FAQ IHM Maintenance & Key Responsibilities for Suppliers

What is IHM Maintenance?

IHM maintenance is the continuous process of keeping the ship's IHM report up-to-date throughout the vessel's operational life. This includes collecting material declarations from suppliers, visual inspections, and updating the inventory of hazardous materials on board.

Why is IHM Maintenance Necessary?

Regulatory Compliance:

It ensures the vessel complies with the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships, which requires a valid IHM certificate or Statement of Compliance.

Port State Control: Ships must present an up-to-date IHM certificate to port state control and classification societies.
Risk of Detentions:

Failure to maintain the IHM can lead to vessel detentions, fines, and other commercial disadvantages.

IHM Certification for New Ships (500 GT and above)

For new ships of 500 GT and above. Under the Hong Kong Convention, all new ships, regardless of flag, must have an International Certificate on IHM starting from June 26, 2025. For EU/EEA flagged ships, this requirement has been in effect since December 31, 2018.

The certification process for new ships involves:

Suppliers providing Material Declarations (MDs) and Supplier’s Declarations of Conformity (SDoCs) for all parts and materials used in construction
Shipyards compiling this information into the ship-specific Inventory of Hazardous Materials (IHM)
Additional investigation of PFOS and HBCDD for EU/EEA flagged vessels to ensure EU Ship Recycling Regulation compliance
Submission of the completed IHM to a Recognized Organization for approval and certification
Issuance of the International Certificate on IHM or Statement of Compliance, valid for up to 5 years

What Needs to be Maintained?

IHM Part I:

This part of the IHM, which details materials used in the vessel's construction, needs to be maintained and updated as items are changed or added during the ship's service life.

Material Declarations (MDs) and Supplier Declarations of Conformity (SDoCs):

These are essential documents from suppliers that must be collected and stored as part of the IHM maintenance process.

Collection of MDs is not only for significant parts, it is about all the machinery and equipment installed on board as a fixed item, and used in order the ship to operate. In this regard, we are talking about but not limited to: any machinery and their sub-parts, valves, pumps, pipes, gaskets, insulation material, brake linings, paints, cables, batteries, navigation equipment installed as fixed items.

Key Responsibilities for Suppliers

Provide Material Declarations (MDs):

For every PO item, suppliers must provide a Material Declaration detailing the presence and quantities of hazardous materials.

Submit Supplier's Declarations of Conformity (SDoCs):

These declarations confirm that the purchased materials and components conform to the regulatory requirements for IHM purposes.

Ensure Accuracy and Timeliness:

The information provided must be correct and submitted promptly to avoid delays in the shipowner's IHM maintenance process.

Understand Regulatory Requirements:

Suppliers should be familiar with the EU Ship Recycling Regulation and the Hong Kong Convention (HKC), which mandate the creation and maintenance of the IHM.

Why This Is Important

Legal Compliance:

Providing accurate documentation is a legal obligation for suppliers, enabling shipowners to maintain their IHM and IHM certificate.

Smooth IHM Updates:

Reliable supplier data ensures the IHM remains current, allowing shipowners to focus on general operations.

Avoid Ship Detentions:

A lack of updated IHM documentation can lead to detention during Port State Control (PSC) inspections, impacting shipping operations.

Support the Supply Chain:

By providing necessary documentation, suppliers support the entire IHM lifecycle, from initial certification to ongoing maintenance and eventual ship recycling.