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

The Brazilian government and Sok Denizcilik Tic. Ve Ltd.Sti (SOK) of Aliaga, Turkey, the buyer of the Aircraft Carrier SÃO PAULO, was sent scrambling on August 9, when Turkish authority Eyüp Karahan General Director of Environmental Management, on behalf of Minister Çevre Yönetimi Genel Müdürü, sent a letter to the Brazilian agency IBAMA, Competent Authority for the Basel Convention, requiring a new Inventory of Hazardous Materials (IHM) to be conducted prior the export:

“… As a result of the Supreme Court’s interim injunction, news in the press, and the hazardous materials notices made to our Ministry, it has emerged that a new Inventory of Hazardous Materials for the ex-naval vessel in question should be prepared while the vessel is in Brazilian territorial waters before it comes to our country.”

Toxic Warship
Image for representation purpose only
Claiming for weeks that the export of the ship from Brazil to Turkey is illegal under the Basel and Barcelona Conventions and that the current IHM is not credible, environmental, and labour rights groups working on this matter in Turkey, Brazil, and internationally praised the Turkish action.

“Turkey is to be applauded for asking for a true and accurate survey and inventory. The current one is simply not believable based on what we know about older aircraft carriers. We have real concerns that the provided inventory grossly underestimates the hazardous and radioactive materials on board the São Paulo.” – Nicola Mulinaris – Senior Communication and Policy Advisor – NGO Shipbreaking Platform 

It must be noted that Grieg Green, the survey company that issued the IHM for SOK, :

– admitted they had access to only 12% of the ship;

– did not have access to the IHM prepared by the Brazilian Navy;

– concluded there were no radioactive materials onboard;

– did not compare with the IHM issued by Bureau Veritas for the vessel’s sister ship CLEMENCEAU;

– did not adequately test (only six samples) Polychlorinated Biphenyls (PCBs) concluding there were none;

– concluded that there might be more asbestos onboard the aircraft carrier than the estimated 9 tons; and

– recommended further sampling during dismantling operations.

The SÃO PAULO’s sister ship CLEMENCEAU was estimated to have at least 760 tons of asbestos, a figure which was later confirmed by Bureau Veritas upon the dismantling of the CLEMENCEAU at the scrap yard ABLE UK.

IBAMA has responded to the Turkish request by saying the ship had already left Brazil so therefore it was not possible to fulfil the request that a new inventory is made in Brazilian territorial waters.

Indeed, just a few hours following the court injunction on August 4, the ship was hastily towed out to sea, and instead of following the towage plan which projected it sailing along the Brazilian coast, the tow train made an easterly heading to leave Brazilian territory as rapidly as possible.

Despite the federal injunction which is now considered out of force and the new demand for a new IHM by Turkey, neither IBAMA, the Brazilian Navy, nor SOK has made any move to turn the ship back to Brazil. It is currently moving at its top speed just off the coast of Mauritania and is just a few days away from the Strait of Gibraltar. Meanwhile, neither Spain, the UK nor Morocco have been notified or given consent for it to pass through their waters at Gibraltar as is required by the Basel Convention.

While IBAMA seems unwilling to respect the request by Turkey that the new survey be conducted in Brazil, they, nevertheless, wrote to the exporting company working with SOK, known as Oceans Prime Offshore Agenciamento Maritimo Ltda., to remind them that it is within the rights of the importing country to amend their import consent with new conditions. They suggested that a new IHM may be required “upon arrival” and would need to be paid for by SOK. However, doing the job in Turkey instead of Brazil is likely to be illegal.

“Under no circumstances should Turkey agree that the new survey be conducted in Turkey or any other country other than Brazil. Under the Basel Convention, a proper inventory of hazardous materials can only be conducted prior to export.” – Jim Puckett – Director – Basel Action Network (BAN) 

“The rush by the Brazilian government to get out to sea without checking to see if Turkey has laws against such import, to alert transit countries, and before a court injunction can be properly served, is not an excuse for Turkey to ever allow this ship into our territory. It must go back now. It should not even be allowed to pass into the Mediterranean Sea.” – Asli Odman – Academic – Istanbul Health and Safety Labour Watch 

Reference: NGO Shipbreaking Platfrom


CREWEXPRESS STCW REST HOURS SOFTWARE - Paris and Tokyo MoU have announced that they will jointly launch a new Concentrated Inspection Campaign (CIC) on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) from 1st September 2022 to 30th November 2022

Although the Other Regulated Material-Domestic (ORM-D) designation was phased out on January 1, 2021 for highway shipments, many shippers have questions about how to move forward. PHMSA recently responded to one question: Is a shipper required to remove or cover the ORM-D marking entirely, or can it appear in addition to the required limited quantity marking?

The Hazardous Materials Regulations (HMR) require limited quantity packages prepared for highway transportation to be marked with the limited quantity marking. There is no explicit requirement for the outdated ORM-D marking to be removed.

In an interpretation dated May 18, 2022, PHMSA warns that although the ORM-D marking may remain on a package when the correct limited quantity marking is used for ground shipping, this can be confusing and potentially problematic.

If both markings appear, the package may be rejected or removed from transportation since hazardous materials are no longer permitted to be reclassed as ORM-D. Not every shipper, carrier, or freight forwarder will see this letter of interpretation. Those that do not may be unsure about accepting or loading a package with both ORM-D and limited quantity markings.

Since the packages display the currently required limited quantity marking, the old ORM-D marking is not required to be removed prior to shipment. However, it is the opinion of this Office that the display of the ORM-D marking is confusing and may frustrate transportation of these packages because hazardous materials are no longer authorized to be reclassed as ORM-D for transport. Therefore, while not covering the phased-out ORM-D marking is not in violation of the HMR, we suggest that the best way to avoid frustration of the shipment is to cover the ORM-D marking and to discontinue its use in future shipments.

PHMSA Reference No. 22-0019

To help address this issue, PHMSA is working on a rulemaking to remove all references to ORM-D in the 49 CFR 172.101 Hazardous Materials Table. An FAQ page on PHMSA’s website to convert letters of interpretation like this one into an easy-to-read, public format is also under consideration. A public webinar is scheduled for June 27, 2022 to discuss the FAQ page and will accept comments until July 22, 2022.

What Happened to ORM-D?

The last day to use the ORM-D classification for highway shipments was December 31, 2020.

Shippers who used the ORM-D designation to ship small quantities of hazardous materials packaged for retail sale benefited from a multitude of reliefs. Now that ORM-D has been phased out, the same materials, in the same quantities, in the same packaging, mostly continue to qualify for relief under US DOT’s limited quantity regulations.

What changed was the label you affix to your packages. Ground shipments of limited quantities must carry the blank limited quantity mark. Limited quantity air shipments must display a “Y” limited quantity marking.

Want More on Limited Quantities?

Be confident you know how to package, mark, and label your limited quantity shipments now that ORM-D is O.V.E.R.

The Shipping Limited Quantities and Consumer Commodities online course provides reliable, up-to-date training to help satisfy DOT, IATA, and IMDG training mandates for hazmat employees who prepare or offer limited quantity shipments for ground, air, or vessel transport.

Verifavia, the global leader in carbon emissions verification services to the maritime and aviation industries, has sold a majority stake to Normec, the leading Dutch testing, inspection and certification organisation.

This strategic transaction will greatly reinforce Normec’s sustainability offering and marks a key milestone in the company’s development with its entry in the French market. Normec’s sustainability services include, among others, biodegradability and compostability and ecotoxicity testing, waste and recycling management, and air, soil and water analyses.

Julien Dufour, President of Verifavia Group – which also provides preparation and maintenance services for Inventory of Hazardous Materials (IHM) on board vessels – revealed that his company had received several offers from global organisations during the acquisition process. However, the board chose Normec because it shared the same entrepreneurial spirit, values and culture.

“We and Normec are both flexible, agile companies that can respond quickly to clients’ requests – which is vital for maritime and aviation companies that need to meet industry regulations on carbon emissions or industry specific legislation such as IHM,” Dufour said.

Dufour added that Verifavia will continue to operate autonomously following the transaction. “Normec’s management wants us to retain the entrepreneurial mindset that has served us so well over the years, which this partnership allows us to do,” he said.

Normec’s purchase of Verifavia gives it a controlling stake in a company that has achieved many milestones since launching in 2010. In shipping, Verifavia was one of the first organisations to offer EU Monitoring Reporting and Verification services, as well as being the original independent verifier to provide the IMO Data Collection System verification for several flag states.

Additionally, Verifavia launched the world’s first real-time Carbon Intensity Indicator (CII) Dashboard in November 2021, allowing owners, operators and charterers of ships over 5,000GT to accurately measure a vessel’s current and predictive CII rating. The CII dashboard provides guidance for ship efficiency, generating data on the amount of carbon produced and, through its calculator, insight into whether emission levels for a single voyage or reporting period meet industry regulation.

“Verifavia stays agile to new regulatory requirements, such as the Energy Efficiency Existing Ship Index and the EU Emissions Trading System (ETS) for shipping, and guides its customers through the awareness and compliance process,” Dufour said.

In aviation, Verifavia was the first verification body to be accredited for the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). As the world’s leading verifier for the industry, Verifavia serves more than 300 airlines in 100 countries for carbon emissions verification under the EU ETS, UK ETS and CORSIA, giving it an overwhelming global market share.

Another gain for Normec is Verifavia’s IHM service, which supports ships that are subject to the EU Ship Recycling Regulation and the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. Verifavia works with shipowners, managers and class societies to develop and implement an IHM maintenance procedure. The IHM must be updated by a collection of suppliers’ declarations if any non-identical or new machinery or equipment is added to, removed or replaced, or the hull coating is renewed.

For Verifavia, the merger gives it access to Normec’s markets, clients and services – including materials testing sites, building services and laboratories that complement the vendor’s IHM services – in The Netherlands, Belgium, and Germany.

Verifavia will also benefit from Normec’s established HR, sales, marketing, IT and finance functions, processes, and procedures, meaning Verifavia can scale its operations, while focusing on service development and delivery.

“We’re particularly excited about tapping into Normec’s advanced IT systems, which aligns with our commitment to developing bespoke software that supports companies across the maritime and aviation industries,” Dufour said.

Joining Normec will create a stronger organisation with knowledge-sharing and career opportunities for employees of both businesses, according to Dufour. “Together, Normec and Verifavia can continue to grow and become even more complete in their services.”

Joep Bruins, CEO of Normec Group, added that the opportunity to acquire a majority stake in Verifavia was too good to miss. “We are very impressed by the position and reputation that Verifavia has built up in the global aviation and maritime markets. The company delivers high-quality services to customers and has a high level of knowledge,” he said.

“Verifavia’s team has extensive experience and expertise. We’re looking forward to working together to participate in the global effort to control CO2 emissions and the carbon footprint.”
Source: Verifavia

1. Instructions

You are required to go through these notes before filling the application form in GoBusiness. Please retain this set of notes with you for future reference.

The application form for Hazardous Substances Licence/Permit can be used to apply for a

  • Hazardous Substances Licence issued under the Environmental Protection and Management Act for the import, use, storage and supply of hazardous substances controlled under the Act.
  • Hazardous Substances Permit issued under the Environmental Protection and Management (Hazardous Substances) Regulations for purchasing hazardous substances controlled under the Regulations from local supplier for own use and/or for storage.

2. Guidance Notes

(To be read together with the application form)

Section 1 – Purpose of Application (for Hazardous Substances Licence Only)

Please tick the relevant box to indicate the reason for your application.

Section 1 – Particulars of Company

The company name and registered address shall be the same as the name and address that your company filed with the Accounting and Corporate Regulatory Authority.

Section 1 – Particulars of Applicant

Applicant’s name shall be the same as in NRIC, PR status, work permit or employment pass.

Applicant for a Hazardous Substances Licence should be a professional in his field or a senior management staff in his company. His academic qualification must be at least a technical diploma. He will be required to sit and pass the Management of Hazardous Substances (MHS) course. MHS course is not required for applicant dealing with only (i) Ozone Depleting Substances (ODS) and Hydrofluorocarbons (HFCs) other than Methyl Bromide, (ii) Restriction of Hazardous Substances (RoHS) in Electrical and Electronic Equipment and (iii) paints in which the total lead exceeds 0.009% by weight of the paint.

Applicant for a Hazardous Substances Permit should be a management staff in his company.

Section 2 – Purpose of Hazardous Substances

Please tick the relevant box to indicate the purpose for the hazardous substances in your application. You may tick more than one box. Please specify the use of the Hazardous Substances in Section 3 and/or 4 for each and every substance.

Section 3 – Details of Storage Premises/Facilities

Address of Store:
Please state address of storage premises.

If you propose to store the hazardous substances at more than one premises, you may add new storage premises at Section 3 of the application form

If storage is not required, please update Section 4 with the hazardous substance and its respective transaction modes of import, transport, sales and/or use of hazardous substances that will be carried out (e.g. deliver direct from port to customer’s store or from supplier’s store to port, etc).

Industrial Allocation / Industrial Siting Consultation Letter

The letter shall be submitted along with the respective Hazardous Substances Licence/Permit application relating to a new site premises. The letter shall include details of the proposed activity at the listed industrial premises.

No-objection letter (for storage at a 3rd party warehouse)
If your company proposes to store hazardous substances at an approved chemical warehouse, please attach a letter of consent from the warehouse (along with company letterhead) stating the name, percentage and maximum quantity of hazardous substances to allow for storage at the stated premises.

No. and Capacity of Fixed Storage Tanks
Please indicate the number and capacity of the tank(s), along with the hazardous substances intended to be stored in the bulk tank. The Certificate of Statutory Completion (CSC) for the bulk tank shall be uploaded along with the application as a supporting document. Alternatively, a certification of the fixed bulk tank from a Professional Engineer is acceptable as well.

Emergency Response Plan to Mitigate a Spill/Release of Hazardous Substances

The plan needs to address the containment/mitigation procedures, the equipment used for mitigation of any incidents involving a spill/release of hazardous substances, the collection and disposal of contaminated waste generated from the incident.



The Partnered Carrier program allows you to send your Fulfillment by Amazon (FBA) inventory from India to fulfillment centers in the US. The program enables you to commercially ship your FBA shipments in a cost-effective manner. Once the partnered carrier picks up your shipment, they will handle shipping from customs clearances to delivery to an Amazon fulfillment center. Doorstep pickup and drop-off at a carrier facility in India is available.

Below is a detailed list of program features:

  • Integration into Seller CentralYou can book shipments, enter customs information, schedule pickup by the carrier, and pay logistics freight charges directly in Seller Central while creating your FBA shipment.
  • Amazon-facilitated shippingYou don’t need to create a separate account with the carrier or do any credit checks to use the Partnered Carrier program for global shipments. Just make sure that your shipment documents and Know-Your-Customer (KYC) documents are ready at the time of pickup. KYC documents establish your proof of identity and address.
  • Commercially clearedPartnered carrier shipments will be commercially cleared, with the carrier taking care of both origin and destinations customs clearance.
  • Amazon-negotiated rates and seamless paymentsYou can rely on Amazon’s negotiated rates along with seamless Seller Central integrated payments.
  • Door-to-door pickup and deliveryOnce you schedule pickup from your location, the carrier will come to your door for pickup and will take ownership for delivery to a US fulfillment center.
  • End-to-end trackingYou can track the status of your FBA shipment within Seller Central.
  • Express shipping solutionThis program offers an express shipping solution. The average delivery time will be 6 to 8 business days for FedEx International (Priority) and 14 to 16 business days for FedEx International (Economy).


Source: sellercentral

The EU Ship Recycling Regulation came into force on 31 December 2020 and effects any in-service ship of 500 GT or over calling at any EU* port or anchorage (regardless of flag). It requires that vessels hold a valid and certified Inventory Hazardous Materials (IHM) on board.

This also continues to apply under the UK Ship Recycling Regulation (UK SRR), following the UK’s exit from the EU.

IHM is a structured system to control hazardous materials onboard ships and achieve compliance with both (EU SRR) and the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships.


Source: lr

An Inventory of Hazardous Materials (IHM) helps ship owners maintain control of hazardous materials by detailing the types, quantities and locations of such materials onboard each vessel.

Most importantly, a thorough and accurate IHM is required for compliance with the EU Ship Recycling Regulation (EU SRR) and the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships. With the deadline to comply with IHM requirements quickly approaching, ship owners must prepare to act now.

Achieving IHM Compliance: A 3-Step Guide

1- Plan for the IHM Compliance Deadline

Ship owners should keep in mind that the entire process for IHM compliance can take up to 3 months. While the delay caused by COVID-19 is unprecedented, it represents only a 6-month period since the adoption of the EU SRR 7 years ago.

Starting 31 December 2020, any ship which is 500 GT or over, regardless of flag, will require a valid and certified IHM onboard if calling at an EU port or anchorage. Non-EU flagged vessels can also be certified against EU SRR by complying with the HKC IHM requirements.

The IHM consists of three parts:

  • Part I: Hazardous materials contained in the ship’s structure and equipment
  • Part II: Operationally generated waste
  • Part III: Stores

2- Gain IHM Compliance

Owners need a seamless and effective way to meet IHM requirements. The ABS Nautical Systems (NS) Asset Management software solution can guide owners and operators through this process.

To help global mariners comply with the IHM requirements, NS has launched comprehensive capabilities that are fully integrated into the existing NS Maintenance Manager and NS Purchasing Manager software modules.

Key IHM compliance features will:

  • Identify equipment, spaces and structures that contain hazardous materials
  • Produce an Inventory of Hazardous Materials report in an approved format
  • Identify spare parts that are hazardous, including hazard type and quantity of hazardous material per part
  • Capture initial inventory using an Export Excel tool
  • Provide automatic updates for IHM Part I through standard maintenance and purchasing processes
  • Document required periodic audits of inventory in the HSQE and Vetting Manager module


Source: abs-group

Track your IHM in an integrated HM system – all you need to know as a shipowner in relation to inventory of hazardous materials.

Creating an IHM is one of the fundamental practices that keeps the maritime industry safe and sustainable. Prepare and maintain IHM for your fleet with the help of provided templates in SERTICA.

What is IHM?

Inventory of Hazardous Material (IHM) is a document identifying all potentially hazardous materials onboard a vessel. Hidden hazards are identified, located and quantified following IMO Resolution guidelines. The inventory replaces the Green Passport, adopted in the Hong Kong International Convention in 2009, and is a requirement by the EU Ship Recycling Regulation 2013.

Other Frequently Asked Questions about IHM

Ensure compliance with HM Inventory

Completing an IHM is only the beginning of compliance. It is the ship owner’s responsibility to ensure continuous conformity of the inventory in compliance with the following regulations:

  • Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009)
  • EU Ship Recycling regulations (SRR)

Prepare for IHM certification

Manage the hidden hazards onboard ships as a natural part of your internal processes. By setting up a HM system, you ensure a smooth IHM certification.

The preparations include:

  1. Research which hazardous materials you have onboard
  2. Identify purchase orders containing hazardous materials (e.g. in relation to dry dock and hull painting or asbestos and Ozone Depleting Substances)
  3. Send Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) templates to your suppliers
  4. Set up Analytics Report in SERTICA

Advantages of a HM System

Once you are working in a HM system, the advantages include less administrative work for preparation and maintaining of the IHM. Managing IHM in SERTICA, you can easily identify the hazardous materials on board and get complete transparency for processes such as procurement and maintenance.

Learn more about key features and benefits in the Item Certificate module managing IHM in SERTICA

Why do you need Inventory of Hazardous Materials (IHM)?

It is mandatory for ships operating in the marine environment, which are equal to or above 500 GT to keep an IHM. Navy ships and domestic ships are excluded. The inventory replaces the Green Passport, adopted in the Hong Kong International Convention in 2009. It is a requirement by the IMO RESOLUTION MEPC.269(68) and EU Ship Recycling Regulation 2013.


Source: sertica

The presence of hazardous materials on ships are commonplace and are unlikely to go away as they are necessary for the construction and maintenance of a vessel. Asbestos, for example, is one of the most common materials found on board and is used primarily in the walls and doors of an engine room due to its thermal insulation and fire-resistant properties. However, it is also extremely hazardous when it is broken up and can lead to fatal diseases if inhaled. Long-term exposure to heavy metals like lead or mercury (which can be found in paints, batteries, etc) can also cause irreversible neurological damage.

As awareness of hazardous materials grows in response to the safety and environmental concerns, various efforts have been initiated by authorities to regulate the inventory and management of hazardous materials throughout the lifecycle of a ship, in particular the Hong Kong Convention and the EU Ship Recycling Regulation (EU SRR).

With the impending deadline for existing ships to comply with the EU SRR set to 31st December 2020, this could be a major cause for concern for all vessels calling at EU ports. That means most of the ocean-going fleet worldwide should comply for all practical purposes or risk restricting the trading options for their fleet. Ships are often fixed for cargo in different parts of the world on very short notice, so make sure that your ship does not get caught out by not meeting the requirements of the different port-states beginning next year.


Source: ship-technology

As people become more concerned about their environment, the shipping community is changing too – to take on a more responsible approach for every single step in the life cycle of a ship. The conventions and regulations adopted by governments across the world are a testament to this change and we, at IRClass, are committed to support your environmental goals.

IMO adopted “The Hong Kong International Convention for the safe of environmentally sound recycling of ships” in the year 2009 followed by the EU Ship Recycling Regulation (EU SRR) in 2013 that requires every ship calling at EU Port to carry an inventory of hazardous material (IHM) verified by the relevant administration or authority and specifying the location and approximate quantities of those materials. (Correct?)


Source: irclass


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