Inventory of Hazardous Materials: Hong Kong Convention and EU SRR

What the inventory contains

Regulation 5 of the Hong Kong Convention requires each new ship to carry an IHM that is specific to the ship, verified by the Administration or an organisation it authorises taking into account IMO guidelines, and that identifies in Part I the hazardous materials of appendices 1 and 2 in the ship’s structure or equipment, their location and approximate quantities.¹ The current guidelines are the 2023 Guidelines for the development of the IHM (resolution MEPC.379(80)), which replaced the 2015 Guidelines (MEPC.269(68)) to add cybutryne after the anti-fouling amendments that took effect on 1 January 2023.⁴

The guidelines sort materials into four tables:⁴

Thresholds apply per homogeneous material, for example asbestos 0.1%, PCBs 50 mg/kg, organotin anti-fouling 2,500 mg total tin per kg, cybutryne 1,000 mg/kg, cadmium 100 mg/kg, lead, mercury and hexavalent chromium 1,000 mg/kg; ozone-depleting substances and radioactive sources have no threshold.⁴ Table B materials inherent in metals used in general construction (hull, pipes, housings) are exempt, and the amounts of hazardous materials in printed circuit boards need not be reported.⁴ Quantities are normally in kilograms, rounded up to at least two significant figures.⁴

Existing ships: building Part I

For existing ships the guidelines set five steps: collect documents; assess them; prepare a visual/sampling check plan; carry out the visual and sampling checks on board; then write Part I and its documentation.⁴ The check plan has three lists: items for visual check, items for sampling, and items classed as “potentially containing hazardous material” without sampling, which needs a comprehensible justification such as the impossibility of sampling safely.⁴ The expert who does the work for the owner “should not be the same” as the person or organisation authorised to approve the IHM.⁴ Field tests are only indicators; where it matters, samples go to an accredited laboratory (ISO 17025 is given as the example) for specific testing.⁴

Keeping Part I valid: the maintenance system

This is the day-to-day job, and the one that fails most often. The guidelines require Part I to be updated whenever machinery or equipment is added, removed or replaced or the hull coating is renewed, following the same material-checking process as for a new ship. Identical parts or coatings need no update.⁴ Part I belongs to the ship and must stay continuous through changes of flag, owner or operator.⁴

Paragraph 5.2 tells the owner to:⁴

1. designate a person responsible for maintaining and updating the IHM (ashore or on board);
2. have that person establish and supervise a system that catches every new installation;
3. keep the IHM with dates of changes, new or deleted entries, and the designated person’s signature; and
4. provide the documents for surveys or sale.

The evidence for each update is the supplier’s Material Declaration (MD), which states whether table A and B materials are present above threshold and their mass, and the Supplier’s Declaration of Conformity (SDoC), which identifies who is responsible for the MD. An SDoC stays valid as long as the product is on board.⁴ In practice the designated person makes the purchasing department ask for an MD and SDoC with every relevant purchase order, logs spare parts and retrofits from yard and voyage repairs, and updates the IHM before the next survey.

Surveys and certificates

Under the Hong Kong Convention:²³

• an initial survey verifies Part I and leads to the International Certificate on Inventory of Hazardous Materials;
• a renewal survey follows at intervals specified by the Administration, not exceeding five years, and the certificate is valid for no more than five years;
• an additional survey may be made at the owner’s request after a change, replacement or significant repair;
• the certificate ceases to be valid if Part I “is not properly maintained and updated”, on change of flag, or if the renewal survey is not completed in time; and
• before recycling, a final survey checks Parts I, II and III and the ship recycling plan, and leads to the International Ready for Recycling Certificate, valid for up to three months.

The EU Ship Recycling Regulation

Regulation (EU) No 1257/2013 applies to ships of 500 GT and above under EU flags and, through Article 12, to ships of other flags calling at a port or anchorage of an EU Member State.⁷ For those third-country ships, Article 12 has applied since 31 December 2020 (Article 32(2)(b)).⁷ The ship must carry an IHM that identifies at least the Annex I materials, with a visual/sampling check plan, maintained and updated throughout its life, and a statement of compliance issued by or for its flag.⁷ The EU lists go slightly beyond the IMO tables: Annex I adds perfluorooctane sulfonic acid (PFOS) and Annex II adds the brominated flame retardant HBCDD.⁷ EMSA has published non-binding best-practice guidance on developing and maintaining the IHM and on port State checks under Articles 5 and 12.⁸