Section 1 Hazards to be recorded in the IHM

1.1 IHM Part I hazards and their thresholds

1.1.1 The following two Sections detail the hazards that are to be recorded in the IHM and their applicable threshold values.

Note the hazards listed in the HKC are shown in Appendix I and II to the convention text. In Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials, these hazards are listed in Table 3.1.1 Table A (HKC) / Annex I (EU SRR) hazards to be recorded in IHM Part I and Table 3.1.2 Table B (HKC) / Annex II (EU SRR) hazards to be recorded in IHM Part I if possible, including additional information on threshold values. For both clarity and consistency, throughout the remainder of this document, only Table 3.1.1 Table A (HKC) / Annex I (EU SRR) hazards to be recorded in IHM Part I and Table 3.1.2 Table B (HKC) / Annex II (EU SRR) hazards to be recorded in IHM Part I if possible will be referred to when referencing HKC hazards.

1.1.2 Table A (HKC) / Annex I (EU SRR)

The Table 3.1.1 Table A (HKC) / Annex I (EU SRR) hazards to be recorded in IHM Part I hazards should not be installed on new ships if they are above the defined threshold levels. On existing ships these hazards should be recorded if they are found to be present; see Table 3.1.1 Table A (HKC) / Annex I (EU SRR) hazards to be recorded in IHM Part I, which is adapted from the IMO HKC, Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials and EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials.

Table 3.1.1 Table A (HKC) / Annex I (EU SRR) hazards to be recorded in IHM Part I

HKC / EU SRR hazards		Threshold
Asbestos		0.1 % see Note 1
Polychlorinated biphenyls (PCBs)		50 mg/kg see Note 2
Ozone-depleting substances (ODS)	CFCs	No threshold value see Note 3
	Halons
	Other fully halogenated CFCs
	Carbon tetrachloride
	1,1,1-Trichloroethane (Methyl chloroform)
	Hydrochlorofluorocarbons (HCFCs)
	Hydrobromofluorocarbons
	Methyl bromide
	Bromochloromethane
Anti-fouling systems containing organotin compounds as a biocide		2,500 mg total tin/kg see Note 4
Perfluorooctane sulfonic acid (PFOS) see Note 5		10 mg/kg (0.001 % by weight) see Note 6

Note 1: In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain asbestos shall be prohibited. According to the UN recommendation ‘Globally Harmonized System of Classification and Labelling of Chemicals (GHS)’ adopted by the United Nations Economic and Social Council's Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS), the UN's Sub- Committee of Experts, in 2002 (published in 2003), carcinogenic mixtures classified as Category 1A (including asbestos mixtures) under the GHS are required to be labelled as carcinogenic if the ratio is more than 0.1%. However, if 1% is applied, this threshold value should be recorded in the Inventory and, if available, the Material Declaration and can be applied not later than five years after the entry into force of the Convention. The threshold value of 0.1% need not be retroactively applied to those Inventories and Material Declarations.

Note 2: In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain PCBs shall be prohibited. The Organisation [IMO] set 50 mg/kg as the threshold value referring to the concentration level at which wastes, substances and articles containing, consisting of or contaminated with PCB are characterised as hazardous under the Basel Convention.

Note 3: ‘No threshold value’ is in accordance with the Montreal Protocol for reporting ODS. Unintentional trace contaminants should not be listed in the Material Declarations and in the Inventory. According to the HKC new installations containing hydrochlorofluorocarbons (HCFCs) are permitted until 1 January 2020. However, this provision has not been incorporated in the SRR.

Note 4: This threshold value is based on the guidelines for brief sampling of anti-fouling systems on ships (Resolution MEPC.104(49) - Guidelines for Brief Sampling of Anti-Fouling Systems on Ships - (Adopted on 18 July 2003)).

Note 5: Applicable to Regulation (EU) no 1257/2013 only.

Note 6: Concentrations of PFOS above 10 mg/kg (0.001% by weight) when it occurs in substances or in preparations or concentrations of PFOS in semi-finished products or articles, or parts thereof equal to or above than 0.1% by weight calculated with reference to the mass of structurally or micro-structurally distinct parts that contain PFOS or for textiles or other coated materials, if the amount of PFOS is equal to or above than 1 μg/m² of the coated material (EMSA Best Practice Guidance).

1.1.3 The EU SRR requirements for HCFCs differ from HKC requirements. In the HKC there is provision to allow HCFCs in new installations until 1 January 2020. This provision is not incorporated into the EU SRR. Therefore:

To comply with both HKC and EU SRR where HCFCs have already been installed on existing ships information should be recorded in the IHM (if present over the stated threshold value).
To comply with EU SRR (and go beyond HKC requirements) newbuild ships and existing ships cannot newly install HCFCs on board from the date of application of the EU SRR.

1.1.4 As such best practice advice is to restrict HCFCs at build now and prohibit new installations of HCFC on board, by making provisions in procurement policies.

1.1.5 PFOS is not applicable to non-EU flagged ships. Therefore, for an existing ship, calling at an EU port or anchorage, it will not be expected that the IHM includes PFOS. However, it will be expected that you prohibit PFOS from being brought on board the ship whilst at an EU port or anchorage. Best practice advice for non-EU flagged shipowners is to include the restriction of PFOS in a company procurement policy.

1.1.6 Table B (HKC) / Annex II (EU SRR)

These Table 3.1.2 Table B (HKC) / Annex II (EU SRR) hazards to be recorded in IHM Part I if possible hazards should be recorded in the IHM if they are present in concentrations above the stated threshold value; see Table 3.1.2 Table B (HKC) / Annex II (EU SRR) hazards to be recorded in IHM Part I if possible, which is adapted from IMO HKC, Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials and EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials. At build, this information should be recorded. However, for existing ships this should be done as far as is practicable.

Table 3.1.2 Table B (HKC) / Annex II (EU SRR) hazards to be recorded in IHM Part I if possible

HKC/EU SRR hazards	Threshold
Cadmium and cadmium compounds	100 mg/kg see Note 7
Hexavalent chromium and hexavalent chromium compounds	1000 mg/kg seeNote 7
Lead and lead compounds	1000 mg/kg see Note 7
Mercury and mercury compounds	1000 mg/kg see Note 7
Polybrominated biphenyls (PBBs)	50 mg/kg see Note 8
Polybrominated diphenyl ethers (PBDEs)	1000 mg/kg see Note 7
Polychlorinated naphthalenes (PCNs, more than 3 chlorine atoms)	50 mg/kg see Note 9
Radioactive substances	No threshold level see Note 10
Certain short-chain chlorinated paraffins (alkanes, C10–C13, chloro)	1% see Note 11
Brominated flame retardant (HBCDD) see Note 12	100 mg/kg (0.01% by weight)

Note 7: The Organisation [IMO] set this as the threshold value referring to the Restriction of Hazardous Substances (RoHS Directive 2011/65/EU, Annex II).

Note 8: The Organisation [IMO] set 50 mg/kg as the threshold value referring to the concentration level at which wastes, substances and articles containing, consisting of or contaminated with PBB are characterised as hazardous under the Basel Convention

Note 9: The Organisation [IMO] set 50 mg/kg as the threshold value referring to the concentration level at which wastes, substances and articles containing, consisting of or contaminated with PCN are characterised as hazardous under the Basel Convention.

Note 10: All radioactive sources should be included in the Material Declaration and in the Inventory. Radioactive source means radioactive material permanently sealed in a capsule or closely bonded and in a solid form that is used as a source of radiation. This includes consumer products and industrial gauges with radioactive materials. Examples are listed in Appendix 10 [of Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials; see Table 4.2.1 ‘Indicative list’ of Table B (HKC) hazards].

Note 11: The Organisation [IMO] set 1% as the threshold value referring to the EU legislation that restricts chlorinated paraffins from being placed on the market for use as substances or as constituents of other substances or preparations in concentrations higher than 1% (EU Regulation 1907/2006, Annex XVII Entry 42 and Regulation 519/2012).

Note 12: Applicable to Regulation (EU) no 1257/2013 only.

1.2 Applicability of IHM Part I hazards to ship life stage and flag

1.2.1 Table 3.1.3 Applicability of Table A/B (HKC) and Annex I/II (EU SRR) hazards to be recorded in IHM Part I shows the requirements for recording various hazards in the IHM at both new construction and as an existing ship. The hazards are previously listed in Table 3.1.1 Table A (HKC) / Annex I (EU SRR) hazards to be recorded in IHM Part I and Table 3.1.2 Table B (HKC) / Annex II (EU SRR) hazards to be recorded in IHM Part I if possible

Table 3.1.3 Applicability of Table A/B (HKC) and Annex I/II (EU SRR) hazards to be recorded in IHM Part I

HKC/EU SRR hazards	Applicability at build	Applicability for existing ships
Table A (HKC) / Annex I (EU SRR)	Shall not be installed on a ship, if present in concentrations above the specified threshold value.	Required to be listed (if present above the specified threshold)
Table B (HKC) / Annex II (EU SRR)	List in IHM if present in concentrations above the specified threshold value.	To be listed as far as practicable. (It is not obligatory for materials listed in Table B to be listed in Part I of the IHM. However, if they can be identified in a practical way, they should be listed in the Inventory if above the specified threshold)

The aforementioned caveats of PFOS and HCFCs should be noted when considering the general applicability of these hazards at build and for existing ships. See Ch 3, 1.1 IHM Part I hazards and their thresholds.