Why It Matters
Maintaining a certified Inventory of Hazardous Materials (IHM Part I) is a legal obligation under both EU Ship Recycling Regulation and the Hong Kong Convention for shipowners. IHM-Maintenance relies fully on declarations provided by suppliers for relevant PO-items. Failure to comply exposes owners and suppliers to penalties, delays, and legal claims.
Our Standard: Item-Based, Not Order-Based
Many service providers work order-oriented and treat entire purchase orders (POs) as IHM-relevant without distinction. This leads to:
- Many unjustified document requests
- Massive administrative burden for suppliers
- Delays and inefficient practices for suppliers and shipowners
- Artificially generated documentation gaps in maintained IHMs
- Increased risk of PSC findings and problems during recertification of IHMs
This is wrong!
We strictly follow best industry practices and work item-oriented. We categorize each PO item separately as:
- IHM-relevant
- Not relevant
- High-risk (requiring additional review)
On average, only 4.7% of all PO-items are truly IHM-relevant.
Source: Industry Guidance to Ship Suppliers and Shipowners on Materials Declarations for Inventories of Hazardous Materials by the International Chamber of Shipping et al
What We Expect and Require from our Business Partners
We actively support provision of accurate declarations to our customers so that they can maintain their IHMs efficiently, by acting selectively and supportive with our own suppliers.
The following basics are important:
- Material Declaration (MD) – product-specific declaration about presence / absence of specific hazardous materials in products
- Supplier Declaration of Conformity (SDoC) –general supplier declaration clarifying legislation related to MD-Management (not customer or order-specific)
We provide templates and clear guidance to our suppliers for ensuring fast and compliant documentation throughout the supply chain of our shipowning customers.
What to Avoid
We explicitly reject the following practices:
- Requesting documents for PO items which are not IHM-relevant
- Blind signature of pre-filled MDs without backup information from supply chain
- Use of software that auto-generates Zero-MDs for all items in a PO
- Selling blacklists of “non-performing” suppliers
These shortcuts are non-compliant, damage the supply chain, and often violate legal standards.
The Right Way to Work with Us
- We assess each PO-item’s IHM-relevance.
- We send targeted requests with full guidance to our suppliers.
- We track responses and support suppliers if documents are incomplete or invalid.
- We process and provide only backed-up MDs to our customers.
- We support our customers to easily and accurately maintain and update their IHMs.
Our Commitment
- No unnecessary bureaucracy
- No hidden costs
- No shifting of responsibility to owners or suppliers
- Transparent, traceable process
- Global compliance and full support
- Guidance to all stakeholders
We relieve all parties from IHM burdens—accurately, efficiently, and legally sound.