IHM Survey For New Ship To Comply With EUSRR and HKC

Compliance Regulation Requirement

The IMO adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships in 2009. Its purpose is to ensure that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risk to the environment or human health and safety. In addition, the convention seeks to clinch the proper management of hazardous materials on board ships.

The convention addresses all the issues surrounding ship recycling, including the fact that ships sold for scrap may contain environmentally hazardous substances such as asbestos, heavy metals, hydrocarbons, ozone depleting materials and others. It also addresses concerns about working conditions in many of the world's ship recycling facilities.

Regulations in the new convention covers: the design, construction, operation and preparation of ships to facilitate a safe and environmentally sound recycling process, without compromising operational efficiency and safety of the ships built, the operation of ship recycling facilities in a safe and environmentally sound manner, and the establishment of an appropriate enforcement mechanism for ship recycling incorporating certification and reporting requirements.

Ships to be sent for recycling will be required to carry an inventory of hazardous materials, which will be specific to each ship. An appendix to the convention provides a list of hazardous materials, the installation or use of which is prohibited in shipyards, ship repair yards, and ships of parties to the convention. Ships will be required to have an initial survey to verify the inventory of hazardous materials, renewal surveys during the lifespan of the ship, and a final survey prior to the recycling process.

Hazardous materials can impair our life and the environment without proper management. They must be identified, managed and recycled over the entire span of the ship’s lifecycle. While the convention still relies on the concept of a ‘Green Passport’, which remains central to most, if not all, operations, the term itself is no longer used. The “Green Passport” is now known as the ‘Inventory of Hazardous Materials’ (IHM), though its purpose remains identical. The IHM still covers the entire lifespan of the ship, from the construction and operation to the preparation for scrapping at the end of the ship’s lifetime.

CTI, as an international leader in IHM surveys, can reliably check the ship’s compliance with the convention, and can guide shipyards in meeting the requirements for class issuing, the endorsement of an international certificate regarding the IHM, and the issuance of an International Ready for Recycling certificate.

The objective of the IHM is to provide information on the hazardous materials present on-board the ship in order to protect the health and safety of the workers and to prevent any potential environmental pollution at ship recycling facilities. This information will be used by the ship recycling facilities to decide how to manage the materials identified in the IHM.

For new ships, Part I (Table A &Table B) of the IHM should be developed at the design and construction stage.

Since 31 Dec. 2018, all ships flying the flag of a Member State have been subjected to a survey regime and have had to carry on-board a ship-specific ‘Inventory Certificate’ issued by the administration or a RO authorised by it and supplemented by Part I of the IHM, which has been attached below for your reference:

No. Materials Threshold level
A1 Asbestos 0.1%
A2 Polychlorinated biphenyls (PCBs) 50mg/kg
A3 Ozone Depleting Substances no threshold level
A4 Anti-fouling systems containing organizing compounds as a biocide 2500mg total tin/kg
A5 Perfluorooctane sulfonic acid ( PFOS) 10mg/kg
B1 Cadmium and Cadmium Compounds 100mg/kg
B2 Hexavalent Chromium and Hexavalent Chromium Compounds 1000mg/kg
B3 Lead and Lead Compounds 1000mg/kg
B4 Mercury and Mercury Compounds 1000mg/kg
B5 Polybrominated Biphenyl ( PBBs) 50mg/kg
B6 Polybrominated Diphenyl Ethers ( PBDEs) 1000mg/kg
B7 Polychlorinated Naphthalenes ( more than 3 chlorine atoms ) 50mg/kg
B8 Radioactive Substances No threshold value
B9 Certain Shortchain Chlorinated Paraffins ( Alkanes, C10 – C13 , chloro) 1%
B10 Brominated Flame Retardant ( HBCDD)  100mg/kg

CTI, as the international leader for IHM surveys, can provide the IHM survey to ensure that ships comply with the Convention, and guide shipyards to meet the requirements for Class issuing and endorsing an International Certificate on IHM and issuing an International Ready for Recycling Certificate.


  • MEPC.269(68): 2015 Guidelines For The Development Of The Inventory Of Hazardous Materials
  • MEPC.196(62): 2011 Guidelines For The Development Of The Ship Recycling Plan
  • MEPC.210(63): 2012 Guidelines For Safe And Environmentally Sound Ship Recycling
  • MEPC.222(64): 2012 Guidelines For The Survey And Certification Of Ships Under The Hong Kong Convention
  • MEPC.223(64): 2012 Guidelines For The Inspection Of Ships Under The Hong Kong Convention
  • Regulation (EU) 1257/2013 of the European Parliament and the Council on ship recycling (EU SRR)
  • EMSA--Guidance on the Inventory of Hazardous Materials, IHM Development and Maintenance in the context of the EU Ship Recycling Regulation
  • EMSA--Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling

Provide The Service

  • Full IHM Part I based on sampling
  • Full IHM Part I based on document analysis (MD&SDoC)

CTI Company Qualification

CTI POLY- CTI Marine Services is the Australian Maritime Safety Authority accepted provider for Inspection, Laboratory testing and Reporting of asbestos containing materials. IHM expert company accepted by Marshall Islands and Liberia flag, We are the worldwide 1st IHM service provider approved by ABS, also one of the oldest (10+ years) by BV, DNVGL, LR, KR, RINA, CCS, with excellent track records, accepted by ClassNK. Our reports have always been approved by the flag state, classification societies upon the first submission for issuance of the IHM certificate till date.




Phases Turn Around Days Output
TRAINING 1 Training for supplier and shipyard internal functional departments
Tech.Support 1 Answer the questions when makers and shipyard found problem for IHM, MD,SDoC
COLLECTING THE "MATERIAL DECLARATION" AND "SUPPLIER'S DECLARATION OF CONFORMITY" 14-21 (depend on efficiency from suppliers) The materials (MD,SDOC) should be furnished by the suppliers in the shipbuilding supply chain (e.g., equipment suppliers, parts suppliers, material suppliers).
CHECKING OF MATERIALS LISTED 3 collection of necessary information
TOTAL 19-26 days  
If suppliers cannot provide accurate information or provide the any false information, Maybe CLASS surveyor will ask to add Visual/sampling onboard.
Preparation of VSCP 1 Preparation of visual/sampling check plan
Onboard check 2 Onboard visual/sampling check
LAB ANALYSIS 5 Lab testing report

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