2015 Guidelines for the development of the inventory of hazardous materials

21 October 2015  |  C15035

The IMO has adopted at its 68th session the revised guidelines for the development of the inventory of hazardous materials through Resolution MEPC.269(68).  The revised guidelines supersede the previous ones adopted by MEPC.197(62).

Ship Owners / Managers / Operators  |  Flag Administrations

These guidelines provide recommendations for developing the Inventory of Hazardous Materials (IHM) in order to assist compliance with regulation 5 (Inventory of Hazardous Materials) of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.

The Inventory consists of:

  • Part I: Materials contained in ship structure or equipment;
  • Part II: Operationally generated wastes; and
  • Part III: Stores.

Appendix 1 of the guidelines, provides information on the hazardous materials that may be found on board a ship.  Materials set out in appendix 1 should be listed in the Inventory.  Each item in appendix 1 of these guidelines is classified under tables A, B, C or D, according to its properties.

Below you may find the new threshold values.

Table A comprises the materials listed in appendix 1 of the Convention

No. Materials Inventory Threshold value
Part I Part II Part III
A-1 Asbestos X 0.1%4
A-2 Polychlorinated biphenyls (PCBs) X 50 mg/kg5
A-3 Ozone depleting substances CFCs X no threshold value6
Halons X
Other fully halogenated CFCs X
Carbon tetrachloride X
1,1,1-Trichloroethane (Methyl chloroform) X
Hydrochlorofluorocarbons X
Hydrobromofluorocarbons X
Methyl bromide X
Bromochloromethane X
A-4 Anti-fouling systems containing organotin compounds as a biocide X 2,500 mg totaltin/kg7


Table B comprises the materials listed in appendix 2 of the Convention

No. Materials Inventory Threshold value
Part I Part II Part III
B-1 Cadmium and cadmium compounds X 100 mg/kg8
B-2 Hexavalent chromium and hexavalent chromium compounds X 1,000 mg/kg8
B-3 Lead and lead compounds X 1,000 mg/kg8
B-4 Mercury and mercury compounds X 1,000 mg/kg8
B-5 Polybrominated biphenyl (PBBs) X 50 mg/kg9
B-6 Polybrominated diphenyl ethers (PBDEs) X 1,000 mg/kg8
B-7 Polychlorinated naphthalenes (more than 3 chlorine atoms) X 50mg/kg10
B-8 Radioactive substances X no threshold value11
B-9 Certain shortchain chlorinated paraffins (Alkanes, C10-C13,chloro) X 1%12


Table C (Potentially hazardous items) comprises items which are potentially hazardous to the environment and human health at ship recycling facilities.

Table D (Regular consumable goods potentially containing hazardous materials) comprises goods which are not integral to a ship and are unlikely to be dismantled or treated at a ship recycling facility.

No. Materials Example Inventory
Part I Part II Part III
D-1 Electrical and electronic equipment Computers, refrigerators, printers, scanners, television sets, radio sets, video cameras, video recorders, telephones, consumer batteries, fluorescent lamps, filament bulbs, lamps X
D-2 Lighting equipment Fluorescent lamps, filament bulbs, lamps X
D-3 Non ship-specific furniture, interior and similar equipment Chairs, sofas, tables, beds, curtains, carpets, garbage bins, bed-linen, pillows, towels, mattresses, storage racks, decoration, bathroom installations, toys, not structurally relevant or integrated artwork X


Tables A and B correspond to part I of the Inventory. Table C corresponds to parts II and III and table D corresponds to part III.

For loosely fitted equipment, there is no need to list this in part I of the Inventory.  Such equipment which remains on board when the ship is recycled should be listed in part III.

Those batteries containing lead acid or other hazardous materials that are fixed in place should be listed in part I of the Inventory.  Batteries that are loosely fitted, which includes consumer batteries and batteries in stores, should be listed in part III of the Inventory.

Similar materials or items that contain hazardous materials that potentially exceed the threshold value can be listed together (not individually) on the IHM with their general location and approximate amount specified there.  An example of how to list those materials and items is shown in row 3 of table 1 of appendix 3.


Exemptions – Materials not required to be listed in the Inventory

Materials listed in Table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.

Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.


Standard format of the Inventory of Hazardous Materials

The Inventory should be developed on the basis of the standard format set out in appendix 2 of these guidelines: Standard format of the Inventory of Hazardous Materials. Examples of how to complete the Inventory are provided for guidance purposes only.


Revision to threshold values

Revised threshold values in tables A and B of appendix 1 should be used for IHMs developed or updated after the adoption of the revised values and need not be applied to existing IHMs and IHMs under development. However, when materials are added to the IHM, such as during maintenance, the revised threshold values should be applied and recorded in the IHM.


Download the revised guidelines

You may download the complete revised guidelines through our website here.


Act Now

Dromon can assist and guide owners / managers / operators to prepare a ship specific Inventory of Hazardous Material in accordance with the revised guidelines and in compliance with the Hong Kong Convention and EU Regulation on Ship Recycling.  Through our programme owners / managers / operators can gain legal compliance on international rules and regulations and ensure that health and safety issues on board are better managed.

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