Inventory of Hazardous Materials (IHM Part I, II & III), MD/SDoC Maintenance & Hong Kong Convention / EU SRR Guide

Two overlapping statutory regimes govern the Inventory of Hazardous Materials (IHM) on board merchant ships of 500 GT and above:

• 2009 Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC, entered into force 26 June 2025): Requires all ships ≥ 500 GT on international voyages to carry a ship-specific IHM Part I verified by the Administration or Recognized Organization and an International Certificate on Inventory of Hazardous Materials (valid up to 5 years, subject to initial, renewal and additional surveys under HKC Regulation 10). Existing ships constructed before 26 June 2025 must comply not later than 26 June 2030 (or before recycling if earlier).
• EU Ship Recycling Regulation (EU) No 1257/2013 (and retained UK SRR): Already mandatory for all EU/EEA-flagged ships ≥ 500 GT and for all third-country (non-EU) ships ≥ 500 GT calling at any port or anchorage of an EU/EEA Member State or the UK. Non-EU ships must carry a verified IHM Part I and a valid Statement of Compliance addressing both IMO Table A/B substances and the additional EU Annex I/II substances (PFOS and, for EU-flagged ships, HBCDD).
• Three-Part Structure under IMO Resolution MEPC.379(80) (§ 4.1–4.5):
  • IHM Part I (Structure and Equipment): Lists hazardous materials in the ship’s hull structure, machinery, piping, coatings and fixed equipment (Appendix 1 Tables A and B), showing exact location, approximate quantity and unit. Maintained throughout the ship’s operational life.
  • IHM Part II (Operationally Generated Wastes): Lists oily sludge, bilge water, cargo residues, ballast tank sediments and garbage (Appendix 1 Table C). Prepared only prior to recycling.
  • IHM Part III (Stores): Lists regular ship stores, consumables, spare parts and liquids/gases sealed inside machinery and electrical units (Appendix 1 Tables C and D). Prepared only prior to recycling before the final survey for the International Ready for Recycling Certificate (IRRC).

Under IMO Resolution MEPC.379(80) (the 2023 Guidelines for the Development of the Inventory of Hazardous Materials, superseding Res. MEPC.269(68)) as amended by IMO Resolution MEPC.405(83) (2025), new installation or use of Table A materials is prohibited or restricted across all ships:

Table B materials (Hong Kong Convention Appendix 2 / EU SRR Annex II) are not prohibited from being present inside shipboard electrical, electronic or mechanical components, but whenever a component contains a Table B substance above its homogeneous threshold value, its location and approximate quantity must be recorded in IHM Part I for new ships and for any newly installed equipment on existing ships:

The most frequent Port State Control deficiency under EU SRR 1257/2013 and the Hong Kong Convention is a "frozen" IHM Part I that has never been updated since the initial Visual/Sampling Check Plan (VSCP) survey years earlier. Under MEPC.379(80) Sections 4.3.2, 5, 6 and 7, shipowners must implement a continuous IHM maintenance loop:

• Designated Person for IHM Continuity (§ 5.2.2): The Company must designate in its Safety Management System a specific person (ashore or on board) responsible for maintaining and updating IHM Part I.
• Material Declaration (MD — § 6 & Appendix 6): For every piece of machinery, equipment, valve, gasket, cable or paint coating supplied to the ship, the supplier must complete an MD declaring whether any Table A or Table B material is present above its threshold value (and if so, its mass and location within the component).
• Supplier’s Declaration of Conformity (SDoC — § 7 & Appendix 7): Each MD must be accompanied by a signed SDoC identifying the issuer, describing the product and confirming that the accompanying Material Declaration conforms to IMO Resolution MEPC.379(80) (and EU SRR 1257/2013). Both the MD and SDoC must be retained in the ship’s IHM archive.
• Dry-Docking, Retrofits & Renewal Survey Updates (§ 4.3.2): Whenever machinery or structural items are added, replaced or removed (for example BWMS or EGCS retrofits, radar/ECDIS replacements, hull anti-fouling re-coating or boiler gasket renewals), the change log in IHM Part I must be updated prior to the 5-year IHM Renewal Survey.

• Verify that the International Certificate on Inventory of Hazardous Materials (or Statement of Compliance under HKC / EU SRR 1257/2013) is valid, signed by the Administration/RO and matches the revision number and date of the onboard IHM Part I report.
• Confirm that the ship’s SMS names the Designated Person responsible for maintaining IHM Part I (MEPC.379(80) § 5.2.2) and that the Master and Chief Engineer can show the change log of equipment additions/replacements since the initial IHM survey.
• Check the engine-room store and deck store for newly delivered flange gaskets, gland packings, thermal lagging and brake linings: ensure every batch is accompanied by an Asbestos-Free Declaration / MD + SDoC complying with SOLAS II-1/3-5 (Res. MSC.194(80) & MSC.282(86)) and the 0.1% threshold.
• Verify that the International Anti-Fouling System (AFS) Certificate and dry-dock paint specifications confirm compliance with both the organotin ban and the 1 January 2023 cybutryne ban (Res. MEPC.331(76) & MEPC.405(83)).
• Verify that the fixed and portable fire-fighting foam concentrate certificates confirm PFOS-free (< 10 mg/kg) compliance under SOLAS II-2/10.11 (Res. MSC.532(107)) and EU SRR Annex I.