Attributed to: Shailesh Singh Gaharwar, Shipping Material and Testing Business Unit Director, Normec Verifavia
The regulations surrounding the inventory of hazardous materials (IHM) are entering a critical phase, and ship owners - especially those flying the Liberian flag - need to get their facts straight if they want to avoid high costs and serious setbacks. There are a few key misconceptions. Let's take a successive look at the top five and set the record straight.
1. Deadlines
The Hong Kong Convention is now active, which means that nearly 6,000 Liberian-flagged ships must already have certified IHM Part I on board. Ships flying other flags have until June 26, 2030, but compliance is necessary for ships entering EU waters under EU SRR, or sailing in areas that have implemented the Convention, including Liberia.
Delay is risky. During the rollout of the EU SRR, service costs rose sharply and classification societies and flag authorities faced an overload of dossiers to approve, delaying certification. The same backlog is expected as 2030 approaches, so shipowners must act early to avoid cost inflation, approval delays and compliance problems.
2. Impact
Having a certified and up-to-date IHM Part I on board is not optional. Port state control authorities have handed out fines of €50,000-€60,000 for non-compliance and in some ports ships have even been detained until hazardous materials sampling is completed, causing costly operational disruptions.
Certain regions require IHM documentation before a vessel enters territorial waters. If asbestos is found, authorities can expect an additional asbestos-free certificate, which adds time and cost.
For example, Australian authorities do not require a certified IHM on board, but require independent verification surveys for certain hazardous materials, such as asbestos. If a ship has an IHM, they use that document to meet the requirement for independent surveys. A ship may enter Australian waters even if it does not have an IHM Part-I on board, provided it has an asbestos survey report.
Asbestos regulations are already enforced on dry docks in China, the UAE and many EU countries, and in European facilities, work can be completely denied unless hazardous materials are removed by certified professionals.
3. Maintenance of IHM Part One.
An approved IHM Part One must be continuously maintained to keep certificates valid. Flag and class authorities require proof of maintenance at renewal, so ship owners need a formal procedure integrated into their safety management system and a designated IHM responsible person.
Service providers such as Normec Verifavia must regularly review purchase orders and collect material declarations (MDs) and supplier declarations of conformity (SDoCs) for all relevant items, even if no hazardous materials are present. All paints and coatings, equipment and machinery, and structure and hull that fall under the scope of the regulation require documentation, and with suppliers charging €15-€20 per declaration, mistakes can be costly.
4. Different regulations, different certificates
The EU SRR and the Hong Kong Convention operate independently and each requires its own certificate. Ships operating exclusively in EU waters need only an EU SRR certificate, while ships sailing internationally must also have an HKC certificate.
While an EU SRR certificate can facilitate obtaining the HKC certificate, the process is not automatic. Owners must submit their approved declaration of compliance and maintenance records.
Conversely, HKC-certified ships can obtain EU SRR approval by demonstrating that they have been sampled and tested for additional restricted materials (PFOS and HBCDD), although the latter applies mainly to new-build ships.
5. Understand Table A and Table B.
IHM Part I divides hazardous materials into two categories: Table A, which includes materials that must be disposed of, and Table B, whose materials may remain but must be registered.
Table A materials such as asbestos, PCBs and ozone-depleting materials are subject to strict international regulations such as SOLAS, the Stockholm Convention and the Montreal Protocol.
Although the general structure is consistent between the HKC Table A and B and the EU SRR Annex I and Annex II, the exact substances listed differ somewhat, making accurate documentation essential for compliance under both regimes.