Ship Recycling & IHM: The Hong Kong Convention Explained

Relevant Conventions & Regulation:

• Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (HKC) – Entries into force June 2025.

• EU Ship Recycling Regulation (EU SRR) 1257/2013.

• Guidelines for the Development of the Inventory of Hazardous Materials (MEPC.269(68)).

Salient Points:

• Objective & Scope: The HKC aims to prevent risk to human health, safety, and the environment during ship recycling. It covers the design, construction, operation, and preparation of ships to facilitate safe recycling. It applies to all vessels >500 GT flying the flag of a party to the convention.

• Inventory of Hazardous Materials (IHM): This living document replaces the "Green Passport" and tracks hazardous materials throughout the vessel's operational life.

  • Part I: Hazardous materials in ship structure/equipment (e.g., Asbestos, PCBs). Maintained permanently.

  • Part II: Operationally generated waste (e.g., sludge). Compiled prior to recycling.

  • Part III: Stores. Compiled prior to recycling.

• Survey Certification Cycle:

  • Initial Survey: Verified during construction; IHM Part I issued.

  • Renewal Survey: Every 5 years (harmonised).

  • Final Survey: Conducted before recycling to issue the International Ready for Recycling Certificate.

• Operational Responsibility: Senior Officers must ensure the IHM is maintained. Any new equipment or stores brought onboard must be accompanied by a Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) to update Part I.

• Commercial Impact: Ships must use authorised Ship Recycling Facilities (SRF). For EU flagged vessels, the yard must be on the European List, which currently excludes many traditional beaching yards (like those in Bangladesh) unless they meet strict upgrades.

Summary:

For the purpose of the MCA Oral Exam, candidates should pivot away from the socio-economics of shipbreaking and focus on the regulatory framework of the Hong Kong Convention. The examiner expects you to understand that ship recycling is a "cradle to grave" responsibility, centred on the maintenance of the Inventory of Hazardous Materials (IHM). Your primary duty as a Senior Officer is to ensure that the IHM Part I is kept accurate through the collection of Material Declarations and SDoCs for all new purchases. Failure to maintain this document will prevent the issuance of the International Ready for Recycling Certificate, legally preventing the vessel from being scrapped.