Inventory of Hazardous Materials (IHM) From Operating Life to Recycling
The IHM is a vessel-specific record. Its preparation, updating, verification and final-survey route depend on the vessel, available records, specialist scope and applicable flag or recognised-organisation instruction.
Parts I, II and III Serve Different Stages
The IHM is vessel-specific and is not only a last-minute recycling document. Part I follows materials contained in the ship’s structure and equipment during its operating life. Parts II and III address operationally generated wastes and stores when the ship is prepared for recycling.
For a recycling-bound ship, the responsible owner and appointed specialist should reconcile the maintained Part I with the current vessel condition and prepare Parts II and III for the final survey route.
New, Existing and Recycling-Bound Ships
The IHM file depends on the vessel’s present status. CPA records whether the ship is operating, under ownership change or committed for recycling, then follows the applicable IHM, survey and certificate position. A recycling instruction does not by itself prove final-survey completion or readiness for recycling.
The applicable flag, recognised organisation and vessel status decide the exact survey and certificate path. CPA records the status supplied by those responsible parties but does not determine statutory applicability.
Separate the Preparation Expert from the Statutory Verifier
The appointed IHM expert prepares or updates the inventory and controls any sampling plan through competent laboratories. The flag Administration or recognized organization controls statutory verification and certification. CPA arranges attendance, follows document delivery and reports gaps or timing exposure; CPA does not prepare the IHM, take samples, issue laboratory findings or act as the statutory verifier.
- Owner or manager: supplies records, maintains Part I and appoints the relevant specialists.
- IHM preparation specialist: prepares or updates the inventory and supporting file within the accepted assignment.
- Flag or recognised organisation: owns statutory verification, survey and certificate decisions.
- Recycling facility: uses the verified vessel information when preparing the vessel-specific Ship Recycling Plan.
The preparation and verification functions should remain clearly identified. CPA may arrange local attendance, access and reporting for appointed parties but does not prepare, verify or certify the IHM unless a separately qualified party is expressly appointed for that work.
Maintain IHM Status Through Ownership, Manager or Flag Changes
A change of owner, manager, operator, name, flag or class does not make the vessel’s material history disappear. The incoming parties should receive the current IHM, supporting records, maintenance/update position and open deficiencies through the agreed handover route.
Where a changeover and recycling preparation are connected, keep two files: the ownership/management handover file and the statutory IHM/recycling file. The same evidence may inform both, but the responsibilities and acceptance parties remain separate.
Send an IHM or Final-Survey Attendance Brief
CPA requires the vessel and IMO number, flag, class or recognized organization, operating or recycling status, current IHM and certificate copies, survey requested, attendance window, named facility where applicable, report recipients and approval contact. The desk return states the survey route, missing documents, attendance position, cost basis and open approval.