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Hazardous Materials Management

IHM Part I & Part II – Inventory of Hazardous Materials Services

Independent technical support for the preparation, verification, maintenance and review of Inventory of Hazardous Materials documentation covering hazardous materials in ship structure, equipment and operationally generated waste.

Inventory of Hazardous Materials – Technical Scope

The Inventory of Hazardous Materials (IHM) is an important element of modern ship recycling and hazardous-material management requirements. PAMS Pacific Admiralty Maritime Services provides independent technical consultancy and inspection support for IHM documentation, including technical assessment of IHM Part I and IHM Part II information.

IHM Part I identifies hazardous materials contained in the ship's structure and equipment, while IHM Part II addresses operationally generated wastes that are present on board during the period covered by the applicable requirements.

Technical principle: IHM documentation should be based on a systematic assessment of the vessel, available documentation, supplier information, hazardous material declarations and, where required, sampling and analysis. The objective is to establish reliable technical information that can support regulatory compliance, safe ship operation, future ship recycling and preparation for recycling.

PAMS IHM Part I & Part II Methodology

IHM Part I Assessment

Technical review of hazardous materials contained in the ship's structure, machinery, electrical systems, equipment and other relevant installations.

IHM Part II Assessment

Review of operationally generated wastes accumulated on board, including relevant waste categories and quantities requiring documentation.

Documentation & Supplier Information

Review of available drawings, equipment lists, Material Declarations, Supplier's Declarations of Conformity and other technical information relevant to hazardous-material identification.

Verification & Technical Review

Cross-checking available information against the vessel's physical condition and agreed inspection scope, with technical findings documented for follow-up and corrective action.

IHM Part I – Hazardous Materials in Ship Structure & Equipment

IHM Part I concerns hazardous materials contained in the ship's structure and equipment. The assessment is intended to identify the presence and location of applicable hazardous materials so that the information can remain available throughout the vessel's operational life and during preparation for recycling.

Paints, Coatings & Surface Materials

  • Paint systems and coatings requiring hazardous-material assessment.
  • Anti-corrosive and protective coating systems.
  • Historical coating information where available.
  • Potential asbestos-containing or other hazardous materials incorporated in coatings or surface systems where applicable.

Machinery & Engineering Systems

  • Main propulsion machinery.
  • Auxiliary engines and generators.
  • Pumps, compressors and associated equipment.
  • Valves, piping systems and machinery components.
  • Insulation, gaskets and other relevant components.

Electrical & Electronic Equipment

  • Electrical distribution equipment.
  • Switchboards and control panels.
  • Cables and electrical components where relevant.
  • Batteries and associated equipment.
  • Electronic equipment containing applicable hazardous substances.

Accommodation & Interior Areas

  • Accommodation spaces.
  • Insulation materials.
  • Flooring and ceiling systems.
  • Fire-resistant materials.
  • Seals, gaskets and other installed materials where applicable.
Part I technical focus: The identification process should consider the vessel's construction history, installed equipment, modifications, replacement components, available supplier information and physical condition. Where documentary evidence is insufficient, additional investigation, sampling or laboratory analysis may be required depending on the applicable requirements and agreed scope.

IHM Part I – Principal Hazardous Material Categories

The IHM assessment considers hazardous materials specified by the applicable regulatory framework. Typical categories requiring consideration include the following.

Material / Category Typical Technical Considerations
Asbestos Assessment of potentially asbestos-containing materials such as insulation, gaskets, packing, pipe lagging and other installed components where relevant.
Polychlorinated Biphenyls (PCBs) Review of relevant electrical equipment, oils, sealants, paints and other materials where PCB contamination or presence may require consideration.
Ozone-Depleting Substances Identification and documentation of applicable refrigerants, fire-extinguishing systems and other equipment containing controlled substances.
Anti-Fouling Systems Review of applicable anti-fouling systems and hazardous substances regulated under the relevant international requirements.
PFOS / PFOA and Other Regulated Substances Assessment of applicable hazardous substances according to the regulatory framework, vessel construction date and relevant amendments in force.
Heavy Metals & Other Hazardous Materials Identification of applicable hazardous materials contained in paints, equipment, electrical components, machinery and other shipboard installations.

IHM Part II – Operationally Generated Wastes

IHM Part II concerns operationally generated wastes that are present on board during the relevant period. These materials are different from hazardous materials incorporated into the ship's structure and equipment and therefore require separate identification and documentation.

Machinery Waste

  • Waste oils and oily residues.
  • Used filters and contaminated consumables.
  • Sludge and machinery-related residues.
  • Other relevant operational waste generated by machinery systems.

Cargo-Related Waste

  • Cargo residues where applicable.
  • Contaminated materials arising from cargo operations.
  • Operational materials requiring controlled disposal.
  • Waste associated with cargo handling systems where relevant.

Maintenance Waste

  • Used maintenance materials.
  • Contaminated rags and absorbents.
  • Used chemical containers.
  • Maintenance-related hazardous residues.

Other Operational Waste

  • Waste arising from routine vessel operations.
  • Contaminated materials requiring controlled handling.
  • Applicable shipboard waste requiring documentation.
  • Quantities and locations relevant to the IHM record.
Part II technical principle: Part II should be maintained using reliable shipboard operational records and information concerning wastes generated, retained and disposed of during vessel operation. The applicable documentation should distinguish operationally generated waste from hazardous materials that are already incorporated into ship structure and equipment.

IHM Documentation Review

Reliable IHM development depends on the quality of the technical information available. PAMS can review the available documentation and identify inconsistencies, missing information and areas requiring additional investigation.

Documentation Area Technical Review Focus
Ship Drawings General arrangement, machinery arrangements, piping, electrical and accommodation drawings relevant to identifying hazardous materials.
Equipment Lists Installed equipment, machinery, components and associated manufacturer information.
Material Declarations Supplier-provided information identifying applicable hazardous materials contained in supplied equipment and components.
Supplier Documentation Supplier's Declarations of Conformity, certificates, technical data and other available material information.
Maintenance Records Replacement components, machinery modifications, repairs and materials introduced during the vessel's operational life.
Waste Records Operational waste generation, storage, transfer and disposal records relevant to IHM Part II.

IHM Inspection & Verification Process

1. Documentation Collection

Available vessel drawings, equipment lists, technical records, supplier declarations, material information and relevant waste records are reviewed.

2. Hazardous Material Screening

Potential locations and equipment associated with regulated hazardous materials are identified for technical assessment.

3. Onboard Verification

Accessible vessel areas, machinery, equipment and installations are checked against available IHM documentation within the agreed inspection scope.

4. Sampling & Analysis

Where documentary evidence cannot adequately establish material composition and sampling is required, representative samples may be taken for appropriate laboratory analysis under the agreed technical scope.

5. Part II Waste Review

Operationally generated waste information is reviewed against available shipboard records, waste management practices and applicable IHM requirements.

6. Technical Reporting

Findings, discrepancies, identified materials and recommended corrective actions are documented in a structured technical format.

IHM Part I & Part II Technical Deliverables

IHM Technical Review

Review of the available IHM documentation against the agreed technical scope and applicable regulatory requirements.

Hazardous Material Location Review

Identification and verification of relevant locations, equipment and materials recorded within the IHM Part I documentation.

Part II Waste Assessment

Technical review of operationally generated waste information, supporting records and quantities where required.

Discrepancy Report

Identification of missing, inconsistent or technically questionable information requiring correction or additional investigation.

Photographic Evidence

Photographic documentation of relevant equipment, materials, locations and observed conditions where permitted and appropriate.

Technical Recommendations

Practical recommendations for additional investigation, sampling, documentation updates and technical follow-up.

When Sampling & Laboratory Analysis May Be Required

Documentary evidence does not always provide sufficient certainty regarding the composition of an installed material. In such cases, additional investigation and representative sampling may be required according to the applicable regulatory requirements and agreed scope.

Insulation & Gaskets

Materials with uncertain composition may require sampling where documentation cannot establish whether a regulated hazardous material is present.

Paint & Coatings

Representative sampling may be considered where coating composition cannot be adequately established through existing documentation.

Electrical Components

Older or undocumented equipment may require further technical investigation where the presence of regulated substances cannot be established from available records.

Other Suspect Materials

Additional investigation may be recommended for materials identified during the onboard inspection that require confirmation before inclusion or exclusion from the IHM.

Sampling principle: Sampling and laboratory analysis should be performed only where justified by the agreed IHM methodology and applicable requirements. The number and location of samples should be based on representative assessment rather than arbitrary sampling.

IHM Management Throughout the Vessel's Life

The IHM is not intended to be a static document. Relevant information should be maintained when materials, equipment or systems are added, removed or replaced during the vessel's operational life.

New Equipment

Supplier material information should be collected and retained when new equipment or components are installed.

Machinery Replacement

Replacement machinery and components should be reviewed for relevant hazardous-material information before the IHM is updated.

Ship Repairs

Significant repairs and modifications may introduce new materials and should be considered in the vessel's IHM management process.

IHM Updating

Relevant changes should be incorporated into the IHM so that the inventory remains consistent with the vessel's actual condition and installed equipment.

Regulatory & Technical Reference Framework

The applicable IHM requirements depend on vessel type, flag, construction date, trading area and the regulatory framework governing the vessel. PAMS technical assessments can be structured with reference to the applicable requirements and client scope.

Hong Kong Convention Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, including requirements relating to the Inventory of Hazardous Materials.
EU Ship Recycling Regulation Regulation (EU) No. 1257/2013 concerning ship recycling and Inventory of Hazardous Materials requirements applicable to ships within its scope.
IMO IHM Guidelines Applicable IMO guidelines and recommendations concerning the development, maintenance and verification of the Inventory of Hazardous Materials.
Flag State Requirements Applicable flag Administration requirements, circulars and instructions relevant to IHM preparation and maintenance.
Classification Society Requirements Applicable class requirements, procedures and verification arrangements relevant to IHM documentation.
Ship Recycling Requirements Technical requirements relevant to preparation for safe and environmentally sound ship recycling.
Supplier Material Information Manufacturer and supplier declarations supporting identification of hazardous materials contained in equipment and components.
Shipboard Waste Records Operational records supporting the identification and documentation of applicable IHM Part II wastes.
Regulatory hierarchy: The applicable flag State, port State, class, international and regional requirements should be determined according to the vessel, construction date, flag, trading area and applicable legislation. Where requirements differ, the governing regulatory framework and applicable statutory instructions should be established before the IHM scope is finalized.

Independent Technical IHM Consultancy

Independent Consultancy

PAMS Pacific Admiralty Maritime Services is an independent Philippine technical consultancy providing marine surveying, technical inspection and maritime regulatory consultancy.

Engineering-Based Assessment

IHM work is approached through technical documentation review, engineering assessment, onboard verification and structured reporting.

Regulatory Awareness

The assessment considers the applicable international, regional, flag State and classification requirements relevant to the vessel and agreed scope.

Practical Technical Reporting

Findings are presented in a structured format designed to help owners, operators and technical stakeholders understand IHM status, deficiencies and required follow-up.

About the Technical Author

Gregory Apostologlou

Managing Director of PAMS Pacific Admiralty Maritime Services. Mechanical Engineer and Marine Technical Superintendent with international maritime experience in marine surveying, vessel inspections, offshore and FPSO/SPM technical engineering and maritime regulatory compliance.

Gregory Apostologlou is also an authorized PHRS Surveyor.

Technical Content Review

Last Technical Review

October 2026

Review Frequency

Content is reviewed periodically to reflect changes in international ship recycling requirements, IHM guidance, applicable regional legislation and recognized technical practices.

Referenced technical framework: Hong Kong Convention, IMO IHM Guidelines, EU Ship Recycling Regulation (EU) No. 1257/2013, applicable Flag State requirements, Classification Society requirements and relevant ship recycling requirements.

IHM Part I & Part II FAQ

What is IHM Part I?

IHM Part I identifies hazardous materials contained in the ship's structure, machinery, equipment, electrical systems and other relevant installed components within the applicable regulatory scope.

What is IHM Part II?

IHM Part II concerns operationally generated wastes that are present on board during the relevant period. It is separate from Part I, which addresses hazardous materials contained in the ship's structure and equipment.

Is IHM Part I the same as an asbestos survey?

No. An asbestos survey addresses asbestos specifically, whereas IHM Part I has a broader scope covering applicable hazardous materials identified by the governing regulatory framework.

Does IHM Part I always require laboratory sampling?

Not necessarily. Available documentation and reliable supplier information may establish the material composition in some cases. Where documentary evidence is insufficient, sampling and laboratory analysis may be required according to the applicable requirements and agreed technical methodology.

Does IHM Part II cover hazardous materials built into the ship?

No. Hazardous materials incorporated into the ship's structure and equipment are addressed under Part I. Part II addresses operationally generated wastes.

Does the IHM need to be updated after vessel modifications?

Relevant changes to equipment, machinery, materials and installations should be considered as part of ongoing IHM management so that the inventory remains consistent with the vessel's actual condition.

Can PAMS review an existing IHM?

Yes. PAMS can provide technical review and verification support for existing IHM documentation within an agreed scope, including comparison with available vessel documentation and accessible physical conditions.

Can PAMS prepare an IHM for an existing vessel?

PAMS can provide technical consultancy, inspection, documentation review and IHM assessment support. The final approval, certification or statutory verification arrangement depends on the applicable flag, class, regulatory framework and authorized organization involved.

Does IHM Part II replace the vessel's normal waste management records?

No. IHM Part II requirements should be considered together with the vessel's applicable garbage, waste, oil and operational recordkeeping requirements. The precise documentation depends on the vessel and governing regulatory framework.

IHM Case Studies, Technical Projects & Articles

Related Marine Technical Services

Engineering Reference Notice

This page describes the general technical scope of PAMS IHM Part I and Part II consultancy, inspection and documentation review services. Actual requirements depend on vessel type, flag, construction date, trading area, applicable international and regional legislation, classification requirements, available documentation and the agreed project scope. IHM technical consultancy does not by itself constitute statutory approval, flag State certification, classification certification or authorization to issue a statutory IHM Certificate unless separately provided by an appropriately authorized organization.

Request an IHM Technical Assessment

Request an independent IHM Part I or Part II technical review, onboard verification, documentation assessment or hazardous-material inspection. Provide the vessel name, IMO number, flag, construction year, location and existing IHM documentation so the appropriate technical scope can be considered.

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