The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009), adopted by the International Maritime Organization (IMO), aims to reduce the negative impacts on human health and the environment caused by ship recycling activities.
Although the convention has not yet entered into force, some major shipowners have proactively adopted its requirements in recent years, often in conjunction with the EU Ship Recycling Regulation (EU-SRR, 2013).
IHM – Inventory of Hazardous Materials
On ships operated by some major container shipowners, IHM compliance has become a routine practice and is implemented in a simple manner. Key aspects include:
1. Certification and Documentation
- Onboard documents include:
- Statement of Compliance on IHM (endorsed by Flag administration)
- IHM Manual, divided into three parts:
- Part I: Hazardous materials used in shipbuilding and equipment currently on board.
- Part II: Operationally generated waste (fuel oil, incinerator ash, bilge water, sludge, garbage, etc.).
- Part III: Stores currently in use.
2. Designated Personnel (as company’s IHM MaintenanceManual)
- The company appoints an IHM Designated Person to oversee IHM compliance.
- On board, as usual, the Chief Engineer (C/E) and Chief Officer (C/O) are responsible for IHM matters.
3. Supplier Requirements
- All suppliers providing materials, equipment, or repair services to these companies’ vessels are required to submit:
- MDs (Material Declarations).
- SDoCs (Supplier’s Declaration of Conformity) for IHM compliance.
- These documents are uploaded to the company’s Computerized ship management system (for example VIMS of Evergreen) allowing vessels to download and present them during Port State Control (PSC) inspections.
4. Exempted Materials
Certain materials are considered inherently safe and do not require MDs or SDoCs, such as: Solid metals and metal alloys: steel, aluminum, brass, bronze, welding rods, etc.
5. Conclusion
Adopting the Hong Kong Convention and implementing the IHM system not only demonstrates an environmental commitment but also ensures transparency, international compliance, and readiness for safe ship recycling at the end of a vessel’s service life.
BBC – SMR Marine
Training department
Capt. Dang Quang Dan (+84 0948 067 095)
