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Navigating the waves of ship recycling regulations

Masters and crew, you should see the wave that’s rolling to you!

The maritime industry is on the brink of significant regulatory changes. With the imminent entry into force of the Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships (SR/CONF/45), understanding the complexities of these regulations is crucial to ensure compliance.​

The Hong Kong Convention, along with the EU Regulation on Ship Recycling (SRR), aims to ensure the safe and environmentally sound dismantling and recycling of ships. However, complying with these regulations can be a monumental task, considering the multitude of requirements and technical specifications involved.​

Ship storm

Hazardous materials on board​

One of the key challenges lies in keeping track of the hazardous materials present on board. It is essential to have an up to date inventory of ship-specific information on these materials to ensure compliance. The following example is just one of many new scenarios you need to be aware of:


Scenario: A ship owner assumes there are no hazardous substances on board

Therefore, the Inventory of Hazardous Materials (IHM) is empty.​ A Port State Controller (PSC) will come on board and ask the crew to show the current IHM. It is empty – the PSC gets suspicious.​

The PSC inspects the refrigeration room, noticing it has been upgraded. This brings up a question about the material declaration for the insulation.

Ship - refrigerator room

The crew presents a material declaration for the insulation from 2019, which does not contain any hazardous substances that need to be declared. The PSC asks for proof of the refrigeration room's upgrade.​

The crew can prove the 2020 upgrade with a certain insulation. Following this statement, the PSC asks for the Supplier's Declaration of Conformity (SDoC) for this material declaration.

If there is no valid 2019 SDoC for this material declaration, the burden of proof for the absence of hazardous substances remains with the ship owner. ​

It must be demonstrated through a costly, external sampling in the refrigeration room.


Don’t let this happen to you

ShipManager by DNV ensures compliance and simplifies the task for the ship’s crew. ​

The software provides a centralized platform to manage and update the inventory of hazardous materials. ​

Due to the material declaration in the procurement module, ShipManager creates an overview of any hazardous substances in your storage. Using the maintenance module, you can easily track the installation and precise location of hazardous materials on the vessel. ​

Trust in ShipManager and you will stay on top of the waves easily. ​

Get to know the trusted solution in ​a personal meeting.

Ship - surveyor entering vessel


Authors: Wiegand Grafe, Ashirvad Srivastava, Stefan Froebe

8/21/2023 4:55:19 PM

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Sebastian Eggert

Sebastian Eggert

Global Head of Sales - Ship product line

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