Maritime Compliance: Materials Declarations for Inventories of Hazardous Materials


( The development and maintenance of the Inventory of Hazardous Materials (IHM) is the key requirement for shipowners under the Hong Kong Convention (HKC) and EU Ship Recycling Regulation (EUSRR). Whilst the HKC has not yet come into force, the EUSRR has and has wide application (to shipowners within the EU, vessels flagged within the EU and non-EU vessels calling to EU ports).

Fundamental to the development and maintenance of the IHM is the collection of available information relevant to the ship’s construction and equipment through the Material Declaration (MD) and the Supplier’s Declaration of Conformity (SDoC). These are required by the EUSRR (and the HKC when it comes into force) to be provided by the suppliers of relevant parts and equipment delivered to the shipyard (IHM-development for new ships) and shipowners (IHM-Maintenance).

The IHM requirements apply for the entire life cycle of a ship, and there are specific provisions relating to each stage in the ship’s life to ensure that hazardous materials can be identified as far as possible, and their disposal properly planned in the ship recycling process.

This Industry Guidance concerns only Part I of the IHM which covers the “structure and equipment of ships” and which needs to be prepared and maintained during the operational lifetime of the ship. Part I has three subparts and this guidance addresses Parts I-2 and I-3 only. This guidance does not address Part I-1 which is on paints and coating systems.

This Industry Guidance is specifically aimed at clarifying the exchange of information between shipowners and suppliers through the supplier’s submission of MDs and SDoCs. It will assist shipowners and suppliers in understanding and complying with their obligations with respect to MD and SDoC under the HKC and EUSRR, reducing the administrative burden for shipowners and suppliers, and ensuring the provision of accurate information necessary for the maintenance of IHM.

The application of the EUSRR and voluntary compliance with IHM requirements under HKC or through companies’ environmental policies, has caused a significant increase in shipowners’ requests for MDs to suppliers. As a consequence of this willingness to demonstrate compliance with the EUSRR and HKC, shipowners and service providers to whom IHM management has been delegated have made MD requests for equipment delivered to the ship, in excess of what is required under the EUSRR or HKC regimes. This has placed a considerable administrative burden on suppliers and can make the maintenance of the IHM by the owner significantly more complicated. Similarly, a lack of awareness by suppliers of their responsibilities in providing accurate MDs on request can also impact on the accuracy of IHM.


The Guidance paper from ICS "Materials Declarations for Inventories of Hazardous Materials", can be downloaded below:



Source: ICS






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