Hong Kong Convention & Inventory of Hazardous Materials
The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships establishes an international regulatory framework for the safe and environmentally sound recycling of ships.
The Convention entered into force on 26 June 2025, establishing internationally applicable requirements covering ship recycling, hazardous materials, ship-specific inventories, surveys, certification, preparation for recycling, and the operation of ship recycling facilities.
A central element of the Convention is the Inventory of Hazardous Materials (IHM). The IHM identifies hazardous materials present on board a ship and provides a controlled record that supports safe ship operation and the eventual recycling process.
The development and maintenance of the IHM are supported by the IMO Guidelines for the Development of the Inventory of Hazardous Materials, including the 2023 Guidelines adopted through IMO Resolution MEPC.379(80).
Shipowners, operators, technical managers and other responsible parties should therefore treat IHM management as an ongoing technical and compliance responsibility rather than as a document prepared only when a vessel approaches recycling.
Scope of the Hong Kong Convention & IHM Requirements
The Hong Kong Convention establishes requirements intended to ensure that ships are recycled safely and in an environmentally sound manner while controlling hazardous materials throughout the relevant stages of the ship's life.
The IHM provides the ship-specific technical record necessary to identify relevant hazardous materials and their locations and quantities in accordance with the applicable requirements.
IHM Part I
Identifies hazardous materials contained in the ship's structure and equipment and is maintained throughout the operational life of the vessel.
IHM Part II
Addresses operationally generated wastes and becomes particularly relevant when the vessel is being prepared for recycling.
IHM Part III
Addresses stores on board that contain or may contain hazardous materials and is relevant to preparation for recycling.
Hazardous Materials
The IHM identifies hazardous materials covered by the applicable Convention, regulations and IMO guidelines, including materials such as asbestos, PCBs, ozone-depleting substances and applicable anti-fouling substances.
Supporting Documentation
Material declarations, supplier declarations, technical records and other supporting documentation provide evidence used in developing and maintaining the IHM.
Verification
The ship-specific IHM is subject to verification through the applicable survey and certification framework established by the Administration or authorized Recognized Organization.
IHM Maintenance
Relevant changes to hazardous materials must be reflected in the IHM during the ship's operational life in accordance with the applicable requirements.
Recycling Preparation
Before recycling, the ship's IHM and related documentation support the safe preparation of the vessel and the identification and management of hazardous materials.
1. Inventory of Hazardous Materials — IHM Part I
IHM Part I is the principal part of the ship-specific Inventory of Hazardous Materials maintained during the operational life of the vessel.
It identifies hazardous materials contained in the ship's structure and equipment and records their relevant locations and approximate quantities in accordance with the applicable requirements and IHM methodology.
The IHM should be sufficiently detailed to allow hazardous materials to be identified and managed effectively during the vessel's operational life and subsequently during preparation for recycling.
IHM Part I Technical Information
- Identification of applicable hazardous materials
- Identification of the relevant equipment, systems, structures, components or locations
- Location information sufficient to identify where the material is installed
- Approximate quantity or relevant quantity information
- Supporting material or supplier documentation where applicable
- Survey and verification records
- Records of changes made during the ship's operational life
- Controlled documentation supporting the current IHM status
The IHM should remain consistent with the actual condition and configuration of the vessel. Changes made during repairs, conversions, renewals, equipment replacement or other technical work may therefore require corresponding IHM updates.
2. IHM Part II & Part III
The Inventory of Hazardous Materials is divided into three parts under the applicable IHM framework. While Part I is maintained during the operational life of the ship, Parts II and III are particularly associated with the preparation of the vessel for recycling.
Part II — Operationally Generated Wastes
Part II identifies operationally generated wastes that are required to be addressed when preparing the ship for recycling, including relevant wastes accumulated during normal ship operations.
Part III — Stores
Part III identifies stores that may contain hazardous materials and must be considered as part of the ship's preparation for recycling.
Recycling Preparation
Parts II and III support the identification and controlled management of relevant wastes and stores before the vessel is delivered to a ship recycling facility.
Ship-Specific Information
The information should correspond to the actual condition and operational status of the vessel and should be supported by appropriate records and verification.
3. Hazardous Materials Covered by the IHM
The IHM addresses hazardous materials identified by the applicable Hong Kong Convention requirements and associated IMO guidelines. The precise substances, applicable thresholds and documentation requirements depend on the regulatory framework applicable to the vessel.
Hazardous materials addressed within the IHM framework include substances such as asbestos, polychlorinated biphenyls (PCBs), ozone-depleting substances and relevant substances associated with anti-fouling systems.
The applicable requirements should always be assessed against the current Convention, IMO guidelines, applicable Administration requirements, and where relevant, additional regional requirements such as the EU Ship Recycling Regulation.
Key Hazardous Material Categories
- Asbestos and asbestos-containing materials
- Polychlorinated biphenyls (PCBs)
- Ozone-depleting substances
- Applicable anti-fouling systems and regulated substances
- Other hazardous materials identified by the applicable Convention and IHM guidelines
The presence of a hazardous material should not be assumed solely from the age or type of equipment. Technical documentation, material declarations, supplier information, visual inspection and, where necessary, sampling and laboratory analysis may be used to establish the applicable IHM information.
4. Material Declarations & Supplier Documentation
Development and maintenance of a reliable IHM depends heavily on the availability and quality of supporting documentation.
Material Declarations and Supplier Declarations can provide important information regarding hazardous materials incorporated into equipment, machinery, systems, components and materials supplied to the vessel.
Shipowners and technical managers should establish appropriate procedures for collecting and retaining relevant documentation when equipment is purchased, installed, renewed or replaced.
Supplier Information
Obtain relevant supplier or manufacturer information for equipment and materials that may be subject to IHM requirements.
Material Declarations
Maintain applicable Material Declarations and supporting documentation as part of the technical record.
Equipment Records
Link relevant declarations and documentation to the equipment, system, location or component to which they apply.
Document Control
Maintain controlled records so that the IHM reflects the latest available information and changes made during the vessel's operational life.
5. IHM Survey, Inspection & Sampling
Verification of an IHM may involve a combination of document review, visual inspection, location verification, quantity assessment and sampling or testing where necessary.
Sampling is not automatically required for every material or every component. Where reliable documentation is unavailable or insufficient to establish whether a relevant hazardous material is present, sampling and appropriate laboratory analysis may be required under the applicable IHM methodology.
The extent of inspection and sampling should therefore be based on the applicable regulatory requirements, available documentation, vessel configuration, material history and the professional assessment of the survey process.
Typical IHM Verification Activities
- Review of existing IHM documentation
- Review of drawings, equipment lists and technical records
- Review of supplier and Material Declarations
- Verification of hazardous-material locations
- Visual inspection of accessible areas and equipment
- Identification of areas requiring additional investigation
- Sampling and laboratory testing where necessary
- Verification of approximate quantities where applicable
- Reconciliation of survey findings with the ship-specific IHM
- Preparation of supporting survey and technical documentation
6. IHM Surveys & Verification Under the Hong Kong Convention
The Hong Kong Convention establishes a survey and certification framework for ships subject to its requirements.
The IHM is subject to verification through the applicable survey process. The Convention provides for an initial survey, additional surveys during the life of the ship, and a final survey prior to recycling.
The purpose of the survey process is to verify that the ship and its IHM comply with the applicable requirements at the relevant stage of the vessel's life.
Initial Survey
The initial survey verifies the ship-specific IHM and associated arrangements in accordance with the applicable Convention and survey requirements.
Additional Surveys
Additional surveys may be carried out during the life of the ship in accordance with the applicable Convention requirements and circumstances affecting the IHM.
Final Survey
The final survey is conducted before recycling to verify the vessel's condition and documentation in accordance with the applicable requirements.
Certification
Statutory certification is issued by the applicable Administration or authorized Recognized Organization in accordance with the relevant regulatory framework.
7. Maintaining & Updating the IHM During the Ship's Life
IHM compliance is an ongoing process. A ship's equipment, materials and systems can change throughout its operational life as a result of repairs, renewals, conversions, modifications, equipment replacement and other technical work.
Where such changes introduce or remove hazardous materials covered by the applicable IHM requirements, the ship-specific IHM should be updated accordingly.
The IHM management system should therefore provide a controlled process for recording changes and retaining supporting evidence.
IHM Update Triggers
- Installation of new equipment containing relevant hazardous materials
- Replacement or renewal of equipment or components
- Removal of equipment containing hazardous materials
- Major repairs or modifications affecting IHM information
- Conversion or alteration of vessel systems
- Discovery of previously unidentified hazardous materials
- Changes affecting the location or quantity information
- New supplier or Material Declarations becoming available
Appropriate records should identify the changes made to the IHM and maintain the supporting information required by the applicable IHM guidelines and ship management procedures.
8. IHM Management System & Responsible Personnel
Effective IHM compliance requires more than maintaining a static document on board. The shipowner or responsible management organization should establish an appropriate system for maintaining and updating the IHM throughout the vessel's operational life.
The applicable IMO IHM guidelines provide for the designation of appropriate responsibility and procedures for maintaining the inventory and associated records.
Designated Responsibility
A responsible person or defined management function should oversee the IHM maintenance and updating process.
Change Control
Technical changes affecting hazardous-material information should be identified and incorporated into the IHM.
Supporting Records
Declarations, certificates, supplier information, survey reports and other supporting evidence should be retained appropriately.
Verification Readiness
IHM records should remain organized and available for inspection, survey and verification when required.
Crew & Technical Awareness
Relevant personnel should understand the procedures for identifying changes that may affect the ship's IHM.
Record Traceability
Changes to the inventory should be traceable to the supporting technical documentation and work performed.
Periodic Review
IHM management procedures should be periodically reviewed to ensure continued effectiveness and compliance.
Survey Preparation
The IHM should be maintained in a condition that allows efficient verification during applicable surveys.
9. EU Ship Recycling Regulation & IHM
In addition to the Hong Kong Convention, ships may be subject to the requirements of the European Union Ship Recycling Regulation (EU) No 1257/2013.
The EU regulatory framework applies to EU-flagged ships and also establishes requirements affecting certain non-EU ships when they call at EU ports or anchorages, subject to the scope and exemptions contained in the Regulation.
The EU Ship Recycling Regulation contains specific IHM requirements and should not simply be treated as identical to the Hong Kong Convention. Additional substances, thresholds, certification requirements and procedural provisions may apply depending on the vessel and regulatory circumstances.
EU-Flag Ships
EU-flag ships are subject to the applicable requirements of the EU Ship Recycling Regulation, including its IHM provisions.
Non-EU Ships
Certain non-EU ships calling at EU ports or anchorages may also be subject to applicable IHM-related requirements under the EU framework.
Additional Requirements
The EU framework contains requirements that may differ from or extend beyond the international Hong Kong Convention framework.
Regulatory Assessment
Shipowners should determine which regulatory regime applies to the vessel and ensure that the IHM is developed and maintained accordingly.
10. Preparing a Vessel for IHM Survey
Early preparation can significantly improve the efficiency of an IHM survey and reduce the risk of delays caused by missing documentation, inaccessible areas, unidentified materials or inconsistencies between the IHM and the actual vessel condition.
Shipowners and technical managers should review the IHM well in advance of the applicable survey and verify that supporting technical records remain complete and traceable.
Review Existing IHM
Review the current ship-specific IHM for completeness, consistency, locations, quantities and supporting documentation.
Check Technical Records
Review recent repairs, renewals, modifications, conversions and equipment replacements that may affect the IHM.
Review Supplier Documentation
Confirm that available Material Declarations, Supplier Declarations and other relevant documentation are properly retained.
Identify Missing Information
Identify areas where existing documentation is incomplete or where additional investigation may be required.
Prepare Access
Ensure that relevant machinery spaces, accommodation areas, technical spaces and other locations can be safely accessed during the survey.
Plan Sampling
Where documentation is insufficient, identify areas that may require sampling and laboratory analysis in accordance with the applicable methodology.
Verify IHM Updates
Confirm that changes made during the vessel's operational life have been incorporated into the current IHM.
Coordinate Survey
Coordinate the vessel, technical management, surveyor, laboratory and other relevant parties before the scheduled verification.
11. Preparing a Ship for Recycling
When a ship approaches its recycling stage, the IHM becomes an essential component of the vessel's recycling preparation.
The ship-specific hazardous-material information should be brought up to date and supported by the appropriate records so that the recycling facility can identify and safely manage hazardous materials during the recycling process.
The preparation process should address the applicable requirements for the ship's IHM, operationally generated wastes and stores, as well as other requirements applicable to the final survey and recycling process.
Recycling Preparation Considerations
- Confirm the latest status of IHM Part I
- Prepare IHM Part II as required for operationally generated wastes
- Prepare IHM Part III as required for stores
- Review the vessel's hazardous-material records
- Identify relevant materials and their locations
- Verify supporting documentation and survey records
- Complete required preparation before the final survey
- Coordinate the required statutory and recycling documentation
12. Hong Kong Convention, IHM & Safe Ship Recycling
The Hong Kong Convention links the identification of hazardous materials on board ships with the wider objective of ensuring that ship recycling is conducted safely and in an environmentally sound manner.
A reliable IHM helps shipowners, technical managers, surveyors and recycling facilities understand which hazardous materials are present and where they are located, allowing appropriate controls to be established during the recycling process.
Effective IHM management therefore contributes to both shipboard risk management and environmental protection.
Hazard Identification
The IHM provides ship-specific information concerning hazardous materials present in the vessel's structure and equipment.
Worker Protection
Accurate hazardous-material information supports safe planning and control of work during ship recycling.
Environmental Protection
Identification and controlled management of hazardous materials support environmentally sound recycling practices.
Regulatory Compliance
Proper IHM development, maintenance and verification support compliance with the applicable international and regional ship recycling requirements.
Independent Marine Surveying & Technical Consultancy
PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy support for shipowners, operators, technical managers and maritime stakeholders.
Technical support relating to IHM and ship recycling may include IHM documentation review, technical survey preparation, vessel condition assessment, hazardous-material information review, inspection coordination, sampling coordination and regulatory compliance support.
PAMS can assist clients in identifying technical documentation gaps, reviewing vessel information, preparing for applicable surveys and coordinating technical activities associated with IHM compliance.
Such consultancy support does not replace statutory verification or certification. Where statutory certification is required, the applicable Administration or authorized Recognized Organization remains responsible for the relevant statutory survey and certification process.
Frequently Asked Questions
What is the Hong Kong Convention?
The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships establishes an international framework for the safe and environmentally sound recycling of ships, including requirements concerning hazardous materials, ship recycling facilities, surveys, certification and the Inventory of Hazardous Materials.
When did the Hong Kong Convention enter into force?
The Hong Kong Convention entered into force on 26 June 2025.
What is an Inventory of Hazardous Materials (IHM)?
An Inventory of Hazardous Materials is a ship-specific record identifying hazardous materials present on board, including relevant information concerning their locations and quantities in accordance with the applicable regulatory requirements and IHM guidelines.
What is IHM Part I?
IHM Part I identifies hazardous materials contained in the ship's structure and equipment. It is maintained during the operational life of the vessel and should be updated when relevant changes occur.
What are IHM Parts II and III?
IHM Part II addresses operationally generated wastes, while IHM Part III addresses stores. These parts are particularly relevant when the ship is being prepared for recycling, subject to the applicable regulatory requirements.
Which hazardous materials are included in the IHM?
Depending on the applicable regulatory regime, IHM requirements can address hazardous materials such as asbestos, PCBs, ozone-depleting substances, applicable anti-fouling substances and other materials identified by the relevant Convention, regulation and IMO guidelines.
Does the IHM have to be updated during the ship's operational life?
Yes. IHM Part I is maintained during the ship's operational life. Relevant changes resulting from installation, removal, replacement, renewal, repair or modification of equipment and materials should be assessed and incorporated into the IHM where required.
Is sampling required for every material during an IHM survey?
No. Sampling is not necessarily required for every material. Where existing documentation and supplier or Material Declarations are insufficient, sampling and laboratory testing may be required in accordance with the applicable IHM methodology and regulatory requirements.
What does an IHM survey involve?
An IHM survey may involve document review, examination of the existing IHM, review of supplier and Material Declarations, visual inspection, location verification, quantity assessment, sampling or testing where necessary, and reconciliation of survey findings with the ship-specific IHM.
What is the relationship between the Hong Kong Convention and the EU Ship Recycling Regulation?
The Hong Kong Convention establishes international requirements for safe and environmentally sound ship recycling, including IHM requirements. The EU Ship Recycling Regulation establishes additional requirements for ships within its scope, including EU-flag ships and certain non-EU ships calling at EU ports or anchorages.
Can PAMS Pacific Admiralty Maritime Services provide IHM technical support?
PAMS Pacific Admiralty Maritime Services provides independent marine technical consultancy and surveying support related to IHM documentation review, survey preparation, technical inspections, compliance readiness, sampling coordination and related ship recycling requirements. Statutory verification and certification remain the responsibility of the applicable Administration or authorized Recognized Organization where required.
PAMS Pacific Admiralty Maritime Services
PAMS Pacific Admiralty Maritime Services is an independent Philippine marine technical consultancy providing marine surveying, marine technical consultancy, offshore engineering consultancy, FPSO engineering support, maritime compliance services, marine audits and technical inspections.
PAMS provides independent technical support to shipowners, operators, technical managers, offshore projects and other maritime stakeholders in relation to vessel condition, regulatory compliance, technical inspections, marine surveys and engineering requirements.
Based in Manila, Philippines — providing independent marine technical consultancy services in the Philippines and internationally.
Need IHM Compliance or Survey Support?
PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy support for IHM documentation review, survey preparation, technical inspections, compliance readiness and related ship recycling requirements.