Competenza GmbH














Concepts for the collection and remediation of pollutants on ships


As experts in the field of indoor pollutants, we can use our experience and know-how to solve the issue of pollution occurrence on ships. The legal international and national requirements for the protection of humans and the environment also apply to shipping.


Background, legal bases, deadlines


The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) is an agreement for worldwide improvements for the environmentally friendly recycling of ships and for working conditions in demolition shipyards and demolition operations. It was adopted by the member states of the International Maritime Organisation (IMO) in Hong Kong in May 2009.


The Maritime Environment Protection Committee (MEPC) published the MEPC Directive in May 2015.269(68) (Guidelines for the Development of the Inventory of Hazardous Materials).


The IMO sets the framework with the HKC and the internationally valid MEPC directive.269(68), which regulate the mandatory collection of hazardous materials (HazMat) on existing ships. In December 2013, the EU Ship Recycling Regulation (EU-SRR) came into force.


A major requirement of both regulations is the creation of an Inventory of Hazardous Materials (IHM) for new and existing ships and platforms.


The following IHM deadlines have been set for vessels over 500 GT:

  • From the end of 2016, recycling ships must embark on their last voyage with a certified IHM/hazardous substances register.
  • New ships must be equipped with a certified IHM from the end of 2015.
  • Existing ships flying the EU flag and ships calling at EU countries (irrespective of the flag flying) must have a certified IHM by 31 December 2020 at the latest.

The HKC and EU-SRR apply to existing ships and new ships over 500 GT, which means that approximately 50,000 ships need an IHM recording the hazardous substances such as asbestos, PCB, ozone-depleting substances and TBT-containing ship paints (+ PFOS [perfluorooctane sulphonic acid] on EU ships e.g. possible in extinguishing foam).


In addition, the 1974 International Convention for the Safety of Life At Sea (ICSLS) and the MSC regulate this.1/Circular 1374 of 3 December 2010, "Information on the prohibition on the use of asbestos on board ships", stated that materials containing asbestos which were installed on ships after mid-2002 must be dismantled or remediated within 3 years of their detection.


Current status


Experience shows that, despite the ban, materials containing asbestos are found again and again, e.g. in fire blankets, connections and insulating materials, sealants, brake linings, wall and ceiling linings, cables, material residues, electrical fuses, etc. and also new ships declared asbestos-free after repair work and/or the purchase of spare parts had asbestos on board.


Stricter PSC (Port State Control) controls on asbestos in the Netherlands and New Zealand are used to check compliance with international regulations. If these are not met or serious deficiencies are found, the ships may be detained.


Why Competenza?


Expertise and experience determine the success or failure of pollutant collection and remediation. The collection of pollutants in ships and the creation of complete, meaningful inventories of hazardous materials (IHM) are the indispensable basis for targeted pollutant remediation or for the dismantling of pollutants in the course of ship recycling. Without IHM, neither a suitable recycling facility can be selected, nor can the recycling company's safety-related planning be carried out.


Our experienced experts (approved HazMat experts, DNV GL) and in-house laboratories (accredited according to DIN EN ISO/IEC 17025:2005, D-PL-14469-01-00) can clarify whether ships are asbestos free and crews safe in advance by creating a complete and meaningful IHM.


Besides the known pollutants like asbestos, synthetic mineral fibres or PCB, other pollutants such as PAHs, CFC, organotin compounds (TBT), heavy metals such as cadmium or lead, and also oils and fuels pose a significant problem. Here, too, we are happy to offer you our support.


Would you like to know more about the inventory of hazardous materials (IHM)? Of course, we are at your disposal for any questions concerning this complex topic. Rely on our competence and many years of experience in the introduction and implementation of new standards.


Contact point for further information:      

Rolf Heykes

Hamburg Office

Tel.: +49 40 18 01 79 96



Cengiz Sisova

Frankfurt Office

Tel.: +49 6103 20 01 16 0



Mr. Mehmet Emin Yaşar

Istanbul Office

Mobile: +90 530 347 59 54