Services for Shipowners and Offshore Companies

IMO has developed the “International Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships” (HKC), adopted in May 2009, and the “EU Ship Recycling Regulation[1] (EU-SRR)” of European Parliament has entered into force end of 2013. Both require documentation of hazardous materials on board new and existing ships and platforms[2] (Inventory of Hazardous Materials - IHM) as well as recycling of ships in approved Ship Recycling Facilities (SRF).

The staff of GSR Services are „Approved IHM-Experts“ by DNVGL and ClassNK. Additionally GSR Services has commited itself to high standards due to it´s leading membership to IHMA e.V. This ensures that due to the status of IHMs as a „Technical File“ no negative effects for the owner can appear due to IHMs lacking quality.

HKC has not entered into force yet but EU-SRR enforces it throughout the EU. That results in various deadlines for EU-flagged and EU-visiting vessels above 500GT between 2015 and 2018. Many different deadlines apply and the following table provides a chronological overview:

Entry into Force of EU-SRR:


Application of EU-SRR:

Earliest 30.12.2015, latest 30.12.2018

Authorization of SRFs:

end of 2016

IHMs for ships:


  • New ships[3]:

From 30.12.2015 (date of contract)

  • Ships for recycling:

when “EU-Liste” is available, latest end of 2016

  • Existing ships:

Until 30.12.2020, or within 6 months after change to EU-flag

Table 1: Deadlines of EU-SRR


The “Inventory of Hazardous Materials – Part I” (IHM) lists quantities and locations of materials onboard, which may be harmful to people or the environment. These materials need special attention during recycling of ships. This information could also be utilized for health & safety and environmental aspects during ship building, operations, maintenance, and repairs. IHM consists of three parts and only “Part I” applies to shipbuilding and the operational phase. The two other parts are to be prepared prior to recycling. Also different tables of hazardous materials apply; the following table provides an overview:


Table 2: Overview of IHM parts

IHMs for existing ships

Not only ships flying the flag of EU-member states but also approximately 30.000 ships above 500GT visiting EU-ports have to have a certified IHM onboard by end of 2020. IHMs for existing vessels have to cover 4 different types hazardous materials (EU = 5) and can be prepared in a practical manner; by inspections and taking of samples. Quality of IHMs is important as they are the basis for planning of HSE aspects during ship recycling and are technical files describing presence or absence of asbestos, PCBs, ozone depleting substances and TBT (plus PFOS for EU-ships). In case the IHM is inaccurate legal actions from the buyer against the vendor are risked.

A proper balance between costs and quality of IHMs is a challenge and is considered by the “International Hazardous Materials Association” (, an international network of IHM-Professionals providing cost-effective preparation of quality-IHMs.

Time pressure

The number of ships which are affected creates a challenge, especially when IHM demand will not increase gradually towards the deadline. Only an insignificant number of IHMs has been prepared so far. The scenarios of progressive and gradual development of IHM-demand until end of 2020 show supply gaps, pricing will reflect this.


Figure 1: IHM supply and demand scenarios

The huge number of required IHMs is topped up with the risks of identification of asbestos onboard ships. According to SOLAS and MSC Circ. 1374 asbestos has to be removed when it has been installed illegally onboard ships after summer 2002.

What to do:


Figure 2: Actions to be taken by shipowners

Todays controls

Already asbestos inspections in the ports of the Netherlands and Australia are conducted. In case illegal asbestos is found the ship might be declared as “non-inspectable”. This means the ship will either be detained in the port until a solution is found or it’ll be banned from territorial waters. In this case, the ship is not “fit for purpose” and it is in danger of losing the charter contract. Often, young ships (<10 years) are inspected by PSC.

The way out

Are your asset values correct or has your ship to cope with unplanned costs due to asbestos onboard and risks of detentions? Is your crew safe? Get to know the details by getting an IHM prepared and become legally compliant comfortably well ahead the applying deadlines.

Also getting your ships and structures recycled in a green way is your responsibility. If you fail to do so you might face bad press, extensive costs or other problems. This happened to the owners of Clemenceau, Otapan, Blue Lady (ex Norway), or Brent Spar as like many others. Without an IHM neither an adequate facility can be selected nor support provided for enabling the ship recycler for planning the safe and environmentally sound recycling.

Effective preparation and maintenance of IHM can be done or arranged by us.

Communication throughout supply chains for compilation and maintenance of relevant documentation (SDoC, MD, IHM) is perfectly supported by use of CDX Services of our Partner HP.

Moreover, we offer support on how to deal with hazardous materials identified on board, health and safety measures (SOPs), and arrange decontamination, in case it’s needed. Also we offer preparation for and monitoring of “green recycling” of your vessel.

Please let us know about your demand, from general information to specific measures onboard, or recycling preparations for your ship or structure, we have detailed knowledge to guide you through these challenging times.


[1] REGULATION (EU) No 1257/2013 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC

[2] "ship" means a vessel of any type whatsoever operating or having operated in the marine environment, and includes submersibles, floating craft, floating platforms, self-elevating platforms, floating storage units (FSUs), and floating production storage and offloading units (FPSOs), as well as a vessel stripped of equipment or being towed

[3] ‘new ship’ when on or after date of application of regulation:

(a) building contract is placed; or

(b) keel is laid six months later; or

(c) delivery thirty months later.