ClassNK

What is the Ship Recycling Convention?

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the Ship Recycling Convention or the Hong Kong Convention, HKC) will enter into force on 26 June 2025. After the entry into force of the Convention, the development and maintenance of an Inventory of Hazardous Materials, which identifies the amount and location of hazardous materials onboard a ship, will be required for all ships over 500GT and engaged in international voyages. Furthermore, ships shall only be recycled at ship recycling facilities authorized by the competent authority.

What is the Inventory of Hazardous Materials (IHM)?

ship recycling facility before the start of recycling. The IHM is a list that specifies the locations and estimated quantities of hazardous materials, wastes and stores on board a ship. The IHM consist of the three parts: Part I, Part II and Part III.

IHM Part I shall be prepared under shipbuilding by shipyard and should be continuously updated and maintained though operational life by a shipowner.

IHM Part II and Part III shall be prepared before recycling..

However, Part I of the IHM for existing ships, whose building contracts have been placed before the entry into force of the Convention, shall be developed not later than 26 June 2030.

The information provided by the IHM is utilized by ship recycling facilities in order to protect human health and safety and prevent environmental pollution.

Contents of IHM

Composition of the IHM

Hazardous Materials to be listed in the IHM (Appendix 1, Resolution MEPC.379(80))

What is Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC)

Forms of Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) are standardized by the IMO guidelines, i.e., Resolution MEPC.379(80).

• Material Declaration (MD) is a document that identifies and declares information on the name, quantities and location of hazardous materials listed in table A or table B which exceed the threshold value contained in a product.
• Supplier’s Declaration of Conformity (SDoC) is a document that ensures the contents of the MD complies with the IMO guidelines Resolution MEPC.379(80) and clarifies the responsibility.

MD and SDoC serve as fundamental data for developing and updating Part I of the Inventory of Hazardous Materials (IHM Part I).

The Inventory covers equipment and/or materials, including electrical cables and gaskets, that are fixed to the ship, by means such as painting, welding, bolts, rivets, or cement, and are used in their designated positions. These equipment and/or materials are investigated based on MD and SDoC which are prepared and submitted by the Suppliers.

*Supplier: Supplier means a company which provides products; it may be a manufacturer, trader or agency.

Some equipment and materials are not required to be listed in the IHM Part I in accordance with IMO Guidelines, i.e., Resolution MEPC.379(80), Section 3.3 as follows.

• Materials listed in table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.
• Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.

Development of the IHM for new ships

Shipbuilders should develop the IHM for new ships in accordance with the format stipulated in the IMO Guidelines and based on the information obtained from the Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) submitted by suppliers.

After the Part I of the IHM is prepared, it must be verified by ClassNK to confirm compliance with the Convention. ClassNK conducts document review and onboard survey for the IHM Initial survey based on the application,

• For ships under construction, the shipyard is requested to submit an application form (Form-1A) to the survey office in charge.
• For ships in service, the shipowner is requested to submit an application form (Form APP IHM_E) to NK GCD.

Development of the IHM for existing ships

For existing ship, IHM can be developed by information analysis by an Expert, instead of collecting Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC).IHM Part I for existing ships is prepared by combination of the document analysis and onboard visual and sampling check.

• Document analysis by collection of necessary information and assessment:
  Ship documents, drawings and available materials submitted by suppliers are collected and assessed to identify potential hazardous materials onboard the ship.
• Onboard check by visual and sampling check:
  After assessment of information, the Expert of hazardous materials prepares the Visual Sampling Check Plan (VSCP) and visit the ship and conducts visual check and sampling check through onboard investigations. The samples are analyzed by the laboratory to determine the presence of hazardous materials.

This method requires the knowledge and experience of specialist personnel (Expert).

After the IHM Part I is prepared, it must be verified by ClassNK to confirm compliance with the Convention. ClassNK conducts a document review of VSCP and IHM Part I, as well as an onboard survey for the IHM Initial survey based on the application. The shipowner should submit an application form (Form APP IHM_E) to ClassNK GCD.

Please note that the application and the VSCP shall be submitted at least two weeks prior to the onboard visual sampling date. Additionally, after the onboard investigation, the laboratory analysis of collected samples requires a certain period of time. We recommend that preparation of IHM for existing ships be well in advance to ensure a smooth process.

In principle, ClassNK surveyor conducts a survey based on the VSCP reviewed by NK GCD, supported by experts. However, the evidence to prove that the visual / sampling check is performed properly is shown in the following manners, the expert may be allowed to visual / sampling check on board by the expert alone.

Maintaining and updating Part I of IHM

Ship owners / ship management companies are required to properly maintain and update IHM Part I throughout the operational life of the ship, reflecting new installations containing Hazardous Materials and relevant changes in ship structure and equipment, considering the IMO Guidelines.

Although the Ship Recycling Convention does not specify a format for the maintenance procedures, ClassNK has made available an example of an IHM maintenance procedure document that meets the requirements of the Convention on this website. You may download it using the following links

Issuance of Certificate / Statement of Compliance (SOC) on the IHM

ClassNK conducts the prescribed surveys and issues SOC for Part I of the IHM developed in preparation for the incoming Convention. After the entry into force of the Convention, ships subject to the Convention are required to convert their SOC to International Certificates of Inventory of Hazardous Materials (ICIHM) by 26 June 2030. ClassNK will converts SOC to ICIHM at the time of ship owner's request. However, because ICIHMs are valid for a maximum of five years, if they are issued at the time of Renewal Survey, it is expected that they will expire earlier than the other certificates and the due date management of certificates will become complicated. As a countermeasure, we recommend that the ICIHM be issued before the Renewal Survey, and renewed at the time of the Renewal Survey to harmonize with the due date of the other certificates.

In order to obtain ICIHM/SOC, preparation of IHM is required. ClassNK recommends the early preparation of the IHM because the need for experts is expected to increase drastically after the entry into force of the Convention.

• For conversion from SOC to ICIHM, shipowners are requested to check the status of authorization from frag states to ClassNK and submit an apply for Occasional Survey using the application for surveys and issue of certificates (form 2A).
• For the IHM of a ship under construction, shipyards are requested to submit an application form (Form-1A) to the survey office in charge.
• For IHM of ships in service, shipowner are requested to submit an application form (Form APP IHM_E) with necessary documents required by “Guidelines for the Inventory of Hazardous Materials” to ClassNK GCD.

In case of calling at EU ports, it is necessary to obtain an EU Certificate or SOC in accordance with the EU-SRR, in addition to the HKC requirements. The EU-SRR requires additional hazardous material(s) investigations compared to the HKC. ClassNK can conduct a document check and the survey and issue the SOC in accordance with EU-SRR.

PrimeShip-GREEN/SRM

In order to develop the IHM for new ships, shipbuilders and suppliers have to exchange and store a huge number of paper documents. It may be a serious burden for shipbuilders and suppliers. ClassNK developed “PrimeShip-GREEN/SRM” to facilitate IHM development utilizing a Cloud Computing System. After registration to the system via Internet, the people who engaged in the development of the IHM, including shipbuilders and suppliers, are able to perform all necessary work for IHM development on the system website.

For registration to “PrimeShip-GREEN/SRM,” please access the following URL, click “Register Organization” on the login page and input the necessary information.

“PrimeShip-GREEN / SRM” also supports the development of IHM that meets the requirements of Article 5 of the EU Regulation.

PrimeShip-GREEN/SRM URL: https://www.psgreensrm.com/

ClassNK Guidelines for IHM

ClassNK published “Guidelines for the Inventory of Hazardous Materials” corresponding to HKC and EU regulations in order to clarify the procedure and requirements for issuance of the SOC. The Guidelines can be downloaded from “ClassNK MyPage” after the registration.

ClassNK Guidelines for Ship Recycling Facility

ClassNK published “Guidelines for Ship Recycling Facilities” which provides the requirement that recycling facility shall meet to comply with HKC. The Guidelines can be downloaded from “ClassNK MyPage” after the registration.

Contact

For more information, please contact us to the following.

Green Certification Department