specifications; product information data sheets (such as Material Declarations); and hazardous material inventories or recycling information from sister ships. Potential sources of information could include previous shipowners, the shipbuilder, historical societies, classification society records and ship recycling facilities with experience working with similar ships.
Step #2 Assessment of collected information
The information collected in step 1 above should be assessed. The assessment should cover all materials listed in table A of appendix 1 (see pdf below); materials listed in table B should be assessed as far as practicable. The results of the assessment should be reflected in the visual/sampling check plan.
Step #3: Preparation of visual/sampling check plan
To specify the materials listed in appendix 1 of these guidelines, a visual/sampling check plan should be prepared taking into account the collated information and any appropriate expertise. The visual/sampling check plan should be based on the three lists (see pdf below for more details)
Visual/sampling checkpoints should be all points where:
- the presence of materials to be considered for the Inventory part I as listed in appendix 1 is likely;
- the documentation is not specific; or
- materials of uncertain composition were used
Step #4 Onboard visual/sampling check
The onboard visual/sampling check should be carried out in accordance with the visual/sampling check plan. When a sampling check is carried out, samples should be taken and the sample points should be clearly marked on the ship plan and the sample results should be referenced. Materials of the same kind may be sampled in a representative manner. Such materials are to be checked to ensure that they are of the same kind. The sampling check should be carried out drawing upon expert assistance.
Any uncertainty regarding the presence of hazardous materials should be clarified by a visual/sampling check. Checkpoints should be documented in the ship’s plan and may be supported by photographs.
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”. 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.
Step #5 Preparation of part I of the Inventory and related documentation
If any equipment, system and/or area is classed as either “containing hazardous material” or “potentially containing hazardous material”, their approximate quantity and location should be listed in part I of the Inventory. These two categories should be indicated separately in the “Remarks” column of the Inventory.
