IHM Part I & Part II — Manila Project
Independent technical assessment supporting Inventory of Hazardous Materials Part I and Part II through documentation review, onboard verification, hazardous materials assessment, operationally generated waste review, technical gap identification, and compliance preparation.
IHM Part I & Part II Manila Project
PAMS Pacific Admiralty Maritime Services carried out an independent technical assessment supporting the review of an Inventory of Hazardous Materials (IHM) Part I and Part II for a commercial vessel project associated with Manila, Philippines.
The project combined technical documentation review, assessment of available hazardous materials information, onboard verification, review of operationally generated waste information, identification of documentation gaps, and technical recommendations for improving the traceability and reliability of the vessel's IHM information.
Location
Manila Anchorage / Manila, Philippines
Vessel Type
Commercial Bulk Carrier
Vessel Size
Approximately 34,650 WDT
Technical Focus
IHM Part I, IHM Part II, documentation review, onboard verification, hazardous materials assessment, and ship recycling compliance preparation.
Client Requirement
The project required independent technical support to assess the available Inventory of Hazardous Materials information and determine whether the documentation provided a sufficiently traceable basis for the vessel's hazardous materials inventory.
The assessment also considered the relationship between existing documentation and the vessel's actual configuration, machinery, equipment, installed materials, maintenance history, and operational waste arrangements.
Particular attention was given to identifying areas where additional documentation, onboard verification, material investigation, sampling, corrective action, or further regulatory review could be required.
Project Scope
The technical assessment covered the principal elements required to establish a structured review of IHM Part I and Part II information, including:
Documentation Review
- Review of available vessel plans and drawings.
- Review of machinery and equipment documentation.
- Review of available material declarations.
- Review of maintenance and repair records.
- Review of previous IHM information where available.
Onboard Verification
- Verification of relevant accessible vessel areas.
- Comparison of documentation with actual configuration.
- Identification of suspect materials.
- Verification of equipment and material locations.
- Recording of technical observations.
IHM Part I Assessment
- Ship structure and installed materials.
- Machinery and equipment.
- Electrical and control systems.
- Coatings and other relevant installed materials.
- Hazardous material identification and traceability.
IHM Part II Assessment
- Operationally generated waste identification.
- Waste records and supporting documentation.
- Waste storage arrangements.
- Relevant onboard procedures.
- Traceability of operational waste information.
Initial Documentation Review
The initial phase established the available documentary basis for the IHM assessment. The objective was to determine what information was available, identify limitations, and establish areas requiring further verification.
Ship Plans and Drawings
General arrangement drawings, machinery information, equipment arrangements, relevant plans, and other available technical documentation were reviewed to establish the vessel configuration and identify relevant locations.
Material Information
Available supplier information, material declarations, certificates, technical specifications, and other supporting information were reviewed for evidence relating to hazardous materials.
Maintenance and Repair Records
Available records were reviewed to identify repairs, replacements, modifications, equipment changes, and other activities that could affect existing IHM information.
Previous IHM Information
Existing IHM information was compared with available vessel documentation to identify potential gaps, inconsistencies, missing evidence, or areas requiring onboard verification.
Technical Documentation Assessment
The technical documentation assessment focused on whether available information could provide reliable evidence for identifying, locating, and tracing hazardous materials and operationally generated wastes.
General Arrangement
Identification of relevant vessel spaces, machinery areas, accommodation areas, equipment locations, and other locations potentially associated with hazardous materials.
Machinery Documentation
Review of machinery, components, equipment, systems, and associated materials potentially relevant to hazardous materials identification.
Material Declarations
Review of supplier declarations and available material information supporting the identification and traceability of hazardous substances.
Maintenance Records
Review of repairs, replacements, modifications, and equipment changes that may affect existing IHM data or material identification.
Previous IHM Records
Comparison of existing inventory information with current vessel documentation and available evidence of onboard condition.
Operational Waste Records
Review of applicable records and documentation relevant to IHM Part II operationally generated wastes and their traceability.
IHM Part I Assessment
IHM Part I concerns hazardous materials contained in the ship's structure, machinery, equipment, systems, coatings, and other installed materials.
Ship Structure
Review of relevant structural areas, materials, coatings, insulation, and other components that may require hazardous materials assessment.
Machinery and Equipment
Assessment of machinery, pumps, valves, piping systems, auxiliary equipment, and other installed equipment within the agreed technical scope.
Electrical and Control Systems
Review of relevant electrical equipment, control systems, cables, components, and associated materials where hazardous materials information may be required.
Coatings and Installed Materials
Review of coatings, insulation, sealants, gaskets, and other installed materials requiring documentary or technical verification.
IHM Part I Verification Methodology
The assessment followed a structured technical process designed to connect documentary evidence with the vessel's actual condition and configuration.
Preparation
Review available hazardous materials documentation, technical records, vessel plans, and relevant project information before onboard verification.
Documentation Comparison
Compare available documentation with vessel plans, equipment arrangements, machinery information, and relevant installed systems.
Onboard Verification
Verify relevant accessible areas and compare actual vessel configuration with available documentary information.
Material Investigation
Identify suspect materials or areas where available documentary evidence is insufficient for a reliable technical determination.
Sampling and Analysis
Determine where sampling and suitable laboratory analysis may be appropriate to establish the presence or absence of relevant hazardous substances.
Traceability and Corrective Action
Review the traceability of findings, identify discrepancies, document corrective actions, and establish supporting technical evidence.
Hazardous Materials Review
The technical review considered hazardous materials categories relevant to the applicable IHM requirements and the evidence available for the vessel.
Asbestos and Asbestos-Containing Materials
Review of available documentation and relevant installed materials for evidence relating to asbestos or asbestos-containing materials requiring further verification.
PCBs
Review of available equipment and material information for potential PCB-related requirements and identification of areas requiring additional technical evidence.
Ozone-Depleting Substances
Review of relevant systems, equipment, refrigerants, and supporting information associated with ozone-depleting substances.
Other Regulated Materials
Consideration of other hazardous or regulated materials applicable to the vessel, project scope, and regulatory requirements.
Sampling and Laboratory Assessment
Where documentary evidence was insufficient to establish the presence or absence of a relevant hazardous material, the assessment considered whether additional investigation or sampling could be technically justified.
Sample Identification
Identification of suspect materials and locations requiring further investigation based on available evidence and onboard observations.
Sampling Plan
Development or recommendation of a structured sampling approach considering material location, accessibility, representativeness, safety, and traceability.
Laboratory Analysis
Coordination or recommendation of appropriate laboratory analysis where testing is required to establish the presence or absence of relevant hazardous substances.
Traceability
Linking sample identification, location, analysis results, supporting evidence, and resulting IHM records to maintain technical traceability.
IHM Part II Assessment
IHM Part II concerns operationally generated wastes associated with the operation of the ship. The assessment considered the available records, procedures, storage arrangements, and supporting documentation relevant to these waste streams.
Waste Identification
Identification of relevant operationally generated waste streams arising from normal vessel operations and maintenance activities.
Waste Records
Review of available records supporting the generation, handling, transfer, storage, and disposal of relevant operational wastes.
Onboard Procedures
Review of applicable onboard procedures for waste handling, segregation, storage, transfer, and documentation.
Traceability
Assessment of the relationship between operational waste records, onboard procedures, storage arrangements, and supporting documentation.
IHM Part II Documentation Review
The IHM Part II documentation review focused on establishing whether operationally generated waste information was sufficiently documented and traceable for the applicable project and regulatory requirements.
Waste Management Procedures
Review of relevant onboard procedures governing the handling, segregation, storage, transfer, and disposal of operationally generated wastes.
Waste Records
Review of available records documenting waste generation, handling, landing, transfer, and disposal activities.
Waste Storage
Assessment of available information concerning designated waste storage areas, segregation arrangements, and identification of relevant waste streams.
Disposal Documentation
Review of available receipts, transfer records, disposal documentation, and other evidence supporting waste traceability.
Recycling Preparation
Assessment of documentation relevant to maintaining IHM Part II information and supporting future ship recycling preparation.
IHM Gap Analysis
The assessment identified areas where available information could require additional evidence, verification, updating, or corrective action.
Documentation Gaps
Missing, incomplete, outdated, or insufficient supporting documentation affecting the technical traceability of IHM information.
Material Identification Gaps
Areas where available evidence did not provide sufficient confidence regarding the identification of relevant hazardous materials.
Location Gaps
Incomplete or insufficient information connecting hazardous materials to specific equipment, systems, spaces, or locations.
Operational Waste Gaps
Gaps relating to operational waste records, procedures, storage information, disposal evidence, or traceability.
Corrective Actions and Improvement Measures
Depending on the individual finding, corrective and improvement measures may include:
- Obtaining missing supplier declarations or material information.
- Updating existing IHM entries to reflect verified vessel configuration.
- Conducting additional onboard verification of relevant areas.
- Identifying suspect materials requiring further investigation.
- Conducting representative sampling where technically justified.
- Obtaining suitable laboratory analysis where required.
- Updating locations and material descriptions within the IHM.
- Improving operational waste documentation and traceability.
- Maintaining supporting evidence for future verification and ship recycling activities.
Technical Assessment Process
The Manila IHM project followed a structured technical assessment process designed to maintain consistency between documentary evidence, onboard observations, technical findings, and corrective actions.
Documentation Review
Review of available technical documents, vessel plans, equipment information, material declarations, maintenance records, and existing IHM information.
Onboard Verification
Verification of relevant accessible areas and comparison of actual vessel configuration with available documentation.
Gap Identification
Identification of missing evidence, inconsistencies, material uncertainties, location gaps, and operational waste documentation issues.
Corrective Action
Development of technical recommendations for documentation updates, additional verification, sampling, analysis, and improvement of IHM traceability.
Results of the Technical Assessment
Improved Traceability
The assessment established a clearer relationship between available documentation, vessel locations, equipment, materials, observations, and supporting evidence.
Improved Documentation Control
Documentation gaps and areas requiring additional evidence were identified for further technical follow-up.
Improved Verification
Onboard observations provided an additional technical basis for comparing documented information with actual vessel configuration.
Improved Compliance Readiness
The resulting technical information supported further preparation for applicable IHM, ship recycling, Flag State, Recognized Organization, or Classification Society requirements.
Technical Lessons Learned
The project demonstrated several important principles applicable to IHM assessments and ship recycling preparation.
- IHM information should be supported by traceable technical evidence.
- Existing documentation should be compared with the vessel's actual configuration.
- Maintenance, repairs, replacements, and modifications can affect the accuracy of existing IHM information.
- Suspect materials may require further technical investigation or representative sampling.
- IHM Part II requires appropriate attention to operationally generated waste information and records.
- Clear location information improves the practical usability of the IHM.
- Supporting evidence should be maintained for future verification, updating, and ship recycling activities.
- Early identification of documentation gaps can reduce later project delays and compliance uncertainties.
Regulatory and Technical Framework
The applicable technical and regulatory framework depends on the vessel, Flag State, trading profile, project requirements, and applicable ship recycling legislation.
- IMO Hong Kong International Convention: Requirements concerning the safe and environmentally sound recycling of ships and the Inventory of Hazardous Materials.
- IMO IHM Guidelines: Applicable IMO guidance supporting the development and maintenance of Inventory of Hazardous Materials information.
- EU Ship Recycling Regulation: Applicable requirements for vessels and activities falling within the scope of the European Union Ship Recycling Regulation.
- Flag State Requirements: Applicable requirements of the vessel's Administration and associated statutory framework.
- Classification Requirements: Applicable requirements, survey procedures, or verification activities of the responsible Classification Society or Recognized Organization.
Project Significance
An effective IHM is not simply a document containing a list of hazardous materials. It is a structured technical information system that should connect material identification with supporting evidence, location, equipment, documentation, verification, and subsequent updating.
The Manila project demonstrated the importance of combining documentation review with practical technical verification and structured gap analysis.
IHM Project and Technical References
The following PAMS resources provide additional information related to the IHM technical services, this case study, and IHM compliance surveys.
Recommendations for Shipowners and Technical Managers
Based on the technical principles demonstrated by this project, shipowners and technical managers should consider the following practices when developing, reviewing, or maintaining IHM information:
- Maintain a controlled and traceable IHM documentation system.
- Retain supplier material declarations and supporting technical evidence wherever available.
- Review IHM information following significant repairs, modifications, replacements, or equipment changes.
- Verify relevant vessel locations rather than relying solely on historical documentation.
- Maintain appropriate evidence for sampling and laboratory analysis where such investigation is required.
- Maintain clear operational waste records supporting IHM Part II.
- Ensure changes to the vessel are reflected in the relevant IHM information.
- Prepare IHM information early enough to allow corrective action before regulatory or ship recycling milestones.
Technical Discussion Questions
- Is the available IHM documentation sufficiently traceable to the vessel's actual configuration?
- Are hazardous material locations clearly identified?
- Are supplier declarations available for relevant equipment and materials?
- Have repairs, replacements, and modifications been incorporated into the current IHM information?
- Are suspect materials supported by sufficient technical evidence?
- Is additional sampling or laboratory analysis technically justified?
- Are IHM Part II operational waste records complete and traceable?
- Is the vessel adequately prepared for applicable ship recycling requirements?
IHM Part I & Part II Manila Project FAQ
What was the purpose of the Manila IHM project?
The purpose was to provide an independent technical assessment of IHM Part I and Part II information, including documentation review, onboard verification, hazardous materials assessment, operational waste review, gap identification, and technical recommendations.
What is IHM Part I?
IHM Part I identifies hazardous materials contained in the ship's structure, machinery, equipment, systems, coatings, and other installed materials that fall within the applicable requirements.
What is IHM Part II?
IHM Part II addresses operationally generated wastes associated with the operation of the ship and includes relevant waste information, records, procedures, storage, handling, and traceability.
Why was onboard verification important?
Onboard verification allows available documentation to be compared with the vessel's actual configuration, equipment, materials, spaces, and condition. This can identify discrepancies that may not be evident from documentation alone.
What documentation was reviewed?
The assessment considered available vessel plans, machinery and equipment information, material declarations, maintenance and repair records, previous IHM information, and relevant operational waste documentation.
When may IHM sampling be required?
Sampling may be appropriate where existing documentation does not provide sufficient evidence to establish whether a suspect material contains a relevant hazardous substance. Sampling should be planned and supported by appropriate technical and laboratory procedures.
Can PAMS support IHM sampling and laboratory coordination?
PAMS Pacific Admiralty Maritime Services can provide technical support for sampling planning, sample identification, documentation, traceability, and coordination with appropriate laboratory analysis, subject to the agreed project scope.
Why is traceability important in an IHM?
Traceability connects hazardous material information with its location, equipment, supporting documentation, sample results, findings, and corrective actions. This improves the technical reliability and future usability of the IHM.
Can IHM information become outdated?
Yes. Repairs, replacements, modifications, equipment changes, and other vessel activities can affect IHM information. Relevant changes should therefore be assessed and incorporated in accordance with applicable requirements.
Does an independent IHM assessment replace Classification Society or Flag State verification?
No. Independent technical consultancy does not replace statutory, Flag State, Recognized Organization, or Classification Society verification where such verification is required. Formal approval or certification remains subject to the applicable authority or appointed organization.
What regulations may apply to an IHM project?
Depending on the vessel and applicable jurisdiction, requirements may include the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, IMO guidance, the EU Ship Recycling Regulation, Flag State requirements, and applicable Classification Society or Recognized Organization requirements.
Can PAMS provide IHM technical consultancy internationally?
Yes. PAMS Pacific Admiralty Maritime Services provides independent marine technical consultancy and can support IHM Part I and Part II technical assessments, documentation review, onboard verification, gap analysis, sampling coordination, and related ship recycling compliance activities in the Philippines and internationally, subject to project scope and applicable requirements.
IHM Technical Reference
IHM technical assessments may involve international conventions, IMO guidance, national and Flag State requirements, regional legislation, Classification Society requirements, Recognized Organization procedures, and project-specific technical requirements.
Hong Kong Convention
International framework concerning the safe and environmentally sound recycling of ships and the Inventory of Hazardous Materials.
IMO IHM Guidelines
Applicable IMO guidance supporting the development, identification, verification, and maintenance of Inventory of Hazardous Materials information.
EU Ship Recycling Regulation
Applicable European requirements for vessels and activities falling within the scope of the EU Ship Recycling Regulation.
Classification and Flag Requirements
Applicable requirements of the responsible Classification Society, Recognized Organization, Flag Administration, and other appointed authorities.
Independent Technical Consultancy Approach
IHM projects require coordination between technical documentation, vessel configuration, material information, onboard observations, operational records, laboratory evidence where required, and applicable regulatory requirements.
PAMS Pacific Admiralty Maritime Services applies an independent technical approach designed to establish a clear relationship between documentary evidence, onboard findings, material identification, location information, corrective actions, and subsequent IHM updating.
Documentation
Review of available technical documents and supporting evidence relevant to the IHM assessment.
Verification
Independent technical verification of relevant accessible vessel areas and comparison with available information.
Assessment
Technical evaluation of hazardous materials, operational wastes, documentation gaps, and traceability.
Reporting
Structured technical reporting and recommendations supporting corrective action and future compliance activities.
Independent IHM Technical Consultancy
The consultancy does not replace the responsibilities of the shipowner, technical manager, shipyard, Flag Administration, Classification Society, Recognized Organization, statutory authority, laboratory, or other appointed project parties.
Where formal statutory, Flag State, Recognized Organization, or Classification Society verification or certification is required, such activities remain subject to the applicable authority or appointed organization.
IHM Manila Project Reference Notice
The information presented in this project case study is intended to illustrate independent technical consultancy, documentation review, onboard verification, hazardous materials assessment, IHM Part I and Part II review, gap identification, sampling considerations, and technical reporting methodologies. The actual scope of any IHM assessment depends on vessel configuration, available documentation, project requirements, access, applicable Flag State requirements, Classification Society or Recognized Organization requirements, regulatory requirements, and the agreed technical scope. Consultancy services do not replace statutory inspections, Classification Society surveys, Flag Administration requirements, Recognized Organization verification, or other mandatory examinations performed by the responsible authorities or appointed organizations.
IHM Part I & Part II Technical Support
Request independent IHM technical consultancy, documentation review, onboard verification, hazardous materials assessment, sampling coordination, operational waste assessment, gap analysis, or ship recycling compliance support. Describe your vessel, location, project stage, and specific IHM requirements and our technical team will review the scope.
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