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EU Ship Recycling Regulation – further clarifications on IHM

Starting 31 December 2020, the EU Ship Recycling Regulation (EU SRR) will be applicable for vessels of 500 GT and above flying the flag of an EU/EEA member state, or third-party-flagged vessels calling at European ports. Those vessels will be required to carry an Inventory Hazardous Materials (IHM) on board which is certified. This statutory news clarifies some relevant IHM topics.

Relevant for ship owners and managers, yards, suppliers, design offices as well as flag states.

The following is a selection of most frequently asked questions received by DNV GL. For more information on IHM, please follow the links under "References" further down.  

Who will approve and certify the IHM?

DNV GL is authorized by most flag states to verify IHMs, taking into account the MEPC.269(68) IHM guidelines.

Who can prepare the IHM Part I?

The ship owner is responsible for the IHM Part I preparation of vessels in operation and may draw upon assistance from a hazmat expert. The hazmat expert can either be an individual from a third-party hazmat expert company or an employee of the ship owner who has received the proper training.

The hazmat experts prepare the IHM by taking samples and making visual checks on board based on the collected shipspecific information. It may take up to one month to generate the IHM Part I report for a single vessel due to the long waiting times between each step of preparation.

How to become a DNV GL-approved service supplier for IHM?

DNV GL offers a four-day approved hazmat expert course for individuals and professionals who would like to serve as IHM experts. The objective of the course is to qualify future hazmat experts who will be able to undertake a comprehensive preparation of IHM, including the development of VSCP (Visual Sampling Check Plan), sampling on board, and preparation of required documentation. Please check the DNV GL Academy’s website for current availability on the approved hazmat expert courses.

Who maintains the IHM?

The ship owner is responsible for the maintenance of IHM Part I, for which he can designate a person who may be employed ashore or on board. According to the EU SRR, the designated person must be qualified. DNV GL supports this task by organizing IHM and maintenance workshops.

IHM Part I shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing any hazardous materials referred to in Annex II of the EU SRR and any relevant changes in the structure and equipment of the ship

If any machinery or equipment or component is added, removed or replaced, or if the hull coating is renewed, the Material Declaration (MD) or Supplier’s Declaration of Conformity (SDoC) forms provided by the suppliers shall be properly filled out and Part I of the IHM shall be updated if the hazardous material situation of the vessel changes. Even if a supplied product does not contain any of the hazardous materials listed in Annex II of the EU SRR, an MD form still needs to be collected from the suppliers which states clearly the absence of the hazardous materials (ref. MEPC.269(68), Appendix 3, Chapter 3.2).

To ensure proper maintenance, the designated person should establish a procedure and supervise a system for proper implementation. The IHM procedure should be integrated into the safety management system.

For a smooth IHM Part I preparation and maintenance, DNV GL recommends its customers to use our smart software solution IHM Green Server (IGS). IGS is not restricted to DNV GL-classed ships and can be used for your whole fleet.

Who will verify if the IHM is maintained?

The IHM Part I certificate / SoC (Statement of Compliance) will be issued after the initial survey and then be subject to periodical checks by the flag states or ROs during the five-yearly renewal surveys and by port state controls during the PSC inspections. There is no annual survey scheme defined in the regulation.

The IHM certificate shall cease to be valid if the condition of the vessel does not correspond substantially with the particulars of that IHM certificate, including where IHM Part I materials has not been properly maintained and updated, reflecting changes in ship structure and equipment, taking into account the relevant IMO guidelines

If a PSC officer has clear grounds to believe that there is no procedure implemented on board the ship for the maintenance of IHM Part I, a detailed inspection may be carried out. The lack of the IHM certificate on board may be a reason for PSC detention.

What is the validity period of the SoC for non-EU-flagged vessels?

The EU SRR does not establish a period of validity for the SoC for third-party flags, unless so specified by the flag state. To date, some third-party flags have already informed DNV GL that they will follow the five-year validity period as specified for the EU/EEA-flagged vessels.

What to do for vessels going for recycling?

The EU regulation requires that if an EU, Norway or Icelandflagged vessel will be sent for recycling, it must obtain a Ready for Recycling certificate and shall be sent to facilities listed in the European List.

Prior to recycling, the IHM shall, in addition to the properly maintained and updated Part I, incorporate Part II for operationally generated waste and Part III for stores, and be verified by the administration or an RO authorised by it. The ship owner shall send the IHM to the selected ship recycling facility for the preparation of the ship recycling plan (SRP). During the final survey, the IHM and SRP will be verified on board and a Ready for Recycling certificate will be issued by the surveyor.


As IHM preparation of a vessel can be quite time-consuming, our recommendation is to start the process now and submit the IHM for approval before end-October 2020.



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