Inventory of Hazardous Materials (IHM) Archives - SHIP IP LTD


The EU Ship Recycling Regulation (the “EU Regulation”) was adopted in 2013 and is in essence an early implementation in the EU of the Hong Kong Convention for the safe and environmentally sound recycling of ships (adopted in 2009); both of which aim to reduce the negative impacts on human health and the environment arising from the recycling of end of life ships. Under the EU Regulation, from 31 December 2020 all EU flagged and non-EU flagged vessels that call at a port or anchorage in an EU member state must have an Inventory of Hazardous Materials (“IHM”) on board.

There is anecdotal evidence to suggest that of the approximately 35,000 vessels that will be required to comply with the EU Regulation by 31 December 2020, almost a third have not yet begun the work required to prepare and have certified an IHM. In addition to the global COVID-19 restrictions preventing site visits and in-person inspections to carry out the work required to compile IHMs, the sheer volume of vessels that will require expert assistance in this area means the risk of vessels failing to comply with the EU Regulation by the end of this year is very real.

While steps are being taken to address these concerns, including remote IHM surveys, it remains to be seen whether this will be enough.
The EU Regulation

The EU Regulation has come into force gradually since its adoption seven years ago. Articles 4 and 5 of the EU Regulation deal with the control of hazardous substances and set out the requirement for an IHM generally. The general concept behind the IHM centres on the need to reduce harm to the environment and worker exposure to hazardous materials in shipbreaking yards; issues which have been well publicised recently.

While the requirement for an IHM for all new EU flagged vessels came into force on 31 December 2018, from 31 December 2020, the EU Regulation has far wider applicability and, specifically, the IHM requirement will apply to all other EU flagged vessels and any non-EU flagged vessels that call at a port or anchorage in an EU member state.

These obligations under Art. 4 and 5 are reinforced through additional requirements in the EU Regulation including:

• “Initial”, “Renewal”, and “Additional” Surveys to be undertaken throughout the vessel’s operational life in order to monitor compliance with the Regulation (including the IHM requirement);
• Member States being empowered to certify compliance with the EU Regulation; and
• A Final Survey to be undertaken prior to the vessel being taken out of service.

It is the responsibility and obligation of the shipowners to ensure that their vessels comply with the EU Regulation.
Practical considerations: what is required?

In broad terms, an IHM is a list setting out vessel-specific information as to the hazardous materials onboard (including their location and quantities). Under Art. 5(5) of the EU Regulation, an IHM shall consist of three parts:

• Materials contained in the vessel itself, or equipment (Part I);
• Operationally generated waste (Part II); and
• Stores onboard the vessel (Part III).

The International Maritime Organisation (“IMO”) Guidelines provide further, more specific detail in relation to what materials must be recorded in the IHM. The EU Regulation requires that Part I be prepared and certified for new vessels and those already in operation and shall be maintained during the vessel’s operational life. Parts II and III need only be prepared when the vessel is to be recycled, in accordance with the other requirements of the EU Regulation.

The IMO Guidelines provide further detail about the requirements for developing the IHM. The preparation of the IHM for new ships seems, on the face of it, more straightforward as it simply requires declarations from suppliers at an early design and construction stage (in relation to Part I) as to the hazardous material content of products used. However, experience of compliance with similar requirements in other established EU waste law, particularly ROHS (Restriction of the Use of Certain Hazardous Substances in Electronic and Electrical Equipment), suggests that establishing materials used in the production of many thousands of components is likely to be a significant endeavour.

This difficulty will be compounded for operational ships, where materials are already installed and will require visual and sampling checks by IHM service providers (and where the original supplier of some components may no longer exist). The inspection process depends largely on the size and type of the vessel, but it is generally estimated to take at least three months to prepare and certify an IHM.

Current estimates indicate that there are approximately 35,000 vessels which need to comply with the EU Regulation from 31 December 2020 and of that number, approximately a third have yet to begin the work required to demonstrate compliance.To complicate the picture further, current global restrictions arising out of the COVID-19 pandemic present real hurdles to shipowners looking to finalise their IHM for certification, ahead of the 31 December 2020 deadline.

In response to these mounting concerns, on 20 April 2020, the International Association of Classification Societies (“IACS”) issued a letter to the wider industry relating to the COVID-19 pandemic. Specifically, in response to the industry suggestion that IHM surveys be undertaken remotely subject to an extended survey during the first year, IACS responded “The initial desktop review may be performed remotely and followed up by onboard verification at a later date, subject to Flag Administration approval”.

Additionally, it was announced in May 2020 that US classification society ABS had expanded its offering to include an IHM remote survey. Through a web-based platform, users can submit a survey request together with all supporting information, including reports, photos and videos, which is then reviewed by an ABS surveyor in order for a “non-attendance verification” of the survey to be made.¹¹

We are aware that a number of trade and industry bodies have written to the EU Commission requesting an extension of the deadline for compliance to allow for the unprecedented delays caused by COVID-19. While it is quite possible that a delay may be granted there is of course no guarantee of this, and it would be unwise to rely upon it.

The delay caused by COVID-19 is unprecedented but it does only represent a six-month period in the seven years since the adoption of the EU Regulation; the direction of travel towards safer environmental and health and safety practices in the maritime sector and more robust regulation of the same has been clear for some time. It remains to be seen how the EU Commission will respond to requests to extend the current 31 December 2020 deadline and, in the interim, it would be prudent for shipowners to continue to move forward with plans to ensure compliance with the EU Regulation, including considering remote inspections as alternatives to in-person site visits and inspections.

There are obvious limitations in relying on a virtual inspection to meet the IHM compliance of a vessel, and these will no doubt be reflected in the assurance and warranties provided by the service providers. Additionally, it remains to be seen how those inspecting IHMs will treat significant discrepancies between a ‘virtual’ IHM and the vessel itself. However, in view of the fact that there is now less than six months to comply with the EU Regulation, it may be the best means available of demonstrating compliance in the short term.

Source: Watson Farley & Williams LLP.


Some of the world’s largest shipowning organisations have written to Virginijus Sinkevičius, the European Commissioner for the environment, oceans and fisheries, urging for a delay of the Europe Unions’s impending shipping hazardous materials regulation.

As of December 31 2020, mobile offshore units and vessels sailing under an EU member states’ flag, or MOUs and vessels calling at a European port will be required to have an inventory of hazardous materials (IHM) onboard, a shipping regulation designed to make ship recycling greener that has been in the pipeline for the last seven years.

Inspection capacity is being squeezed, lifting survey prices while the threat of port state control detentions and fines draws inexorably closer

The heads of Bimco, Intertanko, Intercargo and the European and Asian shipowners’ associations are among eight signatories in the letter sent this week asking for a 12-month delay citing the lateness in regulators getting the methodology fixed for what the IHMs need to contain as well as problems to fix site visits thanks to the coronavirus pandemic.

Law firm Watson Farley & Williams suggests that almost a third of the 35,000 vessels that will be required to comply with the EU regulation by the end of the year have yet to begin the work required to prepare and have certified an IHM. Typically, pre-Covid-19, the law firm suggests it takes at least three months to prepare and certify an IHM.

“In addition to the global Covid-19 restrictions preventing site visits and in-person inspections to carry out the work required to compile IHMs, the sheer volume of vessels that will require expert assistance in this area means the risk of vessels failing to comply with the EU Regulation by the end of this year is very real,” the law firm warned in a recent update.

“Shipowners are probably feeling the pressure now as inspection capacity is being squeezed, lifting survey prices while the threat of port state control detentions and fines draws inexorably closer,” a source in the ship recycling sector told Splash.



In the hazmat world today, most large organizations follow a time-honored process for identifying critical compliance needs and spend the money necessary to make it work. It is a process that tilts the compliance board in advantage of the bigger players.

It starts with a sophisticated purchasing or procurement system, usually with a module that enables environmental health and safety (EHS) staff to review and approve all incoming hazardous items. Nothing arrives into a big company unnoticed. Next, the chemical or product is tracked through some type of bar code or RFID-tagged inventory management system, and data on its location and specific usage is recorded.

Material safety data sheets (MSDSs) are obtained and tracked, using a sophisticated document and data management system that is tied into procurement and chemical tracking. At the end of all this, compliance reports required by EPA and local agencies are generated and submitted, usually electronically. At this point, management plans are made or modified, staff are trained or retrained and the company moves forward safely until the next monthly review period.

This utopian view of compliance management has been practiced for so long in so many high-profile companies that it has become the de facto process for managing compliance. In the world most EHS managers live in, however, the tools and resources just described do not exist. Companies today are forced to manage hazardous materials with limited budgets, staff, tools and systems.

Today, organizations need to create a new framework that takes into account the whole picture of hazmat compliance and its effect on the organization. Companies need to set their sights and marshal resources in one key area – an accurate hazmat inventory.

The picture begins with an accurate, up-to-date inventory of the pure chemicals, mixtures and products within the organization. The inventory becomes the foundation upon which the company manages other critical data and turns that data into knowledge on the hazards present in each of its facilities. This knowledge, when applied on a geographical, functional and hierarchal level within an organization, helps EHS staff make better business decisions.

This increases the value of the organization by reducing risk, cost and liability. A good hazmat inventory improves the bottom line and the basics are easy to understand and implement.

The Inventory

How Often? The frequency with which an inventory should be reviewed will depend on the size of the business and number of locations/departments that contain hazardous materials, the sophistication of purchasing and approval processes and the expected turnover of chemicals and other hazardous materials.

In an ideal world, a master inventory should be taken at least annually by the person responsible for the inventory in a specific location/department. Each new purchase or disposal should be tracked and the inventory modified throughout the year. EHS supervisors at each facility should have pre-purchase review and approval rights for any new product or chemical. Inventories from separate locations within an organization should be rolled up into a corporate-level inventory for analysis and to ensure consistency in process and purchasing.

What Data to Record? At a minimum, the location of each product or chemical should be recorded as well as the container size and quantity on hand of the material, the name of the product or chemical, the name of the company that made the product or chemical and any part number or description assigned by the manufacturer. This basic data will enable EHS staff to match the item to an MSDS, which can provide all the critical data needed for reporting and exposures.

Problems: The staff conducting the inventory may come across unlabeled, illegible and secondary labeled containers. Record these items in a separate discrepancy document, with their specific location and description, then physically flag the item itself, with stickers, labels or string that is easily visible. Review the discrepancy document at the completion of the inventory process to determine appropriate actions such as re-identifying products with appropriate labels and/or removing products from the facility.

Completing the Picture

Once an accurate inventory is obtained, it is possible to begin to add value to each record by associating other data, documents or records with each inventory item and supporting this information with on-site EHS staff or outside resources to assist employees in use and interpretation. This is an important step in seeing the “whole picture.”

MSDSs: Associate each item in the inventory with a manufacturer-specific MSDS and keep the inventory list and MSDS available for easy access by employees. The MSDS provides vital information for exposures and the specific characteristics of the chemicals in a product or mixture. Many companies keep the inventory list and corresponding MSDS in a file – hard copy or electronic – forever to meet OSHA’s exposure record keeping requirements. A process for obtaining new or updated MSDSs will be required as products change, or MSDSs go out of date.

Classification: Assign each item in the inventory a National Fire Protection Association (NFPA) and Hazardous Materials Identification System (HMIS) rating and classify the item for common modes of transport. NFPA has a system for identifying the hazards of a chemical that was developed with the needs of fire protection agencies in mind. The local fire department may require this information be provided along with the chemical inventory.

The HMIS rating is a labeling system developed by the National Paint and Coatings Association to quickly identify the hazards associated with a certain material. Inventory items should also receive a classification based on how the item is shipped, whether by ground, air or vessel. Each mode requires a different classification based on the size and quantity of the chemicals being transported.

Further instructions also will be needed on how to properly package different types of hazardous materials, what marking and labels go on the package, which placards go on the vehicle, how to complete the required shipping documentation and who to call in a transport emergency.

Why is the inventory so important? Because with so many companies doing it so poorly, a company that does it right gains a significant strategic advantage. When analyzed, the size and diversity of hazardous products within an organization is almost always a surprise. EHS staff and managers have not seen the “whole picture” and the result is misguided programs, misleading reporting, insufficient training and poor decision-making.

The accuracy of the inventory has cascading affects within an organization, from specific EHS responsibilities to employee well-being, management decision-making and corporate responsibility. If even 10 percent of your inventory is inaccurate, the following issues may arise:

MSDS Compliance – MSDSs will not always be available when needed, or when reviewed may contain outdated information. Staff may be spending valuable time and resources acquiring and maintaining MSDS for products that are not used or stored on site. At the same time, if a company uses its MSDS files as its 30-year exposure record, it could include chemicals and products that were not actually used, thus increasing the company’s potential liability.

Chemical Exposures – On-site data may not be available for the chemicals to which an employee is exposed. If the data is provided, it may refer to a previous or generic version of the product, increasing the likelihood of mistreatment.

Disposal of Hazardous Waste – The designated budget for disposal costs may be inadequate if there are items being used and disposed/recycled that the company is unaware of. Contingency planning for emergency response will be incomplete.

Regulatory Reporting – Sensitive chemicals (such as those that appear on SARA 302 Extremely Hazardous Substances List) may be excluded from required reporting. Items listed on the inventory but not actually used or stored on site could trigger higher reporting thresholds and unnecessarily lead to higher fees related to the amount reported.

Training and Preparedness – An incomplete inventory can hamper employee awareness of the chemicals in their workplace. This significantly increases the risk of exposure or injury and the related cost of treatment. Lack of related inventory data, such as MSDS and storage quantities, also can mean that all hazards are not properly evaluated.

Similarly, if a company assumes that the inventories at all sites or departments within its organization are the same, the following issues may arise:

MSDS Compliance – Site-specific MSDSs are not immediately available, in another building or office, or are completely unavailable. In a true emergency, such as ingestion, inhalation or exposure, treatment information contained on the MSDS will not be accessible by responding personnel. The company is then out of compliance with the Hazard Communication standard, which requires access to MSDSs for employees, with no barriers. This exposes the organization to the most commonly cited OSHA violations.

Chemical Exposures – If a company is unaware of the specific hazards at a given site or within a department, it may not be prepared to respond to employee exposure or injury. In addition, it may not have proper personal protective equipment, eyewash stations or containment tools in place for the specific chemicals used or stored at a site.

Disposal of Hazardous Waste – Established processes for handling specific waste streams may not be adequate. This could lead to waste on site, and the related risk and cost, longer than necessary. Uncertainty about what exactly is in a company’s waste stream may result in using waste contractors that do not have proper training, certification, tools and insurance to properly handle its needs. This applies to its staff as well, who may not have the training and tools to manage the waste they are generating.

Regulatory Reporting – Using a “master” report based on one location as representative of all locations may cause some chemicals to be reported unnecessarily. This could also trigger additional local or state reporting and their associated cost. The reverse also is true: A “master” report could leave some chemicals unreported, increasing risk and opening the company up to potential fines for not reporting the true on-site chemicals.

Training and Preparedness – Without an understanding of the exact nature of the hazards at a specific location, proper training will not be possible. Locations where the amounts of hazards have been underestimated will not have enough training. This is amplified in situations where substances that require unique handling procedures, such as lead and mercury, are found on site. Overtraining also can occur, which unnecessarily increases training cost.

Simply starting with an accurate inventory can result in more wins under your belt. By focusing efforts on gathering and analyzing the right information, EHS personnel can impact the cost for their organization to acquire, track, store, ship and dispose of hazardous materials and improve the understanding of hazardous materials among the employees throughout the organization.

EHS departments are winning every day because they are looking at the right data and making good decisions. Strive to become one of them.

Jess Kraus is the founder of the 3E Co. of Carlsbad, Calif. For more information, visit


The importance of issues related to ship scrapping and the need to regulate them was recognized by the international community as early as in the 1980s. Ships are considered waste after the end of their operation and as such are subject to the Basel Convention of 22 March 1989 on the Control of Transboundary Movements of Hazardous Waste and their Disposal and the Regulation (EC) No. 1013/2006 of the European Parliament and of the Council of June 14, 2006 on shipments of waste. The Regulation implements the provisions of the Basel Convention, as well as an amendment to this Convention (adopted in 1995), which has not yet entered into force at international level, and which introduces a ban on the export of hazardous waste to countries that are not members of the Organization for Economic Cooperation and Development (OECD). Ships are normally classified as hazardous waste and their export from the European Union for recycling purposes to plants located in non-OECD countries is prohibited.

The issue of limiting the negative impact of the ship recycling process on human health and the environment and preventing accidents, injuries and other adverse events, as well as increasing safety, protecting human health and the marine environment at every stage of the ship’s life cycle, in particular by ensuring the ecological management of hazardous waste from ship recycling, was reflected in the International Convention for the Safe and Environmentally Sound Recycling of Ships, adopted under the auspices of IMO on May 15, 2009 in Hong Kong. It is worth emphasizing that the Hong Kong Convention is the result of cooperation between IMO, the International Labor Organization (ILO) and the Secretariat of the Basel Convention. The agreement reached in 2009 to provide an efficient and effective solution to the problem of harmful and hazardous ship recycling can be considered as an action aimed at introducing mandatory requirements in this respect at the global level.

The Hong Kong Convention covers the entire life cycle of a ship: regulates the design, construction, operation, including modernization and reconstruction, and preparation for recycling to facilitate safe and environmentally sound scrapping, without compromising the safety and operational efficiency of a ship. It also regulates the safe and environmentally sound operation of ship recycling facilities and establishes control and enforcement mechanisms for ship recycling.

The Hong Kong Convention will enter into force 24 months after ratification by at least 15 countries, representing 40 per cent of world merchant shipping by gross tonnage, and the combined maximum annual ship recycling volume over the previous 10 years will be no less than 3 per cent of the gross tonnage of the total merchant fleet of these countries. Unfortunately, eleven years after the adoption of the text of the Convention, none of the above conditions has yet been met.

Ship recycling has also become the subject of work of the International Organization for Standardization (ISO), which has published a series of ISO 30000 standards. This series is a kind of guide on ship recycling, with references to issues related to safety, health and environmental protection. ISO activities in this area are focused on supporting IMO in pursuing the goals set by the Hong Kong Convention, such as a cleaner environment and safer work in recycling plants. It is worth noting that the ISO 30000 series of standards are consistent with ISO 9001 (quality management systems), ISO 14001 (environmental management) and ISO 28000 (security in the global supply chain).

After the adoption of the Hong Kong Convention in 2009, the ship recycling topic has not been taken off the agenda of the International Maritime Organization. During several meetings in 2012-2015, its Marine Environment Protection Committee (MEPC) adopted a number of guidelines containing detailed solutions in the field of ship recycling and the functioning of ship recycling facilities. They were:

  • Resolution MEPC.210(63), adopted on March 2, 2012: 2012 Guidelines for Safe and Environmentally Sound Ship Recycling;
  • Resolution MEPC.211(63), adopted on March 2, 2012: 2012 Guidelines for the Authorization of Ship Recycling Facilities;
  • Resolution MEPC.222(64), adopted on October 5, 2012: 2012 Guidelines for the Survey and Certification of Ships under the Hong Kong Convention;
  • Resolution MEPC.223(64), adopted on October 5, 2012: 2012 Guidelines for the Inspection of Ships under the Hong Kong Convention;
  • Revised guidelines for the Inventory of Hazardous Materials. Threshold values for radioactive substances. Sub-Committee on Pollution Prevention and Response (PPR), January 2015;
  • Resolution MEPC.269(68), adopted on May 15, 2015: 2015 Guidelines for the Development of the Inventory of Hazardous Materials.

Observing the slow pace of ratification of the Hong Kong Convention, the European Union took its legislative action by issuing Regulation (EU) No. 1257/2013 of the European Parliament and of the Council on November 20, 2013 on ship recycling. An EU initiative was aimed to:

  • facilitating the early ratification of the Hong Kong Convention;
  • introducing adequate control measures for ships and ship recycling facilities – both in European Union countries and outside the Union;
  • reducing differences between countries in the field of health and safety at work and environmental standards, as well as between recycling plants in meeting the requirements and implementing the principles for safe and environmentally sound recycling;
  • introducing the obligation to maintain a European list of ship recycling facilities (European list), which can only include ship recycling facilities that meet the requirements for safe and environmentally sound recycling under the Hong Kong Convention and ensure a high level of protection of workers’ lives and health, thereby excluding plants that do not meet the minimum conditions;
  • the harmonization of guidelines introduced by the Hong Kong Convention, the MEPC Committee and other documents regarding ship recycling and ship recycling facilities.

Pursuant to the provisions of Regulation (EU) 1257/2013, from December 31, 2020, any vessel with a gross tonnage of 500 GT and above entering a port or anchorage of an EU Member State will be required to have a verified Inventory of Hazardous Materials (IHM) and Inventory certificates (for EU vessels) or Certificate of compliance (for non-EU vessels). It is worth emphasizing that this requirement will apply to ships flying the flag of both an EU and non-EU countries.

It should be recalled that from December 31, 2018 Regulation (EU) 1257/2013 introduced the requirement that ships with a gross tonnage of 500 GT or more flying the flag of an EU Member State should be recycled only at facilities that are on the European list of ship recycling facilities. Link to European list

The European Union’s actions on ship recycling are similar to its actions on monitoring, reporting and verification of CO2 emissions from ships. Regulation (EU) 757/2015 of the European Parliament and of the Council on monitoring, reporting and verification of carbon dioxide emissions from maritime transport entered into force on 1 July 2015. Its requirements apply to ships with a gross tonnage above 5000 GT and relate to CO2 emissions from ships during their voyages from the last port to a port of a European Union Member State and voyages from a port of a Member State of the Union to the next port, as well as within a port of a EU State member. This regulation applies to all flag vessels in the same way.

It is also worth pointing out that the guidelines on ship recycling were prepared in 2016 by the International Chamber of Shipping (ICS) in cooperation with other maritime organizations and associations, including IACS (of which PRS is a member), BIMCO, INTERCARGO, INTERTANKO and OCIMF. Such a broad approach to the problem of recycling shows that the industry understands the need to conduct this process in a controlled manner. Link to the guidelines

Recognizing the importance of the issue of ship recycling for the protection of health and the environment, the Polish Register of Shipping has prepared its information publications. Those are:

  • Publication No. 31/I – Regulations for Safe and Environmentally Sound Recycling of Ships – 2012. The publication contains Supplement – Expert Parties Engaged in Visual and/or Sampling Checks for Preparation of Inventory of Hazardous Materials based on IACS Recommendation No. 131 (Rev. Oct 1, 2012);
  • Publication No. 33/I – Recycling of Ship – March 2017, which is an extension of the requirements of Publication No. 106/P – Eco Class Rules – January 2017.

The above documents, which are available at, familiarize PRS customers and interested parties with recycling issues and help prepare for the implementation of relevant requirements. One of them, which will come into force at the end of 2020, is having a List of hazardous materials. PRS verifies such lists. In addition, PRS issues Inventory Certificates, Ready for Recycling Certificates and Statements of Compliance.



The UK P&I Club, a leading provider of protection and indemnity insurance to the international shipping community, has published a guide for ship-owners to ensure compliance with the Inventory of Hazardous Materials legislation.

The guide addresses the technical aspects, important concepts, processes and requirements of the Inventory of Hazardous Materials, aiming to assist Members in ensuring compliance with the existing regulations and reduce the likelihood of reputational risks.

Over the last decade international and regional ship recycling legislation has been adopted, some of which is already in force. The IMO Hong Kong Convention and the European Union Ship Recycling Regulation are two key pieces of such legislation. A cornerstone in both the Hong Kong Convention and the EU Ship Recycling Regulation is the Inventory of Hazardous Materials. The code is an important tool when the vessel has reached the end of its useful life and the recycling operation is being planned. It is used when a ship recycling plan is compiled, to ensure minimal environmental impact and safe working conditions in the recycling or scrapping yard.

Ship recycling involves the breaking down or dismantling of entire vessels. However, working practices found at the majority of ship recycling facilities have routinely fallen short of internationally acceptable standards. The traditional beaching methods commonly used during dismantling make it difficult to ensure worker safety and containment of pollutants.

Stuart Edmonston, Loss Prevention Director at UK P&I Club, says: “This guide is a valuable asset for ship-owners and is designed to inform and raise awareness of the critical issues around the current ship recycling legislation. It’s vital to comply with the Inventory of Hazardous Materials, and failure to do so can lead to costly litigation, both from a financial and reputational perspective for all involved.”

Click to download the guide: Risk-Focus-Inventory_of_Hazardous_Materials



ABS is delivering IHM remote survey to support clients ahead of the December 31, 2020, introduction of mandatory IHM for all vessels sailing under an EU member states’ flag or any vessel calling at a European port.

“In this challenging, time-pressured environment, ABS IHM remote survey is the simplest route to compliance without the inconvenience of arranging for a surveyor to be physically present on board,” said John McDonlad, ABS Senior Vice President, Global Business Development.

An IHM initial survey for existing vessels verifies the location of the hazardous materials on board that are listed in the inventory. First step is to submit the inventory and required documents to an ABS engineering office for review. ABS-classed and non-ABS-classed vessels are eligible for an IHM initial survey, which supports compliance with both EU Ship Recycling requirements and the IMO Hong Kong Convention.

These new options are the latest step in a significant expansion of ABS remote survey capability. ABS is now able to conduct almost all classification annual surveys remotely on eligible vessels and has made its remote survey and audit services available to equipment and materials manufacturing clients all over the globe.

Additionally, next week ABS will expand Underwater Inspections In-Lieu of Drydocking (UWILD) to marine vessels.



Research in Germany and the Netherlands found hazardous levels of gases and vapors in around 20% of all freight containers. This represents a hazard to staff responsible for inspecting, stuffing or destuffing these containers.

It is therefore necessary to examine containers before entry. This is usually done using gas detection techniques that help assess the substances of greatest concern.

Chemical Hazards

There are two potential sources of hazardous chemicals inside cargo containers: fumigants and chemicals that arise from the goods or packing materials.

Fumigants are applied to goods to control pests and micro-organisms. Cargoes most likely to have been fumigated include foodstuffs, leather goods, handicrafts, textiles, timber or cane furniture, luxury vehicles and cargo in timber cases or on timber pallets from Asia.

According to the IMO’s international regulations, “Recommendations on the safe use of pesticides in ships,” fumigated containers and ship cargoes must be labelled, giving specifications about dates of fumigation and the fumigation gas used. Furthermore, appropriate certificates are necessary and these records have to be forwarded to the Port Health Authorities without their explicitly asking for them.

Absence of marking cannot be taken to mean fumigants are not present. Containers marked as having been ventilated after fumigation may also contain fumigant that was absorbed by the cargo and released during transit. There is also concern that fumigants may be retained in the goods and subsequently present a hazard to logistics providers, retail staff and consumers.

Common fumigants include Chloropicrine, Methyl bromide, Ethylene dibromide, Sulfuryl fluoride and Phospine.

“While the fumigants are highly toxic, the number of containers exceeding occupational exposure limits (OEL) due to other chemicals is much greater and the number of ‘failed’ containers is likely to rise as more containers are tested, detection methods improve and new gases are identified,” says Peter Broersma, with Reakti, a Dutch firm of health and safety consultants.

Gas Sources

Containers often travel for extended periods and experience a wide range of temperatures. It is therefore not surprising that unsafe levels of gases should accumulate in the confined space of a container. Broersma identifies the typical sources of gases over their OELs as follows:

∙ Solvents from glues used to produce clothing, accessories and shoes;

∙ 1,2, dichloroethane from plastic products, PVC, blister packaging etc.;

∙ Formaldehyde found in cheap furniture (plywood, MDF etc.) but also in used pallets and lashing materials;

∙ Solvents and formaldehyde from poly-resin products;

∙ Carbon monoxide from charcoal and natural products;

∙ Carbon dioxide from natural products;

∙ Ethylene oxide from medical equipment sterilized with ethylene oxide;

∙ Solvents including Benzene, Toluene, Ethylbenzene and Xylene (BTEX) in Christmas and decoration products;

∙ Flammable gases from disposable lighters;

∙ Ammonia in household equipment with Bakelite parts;

∙ Volatile Organic Compounds (VOCs) from fire blocks

∙ Pentanes and hexanes from consumer electronics;

∙ Phosphine/arsine from natural minerals such as ferrosilicon.

Inspection procedures

Major ports have strict regulations in place to protect against potential hazards in cargo containers. In general, every incoming stream of products has to be checked for dangerous gases and if one or more gases are detected during the preliminary investigation, all of the containers from this specific producer must be checked. If no gases are detected, it may be possible to only conduct random tests a few times per year. If it is necessary for Customs staff to enter a container, all containers must first be tested and if necessary de-gassed.

Since there are a large number of gases that might be present inside a container, the traditional approach to monitoring has been either to employ a wide range of instruments or to use chemical stain tubes for the most common gases, or a combination of both.

∙ Chemical stain tubes provide a colorimetric assessment of an individual gas, typically with an accuracy of +/- 15%. Different tubes are available for many gases and results can be obtained between 5 seconds and 15 minutes depending on the test. Once a result has been obtained, the tube itself is hazardous waste and must be disposed of. Historically stain tubes have been popular because the cost per test is low.

∙ Instrumental gas analyzers such as electrochemical sensors that measure either a single gas or a small number of gases impart a level of risk similar to stain tubes because of the possibility of missing or failing to measure a harmful gas. Deploying multiple instruments means each will require maintenance and re-calibration in addition to a power source or re-charging.

∙ A preliminary assessment can be performed with a PID gas detector to measure total VOCs; an LEL combustible gas sensor and handheld electrochemical sensors might be employed for toxic gases such as carbon monoxide, phosphine, ammonia and ethylene oxide. An FTIR (Fourier Transform Infra Red) analyzer could then be employed to measure 50 target gases simultaneously in a test that would take approximately 3 minutes. While a PID gas detector measures total VOCs, it does not provide an individual value for, say, benzene, which is a known carcinogen.

One of the potential problems with electrochemical sensors is their inability to cope with high concentrations in a sample gas. This can result in poisoning of the cell, which would normally result in instrument failure. In contrast, similar high concentrations do not harm FTIR, and the instrument can recommence analysis after a few minutes of backflushing.

“The problems of hazardous gases in cargo containers is now widely publicized and the requirement for testing is growing as employers fulfil their responsibility to protect the health and welfare of staff,” says Broersma. “FTIR has long been established as an accurate technology for the simultaneous measurement of gaseous emissions from industrial processes, so when the Finnish company Gasmet developed a portable version we were very eager to investigate its feasibility in container testing. We are now able to test for all of these gases in around three minutes, which dramatically lowers the time taken for container inspection and greatly increases the number of containers that can be examined every day.”

This technology is now used at Rotterdam, Amsterdam, Vlissingen, Antwerp and Hamburg, and a company providing ship fumigation and degassing is using portable FTIR all over the world.”

While FTIR is able to analyze multiple gases, the technique is not suitable for inert gases, homonuclear diatomic gases (e.g., N2, Cl2, H2, F2, etc) or H2S (detection limit too high).



Over the last decade international and regional ship recycling legislation has been adopted, some of which is already in force. The IMO Hong Kong Convention and the European Union Ship Recycling Regulation are two key pieces of such legislation. A cornerstone in both the Hong Kong Convention and the EU Ship Recycling Regulation is the Inventory of Hazardous Materials (IHM). The IHM is an important tool when the vessel has reached the end of its useful life and the recycling operation is being planned. It is used when a ship recycling plan is compiled, to ensure minimal environmental impact and safe working conditions in  the recycling / scrapping yard.

This Risk Focus provides guidance from UK P&I Club and Marprof to Shipowners when compiling the Inventory of Hazardous Materials (IHM). Addressing important concepts, processes, requirements and the technical aspects of IHM, this publication aims to assist Members’ compliance with the existing ship recycling regulations and reduce the likelihood or reputational risks.

The Inventory of Hazardous Materials (IHM)

Over the last decade international and regional ship recycling legislation has been adopted, some of which is already in force. The cornerstone of this legislation is the IHM, which is based on the same concept as the Green Passport but with two key differences:

Firstly, compiling and maintaining an Inventory of Hazardous Materials is no longer a voluntary requirement, but is mandatory for all ships over 500GT.

Secondly, and crucially, the IHM is expected to be significantly more accurate than the old Green Passport with sampling of unknown hazardous materials expected as standard. This guide aims to explain the key concepts, processes, and requirements of the IHM, based upon guidance materials, experience and best practice.

Deadline for IHM certificate onboard EU ships or Statement of compliance for Non-EU ships, entering EU ports: 31 Dec. 2020



The European Union’s Ship Recycling Regulations (EUSRR) that came into force in December 2018  pose certain obligations to all ships of 500 gross tonnage (GT) and above, flying the flag of countries in the EU or EEA, with certain exceptions such as warships, naval auxiliary or other ships on non-commercial service.

In addition, there is a requirement in EUSRR that applies to not only ships flying the flag of countries in the EU or EEA but also to all ships of 500 GT and above, regardless of the flag they are flying, when calling a port or anchorage of a country that is a member of the EU or EEA.

The requirement is that from 31 December 2020, all such ships should carry an inventory of hazardous materials (IHM) that is compliant with EUSRR, and for ships flying a flag of country outside the EU/EEA region, this must be accompanied by a statement of compliance from the flag state.

Port state control officers will control the certificate and the quality of the IHM and in case of non-compliance, ships may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of a member state.

For existing ships, the IHM should be based on visual and sampling checks and include the approximate quantity and location of a number of specified hazardous materials on board. While the IHM can be generated by own resources of a shipowner, there are IHM service providers, including classification societies, which already offer such services.

The following guidance documents on this subject are available for users through:

  1. International Maritime Organization (IMO)
  2. A guidance document developed by industry associations including BIMCO
  3. The European Maritime Safety Agency’s (EMSA)

When external companies are used, visual and sampling checks require IHM service providers to board each ship. Experience has shown that the whole process may take three months or longer, depending on the size and construction of the ship and how the desktop review has been prepared by the shipowner.

The International Association of Classification Societies (IACS) provides the following guidance about IHM surveys: “The initial desktop review may be performed remotely and followed up by onboard verification at a later date, subject to flag administration’s approval.”

In the present COVID-19 situation however, possibilities of having IHM service providers and surveyors on board is limited due to travel restrictions and lock-down measures arising from COVID-19.

It is therefore recommended that owners and operators of existing ships, who trade in EU and EEA countries, plan well in advance to comply with EUSRR IHM requirements by the 31 December 2020 deadline.



The Australian Maritime Safety Authority (AMSA) has launched an investigation into the loss of 40 containers from a Singapore-flagged container ship during heavy seas off Sydney on May 24.

According to the AMSA, the incident happened in the early morning, after the container ship APL England temporarily lost propulsion a few dozen kilometres off the New South Wales coastline. The ship was sailing from Ningbo, China to Melbourne, Australia.

The ship’s crew said that power was restored after a few minutes, but the ship was rolling heavily due to rough waves, causing 40 containers to fall overboard in waters about 2km deep. An additional 74 containers were damaged and remain collapsed on the deck of the ship.

The APL England has turned around and docked at Brisbane, where the AMSA conducted an investigation. Initial findings revealed that the containers that went overboard contained household appliances, building materials, and medical supplies.

“Firstly, this is a foreign-flagged ship in Australian waters and it will be checked for compliance with both Australian and international maritime safety standards,” said AMSA general manager for operations Allan Schwartz.

“We expect to have an outcome of this inspection in a matter of days which will include any breaches of those safety standards and any measures the ship will need to take to rectify those deficiencies.”

Schwarz added that the investigation will look at whether the ship breached any Australian environmental protection regulations pertaining to the safe and secure carriage of cargo. He estimated that the first phase of that investigation may take at least a month or even longer.

“Subject to the outcome, legal action could be taken by AMSA against various parties including the ship’s owner and others,” he said.



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