HDUM participated in World Maritime Merchants Forum held on Oct 20, 2021, in which a live presentation was given on the importance and future of IHM Regulation. As per EU Ship Recycling Regulation, all vessels either EU Flagged or Non-EU Flagged calling at the ports in Europe after Dec 2020 must have an IHM inventory onboard and should be maintained properly. Failure to comply with IHM maintenance can be a risk for shipowners as Article 11 – EUSRR states that
A detailed inspection may be carried out by the relevant authority involved in port State control activities, taking into account the relevant IMO guidelines, where a ship does not carry a valid certificate or there are clear grounds for believing that:
(b) there is no procedure implemented onboard the ship for the maintenance of Part I of the inventory of hazardous materials.
Similarly, no IHM, uncertified IHMs, IHMs not reflecting the ship, and unmaintained IHMs can lead towards hefty fines or even imprisonment in European states such as
• France: 100000 Euro or 1-year imprisonment (Article L5242-9-2 Code des Transports)
• UK: Financial Penalty and 2 years imprisonment (Reg. 11 of Ship recycling Regulation 2018)
The development of IHM and its maintenance has now become essential for Shipowners. It is in their best interests to appoint a well-trained DP, better be an IHM Expert, with good knowledge of IHM survey and maintenance to minimize commercial risks associated with IHM.