IHM Part I & Part II Case Study
Independent Inventory of Hazardous Materials (IHM) technical assessment covering documentation review, hazardous materials identification, onboard verification, sampling considerations, operationally generated waste assessment and preparation for applicable ship recycling requirements.
Independent IHM Part I & Part II Case Study
PAMS Pacific Admiralty Maritime Services provides independent marine technical consultancy and survey support for Inventory of Hazardous Materials (IHM) assessment, documentation review, onboard verification and applicable ship recycling compliance activities.
This case study presents a structured technical approach to the assessment of IHM Part I and applicable IHM Part II information for a commercial bulk carrier. The assessment considers the relationship between technical documentation, vessel configuration, hazardous materials information, operational records and the applicable regulatory framework.
The objective of an IHM assessment is not simply to compile a list of materials. The technical process should establish whether the available information is sufficiently complete, consistent, traceable and supported by appropriate documentary or physical evidence.
Where documentary evidence is insufficient, additional onboard verification, material investigation, sampling or laboratory analysis may be considered in accordance with the applicable requirements and agreed project scope.
Vessel & Project Context
The case study concerns a commercial bulk carrier assessed in the Philippines at Manila Anchorage, with a vessel size of approximately 34,650 WDT. The project provided a practical context for reviewing IHM information against available vessel documentation, technical records and accessible onboard conditions.
The assessment was structured around the vessel's available information and the technical requirements applicable to the individual project. The exact scope of verification depends on the vessel's Flag State, certification status, applicable regulatory framework, existing IHM documentation and project requirements.
Vessel Type
Commercial bulk carrier requiring technical assessment of vessel structure, machinery, equipment, systems and applicable hazardous materials information.
Project Location
Manila Anchorage, Philippines, with technical activities coordinated according to vessel availability, access and the agreed project requirements.
Vessel Size
Approximately 34,650 WDT, providing a representative commercial vessel context for the technical assessment.
Assessment Focus
IHM Part I hazardous materials information together with applicable Part II operationally generated waste information, documentation, verification and supporting technical evidence.
Project Objectives
The principal objective was to establish a structured technical basis for reviewing the vessel's available IHM information and identifying documentation, verification and traceability requirements.
- Documentation Review: Review available IHM documentation, vessel plans, technical records and supporting material information.
- Information Consistency: Assess whether available hazardous materials information is consistent with the vessel's current technical configuration.
- Onboard Verification: Compare relevant documentary information with accessible vessel areas, equipment, systems and components.
- Material Identification: Identify suspect materials or information gaps requiring additional technical investigation.
- Sampling Considerations: Determine where further sampling or laboratory analysis may be appropriate when documentary evidence is insufficient.
- Part II Review: Review applicable information concerning operationally generated wastes and supporting shipboard records.
- Compliance Readiness: Establish a practical technical basis for further Flag State, Recognized Organization or Classification Society review where applicable.
Initial IHM Documentation Review
The assessment began with a review of the information available for the vessel. The purpose was to determine what documentation already existed, whether it could support the IHM assessment and whether additional technical evidence would be required.
Ship Plans & Drawings
Review of available general arrangement plans, machinery information, equipment arrangements and other technical drawings relevant to identifying vessel spaces, equipment and material locations.
Equipment Information
Review of available equipment lists, machinery information, manufacturer documentation and technical records relevant to the identification of potentially applicable hazardous materials.
Material Declarations
Review of available supplier declarations, material information, certificates and other documentation supporting hazardous materials identification.
Maintenance & Repair Records
Review of relevant maintenance, repair, replacement and modification records that could affect the accuracy or current status of existing IHM information.
Previous IHM Information
Review of existing IHM records and supporting evidence where available, including information that may require confirmation, correction or updating.
Operational Records
Review of applicable operational records and waste-management information relevant to the assessment of IHM Part II where within the agreed project scope.
Technical Documentation Assessment
The technical documentation assessment considers the principal information sources used to establish, verify and maintain the Inventory of Hazardous Materials. Each documentation category should be reviewed against the vessel's configuration and the applicable regulatory requirements.
General Arrangement
Identification of relevant vessel spaces, machinery areas, accommodation areas, deck areas and equipment locations that may require consideration during IHM verification.
Machinery Documentation
Review of machinery, pumps, compressors, systems, components and equipment potentially relevant to hazardous materials identification.
Equipment Documentation
Review of available manufacturer information, equipment data, technical specifications and material information relevant to IHM assessment.
Material Declarations
Review of supplier declarations and other available evidence supporting the identification of applicable hazardous materials and their relevant locations.
Maintenance Records
Review of repairs, replacements, modifications and equipment changes that may affect existing IHM information.
Previous IHM Records
Comparison of existing inventory information with current vessel documentation, modification history and available onboard information.
Operational Waste Records
Review of applicable records and documentation relevant to operationally generated wastes where included within the assessment scope.
Supporting Certificates
Review of applicable certificates, declarations and other supporting evidence where relevant to the vessel's IHM status and certification route.
The exact documentation required depends on the vessel, Flag State, applicable regulatory framework, existing IHM status and agreed project scope.
IHM Part I Assessment
IHM Part I concerns hazardous materials present in the ship's structure, machinery, equipment, systems and other relevant components within the scope of the applicable regulatory requirements.
The technical assessment focused on whether available information could adequately identify relevant hazardous materials and their locations, and whether the documented information remained consistent with the vessel's current configuration.
Ship Structure
Review of relevant structural areas, accommodation spaces, deck areas, machinery spaces and other locations where materials may require consideration under applicable IHM requirements.
Machinery & Equipment
Assessment of machinery, pumps, compressors, electrical equipment, systems and components against available documentation and material information.
Electrical & Control Systems
Review of relevant electrical, electronic and control equipment where hazardous-material information may require verification.
Installed Materials
Review of available information concerning coatings, insulation, sealants, equipment materials and other installed materials within the applicable IHM scope.
IHM Part I Verification Methodology
Preparation
Establish the assessment scope and collect available vessel documentation, previous IHM records and supporting technical information.
Documentation Review
Review available drawings, equipment information, material declarations, certificates, maintenance records and other relevant documentation.
Onboard Verification
Compare available information with accessible vessel areas, equipment, systems, components and actual onboard configuration.
Gap Identification
Identify missing information, discrepancies, suspect materials, traceability issues and areas requiring further evidence.
Technical Resolution
Consider documentation correction, additional verification, sampling, laboratory analysis or other appropriate technical actions.
Reporting & Follow-Up
Document the assessment findings and provide a technical basis for further compliance verification, certification or corrective action where applicable.
Hazardous Materials Review
The assessment considered hazardous materials categories applicable to the vessel under the relevant regulatory framework. The exact materials, thresholds and documentation requirements depend on the applicable convention, regulation, amendments, Flag State requirements and vessel status.
Asbestos
Review of available documentation and identification of areas where asbestos or asbestos-containing materials may require verification under applicable requirements.
Polychlorinated Biphenyls
Review of relevant equipment, electrical components, materials and available documentation where PCB-related information requires consideration.
Ozone-Depleting Substances
Review of relevant systems, equipment and documentation where ozone-depleting substances fall within the applicable inventory requirements.
Anti-Fouling Systems
Review of relevant coatings and anti-fouling system information where applicable under the regulatory framework governing the vessel.
Other Regulated Materials
Assessment of other hazardous materials or regulated substances falling within the applicable IHM framework and relevant amendments.
Supporting Evidence
Review of declarations, certificates, supplier documentation, sampling information and other evidence supporting relevant hazardous materials entries.
Sampling & Laboratory Assessment
Where available documentation cannot provide sufficient evidence to establish the material status, technical consideration may be given to sampling and laboratory analysis.
Sampling should be based on a technically justified approach and carried out using suitable procedures. Where laboratory testing is required, analysis should be performed by an appropriately qualified laboratory consistent with the applicable project and regulatory requirements.
Sample Identification
Identification of suspect materials and specific vessel locations requiring further technical investigation.
Sampling Plan
Development of representative sampling locations based on vessel configuration, available documentation and technical assessment.
Laboratory Analysis
Coordination of appropriate laboratory testing where analytical confirmation is required within the agreed project scope.
Result Traceability
Maintenance of clear identification between the sample, vessel location, analytical result and corresponding IHM information.
IHM Part II Assessment
IHM Part II addresses operationally generated wastes associated with the ship under the applicable regulatory framework. The assessment considers relevant operational information, records and documentation where Part II is applicable to the vessel and project.
The purpose is to establish whether the available information provides a sufficiently clear and traceable basis for identifying applicable operationally generated wastes and supporting preparation for ship recycling.
Waste Identification
Review of operational waste streams relevant to the applicable IHM requirements and the vessel's operations.
Waste Records
Review of available records supporting the identification, handling and documentation of applicable operationally generated wastes.
Shipboard Procedures
Review of applicable procedures and arrangements relevant to operational waste management and record keeping.
Traceability
Assessment of whether applicable operational waste information can be followed through available records and supporting documentation.
IHM Part II Documentation Review
The following documentation areas may be considered when reviewing information relevant to operationally generated wastes. Each area should be considered according to the vessel's actual operations and the requirements applicable to the individual project.
Waste Management Procedures
Review of applicable procedures and responsibilities for operational waste management, including relevant onboard arrangements and documentation controls.
Waste Records
Review of available records supporting the identification, generation, handling and documentation of relevant operationally generated wastes.
Waste Storage
Review of relevant arrangements for retention and storage of applicable operationally generated wastes onboard.
Transfer & Disposal Records
Review of available documentation concerning transfer, landing or disposal of applicable operational waste streams.
Recycling Preparation
Assessment of information relevant to applicable preparation for ship recycling and the development or maintenance of required documentation.
The exact Part II documentation requirements depend on the applicable regulatory framework, vessel status, operational circumstances and agreed technical scope.
IHM Part II Technical Observations
Operational Waste Identification
Operationally generated waste information should be identified and maintained according to the requirements applicable to the vessel and project.
Record Consistency
Available waste records should be considered against applicable onboard procedures and operational practices.
Documentation Traceability
Relevant operational waste information should remain traceable to the applicable records and supporting documentation.
Recycling Preparation
Part II information can form part of the broader technical preparation required for applicable ship recycling activities.
IHM Gap Analysis
The technical assessment considered areas where available documentation, onboard condition and existing IHM information required comparison or additional verification.
Documentation Gaps
Missing, incomplete or insufficient supporting documentation requiring additional evidence or technical review.
Material Identification Gaps
Areas where available information did not provide sufficient certainty regarding the composition or status of a relevant material.
Location Gaps
Areas requiring clearer identification or traceability between relevant material information and its location onboard.
Operational Waste Gaps
Areas requiring further review of operationally generated waste information, records or supporting documentation.
Corrective Actions & Improvement Measures
Corrective actions should focus on improving the completeness, consistency and traceability of IHM information rather than simply correcting individual inventory entries.
- IHM Documentation: Review and update available IHM documentation where required.
- Supplier Information: Obtain additional supplier, manufacturer or material information where appropriate and available.
- Onboard Verification: Verify relevant equipment, systems and locations against the available documentation.
- Sampling: Identify materials requiring additional sampling or laboratory analysis where technically justified.
- Traceability: Improve the relationship between supporting evidence, vessel locations and relevant IHM entries.
- Part II Records: Review applicable operationally generated waste information and supporting records.
- Ongoing Management: Maintain updated information following relevant vessel modifications, replacements or changes.
IHM Technical Assessment Process
Preparation
Establish the agreed IHM assessment scope and collect available vessel documentation, previous IHM records and supporting technical information.
Documentation Review
Review available drawings, equipment information, material declarations, certificates, maintenance records and other relevant documentation.
Onboard Verification
Compare available information with accessible vessel areas, equipment, systems, components and actual onboard configuration.
Gap Identification
Identify missing information, discrepancies, suspect materials, traceability issues and areas requiring further evidence.
Technical Resolution
Consider documentation correction, additional verification, sampling, laboratory analysis or other appropriate technical actions.
Reporting & Follow-Up
Document the assessment findings and provide a technical basis for further compliance verification, certification or corrective action where applicable.
Results of the Technical Assessment
The structured assessment provided a clearer technical basis for evaluating the vessel's IHM information and identifying areas requiring additional attention.
Improved Traceability
Improved linkage between available technical documentation, identified materials and their relevant vessel locations.
Improved Documentation Control
Clearer identification of supporting documents required to substantiate relevant IHM information.
Improved Verification
Greater emphasis on comparing documented information with the vessel's actual configuration and accessible condition.
Improved Compliance Readiness
A more structured technical basis for subsequent Flag State, Recognized Organization or Classification Society review where applicable.
Technical Lessons Learned
- IHM Documentation: Existing IHM documentation should be treated as technical information requiring appropriate review and verification rather than assumed to be automatically complete.
- Vessel Modifications: Repairs, equipment replacements and modifications can affect the accuracy of existing IHM information.
- Traceability: Clear documentation traceability is essential for effective IHM management.
- Physical Verification: Onboard verification can identify discrepancies that may not be evident from documentation alone.
- Sampling: Sampling should be technically justified and properly traceable to the relevant vessel location and material.
- Operational Waste: Applicable operational waste information should be reviewed together with relevant shipboard records and procedures.
- Ongoing Management: IHM management should be maintained throughout the applicable life cycle of the vessel rather than treated solely as a one-time documentation exercise.
Regulatory & Technical Framework
The applicable IHM framework depends on the vessel, Flag State, trading circumstances, recycling requirements and regulatory regime applicable to the project.
- IMO Hong Kong Convention: Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009, including its applicable IHM requirements.
- IMO IHM Guidelines: Applicable IMO guidelines and associated technical guidance concerning the development, verification and maintenance of the Inventory of Hazardous Materials.
- EU Ship Recycling Regulation: Regulation (EU) No 1257/2013 where applicable to the vessel, ownership, trading circumstances and certification route.
- Flag State Requirements: Applicable requirements, interpretations and instructions of the vessel's Administration.
- Classification Requirements: Applicable requirements of the relevant Classification Society or Recognized Organization.
Project Significance
The project demonstrates the importance of combining technical documentation review with practical onboard verification when assessing an Inventory of Hazardous Materials.
For shipowners and technical managers, a structured IHM review can provide a clearer understanding of documentation quality, material identification, evidence gaps and areas requiring additional technical action.
The same technical approach can support vessels preparing for regulatory review, classification verification, ship recycling planning or other technical due-diligence activities where accurate hazardous-material information is required.
IHM Project & Technical References
The following PAMS resources provide additional information concerning IHM Part I and Part II services, the Manila Anchorage bulk-carrier project and IHM compliance surveys.
IHM Part I & Part II Services
Technical information on PAMS IHM Part I and Part II surveying, inventory assessment, verification and compliance support.
IHM Part I & Part II Project
Technical project reference concerning the Manila Anchorage bulk carrier with approximately 34,650 WDT.
IHM Compliance & Surveys
PAMS technical article covering IHM compliance surveys, hazardous materials identification and related regulatory considerations.
Recommendations for Shipowners & Technical Managers
Based on the technical principles demonstrated by this case study, shipowners and technical managers should consider the following practices when managing IHM information.
- Controlled IHM: Maintain a controlled and traceable IHM record.
- Change Management: Update IHM information following relevant repairs, modifications, replacements or other changes affecting hazardous-material information.
- Supplier Documentation: Retain appropriate supplier and material documentation where applicable.
- Suspect Materials: Review suspect materials where documentary evidence is insufficient.
- Sampling Records: Maintain traceability for samples, locations and laboratory results where sampling is undertaken.
- Part II Information: Review applicable operationally generated waste information and supporting records.
- Regulatory Coordination: Coordinate IHM activities with the applicable Flag State, Recognized Organization or Classification Society.
- Technical Integration: Avoid treating IHM compliance as a documentation exercise disconnected from the actual vessel configuration.
Conclusion
An effective IHM Part I and Part II assessment requires more than compiling a list of hazardous materials. It requires a structured technical process connecting documentation, vessel configuration, material identification, verification, operational records and the applicable regulatory requirements.
The Manila Anchorage bulk-carrier project demonstrates how an independent technical assessment can be used to identify documentation gaps, improve traceability and establish a stronger technical basis for subsequent compliance verification.
Technical Discussion Questions
- Configuration: Is the existing IHM documentation consistent with the vessel's current configuration?
- Location: Can hazardous-material information be traced to the relevant equipment, system or vessel location?
- Supplier Evidence: Are supplier declarations and supporting documents available where required?
- Modifications: Have relevant vessel modifications and equipment replacements been reflected in the IHM?
- Suspect Materials: Are suspect materials appropriately identified for further verification or sampling?
- Laboratory Results: Are laboratory results properly linked to the corresponding vessel locations and IHM information?
- Operational Waste: Is applicable IHM Part II operationally generated waste information properly supported by shipboard records?
- Regulatory Readiness: Is the vessel prepared for applicable Flag State, Recognized Organization or Classification Society review?
IHM Part I & Part II Case Study FAQ
What is IHM Part I?
IHM Part I identifies hazardous materials present in the ship's structure, machinery, equipment, systems and other relevant components within the scope of the applicable regulatory framework.
What is IHM Part II?
IHM Part II concerns operationally generated wastes associated with the ship under the applicable regulatory framework. Its application, documentation and maintenance should be considered according to the requirements applicable to the individual vessel.
What was the purpose of the IHM assessment in this case study?
The purpose was to review available IHM information, compare documentary evidence with the vessel's technical configuration, identify information gaps and assess areas requiring additional verification, sampling or corrective action.
Does an IHM assessment require onboard verification?
Depending on the applicable requirements and the status of the existing IHM, onboard verification may be necessary to compare documented information with the vessel's actual configuration and accessible condition.
When may IHM sampling be required?
Sampling may be considered where available documentation does not provide sufficient evidence to determine whether a relevant hazardous material is present. Sampling should be technically justified and performed using appropriate procedures.
Can PAMS support IHM sampling and laboratory coordination?
PAMS can provide technical support for identifying suspect materials, determining where sampling may be appropriate and coordinating suitable laboratory analysis within the agreed IHM technical consultancy scope.
Does an IHM assessment replace Classification Society or Flag State verification?
No. PAMS provides independent marine technical consultancy and survey support. Formal statutory approval, certification or verification remains with the applicable Administration, Recognized Organization or Classification Society where required.
What documentation is normally reviewed during an IHM assessment?
Depending on the vessel and project, documentation may include ship plans, equipment information, supplier declarations, material documentation, previous IHM records, maintenance and repair records, modification information, relevant certificates and applicable operational waste records.
Why is traceability important in an IHM?
Traceability allows relevant inventory information to be supported by identifiable technical information, vessel location, documentary evidence, sampling information or other appropriate supporting records.
Can IHM information become outdated?
Yes. Repairs, equipment replacements, modifications and other changes to the vessel can affect IHM information. Applicable IHM management processes should therefore address relevant changes throughout the vessel's applicable life cycle.
What regulations may apply to an IHM assessment?
Depending on the vessel and circumstances, applicable requirements may include the IMO Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, applicable IMO IHM guidance, the EU Ship Recycling Regulation where applicable, and relevant Flag State and Classification Society or Recognized Organization requirements.
Can PAMS provide IHM Part I and Part II technical consultancy internationally?
PAMS Pacific Admiralty Maritime Services provides independent marine technical consultancy and IHM survey support in the Philippines and internationally, subject to vessel access, project requirements and the applicable regulatory and certification framework.
Technical Reference Framework
IHM assessments should be performed with reference to the regulatory framework applicable to the individual vessel and project. Depending on the circumstances, this may include the IMO Hong Kong Convention, applicable IMO IHM guidelines, the EU Ship Recycling Regulation, Flag State requirements and Classification Society or Recognized Organization requirements.
The technical assessment should also consider vessel-specific documentation, modification history, material declarations, operational records and the actual configuration of the ship.
- IMO Hong Kong Convention: Applicable requirements concerning the safe and environmentally sound recycling of ships and the Inventory of Hazardous Materials.
- IMO IHM Guidelines: Applicable IMO guidance concerning the development and maintenance of the Inventory of Hazardous Materials.
- EU Ship Recycling Regulation: Regulation (EU) No 1257/2013 where applicable to the vessel and relevant circumstances.
- Flag State Requirements: Applicable requirements and interpretations of the vessel's Administration.
- Classification / Recognized Organization: Applicable technical, verification and certification requirements of the relevant organization.
The applicable reference framework should always be confirmed for the individual vessel and project. Requirements may differ according to Flag State, vessel status, trading circumstances, recycling destination and certification route.
Independent Technical Consultancy
Technical Content Review
PAMS technical content is intended to provide practical information concerning marine surveying, hazardous materials assessment, maritime compliance, technical inspection, ship recycling preparation and related marine technical activities.
Project-specific IHM requirements should always be confirmed against the applicable convention, regulation, Flag State requirements, Classification Society or Recognized Organization requirements, approved documentation and instructions of the responsible client or designated authority.
IHM Part I & Part II Technical Support
For independent Inventory of Hazardous Materials assessment, documentation review, onboard verification, hazardous materials identification, sampling coordination, operationally generated waste assessment and applicable ship recycling technical support, contact PAMS Pacific Admiralty Maritime Services to discuss the project requirements and survey scope.
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