IHM and ship recycling

Hong Kong Convention and EU Ship Recycling Regulation

Presently, two regulations are governing the requirements for safe and environmentally sound ship recycling:

• Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC), which will enter into force in June 2025.
• The EU Regulation on Ship Recycling (EU) No. 1257/2013 (EU SRR), which is in force since 31 December 2020.

Both HKC and EU aims to ensure that ships when being recycled, do not pose any unnecessary risk to human health, safety and environment. One of the main concerns is the fact that ships may contain hazardous materials such as asbestos, ozone-depleting substances, heavy metals and others, which may have negative impacts both on workers health safety and to environment.

HKC is applicable to ships, operating in the marine environment, which are equal to and above 500 GT. The HKC has two key issues:

• Inventory of hazardous materials (IHM, 13 hazmats)
• Authorization of ship recycling facilities

EU SRR is applicable to ships, operating in the marine environment, which are EU/EEA/UK flagged and 3rd party flagged vessels, visiting European ports or anchorages, equal to and above 500 GT. The EU SRR has two key issues:

• Inventory of hazardous materials (IHM, 15 hazmats)
• European list of approved ship recycling facilities

Navy ships and domestic ships are excluded from the scope of HKC and EU SRR.

The Inventory of Hazardous Materials (IHM) in a nutshell

The IHM is a list of hazardous materials that are present on a ship. The IHM quantifies and locates hazardous materials on board ships which are known to represent a potential hazard to people and the environment. 

The IHM consists of three parts:

• Part I: Hazardous materials contained in the ship’s structure and equipment (Refer to “IHM Part I Certification” page for details)
• Part II: Operationally generated wastes
• Part III: Stores

The IHM Part I is prepared either during the construction of the ship or while the vessel is in operation. For latter, hazmat experts should be contracted for the preparation of the IHM. Refer to the list of DNV approved service suppliers for IHM preparation. Search | Approval finder (dnv.com) 

IHM Part II and III shall be prepared by the shipowner once the decision is given to send the ship for recycling. The IHM Part II and III can be prepared by the crew or by a hazmat expert. (Refer to “Ready for Recycling Certificate” page for details)

Maintain the IHM to stay compliant

Once the IHM Part I is certified, it must be kept up to date and maintained throughout the operational life of the vessel. IHM Maintenance can either be done by the shipowner/shipmanager itself as inhouse or outsourced to 3rd party hazmat experts.

The details on IHM Maintenance is described in “IHM Part I Maintenance” page.

DNV offers services for

• IHM Part I approval and certification
• IHM Manager software for IHM Maintenance
• IHM Part II & III approval and Ready for Recycling certification