Ship detentions trigger warning over hazardous materials compliance gaps

Hazardous materials specialists Lucion are warning shipowners and technical managers not to treat Inventory of Hazardous Materials (IHM) documentation as a one-time compliance exercise, after recent vessel detentions exposed gaps in hazardous materials compliance.

According to Lucion’s marine compliance specialists, the incidents highlight a growing compliance risk across the global maritime sector as regulators increase scrutiny of hazardous materials documentation.

In recent weeks, two vessels registered under the Marshall Islands flag were detained by Port State Control after inspectors identified that the vessels’ IHM Statements of Compliance were either expired or inaccurate. The incidents prompted the Republic of the Marshall Islands Maritime Administrator to issue Marine Safety Advisory No. 04-26, urging operators trading to UK and EU ports to urgently review the accuracy and validity of their IHM documentation.

Kevan O’Neill, Principal Consultant at Lucion, says the detentions highlight a common misconception within parts of the maritime industry.

“For many shipowners, the IHM was initially developed to meet a compliance deadline when the EU Ship Recycling Regulation came into force. However, compliance does not stop once the inventory has been produced. It is a live document that must be maintained,” he explains.

The advisory reinforces the importance of maintaining compliance with the EU Ship Recycling Regulation (EU SRR 1257/2013), which was introduced to ensure ships are dismantled safely and responsibly at the end of their service life. A key requirement of the regulation is that vessels calling at EU ports must carry a valid Inventory of Hazardous Materials, a detailed record of hazardous substances present within the vessel’s structure and equipment.

The regulation applies to ships flying the flag of an EU Member State, as well as any vessels calling at EU or UK ports or anchorages, regardless of their flag state. This means operators trading or transiting through Europe must ensure their IHM documentation remains accurate and up to date throughout the vessel’s operational life.

The IHM identifies and records the location and approximate quantities of hazardous materials on board a vessel, including substances such as asbestos, polychlorinated biphenyls (PCBs), ozone-depleting substances, heavy metals and certain flame retardants.

The inventory itself is structured into three parts. Part one records hazardous materials contained within the vessel’s structure and equipment and is mandatory for all vessels in operation. Parts two and three relate to operationally generated wastes and stores, which become relevant when a vessel is prepared for recycling.

Crucially, the regulation requires that the IHM remains accurate for the entire operational life of the vessel, something Lucion says is often overlooked once the initial inventory has been produced.

According to Lucion, even routine operational changes can require updates to the IHM. “Any structural modification, equipment replacement or retrofit can trigger the need to review and potentially update the inventory. If those processes are not embedded into day-to-day technical management, discrepancies can quickly develop between the documentation and the actual configuration of the vessel,” Kevan adds.

Lucion has also observed that Port State Control inspections are becoming increasingly more stringent when reviewing hazardous materials documentation.

“Inspectors are no longer simply checking whether an IHM certificate exists. They are examining whether the Statement of Compliance is valid and within date, whether the inventory reflects the vessel’s current configuration, and whether supporting documentation aligns with equipment purchases, retrofits and shipyard work,” Kevan says.

Detentions linked to IHM compliance can carry significant operational consequences for shipowners and operators. Alongside financial penalties, vessels may face operational delays that disrupt charter schedules and contractual commitments while also raising concerns among insurers, charterers and regulators.

“Detentions carry both financial and reputational implications. They can halt operations overnight and create wider commercial impacts for operators who rely on tight scheduling and regulatory certainty,” Kevan notes.

For this reason, Lucion advises shipowners and technical managers to treat IHM maintenance as a routine compliance process rather than a reactive correction exercise.

“The safest position is proactive compliance. If an operator cannot confidently demonstrate that their IHM accurately reflects the vessel’s current condition, that is a risk that will only become more visible as inspections continue to tighten,” Kevan concludes.