IHM and ship recycling

To be in compliance, we strongly recommend that you request for the IHM initial survey as soon as possible. DNV may, depending on flag and other criteria, perform the initial survey remotely. Select RR 1051b in the scope and then select the option “remote” if this appears as an option. If a remote survey is not possible, a normal attendance survey is required.

There are two main legislations with respect to ship recycling in the market, one is IMO Hong Kong Convention (HKC) SR/CONF/45 and the other one is the EU Ship Recycling Regulation (EU SRR) EC No 1257/2013. HKC has in total 6 guidelines and MEPC.269(68) is the guidelines for the development of the inventory of hazardous materials (IHM) under IMO.

The HKC will enter into force in June 2025.

• Inventory of hazardous materials (IHM)
• Authorization of ship recycling facilities

The EU SRR has entered into force in 2013 and general application has started at the end of 2018. Same as the HKC, EU SRR is applicable for ships, operating in the marine environment, which are equal to or above 500 GT. Navy ships and domestic ships are excluded from the scope. The EU SRR has two key issues

• Inventory of hazardous materials (IHM)
• EU List of approved ship recycling facilities

According to the EU SRR;

a) New ships flying a flag of an EU member state, shall be delivered with a valid IHM which is certified;

b) End-of-life ships going for recycling shall have a valid IHM certified and shall be sent to one of the recycling facilities in the EU List of approved ship recycling facilities.

c) Existing ships flying the flag of an EU member state and third-party ships visiting EU ports and anchorages, from 31 December 2020, shall have a valid IHM on-board, which is certified.

“New ship” means a ship for which either:

(a) the building contract is placed on or after the date of application of this Regulation;

(b) in the absence of a building contract, the keel is laid or the ship is at a similar stage of construction six months after the date of application of this Regulation or thereafter; or

(c) the delivery takes place thirty months after the date of application of this Regulation or thereafter.

IHM is a list that provides ship-specific information on the actual hazardous materials present on board, their location and approximate quantities. The IHM has following parts:

• I. Materials contained in ship structure or equipment
• II. Operationally generated wastes, and
• III. Stores

The IHM Part I shall be prepared and certified for new ships and ships in operation and shall be maintained and kept up to date during the operational life of the ship, while the IHM Part II & III are only required to be prepared when the ship is decided to be sent for recycling. For the preparation of IHM Part I, hazardous materials set out in appendix 1 and 2 of the HKC or Annex I and II of the EU SRR shall be investigated.

IHM Part I for new ships should be developed at the design and construction stage based on suppliers’ declarations on hazardous material content of the products. The determination of hazardous materials present on board existing ships should, as far as practicable, be conducted as prescribed for new ships. Alternatively, in case where documentation is not available, samples shall be taken from the ships to investigate on the hazardous materials.

For new ships all the hazardous materials listed in Appendix 1 & 2 or Annex I & II shall be investigated, while for ships in operation Appendix 1 / Annex I is a must and Appendix 2 / Annex II is to be investigated as far as practicable.

Based on our newly published DNV Statutory Interpretation on IHM:

“The study of documents for inspection of Annex II of EU SRR-listed hazardous materials is considered 'as far as practicable'. For testing of Annex II of EU SRR listed substances it is considered 'as far as practicable' using samples already taken for testing of Annex I of EU SRR listed substances.”

For instance, the cable samples already taken to analyse PCB (Annex I substance) can be analysed for PBB/PBDE; paint samples taken can be analysed for PCN; vinyl cover floor samples taken for asbestos and PCB can be analysed CSCCPs.

Appendix 2 to the HKC or Annex II of EU SRR listed hazardous materials can also be identified through available documents or visual checks such as checking the label of the batteries for lead; or smoke detectors for radioactive substances. In case those materials are tested and analysed at a sister vessel, as long as visually proven, the analyses result of the sister vessel can be used for the inspected vessel, as a reliable document.

EU SRR is aimed at facilitating early ratification of HKC with higher requirements on control of hazardous materials and approval of ship recycling facilities. Concerning the IHM preparation, in addition to Appendix 1 and 2 of the HKC which lists 13 hazardous materials, two additional hazardous materials have been added by the EU SRR, namely Perfluorooctane Sulfonic Acid (PFOS) and Brominated Flame Retardant (HBCDD). PFOS is listed in Annex I and shall be identified for the ships that are flying a flag of an EU Member State. HBCDD is listed in Annex II and shall be identified for existing ships as far as practicable.

EU SRR is implemented in Norwegian legislation through the European Economic Area (EEA) Agreement – in Regulation 2018-12-06 No. 1813. (The Norwegian regulation is available at: https://lovdata.no/dokument/SF/forskrift/2018-12-06-1813?q=forskrift%20om%20gjenvinning%20av%20skip)

The European Economic Area (EEA) unites the EU Member States and the three EEA EFTA States (Iceland, Liechtenstein, and Norway) into an Internal Market governed by the same basic rules.

With the DECISION OF THE EEA JOINT COMMITTEE (No 257/2018) of 5 December 2018 amending Annex XIII (Transport), Annex XX (Environment) to the EEA Agreement shall be amended as follows:

1. The following indent is added in point 32c (Regulation (EC) No 1013/2006 of the European Parliament and of the Council):

• 32013 R 1257: Regulation (EU) No 1257/2013 of the European Parliament and of the Council of 20 November 2013 (OJ L 330, 10.12.2013, p. 1).

2. The following point is inserted after point 32fg (Commission Implementing Decision 2011/632/EU):

• 32fh. 32013 R 1257: Regulation (EU) No 1257/2013 (EU SRR) of the European Parliament and of the Council of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC (OJ L 330, 10.12.2013, p. 1).

This Decision has been entered into force on 6 December 2018, provided that all the notifications under Article 103(1) of the EEA Agreement have been made.

Conclusion: EU SRR applies to Norway, Liechtenstein and Iceland as well.

EU SRR is relevant if a ship is flying the flag of an EU/EEA Member State or if a ship is flagged under a third country (non-EU) but calls at EU ports or anchorages, provided the ship is operating in marine environment (sea going) and is equal to or above 500 gross tonnage.

According to the EU SRR;

• a) New ships flying a flag of an EU member state, shall be delivered with a valid IHM which is certified;
• b) End-of-life ships going for recycling shall have a valid IHM certified and shall be sent to one of the recycling facilities in the EU List of approved ship recycling facilities.
• c) Existing ships flying the flag of an EU member state and third-party ships visiting EU ports and anchorages, from 31 December 2020, shall have a valid IHM on-board, which is certified.

Please check our website where you can find the relevant regulation documents, useful forms, and technical updates.

Please use our tool DATE to get in contact with our technical experts.

For new building ships, the ship yard is responsible for the IHM preparation. IHM preparation for new ships is based on documentation which is provided by the suppliers in the form of Material Declarations (MDs) and Suppliers Declaration of Conformity (SDOC).

Many shipyards already have experience of IHM preparation by collecting declarations from suppliers. Regardless of the scope of the IHM, whether HKC or EU SRR, our recommendation to shipyards is that; to instruct the suppliers to fill in and submit the EU SRR material declaration forms for their products, which cover 15 substances instead of 13 as per HKC. Since EU SRR covers the HKC requirements, if the owner orders the IHM as per EU SRR, this will save the effort to collect extra declarations for the two additional substances.

The forms of declaration can be downloaded here. 

For new building ships, the ship yard is responsible for the IHM preparation. IHM preparation for new ships is based on documentation which is provided by the suppliers in the form of Material Declarations (MDs) and Suppliers Declaration of Conformity (SDOC).

Please find the instruction “How to prepare MD and SDoC".

For ships in operation, shipowner is responsible for the IHM preparation. To comply with the HKC and EU SRR for your fleet, please follow up below procedures:

a) IHM Part I preparation

The steps for IHM preparation are as follows:

• To collect information about the ship;
• To assess collected information
• To prepare visual and sampling check plan (VSCP);
• On board visual and sampling check,
• To send samples for laboratory analysis and preparation of IHM and IHM inspection report.

For EU SRR compliance for EU/EEA flagged vessels, PFOS must be investigated and HBCDD shall be investigated as far as practicable.

The whole process requires close cooperation of several parties and at best it would need one month until the IHM inspection report is finalized, therefore an early planning is highly recommended.

Once the IHM and IHM inspection report is ready, shipowner shall submit the IHM report to DNV for approval, and verification.

The IHM preparation shall be carried out by qualified HazMat experts and expert companies approved by DNV. Equivalent qualifications may be accepted upon agreement. Please refer to this list for the DNV approved companies. 

b) DNV IHM Part I certification

• Plan approval engineers of DNV review and approve IHM and IHM inspection report;
• After successful approval, ship owner shall apply for an IHM initial survey on board ship done by a DNV 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.

Therefore, shipowner should arrange above step a) first, and contact DNV to prepare a proposal for IHM certification accordingly.

If the vessel is flagged under an EU/EEA Member State, an IHM certificate per EU SRR is required.

If the vessel is flagged under a third county, but visiting EU/EEA ports or anchorages, the vessel would need an EU SRR IHM Statement of Compliance (SoC).

Considering the change of trading route and possibility of change of flag, we advise our customers to prepare the new IHM according to the EU SRR requirements, and to obtain two compliance declarations (EU SRR and HKC).

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. The up-to-date IHM must be submitted to class for approval. For example, if the HKC IHM was prepared 4 years ago, to issue the EU SRR SoC, DNV needs to see the IHM maintenance procedure of the vessel with supporting documents such as Material Declarations (MD) from suppliers and updated IHM, in case the hazardous material situation of the vessel has changed.
2. The owner should also make a statement 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 we strongly recommend our clients to use the MD form with 15 hazardous materials, including PFOS and HBCDD for future maintenance.
3. The document of item 1. and 2. should be sent to Class for review and approval.
4. An IHM initial survey is required to verify the content. EU SRR Statement of Compliance (EU-REC-IHM SoC) 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.

If the vessel is flagged under an EU/EEA Member State, an IHM certificate per EU SRR is required. Therefore, the existing HKC IHM compliance declaration (CoC or SoC) shall be converted into an EU IHM certificate. Due to different control requirements of hazardous materials, an evaluation of asbestos, PFOS, HBCDD and HCFC according to the EU SRR is needed, and this can trigger an additional sampling check or request for documents.

To do that the following is required:

1. The maintenance record of the existing IHM should be kept. For example, if the HKC IHM was prepared 4 years ago, to issue the EU SRR SoC, DNV needs to see the IHM maintenance procedure of the vessel with supporting documents such as Material Declarations (MD) from suppliers and updated IHM, in case the hazardous material situation of the vessel has changed.
2. Additional investigation should be carried out to cover PFOS and HBCDD (as far as practicable), and evaluation should be made for asbestos and HCFC presence by visual and sampling check or request of document.
3. An updated IHM and the investigation report reflecting the above point 1 and 2 are to be submitted to DNV for approval.
4. An IHM initial survey is required to verify the content. EU SRR Certificate (EU-REC-IHM C) 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.

If DNV has authorization from the ship’s flag, we will issue a Certificate on behalf of the flag. If DNV doesn’t have any authorization, this has to be clarified with the flag since without authorization we will issue an SoC by DNV only.

We are offering an Approved HazMat Expert course for the individuals and professionals who would like to act professionally 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, taking of samples onboard and the preparation of required documentation, through both theoretical and practical parts. Information on the courses is available on Approved HazMat Expert - DNV.

DNV implements approval schemes for individuals and companies involved in IHM services. The schemes are, approval of individual personnel, so called “HazMat Expert”, approval of inspection company, so called “HazMat Expert Company” and approval of chemical laboratories – “HazMat Expert Lab”.

The individual HazMat Expert is qualified through our four-days HazMat Expert course. See "What is the Approved HazMat Expert course?" for more details for the course.

The company approval is for the IHM inspection, sampling and reporting, and laboratory approval is for the analysis part. Both are carried out through a one-day company audit at client premises in style of ISO 9001.

For the company approval, the precondition is at least one staff shall be fully approved HazMat Expert. To achieve this, he/she should participate in our HazMat Course, pass the exam, and have one real project supervised by DNV.

For laboratory approval, the accreditation of ISO 17025 is required, also at least one staff should be Approved HazMat Expert.

Based on DNV Rules for Recycling (DNV RU SHIP Pt. 6 Ch.7 Sec. 4) “the IHM preparation shall be carried out by qualified HazMat experts and expert companies approved by the Society. Equivalent qualifications may be accepted upon agreement with the Society”.

We recommend our approved service suppliers to our customers, giving the competence of these companies has been verified by DNV. Our approval of IHM is based on the quality of the IHM documentation, as long as the IHM job fulfils the regulation requirement the approval will be granted.

Please see below the procedure to become an approved service supplier as a HazMat Expert Company:

1. Fully Approved HazMat Expert Certificate
2. Approval as a service supplier

Step 1: Fully Approved HazMat Expert Certificate

A precondition of the company approval is to have at least one employee in your company qualified as the “Fully Approved HazMat Expert”. To achieve this, he/she has to attend the HazMat course pass the course exam, and have one project supervised by DNV.

During IHM job supervision, one IHM project lead by the HazMat Expert(s) will be followed by a DNV expert remotely. The overall project management, the preparation of check plan, the communication with the crew members, the sampling skill and the reporting will be assessed and discussed.

Step 2: Company audit

a) Sign contract for company audit;

b) Receive the requirement/check list for audit;

c) To conduct audit;

d) To receive the AoSS (Approval of Service Supplier) certificate issued by DNV, which will be published in the DNV Hazmat and Lab AoSS list.

DNV has the class notation Recyclable about ship's hazardous materials status.

The class notation Recyclable has the same requirements for the development of the IHM part I for new and existing ships as per EU Ship Recycling Regulation (EU SRR). See detailed information in DNV Rules for Recycling.

1. Green Passport (GP) is initiated on Dec 2003 by IMO resolution A 962(23) which is obsolete;
2. IHM is GP’s successor regulated by IMO’s Hong Kong Convention (HKC) and EU Ship Recycling Regulation (EU SRR).
3. The main differences between GP and IHM are that IHM has specific preparation patterns for new buildings and existing ships, has control measures for asbestos, PCB, ozone depleting substances, antifouling compounds and PFOS (ref. Appendix 1 to the HKC / Annex I to the EU SRR) and survey scheme is required as well. There are also changes to the hazardous materials to be declared (ref Appendix 1 & 2 to the HKC / Annex I & II to the EU SRR) including threshold values that were not part of Resolution A.962(23). GP was prepared without any legal statements such as MD and SDoCs, but only based on ship yards or shipowners declarations, while IHM is also supported by sampling and analyzes of materials. Last but not least, IHM is subject to checks by periodic survey and through port state controls.
4. For the ships with GP to apply for the certificate under EU SRR, the GP should be converted into IHM (Part I) by support of the additional site sampling checks, reporting and Class approval.

Yes, based on the flag requirements, the Green Passport (GP) certificate shall be converted into an HKC IHM or EU SRR IHM.

GP Certificate was issued based on IMO Resolution A.962 (23), which is now obsolete. To convert the GP into an IHM, the IHM certification procedure for ships in operation shall apply, please see: How to comply with HKC and EU SRR for existing ships?.

It is advised that the shipowner contracts a qualified HazMat Expert company to do a gap analysis of the existing GP and compares it with the EU SRR / HKC requirements. Based on the gaps, the HazMat Expert may require on additional documents and/or conduct sampling and visual checks on board to do an inspection according to EU SRR / HKC requirements. Once the IHM and IHM inspection report is prepared by the HazMat Expert, shipowner shall submit the IHM report to DNV for approval, and verification. An on board IHM initial survey is a must for issuance of the respective SoC or Certificate.

The vessel's Green Passport SoC has been expired and owner wants to renew the GP SoC, he should prepare the necessary document and an occasional survey should be conducted.

However, the ship-owner is advised not to do above since the GP concept, based on IMO Resolution A.962(23) adopted on 2003, has been replaced by the IHM concept by the IMO Hong Kong Convention (HKC) adopted on 2009 and EU Ship Recycling Regulation (EUSRR) entered into force in 2013. EUSRR is mandatory for the EU flagged ships and third-party ships that calls at EU ports and anchorages starting from 31 December 2020.

For the ships with GP, it should firstly be converted into IHM Part I based on the scope; either HKC or EU SRR and shall be submitted to class for approval and verification.

It is the owner's responsibility to keep the Inventory of Hazardous Materials Part I up to date. Part I of the Inventory shall be appropriately maintained and updated especially after any repair or conversion of a ship. An IHM maintenance procedure shall be implemented including the assignment of a designated person, by keeping records of changes.

If any machinery or equipment or component is added to, removed or replaced or the hull coating is renewed, the MD/SDoC forms provided by the suppliers shall be properly filed and Part I of the IHM shall be updated. Updating is not required if identical parts or coatings are installed or applied. During the IHM renewal survey updated IHM together with maintenance records will be checked by the surveyors.

See detailed requirement in subsections 4.1.2 to 4.1.4 of the IHM Guidelines (Resolution MEPC.269(68)) and Article 5 in EU SRR 1257/2013.

Shipowners may have implemented the procedure based on HKC and it is suggested to review and advance the procedure to EU SRR.

Yes, for the IHM maintenance shipowner should collect MDs and SDoCs for all the purchased items that are falling into the scope of IHM Part I.

DNV follows what is written in the Hong Kong Convention (HKC) and EU Ship Recycling Regulation (EU SRR). HKC Reg 5.3 says that “Part I of the Inventory of Hazardous Materials shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing Hazardous Materials listed in Appendix 2 and relevant changes in ship structure and equipment, taking into account the guidelines developed by the Organization”. It refers to the MEPC IHM Guidelines. And MEPC IHM Guidelines 4.1.4 say “The checking of materials as provided in paragraphs 4.1.2 and 4.1.3 above should be based on the Material Declaration furnished by the suppliers in the shipbuilding supply chain”.

IHM renewal survey is required for every five years after the IHM initial survey. The requirements are as below:

a) Ship’s existing IHM certificate and IHM Part I;

b) The updated IHM (Part I), reflecting any change, replacement or significant repair of structure, equipment, systems, fittings, arrangements and materials since last survey;

c) Ship’s IHM Part I maintenance record, MDs and SDoCs reflecting the ship’s hazardous materials management since last IHM survey;

Hong Kong Convention Regulation 11.8 reads as follows: “If a ship at the time when a certificate expires is not in a port in which it is to be surveyed, the Administration may extend the period of validity of the certificate but this extension shall be granted only for the purpose of allowing the ship to complete its voyage to the port in which it is to be surveyed and then only in cases where it appears proper and reasonable to do so. No certificate shall be extended for a period longer than three months, and a ship to which an extension is granted shall not, on its arrival in the port in which it is to be surveyed, be entitled by virtue of such extension to leave that port without having a new certificate. When the renewal survey is completed, the new certificate shall be valid to a date not exceeding five years from the date of expiry of the existing certificate before the extension was granted.”

The port state control shall be limited to verifying that either an IHM certificate or a ready for recycling certificate is on board, both supplemented by the verified IHM, which, if valid, shall be accepted for the inspection. A detailed inspection may be carried out where a ship does not carry a valid certificate or there are clear grounds for believing that:

• the condition of the ship or its equipment does not correspond substantially with the particulars of the certificate, and/or IHM Part I; or
• there is no procedure implemented on board the ship for the maintenance of IHM Part I.

A ship may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of a Member State in the event that:

• it fails to submit to the relevant authorities of that Member State a copy of the IHM certificate or the ready for recycling certificate; or
• non-compliance with the control measures for Hazardous Materials listed in appendix 1 to the HKC / Annex I to the EU SRR are identified.

A Member State taking such action shall immediately inform the administration concerned.

Failure to update the IHM shall not constitute a detainable deficiency, but any inconsistencies in the IHM shall be reported to the administration concerned and shall be rectified at the time of the next survey.

IHM Part II operationally generated wastes and IHM Part III stores shall be prepared by the shipowner once the decision is given to send the ship for recycling. The IHM Part II and III can be prepared by the crew or if shipowner prefers a hazmat expert can also prepare it.

For IHM Part II & III preparation, please refer to MEPC.269(68) IHM Guidelines as below:

a) Refer to 4.4 & 4.5 in Annex 17, page 8 for IHM part II & part III development requirements;

b) Refer to Table C and Table D in Annex 17, page 14 & 15 for the potentially hazardous materials;

c) Refer to the IHM Part II & III example table in Annex 17, page 18-21;

d) Additionally, IHM Part II & III investigation report with supporting documents, such as inventories, recordings, log books, site pictures, etc. attached as the appendices should be provided to DNV for approval.

It is a list of ship recycling facilities which meet the EU SRR requirements. Starting 2018-12-31 ships, flying the flag of an EU/EEA Member State, shall be recycled only in the listed facilities. The list can be found here.

If an owner decides to send his EU/EEA flagged ship for recycling, he has to send his ship to a ship recycling facility (SRF) which is in the EU List of approved ship recycling facilities and apply for a final survey to get the Ready for Recycling (RfR) certificate.

To get the ready for recycling certificate, first IHM Part II and III shall be prepared by the owner, and together with the updated IHM Part I, he should send the whole IHM to the agreed SRF for the preparation of the ship specific ship recycling plan (SRP). The SRP shall be tacitly or explicitly approved by the competent authority of the SRF in accordance with the requirements of the state where the ship recycling facility is located, where applicable.

a) During the plan approval following documents would be checked:

1. IHM Part I, II and III will be checked with respect to locations and approximate quantities
2. SRP (if applicable approved by the competent authority of the SRF) to confirm the following:
   • The information in the IHM is reflected in the SRP
   • Information concerning the establishment, maintenance and monitoring of the safe-for-entry and safe-for hot work conditions for the specific ship, taking into account features such as its structure, configuration and previous cargo, and other necessary information on how the ship recycling plan is to be implemented.

After successful approval, ship owner shall apply for an IHM final survey on board ship done by DNV surveyor;

b) During the final survey the following documents will be checked

1. IHM Part I, II and III stamped by DNV engineers
2. SRP, approved by the competent authority of the SRF, if applicable
3. EU Listed SRF

After successful completion of the IHM final survey, Ready for Recycling Certificate will be issued by the surveyor with maximum 3 months validity.

For ships built before 1 July 2002

Ships built before 1 July 2002 may contain asbestos, but it should be managed properly - further guidance is available in MSC/Circ.1045 Guidelines for Maintenance and Monitoring of On-Board Materials Containing Asbestos.

For ships built between 1 July 2002 and 1 January 2011

For all ships, new installation of materials which contain asbestos shall be prohibited except for:

• vanes used in rotary vane compressors and rotary vane vacuum pumps;
• watertight joints and linings used for the circulation of fluids when, at high temperature (in excess of 350ºC) or pressure (in excess of 7 x 106 Pa), there is a risk of fire, corrosion or toxicity; and
• supple and flexible thermal insulation assemblies used for temperatures above 1000ºC.

For ships built after 1 January 2011

The 2009 Amendments to SOLAS (resolution MSC.282(86)), further amended the text to prohibit all new installation of asbestos on board ships. These came into force on 1 January 2011;

IMO MSC.1/Circ.1374, Article 13 reads as follows:

“When asbestos is detected on board, in contravention of SOLAS regulation II-1/3-5, action should be taken to have it removed. The removal – assigned to professional asbestos removal companies – should take place within a time frame of 3 years from the date when the contravention is found and should be conducted in close consultation with and, where applicable, under the supervision of the flag State concerned. In such cases, a suitable exemption certificate should be issued by the flag State.”

If Asbestos is detected on board, it may affect Safety Construction Certificate of the ship according to SOLAS requirement. Shipowner shall notify the flag state, and flag state would either decide to issue an exemption certificate or would give a time frame to the shipowner to remove the asbestos according to MSC/Circ.1045. Flag has the final say.