IHM Maintenance Handbook
for Superyachts

What certificates are required?

Every vessel ≥500 GT must hold one of the following:

• ICIHM — International Certificate on Inventory of Hazardous Materials (Hong Kong Convention)
• EU Inventory Certificate — under EU SRR 1257/2013 (for EU-flagged vessels or vessels calling EU ports)
• Statement of Compliance — issued by the classification society

Certificates must be kept onboard at all times and presented to surveyors and Port State Control inspectors on request.

Survey intervals and certificate endorsement

Certificates are issued at the initial survey and endorsed at:

• Annual surveys — every 12 months
• Intermediate surveys — at the midpoint of the 5-year cycle
• Renewal surveys — every 5 years

When a new certificate is issued following a renewal survey, the previous version must be retained as a superseded record. Never delete old certificates — they form part of the vessel's IHM history.

What goes in Part I?

Part I tracks all hazardous materials permanently fixed in the vessel's structure, equipment, and systems. The three categories are:

• I-1: Paints and coating systems — hull, deck, superstructure
• I-2: Equipment and machinery — engines, HVAC, fire suppression, UPS, switchboards
• I-3: Structure — hull plating, insulation, piping, cables, gaskets

Table A materials (asbestos, PCBs, TBT, PFOS, HBB, PBDE) are prohibited or restricted. Table B materials (lead, mercury, cadmium, hexavalent chromium, etc.) are controlled above threshold quantities. Both must be tracked with quantities and locations for every item in the IHM.

Material change workflow

Every installation, replacement, or removal of a Table A or Table B material must follow this sequence:

1. Identify the change (new installation, replacement, or removal)
2. Check Table A/B thresholds against the substance
3. Request MD or SDoC from the supplier before installation — per MEPC.379(80) §4.2.2, items should not be installed until documentation is received
4. Record the change in the Change Log contemporaneously
5. Update the Part I Working File
6. File the MD/SDoC in the Documentation Archive
7. Index the document for retrieval at the next survey

Identical replacements

If equipment is replaced with an identical part — same manufacturer, same model, same substance content — no IHM revision is required per MEPC.379(80) Appendix 4 §2.3. However, the replacement event must still appear in the Change Log with a note: "Identical replacement — no IHM revision required."

Archived items

When materials are removed from the vessel, archive the Part I entry rather than deleting it. Per MEPC.379(80) §5.2.3, the removal must be documented with date and quantity removed. Archived items are retained for the life of the vessel as evidence of removal.

ODS cross-reference

Ozone-depleting substances (R-22, halons, CFCs) recorded in Part I should reconcile with the ODS Record Book entries under MARPOL Annex VI. Cross-check them periodically and before each survey — mismatches are a common and easily avoided finding.

Purpose of Part II

Part II indexes all operationally generated waste streams. It is maintained as an index during vessel operations, and compiled as a formal document when the vessel enters the recycling process. Organise entries by MARPOL Annex:

• Annex I: Oily waste — bilge water, sludge, waste oil
• Annex IV: Sewage
• Annex V: Garbage — food waste, plastics, metals, glass, operational waste
• Annex VI: ODS releases and air pollution (refrigerant servicing events, exhaust cleaning residues)

MARPOL cross-references

Each Part II entry must reference the corresponding MARPOL record book page — Oil Record Book for Annex I, Garbage Record Book for Annex V, ODS Record Book for Annex VI. Do not duplicate records: reference the existing entries with the page number. Upload scans of record book pages and disposal receipts as supporting evidence against each entry.

Disposal receipts

Retain all shore facility disposal receipts for a minimum of 3 years — this is a MARPOL requirement independent of IHM. File receipts linked to the corresponding Part II waste entry so they can be produced as evidence during a PSC inspection or survey.

Purpose of Part III

Part III maintains current MSDS/SDS documents for all hazardous stores onboard. Compliance is multi-layered:

• IHM Part III — for eventual ship recycling under MEPC.379(80) Table D
• SOLAS Chapter II-2 — fire safety
• MLC 2006 Regulation 4.3 — crew occupational health and safety
• Flag state requirements — most flag states mandate current SDS for all hazardous products aboard

SDS version control

Always hold the current SDS revision. When a supplier issues a new SDS version:

1. File the new SDS in the Part III record
2. Mark the previous version as superseded with the withdrawal date
3. Retain the superseded SDS for 3 years per EU SRR Article 5(3) and the MARPOL minimum retention requirement

Check SDS currency quarterly. Products change formulation and suppliers update SDS versions — an SDS more than 5 years old is almost always superseded.

Spare parts with hazardous content

Spare parts containing Table A or Table B substances — lead-acid batteries, asbestos-containing gaskets, refrigeration components, hydraulic components — must be listed in the spare parts records with the substance name and quantity. When a spare part is installed, record the installation in the Change Log and update Part I accordingly.

When to log a change

Every material change must be logged contemporaneously — at the time it happens, never backdated. This includes:

• New equipment installation
• Equipment replacement (identical or non-identical)
• Equipment removal
• Coating or paint system changes
• Structural modifications
• All refit work across all trades

If a surveyor finds an undocumented change, the finding is typically a non-conformity requiring corrective action before certificate endorsement.

Refit procedure

Refits are the highest-risk period for IHM compliance — large numbers of materials are installed by multiple contractors in a short time. Follow this procedure:

1. Brief the yard and all subcontractors on IHM MD/SDoC requirements before work begins
2. Provide a standard MD request template to all contractors
3. Collect MDs/SDoCs progressively during the refit — not as a batch at completion, when contractors have left site
4. Post-refit: reconcile all documentation against the scope of work
5. Verify every change is in the Change Log and every MD/SDoC is filed
6. Submit the updated Part I to the classification society for endorsement before departure

MD/SDoC documentation requirements

Material Declaration (MD): Required for every new material or product installed. The MD declares which Table A/B substances are present in the product and at what concentration. Suppliers are required to provide this under MEPC.379(80) §4.2.

Supplier Declaration of Conformity (SDoC): Confirms that the product does not contain Table A/B substances above threshold values, with stated exceptions. Used where Table A/B materials are absent or below threshold.

Prepare a standard MD/SDoC request template to send to all contractors and suppliers before any installation work. This sets expectations early and prevents documentation gaps at the end of a refit.

Quarterly review

Every quarter, verify:

• Change Log is complete with no gaps since the last review
• All MDs/SDoCs referenced in the Change Log are filed
• Part I Working File entries match Change Log records
• Onboard copy synchronised with the ashore master copy
• ODS cross-reference check: Part I ODS entries match the ODS Record Book

Annual review

In addition to the quarterly checks, the annual review includes:

• Full Part I accuracy review against the last endorsed IHM
• Certificate verification — ICIHM or EU cert current, next survey date confirmed
• MSDS/SDS currency check across all Part III products
• Maintenance Manual review — update procedures if practices have changed
• Changes summary prepared for the upcoming surveyor visit

Internal audit (EU SRR)

EU SRR Article 5(3) requires an annual minimum internal audit. A thorough internal audit covers 19 items across five categories:

• Documentation (6 items) — Change Log completeness, MD/SDoC filing, Working File sync, archive indexing, copy synchronisation, Maintenance Manual currency
• Certificates (3 items) — ICIHM/EU cert current, Statement of Compliance current, previous survey findings closed
• Part II waste (4 items) — MARPOL cross-references present, disposal receipts filed, ODS releases documented, 3-year retention maintained
• Part III stores (3 items) — current SDS for all hazardous products, superseded SDS retained, spare parts with hazardous content listed
• Surveys (3 items) — previous survey findings closed, corrective actions evidenced, next survey date confirmed

Each non-conformity found during the audit requires a corrective action with an owner, a target close date, and documented closure evidence. Audit records must be retained for 5 years per EU SRR.

Pre-survey checklist

Before any IHM survey — initial, annual, intermediate, or renewal — work through this 8-item checklist. Begin at least 2 weeks before the survey date:

1. Part I Working File updated with all changes since last survey
2. Change Log complete — no undocumented gaps
3. All MDs/SDoCs filed and indexed against Change Log entries
4. Maintenance Manual customised for your vessel's systems and procedures
5. Certificate current and not expired
6. Onboard copy synchronised with the ashore master
7. Previous survey findings closed with evidence
8. Changes summary prepared for the surveyor

Start this checklist minimum 2 weeks before the survey date — any documentation gaps found during preparation can still be rectified before the surveyor arrives.