Ship Scrapping: Material Matters


Regulations concerning the scrapping of vessels have taken effect in a number of countries. 

In Signals 113, our article “Scrapheap Challenge” outlined the new European Union (EU) regulations that require vessels flying the flag of an EU state can only be scrapped in approved ship-recycling facilities.

Outside the EU, some countries have already ratified the Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, which will come into force 24 months after it is fully ratified.

What’s required?

Both regulations require ships to be in possession of an Inventory of Hazardous Material (IHM) which is approved by their Flag State.

The inventory is a list of hazardous materials that form part of the ship’s structure and equipment, operationally generated hazardous wastes and stores on board.

The below table, provided by GSR Services GmbH, outlines the requirements for new and existing vessels:

Inventory of Hazardous Materials

Shipbuilding & Operation

Prior to Recycling

Part 1

Structure & Equipment

Part 2

Hazardous Wastes

Part 3


IMO Table A (and EU Annex I):

Mandatory for all ships and installation




IMO Table B (and EU Annex II:

Mandatory for new ships and installations, voluntary for existing ships




Table C:

Potentially hazardous items




Table D:

Regular consumer products




What’s the issue?

This sounds simple, but there are concerns within the shipping industry that this may be difficult to achieve.

Earlier this year at the Tradewinds Ship Recycling Forum, experts representing different sectors of the shipping industry, including class societies, revealed that there is no mandatory instruction on how to draft IHM and what should be in it.

The impact of this could be felt most strongly during future port state control (PSC) inspections. As Tradewinds later reported: “With little consistency on how IHMs should be drafted, it is more than likely that the same will apply on the enforcement side”.

There are some differences between the IMO and regional regulations. For example, the EU regulations have two additional substances compared to the IMO tables (Perfluorooctane sulfonic acid (PFOS) and Brominated Flame Retardant (HBCDD)).

The compilation of the IHM for new build vessels may be simpler for the shipowner as it is the responsibility of the shipyard to provide the necessary approved documentation. But for existing vessels, compiling the IHM will be more difficult and time-consuming based on a scheme of inspections and sampling.

Given that all vessels calling at an EU port must have an IHM by 31 December 2020, demand for services to assist in this process will be high. IHM consultants are advising shipowners not to leave this process to the last minute.

With thanks to GSR Services GmBH – for their assistance in writing this article.


Author: John Southam
Executive (Loss Prevention)