⚓Strengthening Vessel Compliance with Proactive HazMat Oversight

⚠️ Is Your Shipyard HazMat-Compliant?

🚢Critical Compliance Challenge

Dry docking is essential for enhancing vessel performance—but it's also one of the riskiest periods for IHM compliance. Every pipe replacement, gasket change, or new paint layer could introduce hazardous materials. If these aren't documented in your Inventory of Hazardous Materials (IHM), you're exposed to serious regulatory and operational risks.

🛠️High-Risk Phase

Think of dry dock like surgery for your vessel. Would you skip updating the patient's medical record after the operation? During dry dock, new materials are brought onboard, old ones removed, and documentation is often missed or delayed, making your IHM outdated before the vessel even leaves the yard.

🚨 What Can Go Wrong?

❌Hazardous Materials Remain Undocumented

Untracked substances onboard pose safety and legal risks during inspections.

🧾IHM Certification Becomes Invalid

Technically, certification isn't "invalid" but "not in accordance"/"not valid at inspection" due to non-updating.

🚫Risk of Failure During Port State Control (PSC) Inspections

Non-compliance can lead to detentions, delays, and operational disruptions.

💰Fines, Delays, or Rejection from Certified Recycling Yards

Regulatory breaches can result not just in penalties, but also disqualification from legally approved ship recycling.

🚫Blocked from Certified Ship Recycling Yards

In addition to fines and operational disruption, ships lacking a valid, up-to-date IHM may be rejected by EU-approved recycling yards at end-of-life. Under EU Ship Recycling Regulation (EU SRR 1257/2013), certified facilities may only accept ships with a fully compliant IHM. Non-compliance can limit owners to less secure recycling options and lower the vessel's final asset value.

🔍 The Pre-Dock Compliance Gap

Many shipowners prepare for dry dock by focusing on the technical scope and budget, but skip the IHM review—a costly oversight.

🔄No Material Declarations (MDs) for Incoming Parts

Without MDs, new materials may introduce unknown hazards that aren't recorded in the IHM.

🗂️Old Components Still Listed Despite Removal

Failing to remove outdated entries makes the IHM inaccurate and non-compliant.

🧪HazMat Testing Skipped for Replaced Equipment

Replaced parts may contain hazardous substances that are undocumented unless supported by new MDs/SDoCs or tested as necessary.

🧩 Shipyards Prioritize Repairs—Not Compliance

⚙️Technical Focus

Shipyards excel at meeting deadlines and managing technical tasks—but HazMat compliance isn't their domain.

📦Unverified Materials

Without IHM oversight, unverified materials are accepted without checks, SDoCs or MDs are missing or incomplete, and new parts are installed with no hazard screening.

🔗Weakest Link

Remember: Your IHM is only as strong as its weakest link—and often, it's untracked.

✅ The 3-Step Approach to Stay IHM-Compliant

Pre-Dock Risk Review

List all expected component changes
Identify high-risk areas (insulation, paint, valves)
Request Material Declarations and SDoCs in advance

In-Dock Oversight

Appoint a HazMat officer or IHM consultant
Monitor installations and removals in real time
Flag undocumented materials immediately

Post-Dock Update & Submission

Reassess onboard materials and systems
Update IHM Part I documentation
Compile a PSC-ready compliance kit

🚀 Varuna Sentinels BV: Your IHM Compliance Partner

Dry dock is complex—we make IHM simple. Our end-to-end services include:

🔍Pre-Dock IHM Risk Assessment

Identify high-risk materials and compliance gaps before dry dock begins.

📦Supplier Coordination

We liaise with suppliers to gather all necessary hazardous material documentation (MDs, SDoCs collection).

🛠️Onsite HazMat Supervision

Our experts monitor installations and removals during dry dock to ensure nothing goes undocumented.

📄Post-Dock IHM Part I Update

We update your IHM with all changes and submit it in line with regulatory requirements.

📁PSC-Ready Documentation Kit

A complete compliance package to support smooth Port State Control inspections.

Let us handle your compliance, so you can focus on the refit.

⚓ Don't Let Dry Dock Become a Compliance Nightmare

In today's highly regulated maritime environment, a non-compliant IHM isn't just a paperwork issue—it's a commercial liability. Avoid last-minute scrambles, inspection failures, and reputational hits by preparing smarter.

📧 Planning a dry dock?

Reach out to us at contact@varuna-sentinels.com

We'll ensure your IHM compliance stays watertight—before, during, and after dry dock.