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March 17, 2020
5 things to know about Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, 2009
The International Maritime Organization's Marine Environment Protection Committee (MEPC) developed the Convention with the participation of the Secretariats of the Basel Convention and the International Labour Organization from 2006 to 2009. The diplomatic conference that adopted the Convention took place in Hong Kong, and thus, it's commonly known as the "Hong Kong Convention" (HKC). In this article, I am answering the top 5 frequently asked questions on the Hong Kong Convention. 
1) Why was the Hong Kong International Convention required for end-of-life ships?
The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal,1989 considers end-of-life ships as Wastes. The Basel Convention was successful in controlling illegal transport of hazardous wastes from many industrial sectors to countries with minimum or no capacity for waste disposal in an environmentally sound manner. However, when it comes to the ship recycling sector, it was not suitable for end-of-life ships. It does not define a minimum standard for ship recycling other than prior-informed consent to export and import, nor does it make any provisions for workers' safety issues. Basel Convention is not cognizant of the concept of flag State for ship recycling sector, and the State from which the ship departs for its last voyage is regarded as exporting State, both of which create a problem of enforcement.  Therefore, a standalone international regulation on ship recycling was required, which can address ship recycling issues in a safe and environmentally sound manner. 
2) To whom does HKC will apply? 
The Convention, after its entry into force, will apply to all ships, except ships below 500 GT, government-owned non-commercial service ships, and ships operated throughout their life exclusively in waters of the State whose flag the ship is flying.
3) What HKC include?
1. the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling, without compromising the safety and operational efficiency of ships;
2. the operation of ship recycling facilities in a safe and environmentally sound manner; and
3. the establishment of an appropriate enforcement mechanism for ship recycling (certification/reporting requirements).
The central part of the Convention contains 21 Articles and 25 regulations. The Convention has
seven appendices, with lists of hazardous materials, standard formats for certificates, etc. It has six guidelines that were developed by IMO's MEPC, namely:
• Resolution MEPC.196(62) - 2011 Guidelines for the Development of the Ship Recycling Plan
• Resolution MEPC.210(63) - 2012 Guidelines for Safe and Environmentally Sound Ship Recycling
• Resolution MEPC.211(63) - 2012 Guidelines for the Authorization of Ship Recycling Facilities
• Resolution MEPC.222(64) - 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention
• Resolution MEPC.223(64) - 2012 Guidelines for the inspection of ships under the Hong Kong Convention
• Resolution MEPC.269(68) - 2015 Guidelines for the development of the Inventory of the Hazardous Materials
4)  When will HKC come into force?
HKC will come into force 24 months after the date on which it meets the following three conditions: 
1. not less than 15 States have either acceded to it or have ratified it;
2. the combined merchant fleets of the States that have acceded to it or have ratified it represent not less than 40 percent of world merchant shipping by gross tonnage;
3. the combined maximum annual ship recycling volume of the States that have acceded to it or have ratified it must constitute not less than three percent (3%) of their combined merchant shipping tonnage.
5) Which all conditions of HKC are fulfilled to date? And how many ship recycling yards in South Asia voluntarily complied with the same?  
1. As of 20 January 2020, 15 countries have acceded/ratified the HKC. Namely, Norway, Congo, France, Belgium, Panama, Denmark, Turkey, Netherland, Serbia, Japan, Estonia, Malta, Germany, Ghana, and India;
2. 30.1% is the combined merchant fleets of the above 15 States that have acceded/ratified to HKC. 9.9% less than the mandatory 40 percent of world merchant shipping by gross tonnage to meet the second condition (estimation is as per 2018 fleet data which is subjected to change once 2019 fleet data is available);
3. 2.6% is the combined maximum annual ship recycling volume of the States that have acceded which is still 0.4% less than the required three percent (3%) of their combined merchant shipping tonnage to mee the third condition (estimation is as per 2018 recycling data which is subjected to change once 2019 recycling data is available);
This means, though the first condition is met, we still need to fulfill the second and third conditions for HKC to enter into force. 
To fully satisfy the 2nd condition is quite straightforward, as ratification by either Liberia or Marshall Islands is enough to meet the 40 percent requirement. Whereas both these open registers appear keen to see the Convention enter into force, they, as well as other registers, have been reluctant to ratify, in case too much tonnage is accumulated, making it difficult, or even impossible, for the third condition to be met. This is because the third condition on recycling capacity is expressed in terms of a percentage of the second condition on the tonnage in operation.
An additional recycling capacity of 2.1 million GT is presently needed to satisfy the third condition. This can only be provided by Bangladesh (present capacity 9.9 million GT), or Pakistan (5.7 million GT), or by China (8.2 million GT). The rest of the world (excepting Turkey and India who have already ratified) can only contribute 0.6 million GT altogether.  
For a few more years, China will be able to contribute significant "notional" ship recycling capacity arising from the tonnages it recycled before banning the import of end-of-life ships. This legacy capacity will stand at 8.2 million GT until May 2023 (which was the volume recycled in 2012) and will then progressively decline until a decade has passed from the time China banned the import of ships for recycling. Therefore, noting that the fleets of China and Hong Kong together currently represent 13.4% of the world's fleet, it follows that if China with Hong Kong were to ratify the Convention today, then the three conditions will have been met today and the Convention would enter into force in just 24 months. 
However, considering above all conditions into consideration, we can expect HKC to come into force before 2025.
Seventy-seven ship recycling yards received over 105 Statement of Compliance (SOC) from IACS, mainly ClassNK, RINA, IRClass, and Lloyd's Register in India.  Whereas, In Bangladesh, one recycling yard (PHP) achieved SOC with HKC from ClassNK. 
About the Author
Dr. Anand Hiremath is the Head of Research and Development Division of GMS. A Civil Engineer and a Master's degree holder in Environmental Engineering from the Indian Institute of Technology Guwahati (IIT-G). He has been awarded Doctorate Degree for his research work on Ship Recycling by the Indian Institute of Technology Bombay (IIT-B). Also, he is a qualified OHSAS 18001:2007 Lead Auditor from Bureau Veritas and an "Approved HazMat Expert" from DNV GL.
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March 5, 2020


Introduction of IHM Gap Analysis Service by GMS RSRP

GMS’s Responsible Ship Recycling Program (GMS RSRP) has introduced a new service of fulfilling gaps in the Inventory of Hazardous Material (IHM) reports submitted by Ship Owners for their end-of-life vessels at the time of recycling.


Why IHM Gap Analysis?

An IHM is the soul of safe and environmentally friendly ship recycling. Unfortunately, a majority of IHM reports being prepared are done when a vessel is in operation and hazardous materials experts are not always permitted access to samples of insulation on running machinery, control panels, and equipment, as well as in many operational / occupied / confined spaces on-board. Therefore, inaccessible locations get reported as the location with “Potentially Containing Hazardous Materials (PCHM)” in the IHM. PCHM locations do not confirm the existence or even the type(s) and quantity of wastes on-board, which eventually creates a gap in the IHM report.

Under GMS RSRP, we have recycled over 100 ships so far and have seen this potentially hazardous gap in various IHM reports generated by third parties. More dangerously, we have noticed that a few IHM reports do not even cover sampling of areas that were accessible to the hazmat experts. An argument on the number of samples for generating the IHM report certainly exists and few experts claim that the volume of sampling does not define the accuracy of the IHM report, but the experience of hazmat expert that matters the most. However, we have realized that the end-users of the IHM report come to realize the gaps in the IHM only after the vessel is delivered to their yard.


What will GMS’s IHM Gap Analysis Cover?

The objective of GMS IHM gap analysis report is to analyze and address the gaps in an IHM Report submitted by ship owners when committing their ships for recycling. The IHM Gap Analysis includes

  1. - Visual/sampling checks of PCHM locations identified in the IHM report submitted by Shipowners.
  2. - Sampling of locations and components which were not covered in the IHM report
  3. - Re-sampling of locations which were already covered in the IHM report, in order to ensure correctness of results in the IHM.
  4. - Re-sampling of locations already covered in the IHM report in order to test for identification of hazardous wastes other than those already tested.

This four-prong approach will ensure all potential gaps are accurately addressed.


Advantages of GMS’s IHM Gap Analysis?

  • - Cost effective (fraction of cost)
  • - Comprehensive (see below)
  • - Simple and Seamless (no need to pay extra. Cost of IHM can be deducted from the purchase price)

IHM Gap Analysis will ensure that any IHM report provided by ship owners covers all types of wastes and its respective quantities, with no PCHM locations on-board as per MEPC 269 (68). Gap Analysis through our four-prong approach will strive to confirm that the results generated in the IHM submitted by ship owners are accurate - which further ensures that workers are not exposed to unidentified hazardous wastes during the recycling of end-of-life ships. GMS’s IHM Gap Analysis further endorses the effective management of hazardous wastes and tracking of wastes on-board.

GMS is proud to introduce this first-of-a-kind service to Ship Owners and Owners of Recycling Yards to ensure the effective implementation of Safe and Environmentally Sound Recycling of Ships.




For more details regarding IHM Gap Analysis, please contact:




Founded in 1992 in the USA, GMS is the world’s largest Buyer of ships and offshore units for recycling. GMS has successfully negotiated several thousand assets since its inception—more than any other company in the world! For more than a decade GMS has led the industry by sheer volume of transactions and innovative products. The firm's mission is to simplify the disposal and recycling processes in the maritime world by providing end-to-end solutions, sustaining an asset’s residual value while simultaneously improving international health, safety and environmental standards. With nine international offices, an award-winning Responsible Ship Recycling Program, and a team of specialized experts, GMS continues to influence positive change in the global maritime and offshore industry.

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