What is the Hong Kong Convention?
In May 2009, the “Hong Kong International Convention for the safe and environmentally sound recycling of ships” (or “Hong Kong Convention”) was adopted at an assembly of the International Maritime Organisation (IMO). This Convention aims to minimize work accidents and environment pollution due to ship recycling (breaking) by stipulating recycling facility and ship obligations, therefore ships must carry an Inventory of Hazardous Materials (IHM) clearly stipulating where hazardous materials are located on the applicable ships, and a related Statement of Fact (SOF), otherwise the ship will not be allowed to engage in international voyages. We recommend preparing an Inventory of Hazardous Materials early to avoid the busy period when the Convention enters force.
Applicable Ships
All ships 500 gross tonnes (GT) or greater engaging in international voyages must comply with the Convention. However, warships, research ships, other non-commercial ships, and ships operating their whole life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly, are exempt from the Convention.
Applicable Period
Ships must prepare an IHM and SOF onboard within five years of the Convention entering force. The precise date that the Convention will enter into force is unknown, however it is predicted to be applied in the near future due to the EU Ship Recycling Regulation coming into force.
EU Ship Recycling Regulation
The EU Ship Recycling Regulation entered into force on 30 December 2013. This Regulation complies with the IMO’s Hong Kong Convention. As such, from the end of 2020, all ships that enter EU waters, including those from non-EU countries, are obligated to carry an IHM and SOF onboard.
Inventory of Hazardous Materials (IHM)
A list detailing the quantities and location of hazardous materials, waste and stores.
Aim of IHM
By clarifying information relating to the hazardous materials onboard a ship, the IHM aims to protect the safety and health of workers at ship recycling facilities, prevent environmental pollution and promote the development of substitutes for hazardous materials and effective utilization of resources.
Main hazardous substances prohibited to be carried on ships – to be noted on the device list
- Asbestos: packing, gaskets, insulation, material used in sleeping quarters, etc.
- Polyvinyl chloride: Transformers, capacitors, electrical cable covering/insulation tape
- Ozone-depleting substances: Refrigerator refrigerant (CFCs, HCFC), halon gas, etc.
- Organotin compounds: Tributyltin chloride (TBT), triphenyltin chloride (TPT) in the paint on the ship’s bottom.
The following is not mandatory to include in the device list but noted here for reference only.
- Mercury for gyro compasses
- Lead for battery electrodes will be added to the list.
Flow of preparing an IHM
Contact for requesting IHM preparation
NKCS: ClassNK Consulting Service Co., Ltd. (ClassNK affiliate company)Cost of IHM preparation
Varies depending on ship type, age, dock location and management status of drawings and materials. The abovementioned contact, NKCS, will provide a quotation separately.IHM preparation timeframe
Varies depending on management status of drawings and materials and condition of ship itself, but it generally takes around three months from a drawings investigation and onboard investigation until the customer receives a completed IHM and SOF.IHM preparation
Service
As a registered specialist of ClassNK Consulting Service Co., Ltd., our company prepares IHM through drawing and onboard investigations based on the ship temporarily loaned to us (for IHM preparation purposes) by the ship owner.IHM preparation service bases
