Shipowners Need to Prepare for the HKC Hazardous Materials Inventory
On June 26, 2025—right around the corner—the International Maritime Organization's (IMO) Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention) will enter into force. This landmark agreement is crucial for ensuring that the ship recycling industry operates safely and sustainably, aiming to protect both workers and the environment from the dangers posed by hazardous materials on ships.
Without proper management, hazardous materials can lead to acute and chronic illness as well as environmental pollution, including oil spills, leakage of toxic substances, and contamination of soil and water. These issues can harm marine life, local ecosystems, and even drinking water supplies.
Each year, approximately 500 ocean-going commercial vessels reach the end of their service life and undergo the process of shipbreaking (i.e., the dismantling of ships for recycling). In accordance with the HKC, vessels over 500 gross tonnage (GT) are required to maintain an Inventory of Hazardous Materials (IHM). This inventory details all hazardous substances on board, such as asbestos and heavy metals, thereby enabling safe and compliant handling and disposal during the ship dismantling process.
As the HKC comes into force, all ships greater than 500 GT will need to have an IHM prepared and approved by the date of implementation. This requirement applies to vessels flagged under countries that are parties to the HKC, and flag Administrators are expected to enforce adherence to it. The HKC outlines specific hazardous materials that must be inventoried and managed, including asbestos, heavy metals, chromium-6, and polychlorinated biphenyls (PCBs). Proper identification and handling of these substances will mitigate the risks associated with their disposal during recycling.
Regrettably, the history of ship recycling has been marred by numerous accidents. These incidents highlight the urgent need for stringent safety measures and compliance with regulations stipulated by the HKC. The IHM, integral to the HKC, plays a crucial role in mitigating risks associated with hazardous materials. It establishes best practices widely accepted in the shipping and recycling industries.
IHM inventories should be conducted at various stages of a ship’s life:
- Approval and Certification (PART I): Initial inventory creation
- Maintenance and Renewal: Regular updates every five years
- Dismantling and Recycling (PART II and III): Final inventory management during the recycling process.
Experienced hazardous materials (HAZMAT) certified inspectors carry out these assessments and can guide shipowners on compliance. If hazardous materials are identified, remediation can be implemented under expert supervision, including the removal and replacement with non-hazardous alternatives.
As the HKC approaches its enforcement date, it represents a leap forward in improving the safety of ship recycling processes and protecting both workers and the marine environment. By ensuring all vessels possess a comprehensive IHM, the maritime industry can foster a safer, more responsible approach to ship disposal, ultimately benefiting society at large. Monitoring hazardous materials throughout a ship's lifecycle is essential for minimizing health risks and adhering to environmental regulations. The HKC, together with the implementation of IHM, underscores the commitment of the shipping industry to sustainable practices and the well-being of communities worldwide.
Pim Versteegt is the Technical Manager at SGS Search, managing the quality and maintenance of Inventory of Hazardous Materials (IHM) surveys. Under his guidance, SGS Search has conducted hundreds of IHM surveys globally and actively ensures the ongoing compliance and updates for over 400 vessels.
Captain Jos Geene, with more than three decades of experience in the dredging and offshore industry, plays a key role in shaping the SGS IHM program (including IHM maintenance). Additionally, he provides global support to SGS Inspectors, contributing to the high standards of the maritime industry.
Ersi Zacharopoulou, MSc (Eng) is the Development Manager of SGS, Europe, Africa and Middle East Marine Services, where she leads efforts to promote environmental compliance projects for the shipping industry. Additionally, she is a member of the Technical Chamber of Greece.
Lisa Drake, PhD manages marine environmental services in the Americas for SGS, the world's leading testing, inspection and certification company. She—along with a global team of experts—guides this work in more than 600 ports worldwide.
The opinions are the authors' alone and do not necessarily reflect the views of SGS.
The opinions expressed herein are the author's and not necessarily those of The Maritime Executive.
RightShip Revises Timeline for Increased Safety Inspections for Bulkers
The widely used digital maritime platform RightShip which tracks safety and sustainable practices has agreed with the bulker industry to revise the timeline for increasing its safety inspection program. Two months ago, the group cited safety concerns saying that it was responding by lowering the age of a vessel to trigger inspections and expanding the regime to wider segments of the industry.
While one of the key segments of merchant shipping, and one of the largest categories, the average age of bulkers is increasing, and with it comes more safety risks. In addition, like all parts of the industry, bulkers are under pressure to increase their performance and sustainable operations. The group reported that its data showed the average of bulkers has reached 14.7 years and is continuing to rise. Construction of new bulkers has also lagged other segments which are aggressively adding new tonnage.
RightShip in October announced it had decided in a two-step process to lower the age of a vessel to start inspections from 14 to 12 years in 2025 and 10 years in 2026. It also reported that the inspection requirement would also be extended to cover smaller vessels under 8,000 dwt, which had been exempt until recently.
Despite saying it had consulted with the industry, the proposal was met with widespread complaints. INTERCARGO, which represents a large portion of the operators, issued a statement expressing “deep concern” saying that it required more consultation and time to prepare for the accelerated timeline.
After discussions with INTERCARGO as well as the International Chamber of Shipping and the Union of Greek Shipowners, RightShip confirmed it was refining the approach to align with the operational realities. It said however the fundamentals of the changes designed to reinforce the shared commitment to safety remain in place.
“Our updated approach directly addresses some of the key stakeholder concerns, balancing inspection workloads, and providing flexibility while maintaining rigorous safety standards,” said Christopher Saunders, Chief Maritime Officer at RightShip. “We've also committed to enhanced transparency in our processes to offer greater clarity through industry dialogue going forward.”
The 10-year trigger to start inspections remains, but RightShip expanded the timeline to four steps starting at 13 years in October 2025 (instead of 12 years in March 2025) and by January 1, 2027 (instead of March 31, 2026) reaching 10 years. They said this would give vessel owners and operators more time to adjust budgets, train crew, and plan for the inspections. Vessels will now have 12 months’ notice before the changes start and it is also providing a three-month inspection buffer.
The expansion to require vessels of less than 8,0000 dwt to undergo similar inspections remains in the program. RightShip emphasizes that this will make the safety standard more consistent across the global dry bulk and general cargo fleet.
“Safety is a collective journey,” said Steen Lund, CEO of RightShip. “This phased rollout is a step forward in working toward zero harm in maritime operations while ensuring a realistic transition period for our stakeholders. We look forward to continuing our dialogue and working with the industry to improving and advocating for higher safety standards.”
INTERCARGO issued a statement welcoming the revision. Chairman Elect John Xylas also highlighted an agreement with RightShip for regular structured consultations. He said it would ensure that dry bulk owners and operators would contribute in the development of industry initiatives that promote safety and sustainability.
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