1 Introduction
The goal of this Instruction to Recognised Organisation on Inventory of Hazardous Materials and Ship Recycling' (further: 'Instruction') is to provide instructions to RO's on what need to be verified by ROs relating to the ship owner's documentation associated with identifying and specifying materials comprising the IHM specific to each ship and keeping such inventory current and up to date.
As per Article 5 of the SRR and taking into account the EIF (as per June 26, 2025) of HKC, an IHM is required which is to be maintained properly until the moment of recycling of the ship. The used format shall mention that it covers both SRR and HKC (for SSR, 2 additional HazMats (i.e. PFOS and HBCDD) are to be included.
Reference is made either to the ItoS – Inventory of Hazardous Materials and Ship Recycling.
2 Responsibilities
To confirm the different responsibilities with regards to IHM related HazMats, the following applies:
2.1 Shipyard
The shipyard , until the delivery of the ship, is responsible that:
-
any material used (i.e. repaired, replaced, maintained or added) as a working part of the ship should be demonstrable compliant with Table A of Appendix 1 of Resolution 379(80); and
-
for Table B (of Appendix 1 of Resolution 379(80)) containing substances, these materials are to be registered in detail in (an updated version of) the IHM report. For this the Standard forms ('Supplier Declaration of Conformity' and 'Material Declaration') as per Appendix 6 & 7 of Resolution MEPC.379(80) are to be used.
2.2 Shipowner
The shipowner (as defined in the Maritime Labour Convention, Article II, sub 1. (j)) is responsible to ensure (to the extent possible) the purchase of a ship which is in compliance with the SRR and that this compliant status shall be maintained after taken the responsibility of the ship. Specific Netherlands' instructions to the shipowner are included in the 'ItoS - Inventory of Hazardous Materials and Ships Recycling'.
2.3 Recognised Organisation
The RO shall verify and certify/approve that all the provisions of the relevant IMO instruments and EU requirements as well as the requirements of this Instruction have been complied with. The RO shall verify all the submitted relevant information on the correct application of the (referenced) conditions set in this Instruction, before issuing a (renewed) Statement of Compliance regarding the correctness of the IHM and its maintenance procedures.
4 Verification of documents
The EMSA has developed a best practice guidance on IHM largely based on the relevant IMO-guidelines and an indicative list of items possibly containing HazMats has been developed. The relevant parts of this EMSA guidance regarding the IHM are strongly advised to be adhered to in general, so also in relation to the verification of IHM Maintenance related documents.
Information about HazMats is foreseen to be provided to the shipowner by suppliers using standardized documents (SDoC and MD); see also ItoS – Inventory of Hazardous Materials and Ship Recycling.
As per Resolution MEPC.379(80), Chapter 5, the IHM should be maintained (IHM Maintenance). Only items that are part of the following categories are to be included in the IHM Maintenance:
-
Part I-1 Paints and coating systems;
-
Part I-2 Equipment and machinery; and
-
Part I-3 Structure and hull
Bear in mind that consumables and items that are not nail-bound to the ship do not need to be inventoried. It shall however be noted that when a spare part of a machinery & equipment is installed, it becomes a fixed item, and thus falls into the scope of IHM Part I.
It will be the ROs responsibility to check if the provided documentation and/or alternatives are containing the required HazMat information. The RO shall verify and state that the Company requires and ensures that suppliers identify and declare, when relevant, the presence of HazMats which exceed the relevant threshold values, using the applicable formats as per Res.MEPC.379(80).
Neither the EMSA-guidelines nor the IMO-guidelines are mandatory under international law. The NSI is requesting and will accept declarations which positively document HazMats as per Res.MEPC.379(80), Table A (when below threshold values) and Table B (which comprise the IHM-register).
5 Issuance of certificates
Reference is made to article 12c and article 12d of the Netherlands Regulation for the prevention of pollution from ships1.
5.1 Certificates regarding inventory of hazardous materials
The ICHKC shall be issued based on the already issued ICSRR.
The ICHKC and the ICSRR, shall have identical validity periods.
5.1.1 Endorsements of certificates
With regard to article 9(2) of the SRR and regulation 11 of the HKC, the RO may, following successful completion of a renewal survey or an additional survey under the provisions of the SRR, simultaneously issue or endorse:
-
the ICSRR; and
-
the ICHKC.
5.2 Ready for recycling certificate
Reference is made to article 9(9) of the SRR and regulation 11 of the HKC.
When applicable, and after the relevant survey under the provisions of the SRR, the 'Ready for recycling' certificates can be issued under both the SRR and the HKC; having identical validity periods and with a maximum of three months.