IMSML Website Article 15/2025: Resolution MEPC.379(80) - 2023 Guidelines for the Development of the Inventory of Hazardous Materials
The 2003 Guidelines were made pursuant to the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the HK Convention) and its six Conference resolutions. The 2023 Guidelines are a response to the requirement that an Inventory of Hazardous Materials shall be on board ships. This document shall be prepared and verified in accordance with the 2023 Guidelines. In the light of this requirement, the Marine Environment Protection Committee passed Resolution MEPC.379(80) which was adopted on 7 July 2023. These 2023 Guidelines supersede the 2015 Guidelines previously adopted by MEPC.269(68).
SECTION 1 - INTRODUCTION
Who are the relevant stakeholders for these Guidelines? Shipbuilders, equipment suppliers, repairers, shipowners and ship management companies. These industry participants will benefit from the practical and logical development of the Inventory, see Paragraph 1.2.
What are the objectives of the 2003 Guidelines? Paragraph 1.3 outlines the following objectives:
[1] Provide ship specific information on the actual hazardous materials present onboard;
[2] Protect the health and safety, and prevent environmental pollution at ship recycling facilities;
[3] Help in decision making at ship recycling facilities depending on the type and amounts of materials identified in the Inventory of Hazardous Materials.
SECTION 2 - DEFINITIONS
What are some of the important definitions used in the 2023 Guidelines? Some of the terminology listed in Paragraph 2, titled ‘Definitions’, include:
[1] Fixed - Equipment of materials that are securely fitted with the ship, eg welding, bolts, riveted or cemented. These equipment are used at their position and also includes electrical cables and gaskets, see Paragraph 2.2
[2] Loosely fitted equipment - Equipment or materials present on board the ship ‘other than fixed’, eg fire extinguishers, distress flares and life buoys, see Paragraph 2.4;
[3] Supply chain - The series of entities involved in the supply and purchase of materials and goods., ie from raw materials to the final products, see Paragraph 2.7.
[4] Threshold value - Concentration value in homogenous materials, see Paragraph 2.8.
SECTION 3 - REQUIREMENTS FOR THE INVENTORY
How is the inventory organised? According its properties. An examination of Paragraph 3.1, shows there are 3 main parts:
[1] PART I - Materials contained in the ship structure or equipment.
Note, Table A and B of the materials listed in the HK Convention corresponds to this, see Paragraph 3.2.2.
[2] PART II - Operationally generated wastes.
[3] PART III - Stores.
Note:
[a] Table C (Potentially Hazardous Items) corresponds to PART II and PART III, see Paragraph 3.2.2. This table comprises items which are potentially hazardous to the environment and human health at ship recycling facilities..
[b] Table D (Regular consumable goods potentially containing hazardous materials) corresponds to PART III, see Paragraph 3.2.2. This table comprises good which are not integral to a ship and are unlikely to be dismantled or treated at a ship recycling facility.
Is there a need to list in PART I, loosely fitted equipment? No. Such equipment which remains on board the ship when it is recycled should instead be listed in PART III, see Paragraph 3.2.3.
Where should batteries that contain lead acid or hazardous materials that are fixed in place be listed? In PART I of the Inventory, see Paragraph 3.2.4.
What if the batteries are loosely fitted? These include consumer batteries and batteries in stores, that should be listed in PART III of the Inventory, see Paragraph 3.2.4.
How does one list similar materials or items that contain hazardous materials that potentially exceed the threshold value? These can be listed together (not individually) on the Inventory of Hazardous Materials (IHM) also commonly referred to as the Inventory. Accompanying this should be the general location and the approximate amount specified there (ie referred to as ‘bulk listing’), see Paragraph 3.2.5.
Are there materials that are NOT required to be listed in the Inventory? Yes, materials subject to ‘Exemptions’, see Paragraph 3.3. For example:
[1] Materials listed in Table B that are inherent in solid metals or metal alloys (such as steel, aluminium, brass, bronze, plating and solders). The applicable proviso here is that these materials are used in general construction (such as hull, superstructure, pipes or housings for equipment and machinery), see Paragraph 3.3.1;
[2] The amount of hazardous materials potentially contained in printed wiring board (eg printed circuit boards) installed in equipment, see Paragraph 3.3.2 (Note: Contrast with electrical and electronic equipment which have to be listed in the Inventory).
Is there a standard format for the Inventory? Yes. The Inventory should be developed on the format set out in Appendix 2 which sets of the Standard Format for the Inventory of Hazardous Materials, see Paragraph 3.4.
How should threshold values be developed or updated after the adoption of revised values? This could be done with the values in Tables A and B of Appendix 1 (ie Items to be listed in the Inventory of Hazardous Materials at Annex 18, p 12). Values could also be added to the Inventory during maintenance, see Paragraph 3.5.
SECTION 4 - REQUIREMENTS FOR DEVELOPMENT OF THE INVENTORY
For new ship, when should the Inventory be developed? For PART 1 of the Inventory for new ships, it should be developed at the design and construction stage, see Paragraph 4.1.1.
How should the presence of materials listed in Table A of Appendix 1 be treated? It should be checked and confirmed. The quantity and location of such materials should be listed in the Inventory. Materials used in compliance with the HK Convention should be listed in PART I. Whereas spare parts which contain materials listed in Table A should be listed in PART III of the Inventory, see Paragraph 4.1.2.
How should materials listed in Table B of Appendix 1 be treated? For products above the threshold values, the quantity and location of the the products (and the contents present in them) should be listed in PART I of the Inventory. Any spare parts containing materials listed in Table B should be listed in PART III of the Inventory, see Paragraph 4.1.3.
What is the basis for the checking of materials? It should be based on the Materials Declaration furnished by suppliers in the shipbuilding supply chain. For example, equipment suppliers, parts suppliers and material suppliers, see Paragraph 4.1.4.
How should PART I of the Inventory for existing ships be developed? Paragraph 4.2.1 stipulates that the following procedures should be followed:
[1] Collection of necessary information, see Paragraph 4..2.1.1;
[2] Assessment of collected information, see Paragraph 4.2.1.2;
[3] Preparation of visual / sampling check plan, see Paragraph 4.2.1.3;
[4] Onboard visual check and sampling check, see Paragraph 4.2.1.4;
[5] Preparation of PART I Inventory and related documentation, see Paragraph 4.2.1.5.
Should the procedures above be used for any new installation resulting from the conversion or repair of any existing ships after the initial preparation of the Inventory? No, see Paragraph 4.2.2.
Who should carry out the procedures above? The shipowner, although expert assistance could be drawn upon. Note, that such an expert or expert party should not be the same as the person or organisation authorised by IMO to approve the Inventory, see Paragraph 4.2.3.
What should the shipowner do to collect the necessary information for the Inventory? The shipowner should identify, research, request and procure all reasonably available documentation, see Paragraph 4.2.5.
What information should the shipowner procure? According to Paragraph 4.2.5, the shipowner should obtain the following useful information:
[1] Maintenance, conversion and repair documents;
[2] Certificates, manuals, ship plans, drawings and technical specification;
[3] Product information data sheets (eg Material Declarations);
[4] Hazardous materials inventories or recycling information from sister ships.
STEP 1
What additional sources of information could shipowners refer to? Paragraph 4.2.5 states that potential sources of information could include the following:
[1] Previous shipowners;
[2] The Shipbuilder;
[3] Historical societies;
[4] Classification society records;
[5] Ship recycling facilities with experience working with similar ships.
STEP 2
How should the information collected above be assessed? As far as practicable, the materials above should be assessed visually, or via a sampling check plan, see Paragraph 4.2.6.
STEP 3
How should the Visual / Sampling check plan be prepared and implemented? According to Paragraph 4.2.7, there are three lists that should be used for this process:
[1] First List (see Paragraph 4.2.7.1.1):
[a] Equipment / System for visual check;
[b] Area specified where the materials listed in Appendix 1 identified by document analysis are present;
[2] Second List (see Paragraph 4.2.7.1.2):
[a] Equipment, system and/or area for sampling check (ie those that cannot be specified in the presence of materials listed in Appendix 1 by document or visual analysis);
[b] A sampling check is the taking of samples to identify the presence or absence of hazardous materials contained in the equipment, systems and/or areas;
[c] This is to help identify the presence or absence of hazardous material contained in the equipment, system or areas, using suitable and generally accepted methods (eg laboratory tests analysis).
[3] Third List (see Paragraph 4.2.7.3):
[a] List of equipment, system and/or area class es as ‘potentially containing hazardous material’;
[b] This could be done by document analysis, without the need for a ‘sampling check’;
[c] Pre-requisite justification: The impossibility of conducting sampling without compromising the safety of the ship and its operational efficiency.
Where should be the visual / sampling checkpoints be? Paragraph 4.2.7.2 designates the following:
[1] Where there is likely to be present, material considered for Part I of the Inventory (as listed in the Appendix), see Paragraph 4.2.7.2.1;
[2] Documentation is not specific, see Paragraph 4.2.7.2.2;
[3] Usage of materials of uncertain composition, see Paragraph 4.2.7.3.
STEP 4
How should onboard visual / sampling checks be conducted? It should be done in accordance with a visual / sampling check plan. Samples should be taken, sample points clearly marked of the ship’s plan and sample results should be referenced, see Paragraph 4.2.8.1.
How materials of the same kind be treated? After checking to ensure that it is of the same kind, it could be sampled in a representative manner, with the aid of expert assistance, see Paragraph 4.2.8.
What is the approach when there is any uncertainty regarding the presence of hazardous materials? This should be clarified by a visual / sampling check. With the aid of photograph, the checkpoints should be documented in the ship’s plan, see Paragraph 4.2.8.2.
What if the area of the ship is not accessible for a visual or sampling check? The correct classification for this should be ‘potentially containing hazardous material’. Materials classed in this manner may be investigated or subject to a sampling check at the request of a shipowner during a later survey (eg during repair, refit or conversion), see Paragraph 4.2.8.2.
STEP 5
What should be done with materials classed as ‘containing hazardous materials’ or ‘potentially containing hazardous material’? The approximate quantity and location should be listed in PART I of the Inventory. In the ‘Remarks’ column of the Inventory, both these two categories should be indicated separately, see Paragraph 4.2.9.
When should ‘indicative’ or field’ tests be used? According to Paragraph 4.2.10, this should be done when:
[1] The likelihood of a hazard is high, see Paragraph 4.2.10.1.1;
[2] The test is expected to indicate that the hazard exists, see Paragraph 4.2.10.1.2;
[3] The sample is being tested by ‘specific testing’ to show that the hazard is present, see Paragraph 4.2.10.1.3.
What are the advantages of ‘indicative or field’ tests? They are quick, inexpensive and useful on board the ship or on site, see Paragraph 4.2.10.2.
What are the disadvantages of ‘indicative or field’ tests? It cannot be accurately reproduced or repeated. It cannot identify the hazard specifically, see Paragraph 4.2.10.2.
Why is ‘specific’ testing preferred? Mostly, to avoid dispute. The ‘specific’ test is repeatable, reliable and can demonstrate definitively whether a hazard exists, see Paragraph 4.2.10.3.
What are the additional advantages of ‘specific’ testing? The outcome of testing is the identification of a known type of hazard. Further, appropriate qualitative and quantitative testing methods could be used. ‘Specific’ tests can be carried in a suitably accredited laboratory in accordance with international standards (or its equivalent), and a reliable written report could be produced for all stakeholders to use, see Paragraph 4.2.10.3.
What is the importance of preparing a diagram of the location of hazardous materials on board a ship? Materials listed in TABLE A can help ship recycling facilities gain a visual understanding of the Inventory, see Paragraph 4.2.11.
How should changes to the Inventory be dealt with? By appropriately maintaining and keeping the Inventory updated, especially after any repair, conversion or sale of a ship, see Paragraph 4.3.1.
What should be done with the Inventory when there is a ‘new installation’? According to Paragraph 4.3.2, PART I of the Inventory should be updated when:
[1] Any machinery or equipment is added to, removed or replaced;
[2] Hull coating is renewed.
Note, if identical parts or coatings are installed or applied, updating is not required.
How should continuity of PART I of the Inventory be maintained? It should belong to the ship and its contents be confirmed, especially if the flag, owner or operator of the ship changes, see Paragraph 4.3.3.
What is the developmental process for PART II of the Inventory (ie for operationally generated waste)? According to Paragraph 4.4.1, this should be developed before the final survey, after it has been decided that a ship is to be recycled, and before the ship enters the ship recycling facility. This will help minimise the amount of cargo residues, fuel oil and wastes remaining on board (see Regulation 8.2 of the HK Convention).
What is the procedure if wastes listed in PART II of the Inventory as provided in TABLE C (ie potentially hazardous items) of APPENDIX 1 are intended for delivery with the ship to a ship recycling facility? The quantity of the operationally generated wastes should be estimated and their approximate quantities / locations be listed in PART II of the Inventory, see Paragraph 4.4.2.
What is the developmental process for PART II of the Inventory (ie Stores)? This should be developed before the final survey once it has been decided to recycle the ship. Effort must be made to minimise wastes remaining board (see Regulation 8.2 of the HK Convention). Each item listed in PART III should correspond to the ship’s operations during its last voyage, see Paragraph 4.5.1. The unit (eg capacity of cans and cylinder), quantity and location of stores should be listed in PART III of the Inventory, see Paragraph 4.5.2.
How should liquids and gases sealed in the ship’s machinery and equipment be dealt with? If listed in TABLE C of APPENDIX 1, this means that it is integral in machinery and equipment on board the ship. The approximate quantity and location should be listed in PART III of the Inventory. The exceptions are small amounts of lubricating oil, anti-seize compounds and grease which are applied to or injected into machinery to maintain normal performance. These do not fall within the scope of the general provisions, see Paragraph 4.5.3.
During the recycling preparation process, what should be done with the quantity of liquids and gases listed in TABLE C of APPENDIX 1 that are required for normal operations? This typically includes related pipe system volumes. It should be prepared and documented at the design and construction stage. This information belongs with the ship and continuity of this information should be maintained, especially if the flag, owner or operator of the ship changes, see Paragraph 4.5.3.
Should regular consumable goods be listed in the Inventory? It is stipulated in Paragraph 4.5.4, that this is usually provided for in TABLE D of APPENDIX 1. It should not be listed in PART I or PART II. The correct place for it is PART III of the Inventory, especially if it is going to be delivered with the ship to a recycling facility. The general description should include the following:
[1] Name of item;
[2] Manufacturer;
[3] Quantity;
[4] Location.
How should the description of location of hazardous materials on board be drafted? Paragraph 4.6 proposes the following:
[1] Name of location (eg second floor of engine-room, bridge DK, APT, No.1 cargo tank, frame number);
[2] Designation given in the plans (eg general arrangement, fire and safety plan, machinery arrangement or tank arrangement).
How should the approximate quantity of hazardous materials be described? The standardised unit should be in kg, unless other units are considered more appropriate (eg m3 for liquids or gases, m2 for materials used in floors or walls). Approximation should rounded up to at least two significant figures, see Paragraph 4.7.
SECTION 5 - REQUIREMENTS FOR ASCERTAINING THE CONFORMITY OF THE INVENTORY
What is the reference standard for this conformity? In PART I of the Inventory, at the design and construction stage, this should be ascertained by reference to the collected SUPPLIER’S DECLARATION OF CONFORMITY (see for example Section 7 and the related Materials Declaration collected from the suppliers, see Paragraph 5.1.
What are the measures shipowners should implement to ensure the conformity of PART I of the Inventory? Paragraph 5.2 recommends the following:
[1] Designate a person responsible for maintaining / updating the Inventory (ie this person could be onshore or board), see Paragraph 5.2.1;
[2] Designate a person to establish and supervise a system to ensure necessary updating of the Inventory in the event of new installation, see Paragraph 5.2.2;
[3] Maintenance of the Inventory, eg dates of changes or new deleted entries, and the signature of the designated person, see Paragraph 5.2.3;
[4] Provision of documents required for survey or sale of the ship, see Paragraph 5.2.4.
SECTION 6 - MATERIAL DECLARATION
What declarations should suppliers to the shipbuilding industry make? They should identify and declare whether the materials listed in TABLES A or B are present above the threshold value specified in APPENDIX 1, see Paragraph 6.1.
Note, this provision does not apply to chemicals which do not constitute a part of the finished product.
A sample of the Material Declaration can be found in APPENDIX 6, see Paragraph 6.2.2.
What information is required in the declaration? A list of the minimum information is found in Paragraph 6.2.1:
[1] Date of declaration, see Paragraph 6.2.1.1;
[2] Material declaration identification number, see Paragraph 6.2.1.2;
[3] Suppliers’ name(s), see Paragraph 6.2.1.3;
[4] Product name (ie common name or the name used by the manufacturer), see Paragraph 6.2.1.4;
[5] Product number (ie for identification by the manufacturer), see Paragraph 6.2.1.5;
[6] Declaration whether the product is present according to the threshold value specified in APPENDIX 1, see Paragraph 6.2.1.6;
[7] Mass of each material listed in TABLES A and/or B of APPENDIX 1, if present above the threshold value, see Paragraph 6.2.1.7.
SECTION 7 - SUPPLIER’S DECLARATION OF CONFORMITY
What is the scope and purpose of this declaration? To provide assurance that the related Material Declaration is in line with Section 6.2, and to identify the responsible entity, see Paragraph 7.1.1.
How long is the Supplier’s Declaration of Conformity valid? As long as the products are present on board the ship, see Paragraph 7.1.2.
What additional document other than the Supplier’s Declaration of Conformity is required to be compiled by the Supplier? A company policy on the management of chemical substances in products which the supplier manufactures or sells. Paragraph 7.1.3 states that it should cover the following:
[1] Compliance with the law, see Paragraph 7.1.3.1;
[2] Obtaining of information on chemical substances content, see Paragraph 7.1.3.2.
What should the Supplier’s Declaration of Conformity contain? According to Paragraph 7.2.1, the following should be found in that document:
[1] Unique identification number, see Paragraph 7..2.1.1;
[2] Name and contact address of the issuer, see Paragraph 7.2.1.2;
[3] Identification of the subject-matter, eg name type, model number, and/or other relevant supplementary information, see Paragraph 7.2.1.3;
[4] A statement of conformity, see Paragraph 7.2.1.4;
[5] Date and place of issue, see Paragraph 7.2.1.5;
[6] Signature (or equivalent sign of validation), name and function of the authorised person(s) acting on behalf of the issuer, see Paragraph 7.2.1.6.
Note, an example of the Supplier’s Declaration of Conformity can be found in APPENDIX 7, see Paragraph 7.2.2.
SECTION 8 - THE APPENDICES
APPENDIX 1 - ITEMS TO BE LISTED IN THE INVENTORY OF HAZARDOUS MATERIALS
What are the contents of TABLE A? These are materials listed in APPENDIX 1 of the ANNEX to the HK Convention, see Annex 18, p 12. Among the materials covered here are:
[1] Asbestos, see A-1;
[2] Polychlorinated Biphenyls (PCBs), see A-2;
[3] Ozone-depleting substances (eg CFCs and Halons etc), see A-3;
[4] Anti-fouling systems containing organotin compounds as a biocide, see A-4;
[5] Anti-fouling systems containing cybutryne, see A-4.
What are the contents of TABLE B? These are materials listed in APPENDIX 2 of the Annex to the HK Convention, see Annex 18, p 13. These materials range from Cadmium and cadmium compounds, see B1, to certain short-chain chlorinated paraffins (alkanes, C10-C13, chloro), see B-9.
What are the contents of TABLE C? This table contains ‘potentially hazardous items’. There are the following:
[1] Liquids ranging from Kerosene (C-1) to Alcohol, methylated spirits (C-17);
[2] Explosive gases such as Acetylene (C-18) to Oxygen (C-21);
[3] Green House Gases such as CO2 to Sulphur Hexaflouride (SF6, see C-28);
[4] Oily liquids such as bunkers / fuel oil (C-29);
[5] Non-oily liquids such cargo residues (C-37);
[6] Explosive gases such as fuel gas (C-38);
[7] Solids ranging from dry cargo residues (C-39) to dry tank residues (C-53).
What are the contents of TABLE D? The table concerns regular consumable good potentially containing hazardous materials. Materials here include electrical / electronic equipment (D-1) as well as Non-ship-specific furniture, interior and similar equipment (D-3).
APPENDIX 2 - STANDARD FORMAT OF THE INVENTORY OF HAZARDOUS MATERIALS
What are the contents of PART I? This part deals with hazardous materials contained in the ship’s structure and equipment.
[1] PART I-1 contains paints and coating systems containing materials listed in TABLE A and TABLE B of APPENDIX 1 of the Guidelines;
[2] PART I-2 contains equipment and machinery having materials listed in TABLE A and TABLE B of APPENDIX 1 of these Guidelines;
[3] PART I-3 deals with the structure and hull containing materials listed in TABLE A and TABLE B of Appendix 1 of these Guidelines;
What are the contents of PART II? This table deals with ‘operationally generated waste’ ranging from the Garbage Locker to the Ballast Tank.
What are the contents of PART III? This part is for ‘Stores’.
[1] PART III-1 - deals simply with ‘stores’ in general;
[2] PART III-2 is for liquids sealed in ship’s machinery and equipment;
[3] PART III-3 is for gases sealed in the ship’s machinery and equipment;
[4] PART III-4 deals with regular consumable goods potentially containing hazardous materials.
APPENDIX 3 - EXAMPLE OF THE DEVELOPMENT PROCESS FOR PART I OF THE INVENTORY FOR SHIPS
There are three main steps identified in the process:
[1] Collection of hazardous materials information, see Paragraph 2.1;
[2] Utilisation of hazardous materials information, see Paragraph 2.2;
[3] Preparation of the Inventory (by filling out standard format), see Paragraph 2.3.
APPENDIX 4 - FLOW DIAGRAM FOR DEVELOPING PART I OF THE INVENTORY FOR EXISTING SHIPS
These are the steps picture in the diagram:
Step [1] - Collection of the necessary information;
Step [2] - Analysis and definition of the scope of assessment;
Step [3] - Preparation of the visual / sampling check plan;
Step [4] - Conducting the onboard visual check / sampling check, ie to determine whether a listing is necessary;
Step [5] - Preparation of the Inventory PART I.
APPENDIX 5 - EXAMPLE OF THE DEVELOPMENT PROCESS FOR PART I OF THE INVENTORY FOR EXISTING SHIPS
This Appendix elaborates the various steps pictured in the diagram for Appendix 4, see Annex 18, p 29. This requires the knowledge and experience of specialist personnel (ie experts), see Paragraph 1.1.
Step [1] commences with the sighting of available document, see Paragraph 2.1. This results in the formulation of an indicative list as it is impossible to check all equipment, systems and/or areas on board the ship to determine the presence or absence of hazardous materials. This list consists of materials presumed to contain hazardous materials, see Paragraph 2.2.1. Step [1] continues with checking and documenting materials as identified in Appendix 1 of these Guidelines. These are divided in Materials listed in TABLE A (eg asbestos and PCBs), as well as Materials listed in TABLE B (eg Cadmium and Mercury).
When Step [2] starts, this results in the preparation of a checklist of all materials presumed to contain hazardous materials. The existence of such materials may also be judged and calculated from Spare parts and tools lists, as well as maker’s drawings. Reference could also be made to Fire Protection Planck and the International Anti-Fouling System Certificate, see Paragraph 3.
When the visual / sampling check plan is prepared for Step [3], each item can be classified as follows (see Paragraph 4):
[1] ‘Contained’ or ‘Not Contained’, see Paragraph 4.1;
[2] Entry of ‘V’ in the Check Procedure Column to denote a visual check, see Paragraph 4.1;
[3] ‘Unknown’ is used for ‘potentially containing hazardous materials’. This may require a sampling check which requires disassembly of the the unit / machinery, see Paragraph 4.2.
Onboard visual / sampling check for Step [4] in accordance with the plan and documented with photographs, see Paragraph 5.1. The person collecting the samples should be using protective clothing as hazardous materials may be encountered, see Paragraph 5.2. The following safety precautions for personnel include (see Paragraph 5.2):
[1] Posting signs;
[2] Verbal notification;
[3] Written notification.
Development of PART I of the Inventory is the start of Step [5], check and estimating the quantity of hazardous materials are recorded on the checklist, see Paragraph 6.1. This is followed up with a development of the location diagram for such materials, see Paragraph 6.2.
APPENDIX 6 - FORM OF MATERIAL DECLARATION
A sample of this form can be found at Annex 18, p 46.
APPENDIX 7 - FORM OF SUPPLIER’S DECLARATION
A sample of this form can be found at Annex 18, p 48.
APPENDIX 8 - EXAMPLES OF TABLE A AND TABLE B MATERIALS WITH CAS NUMBERS
Both tables were developed with the aid of Joint Industry Guide No.101. Appendix 8 makes it very clear that the list is not exhaustive. It represents chemical with known CAS numbers. Obviously, this requires updating from time to time, see Annex 18, p 49.
An example of a TABLE A material listed in Appendix 1 of the HK Convention is Asbestos. This has a CAS number of 1332-21-4 and is the first material listed in the table. The last TABLE A material in Cybutryne (ie used in anti-fouling systems). This material has a CAS number of 28159-98-0.
TABLE B (for materials listed in Appendix 2 of the HK Convention) starts with cadmium, which has a CAS number of 7440-43-9. The table ends with ‘Other short-chain chlorinated paraffins’ (with a carbon length of 10-13 atoms). This material does not have a CAS number.
APPENDIX 9 - SPECIFIC TEST METHODS
This appendix is found at Annex 18, p 54. It starts with Asbestos and the various types that could be tested for. Eg Actinolite (CAS No 77538-66-4) and Tremolite (CAS No 77536-68-6).
Specific testing testing techniques, for example, for Asbestos include (see Paragraph 1):
[1] Polarised light microscopy;
[2] electron microscope techniques;
[3] X-Ray Diffraction (XRD).
Note, whichever is applicable for the material as each technique has its limitation. The test could result in ‘no asbestos detected’ to ‘asbestos content greater than 40 percent by mass’.
APPENDIX 10 - EXAMPLE OF RADIOACTIVE SOURCES
At Annex 18, p 57, there is a list of example of radioactive sources that should be included in the Inventory. The inclusion is regardless of the number, the amount of radioactivity or the type of radionuclide.
Consumer products with radioactive materials include ‘ionization chambers make detectors’ (with typical radionuclides 241Am and 226Ra). An example of an industrial gauge with radioactive materials include radioactive spinning pipe gauges (ie typically with 241Am to 169Yb).
ANNEX 19 - DRAFT AMENDMENTS TO ARTICLE V OF PROTOCOL I OF MARPOL
PROTOCOL I deals with ‘Provisions Concerning Reports On Incidents Involving Harmful Substances’, see Annex 19, p 1. For Article V on ‘Reporting Procedures’ a new Paragraph 3 is inserted (after the existing Paragraph 2):
In case of loss of freight container(s), the report required by Article II(1)(b) shall be made in accordance with the provisions of Regulations V/31 and V/32.
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Signing-off for today,
Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT
Professor of Maritime and Transport Law
Head of the Centre for Advocacy and Dispute Resolution
Faculty of Law
Universiti Teknologi MARA Shah Alam
Selangor, Malaysia
Tuesday, 15 April 2025
Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my