ass

CHARTING THE FUTURE®'

Guidelines for the Inventory of Hazardous Materials

Ver. 5.00
[English]
Guidelines for the Inventory of Hazardous Materials

Introduction

In recent years, much of the work related to the scrapping and recycling ships has been conducted
in developing countries. However, this work is often unsupervised and unregulated so in many
instances hazardous materials such as asbestos, polychlorinated biphenyls (PCBs), fuel oils, etc., are
not properly disposed of and left to remain in the scrapped ships. This type of work is often
performed without proper dismantling equipment and systems in place, so the water and soil in
surrounding coastal areas becomes polluted, thus causing serious environmental problems. In
addition to the environmental impact, there are also serious concerns being raised globally
regarding about the adverse effects such working conditions have upon the health and safety of the
laborers involved in such projects. In light of the current situation, the International Maritime
Organization (IMO) adopted the “Hong Kong International Convention for the Safe and
Environmentally Sound Recycling of Ships, 2009 (generally known as the Ship Recycling
Convention (SRC))” in May 2009 to help try and solve these problems.

This SRC will require that all ships of 500 gross tons and above engaged in international voyages
maintain an inventory of the approximate quantity and location of all of the hazardous materials
onboard a ship. Therefore, in order to ensure full compliance with the SRC once it takes effect,
concerned industries have been taking steps to prepare such inventories beforehand for those ships
subject to the provisions of the Convention as an “existing ship”.

In order to assist in the smooth implementation of these industry initiatives, ClassNK has been
issuing a document called the “Statement of Fact” since June 2010 to those ships having an
inventory subject to the terms of Regulation 5 of Annex to the SRC and its ”Guidelines for the
development of the inventory of hazardous materials”. Moreover and relevant ClassNK Rules have
been revised to allow for the affixation of the notation “Inventory of Hazardous Materials”
(abbreviated IHM) to the classification characters of those ships complying with the SRC.

In this circumstance, the EU Regulation on Ship Recycling entered into force on December 30,
2013. According to the Regulation, inventory of hazardous materials (IHMs) is required to keep
onboard both EU flagged ships and non-EU flagged ships. Non-EU flagged ships calling at a port or
anchorage of a Member State shall have on board an IHM, until 31 December 2020, as well as a
statement of compliance (SOC) issued by the relevant authorities of the third country whose flag the
ship is flying or an recognized organization (RO) in accordance with the national requirements.
Further, Resolution MEPC.269(68) “2015 Guidelines for the Development of Inventory of
Hazardous Materials” was adopted at IMO MEPC68 in May 2015.
In order to address this 2015 Guidelines, in October 2015, this ClassNK guidelines was revised
taking the resolution into account, such as the form of SOC, maintenance of IHM by ship owner.

Under these circumstances, the application of European regulations to EU flag ships began
(December 31, 2018), and Japan ratified the Hong Kong Convention and started issuing equivalent
certificates for Japanese vessels (2019 April 1st). Therefore, necessary revisions were made to these
guidelines.

In July 2023, Resolution MEPC.379(80) “2023 Guidelines for the Development of Inventory of
Hazardous Materials” was adopted at IMO MEPC80. In order to address the 2023 Guidelines, this ClassNK
guidelines was updated in October 2023.
 Guidelines for the Inventory of Hazardous Materials

The authors will be happy if these Guidelines help contribute to early initiatives taken by
concerned industries in complying with the SRC and the EU Regulation.
Guidelines for the Inventory of Hazardous Materials

Correction/Revision Record

Version Date Part Details

Ver.1.00 June 2011 － －
Ver.2.00 October 2011 3.1.1 Review of contents
[refer to IMO Resolution MEPC.197(62)]
3.3.4-2 Review of contents
[refer to IMO Resolution MEPC.197(62)]
3.3.7 Stipulation for testing method of samples
[refer to IMO Resolution MEPC.197(62)]
Appendix 1 Review of the application form
Appendix 2-1 Review of the sample of Statement of Fact
Appendix 9 Stipulation for the specific testing method of
samples
[refer to IMO Resolution MEPC.197(62)]
Ver.3.00 August 2015 1.2, 1.3 Revision to issue Statement of Compliance
1.4 Review for Terminology[refer to IMO
Resolution MEPC.269(68)]
2.1.2, 2.3.2, 2.4 Revision to issue Statement of Compliance
3.1 Review of threshold value, exemptions for
materials to be listed in the Inventory [refer
to IMO Resolution MEPC.269(68)]
Appendix 1 Review of the application form
Appendix2-1, Appendix 2-2 Review of the sample of Statement of
Compliance

Appendix 3, Appendix 4 Review of sample disruption in Satndard

Format of the Inventory [refer to IMO
Resolution MEPC.269(68)]
Appendix 5 Review of “Indicative List” of materials
listed in Table B [refer to IMO Resolution
MEPC.269(68)]
Appendix 6 Review of Form of Material Declaration
regarding the revised threshold values [refer
to IMO Resolution MEPC.269(68)]
Others Editorial review [refer to IMO Resolution
MEPC.269(68)]

Ver.4.00 Revised on 1.1 Notation to Classification Characters for

September 2019 1.2 ships flying flag of the states which apply
Applied on 11 1.3 their national regulation for IHM
October 2019
1.4 Additional investigation for PFOS and
3.1 HBCDD which are required by EU
Appendix 4, 5, 7, 8 Regulation
Chapter 2 Amendment of the survey system for the
Inventory (ex. Renewal Survey,
Additional Survey)
2.2.4 Amendment of standard format of SOC
2.3.4
2.4.4
Appendix 1
Appendix 2
 Guidelines for the Inventory of Hazardous Materials

Ver.5.00 Revised in Added Cybutryne

October 2023 [refer to IMO Resolution MEPC.379(80)]
Guidelines for the Inventory of Hazardous Materials

Guidelines for the Inventory of Hazardous Materials

Contents
Chapter 1 General .............................................................................................................................................. 1
1.1 Objectives .................................................................................................................................................. 1
1.2 Application ................................................................................................................................................. 1
1.3 Notation...................................................................................................................................................... 2
1.4 Terminology .............................................................................................................................................. 2

Chapter 2 Surveys and Issue of Statement of Compliance for the Inventory .................................................... 6
2.1 General ...................................................................................................................................................... 6
2.1.1 Kinds of surveys ................................................................................................................................... 6
2.1.2 Timing and Implementation of surveys ................................................................................................ 6
2.1.3 Renewal Survey carried out in advance and Postponement ................................................................. 7
2.1.4 Preparations for survey and other related issues................................................................................... 7
2.2 Initial survey .............................................................................................................................................. 8
2.2.1 General ................................................................................................................................................. 8
2.2.2 Submission of documents ..................................................................................................................... 8
2.2.3 Survey items ......................................................................................................................................... 9
2.2.4 Issuance of the statement or certificate, and Class Notation ................................................................ 9
2.3 Renewal Survey ....................................................................................................................................... 9
2.3.1 General ................................................................................................................................................. 9
2.3.2 Submission of documents ................................................................................................................... 10
2.3.3 Survey items ....................................................................................................................................... 10
2.3.4 Issue of statement or certificate, and Class Notation .......................................................................... 10
2.4 Additional Survey ................................................................................................................................... 10
2.4.1 General ............................................................................................................................................... 10
2.4.2 Submission of documents ................................................................................................................... 11
2.4.3 Survey items ....................................................................................................................................... 11
2.4.4 Endorsement or re-issue of statement or certificate ........................................................................... 11
2.5 Occasional Survey ................................................................................................................................. 11
2.5.1 General ............................................................................................................................................... 11
2.5.2 Submission of documents ................................................................................................................... 12
2.5.3 Survey items ....................................................................................................................................... 12
2.5.4 Endorsement or re-issue of statement or certificate ........................................................................... 12
2.6 Duration and validity of statements or certificates ............................................................................ 13
2.6.1 General ............................................................................................................................................... 13
2.6.2 Issuance of certificates after transfer of flag state .............................................................................. 13

Chapter 3 Inventory ......................................................................................................................................... 14

3.1 General .................................................................................................................................................... 14
3.1.1 Materials to be listed in the Inventory ................................................................................................ 14
3.1.2 Revision to threshold values ............................................................................................................... 14
3.1.3 Standard format of the Inventory of Hazardous Materials ................................................................. 16
3.1.4 Exemptions - Materials not required to be listed in the Inventory ..................................................... 16
3.1.5 Description of location of Hazardous Materials on board .................................................................. 16
3.1.6 Description of approximate quantity of Hazardous Materials ............................................................ 16
3.2 Development of the Inventory .............................................................................................................. 17
3.2.1 General ............................................................................................................................................... 17
3.2.2 Development of the Inventory ............................................................................................................ 17
3.2.3 Alternative Inventory development method ....................................................................................... 17
3.3 Development of Inventory by information analysis ........................................................................... 18
3.3.1 General ............................................................................................................................................... 18
 Guidelines for the Inventory of Hazardous Materials

3.3.2 Collection of necessary information [Step 1] ..................................................................................... 18

3.3.3 Assessment of collected information [Step 2] .................................................................................... 18
3.3.4 Preparation of visual/sampling check plan [Step 3] ........................................................................... 19
3.3.5 Onboard visual/sampling check [Step 4] ............................................................................................ 20
3.3.6 Preparation of the Inventory and related documentation [Step 5] ...................................................... 21
3.3.7 Testing methods.................................................................................................................................. 21
3.3.8 Diagram of the location of Hazardous Materials on board a ship ...................................................... 21
3.4 Maintaining and updating the Inventory during operations .............................................................. 21
3.4.1 General ............................................................................................................................................... 21
3.4.2 Updating of the Inventory in the event of new installation ................................................................ 22
3.4.3 Continuity of the Inventory ................................................................................................................ 22
3.5 Requirements for ascertaining the conformity of the Inventory ...................................................... 22
3.5.1 Design and construction stage ............................................................................................................ 22
3.5.2 Operational stage ................................................................................................................................ 22
3.6 Material Declaration (MD) ..................................................................................................................... 23
3.6.1 General ............................................................................................................................................... 23
3.6.2 Information required in the declaration .............................................................................................. 23
3.7 Suppliers Declaration of Conformity (SDoC) ..................................................................................... 23
3.7.1 General ............................................................................................................................................... 23
3.7.2 Requirements ...................................................................................................................................... 24
3.7.3 Contents and format of Supplier’s Declaration of Conformity .......................................................... 24

List of appendices ......................................................................................................................................... 25

Appendix 1 Example of Statement of Compliance for the Convention .......................................................... 26
Appendix 2 (Void)........................................................................................................................................... 29
Appendix 3 Standard Format of the Inventory ................................................................................................ 30
Appendix 4 Example of Typical Development Process of the Inventory ....................................................... 32
1 Objective of the typical example .............................................................................................................. 32
2 Development flow for the Inventory ........................................................................................................ 32
3 Collection of Hazardous Materials information ....................................................................................... 32
3.1 Data collection process for Hazardous Materials .............................................................................. 32
3.2 Declaration of Hazardous Materials .................................................................................................. 33
3.3 Example of homogeneous materials .................................................................................................. 33
4 Utilization of Hazardous Materials information ....................................................................................... 33
5 Preparation of the Inventory (by filling out standard format) .................................................................. 34
5.1 “Name of equipment and machinery” column .................................................................................. 34
5.2 “Approximate quantity” column ....................................................................................................... 35
5.3 “Location” column ............................................................................................................................ 35
Appendix 5 Example of the typical development process of the Inventory by information analysis ............. 38
1. Introduction ............................................................................................................................................. 38
2. Step1: Collection of necessary information............................................................................................. 38
2.1 Necessary documents ........................................................................................................................ 38
2.2 Indicative list ..................................................................................................................................... 39
2.2.1 Materials to be checked and documented ................................................................................... 39
2.2.2 Materials listed in Table A ......................................................................................................... 39
2.2.2.1 Asbestos ................................................................................................................................... 39
2.2.2.2 Polychlorinated biphenyls (PCBs)........................................................................................... 42
2.2.2.3 Ozone depleting substances ..................................................................................................... 42
2.2.2.4 Organotin compounds.............................................................................................................. 43
2.2.2.4.1 Cybutryne……………………………………………………………………...……………43
2.2.2.5 Perfluorooctane sulfonic acid (PFOS) (related to EU regulations) ......................................... 44
2.2.3 Materials listed in Table B.............................................................................................................. 44
3. Step 2: Assessment of collected information; ......................................................................................... 45
Guidelines for the Inventory of Hazardous Materials

4. Step 3: Preparation of visual/sampling check plan .................................................................................. 50

5. Step 4: Onboard visual/sampling check .................................................................................................. 55
6. Step 5: Preparation of the Inventory and related documentation............................................................. 55
6.1 Development of the Inventory ........................................................................................................... 55
6.2 Development of location diagram of Hazardous Materials ............................................................... 55
Appendix 6 Form of Material Declaration ...................................................................................................... 61
Appendix 7 Form of Supplier’s Declaration of Conformity ........................................................................... 63
Appendix 8 Examples of Table A and Table B Materials with CAS Numbers .............................................. 64
Appendix 9 Specific test methods ................................................................................................................... 72
Appendix 10 Examples of radioactive sources................................................................................................ 76
Guidelines for the Inventory of Hazardous Materials

Guidelines for the Inventory of Hazardous Materials

Chapter 1 General

1.1 Objectives
These Guidelines have been established to provide information to those shipowners, etc.
whose ships are subject to the provisions of Part I of the Inventory of Hazardous Materials
(hereinafter referred to as “Inventory”) specified in Regulation 5 of the Annex to the Hong
Kong International Convention for the Safe and Environmentally Sound Recycling of Ships,
2009, hereinafter referred to as “the Convention”) before said Convention enters into force, or
subject to the provisions of the national requirements on the Inventory. The primary
objectives of these Guidelines are: to provide assistance regarding the issuance of the
“Statement of Compliance” for the Inventory or “Certificate” stipulated by the national
regulation (hereinafter referred as “Statement of Compliance” interchangeably); and to
introduce the notation to be affixed to the classification characters of ships which possess the
Inventory.

Remarks: According to the Convention, the inventory consists:

Part I: Materials contained in ship structure or equipment;
Part II: Operationally generated wastes; and
Part III: Stores.
Of these, Part II and Part III will not be required until just before dismantling the ship, according to Clause 4,
Regulation 5 of the Annex to the Convention. For this reason, the materials contained in ship structure and
equipment pointed out in Part I will fall under the scope of these Guidelines.

1.2 Application
These Guidelines are applicable to all ships registered with Nippon Kaiji Kyokai
(hereinafter referred to as “the Society”) for which applications for the issuance of a
“Statement of Compliance” for the Inventory and for the assignment of class notation
indicating the possession of such an inventory have been received by the Society.
In applying these guidelines, the ship is categorized as follows.
(1) Ships (excluding ships specified in (2) and (3) below) on which the shipowners intend
to hold inventory as stipulated in Annex 5 of the Convention before the entry into force
of the 2009 Hong Kong International Convention for the Safe and Environmentally
Reuse of Ships

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 Guidelines for the Inventory of Hazardous Materials

(2) Ships (excluding the ships specified in (3) below) on which the shipowners intend to
hold inventory as defined in Article 5 of the Regulation (EU) No 1257/2013 of the
European Parliament and the Commission on Ship Recycling(Hereinafter referred to as
EU regulations)
(3) Ships which are flying the flags of the states which have established the rules for the
Inventory to be applied

1.3 Notation
The class notation “Inventory of Hazardous Materials” (abbreviated IHM) will be
assigned in accordance with these Guidelines to those ships which possess the Inventory and
“Statement of Compliance” for the Inventory or the certificate prescribed by the flag state.

Notes: The requirements based on these Guidelines are optional and are not necessary for class
maintenance. However, if compliance with the requirements related to Inventory
specified in these Guidelines is not maintained, the corresponding notation will be deleted.

1.4 Terminology
The terms used in these Guidelines, including the following have the same meaning as
those defined in the Convention.
-1. “Hazardous Material” means any material or substance given in Table 1.1 (hereinafter
referred to as Table A as used in the Convention) and in Table 1.2 (hereinafter referred to as
Table B as used in the Convention).
-2. “Administration” means the Government of the State whose flag the ship is entitled to fly,
or under whose authority it is operating.
-3. “Ship Recycling Facility” means a defined area that is a site, yard or facility used for the
recycling of ships.
-4. “Shipowner” means the person or persons or company registered as the owner of the ship
or, in the absence of registration, the person or persons or company owning the ship or any
other organization or person such as the manager, or the bareboat charterer, who has assumed
the responsibility for operation of the ship from the owner of the ship. However, in the case of
a ship owned by a State and operated by a company which in that State is registered as the
ship’s operator, “owner” shall mean such company. This term also includes those who have
ownership of the ship for a limited period pending its sale or handing over to a Ship
Recycling Facility.
-5. “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), including a vessel stripped of equipment or being towed.

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Guidelines for the Inventory of Hazardous Materials

-6. “Product” means machinery, equipment, materials and applied coatings on board a ship.
-7. “Supplier” means a company which provides products; which may be a manufacturer,
trader or agency.
-8. “Material Declaration” means a declaration indicating that the product (such as machinery,
equipment, material, paint) supplied by the supplier contains/does not contain the material(s)
indicated in Table A and Table B, and also indicates the contents of the product.
-9. “Supplier’s Declaration of Conformity” means a declaration by the supplier assuming
responsibility that the supplier’s product has been manufactured or sold in accordance with
the requirements of section 3.7 of these Guidelines.
-10. “Homogeneous material” means a material of uniform composition throughout that
cannot be mechanically disjointed into different materials, meaning that the materials cannot,
in principle, be separated by mechanical actions such as unscrewing, cutting, crushing,
grinding and abrasive processes.
-11. “Threshold value” is defined as the concentration value in homogeneous materials.
-12. “Supply chain” means the series of entities involved in the supply and purchase of
materials and goods, from raw materials to final product.
-13. “Check List” means a list used for clarifying the results at each step of the work for
confirming the preparation of the Inventory by information analysis, mentioned in Appendix
4 of these Guidelines.
-14. “Exemption” means materials specified in paragraph 3.1.4 in these Guidelines that do not
need to be listed on the IHM, even if such materials or items exceed the IHM threshold
values.
-15 “Fixed” means the conditions that equipment or materials are securely fitted with the ship,
such as by welding or with bolts, riveted or cemented, and used at their position, including
electrical cables and gaskets.
-16 “Loosely fitted equipment” means equipment or materials present on board the ship by
the conditions other than "fixed", such as fire extinguishers, distress flares, and lifebuoys."

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 Guidelines for the Inventory of Hazardous Materials

Table 1.1 (Table A) Materials listed in Appendix 1 of the Convention and Annex I of EU Regulation
Hazardous Definitions Control measures
Material
Asbestos Materials containing asbestos For all ships, new installation of
materials which contain asbestos shall
be prohibited.
Ozone- Ozone-depleting substances means controlled New installations which contain
depleting substances defined in paragraph 4 of article 1 of the ozone-depleting substances shall be
substances Montreal Protocol on Substances that Deplete the prohibited on all ships, except that new
Ozone Layer, 1987. These are substances listed in installations containing
Annexes A,B,C or E to the said Protocol in force at Hydrochlorofluorocarbons (HCFCs)
the time of application or interpretation of this are permitted until 1 January 2020.
Annex. However, new installation which
Halon 1211 Bromochlorodifluoromethane contain ozone-depleting substances
Halon 1301 Bromotrifluoromethane shall be prohibited on all ships
Halon 2402 1,2-Dibromo-1,1,2,2-tetrafluoroethane specified in 1.2 (2) and ships specified
(also known as Halon 114B2) in the national regulations of the flag
CFC-11 Trichlorofluoromethane state among the ships specified in 1.2.
CFC-12 Dichlorodifluoromethane (3).
CFC-113 1,1,2-Trichloro-1,2,2-trifluoroethane
CFC-114 1,2-Dichloro-1,1,2,2-tetrafluoroethane
CFC-115 Chloropentafluoroethane
Polychlori-nate “Polychlorinated biphenyls” means aromatic For all ships, new installation of
d biphenyl compounds formed in such a manner that the materials which contain
(PCB) hydrogen atoms on the biphenyl molecule (two Polychlorinated biphenyls shall be
benzene rings bonded together by a single prohibited.
carbon-carbon bond) may be replaced by up to ten
chlorine atoms.
Anti- Anti-fouling compounds and systems regulated 1. No ship may apply anti-fouling
fouling under Annex I to the International Convention on systems containing organotin
compounds and the Control of Harmful Anti-fouling Systems on compounds as a biocide or any other
systems Ships, 2001 (AFS Convention) in force at the time anti-fouling system whose application
of application or interpretation of these Guidelines. or use is prohibited by the AFS
Convention.
2. No new ships or new installations
on ships shall apply or employ
anti-fouling compounds or systems in
a manner inconsistent with the AFS
Convention.

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Guidelines for the Inventory of Hazardous Materials

Perfluorooctane perfluorooctane sulfonic acid’ (PFOS) means New installations which contain
sulfonic acid perfluorooctane sulfonic acid and its derivatives perfluorooctane sulfonic acid (PFOS)
(PFOS) ( 1 ) and its derivatives shall be prohibited
in accordance with Regulation (EC)
No 850/2004 of the European
Parliament and of the Council
(1)
This applies only to all ships specified in 1.2 (2) and ships specified in the rules of the flag state among the
ships specified in 1.2. (3).

Table 1.2 (Table B) Hazardous Materials listed in Appendix 2 of the Convention and Annex II of EU
Regulation (excluding Annex I substances)
Hazardous Material
Any Hazardous Materials listed in Annex 1 of the Convention
Cadmium and Cadmium Compounds
Hexavalent Chromium and Hexavalent Chromium Compounds
Lead and Lead Compounds
Mercury and Mercury Compounds
Polybrominated Biphenyls (PBBs)
Polybrominated Diphenyl Ethers (PBDEs)
Polychlorinated Naphthalene (more than 3 chlorine atoms)
Radioactive Substances
Certain Short-chain Chlorinated Paraffins (Alkanes, C10-C13, chloro)
Brominated Flame Retardant (HBCDD)(1)
(1)
This applies only to all ships specified in 1.2 (2) and ships specified in the rules of the flag state among the
ships specified in 1.2. (3).

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 Guidelines for the Inventory of Hazardous Materials

Chapter 2 Surveys and Issue of Statement of Compliance for the

Inventory

For ships which are specified in 1.2 (1) and (2), survey and issuance of the Statement of
Compliance shall be conducted as stipulated in this Chapter.
For ships specified in 1.2 (3), survey and issuance of the certificate shall be conducted as
stipulated in this Chapter in principle. However, if there are special provisions in the rules of the
flag state of the ship, they shall be applied,

2.1 General

2.1.1 Kinds of surveys

The kinds of surveys are specified as follows:
(1) Initial survey
(2) Renewal survey
(3) Additional survey
(4) Occasional survey

2.1.2 Timing and Implementation of surveys

-1. Surveys by ClassNK specified in 2.1.1 shall be carried out for the ship which has the
“Statement of Compliance” for the Inventory issued in accordance with these ClassNK
guidelines or the certificate stipulated by the flag state (Hereafter referred to as “the Statement
or Certificate for IHM”).
-2. The timing of a survey is specified as follows:
(1) Initial surveys are to be carried out at the time the application for the first survey of
ship possessing the Inventory is made.
(2) Renewal surveys are to be carried out at the times of Special Surveys for Classification
(e.g. those times specified in 1.1.3-1. (3), Part B of the Rules for the Survey and
Construction of Steel Ships).
However, if there are special provisions in the regulation of the flag state regarding the
timing of renewal inspection for ships specified in 1.2 (3), the relevant provisions are
to be applied.
(3) Additional surveys are to be carried out at the request of the shipowner in the
following cases except at the time of the initial survey and renewal survey.
- When conducting major modifications or repairs involving changes in the type or
amount of hazardous substances listed in the inventory provided for the ship
(4) Occasional surveys are to be carried out at the request of the shipowner in the

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Guidelines for the Inventory of Hazardous Materials

following cases except at the time of the initial survey, survey inspection and
additional survey.
- When it is necessary to conduct other inspections (for example, when there is a
change in the items described in the inventory certificate, etc.)

2.1.3 Renewal Survey carried out in advance and Postponement

-1. Renewal Survey carried out in advance
The renewal inspection is conducted at the same time as other survey necessary for
registration or maintenance of the class even if it does not fall within the time to receive it, so
that it can be advanced if requested by the ship owner.
-2. When the Renewal Survey is carried out early including the items applicable to the
Additional Survey, the Additional Survey is not carried out.
-3. Postponement of Renewal Survey
The Renewal Survey can be postponed in accordance with the provisions of ClassNK Rules
for the Survey and Construction of Steel Ships (Part B, 1.1.5-1.).

The requirements for Renewal Survey carried out in advance and the postponement of such
audits are to be in accordance with the provisions relevant to Periodical Surveys for
Classification (e.g. 1.1.4 and 1.1.5, Part B of the Rules for the Survey and Construction of
Steel Ships).

2.1.4 Preparations for survey and other related issues

-1. In cases where ships are to be surveyed in accordance with these Guidelines, it is the
responsibility of the Owners to notify Surveyors of the locations where they wish to undergo
such surveys. Surveyors are to be advised of surveys a reasonable time in advance so that
such surveys can be carried out at proper times.
-2. All such preparations as required for the type of survey requested as well as those which
may be required by Surveyors in accordance with the provisions given in these Guidelines so
that survey may be carried out appropriately are the responsibility of the applicant for the
survey.
-3. Applicants for surveys are to arrange supervisors who are well conversant with all of the
items required for the preparation of the survey and who are able to provide all necessary
assistance as requested by Surveyors during such surveys.
-4. Surveys may be suspended at Surveyor discretion in cases where the necessary
preparations for the survey have not been made, no appropriate supervisor is present, or the
Surveyor considers the conditions needed for the safe execution of the survey are not ensured.

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 Guidelines for the Inventory of Hazardous Materials

2.2 Initial survey

2.2.1 General
During Initial Surveys, items related to the Inventory are to be confirmed in two stages: the
pre-audit and the final audit. Compliance with the provisions of Chapter 3 of these
Guidelines is to be verified prior to the issuance of the “Statement of Compliance” for the
Inventory.

2.2.2 Submission of documents

One application and the documents listed below are to be submitted to the Society.
-1. Documents necessary for pre-audit to be submitted
(1) Shipbuilders are to submit each of the following documents as electronic data to the
Society. However, documents may be submitted by means other than electronic data
provided the Society deems it appropriate. In such cases, the following documents are
to be submitted in triplicate:
(a) Inventory
(b) Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) or
documents that confirm the same
(c) Other documents deemed necessary by the Society
(2) Shipowners are to submit the following documents in triplicate to the Society in cases
where 3.3 is applicable:
(a) Check list (including location data)
(b) Visual/sampling check plan (as reference document)
(c) Other documents deemed necessary by the Society

-2. Documents necessary for final audit to be submitted

(1) After the complete of an onboard audit, the shipbuilder is to submit each of the
following documents as electronic data to the Society. However, documents may be
submitted by means other than electronic data provided the Society deems it
appropriate. In such cases, the following documents are to be submitted in triplicate:
(a) Final inventory (if revised)
(b) If necessary, an addition Material Declaration (MD) and Supplier’s Declaration of
Conformity (SDoC) or documents that confirm the same
(c) Other documents deemed necessary by the Society
(2) Shipowners are to submit the following documents in triplicate to the Society after an
onboard audit is completed in cases where 3.3 is applicable:
(a) Final Inventory
(b) Result of visual/sampling check
(c) Other documents deemed necessary by the Society

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Guidelines for the Inventory of Hazardous Materials

2.2.3 Survey items

The following items are to be confirmed during Initial Surveys:
-1. The items to be confirmed during Initial Surveys are as follows:
(1) Pre-audit
(a) Audit of documents to be submitted as listed in 2.2.2-1.(1) above
(b) Confirmation on board the ship based on the Inventory audited in (a) above (in
such cases, the shipyard is to provide personnel to accompany the Surveyor and
provide support).
(2) Final audit
Audit of documents submitted according to subsection 2.2.2-2.(1) above, prepared to
reflect the results of (1)(b) above
-2. In cases where 3.3 is applicable, the items to be confirmed during Initial Surveys are as
follows:
(1) Pre-audit
(a) Audit of documents to be submitted as listed in 2.2.2-1.(2) above
(b) Confirmation on board the ship based on the check list audited in (a) above (in
such cases, either the shipowner or their representative expert is to accompany the
Surveyor and provide support).
(2) Final audit
Audit of documents submitted according to subsection 2.2.2-2.(2) above, prepared to
reflect the results of (1)(b) above.

2.2.4 Issuance of the statement or certificate, and Class Notation

As a result of the initial survey, if it is found that the inventory conforms to the requirements
of this guideline, the Society will issue a statement or certificate for IHM. In addition, the
class notation of “Inventory of Hazardous Materials” (abbreviated IHM) will be assigned to
the ship. The standard format of the statement of compliance is to be referred to Appendix 1
and Appendix 2. If there are special provisions in the rules of the flag state of the ship, they
shall be applied,

2.3 Renewal Survey

2.3.1 General
During Renewal Survey, the status of the Inventory existing on the ship is to be checked,
and the Inventory is to be confirmed to ensure that it is being appropriately maintained
according to the provisions of Chapter 3 of these Guidelines.

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2.3.2 Submission of documents

An application and the documents listed below are to be submitted to the Society.
(1) Valid statement or certificate
(2) The latest version of the Inventory
(3) Material Declaration and Supplier’s Declaration of Conformity regarding changes,
updates, or major repairs of structures, equipment, systems, appendages, arrangements,
materials made since the last survey.
(4) Other documents deemed necessary by the Society

2.3.3 Survey items

The following items are to be confirmed during Renewal Survey:
(1) A person as responsible for maintaining and updating the inventory is designated.
(2) A system to ensure the necessary updating of the inventory is establish and supervised by
the designated person.
(3) Inventory is appropriately maintained and updated as necessary according to the system.
(4) Relevant documents such as Material Declaration and Supplier’s Declaration of
Conformity are appropriately maintained.
(5) Statement or certificate for IHM is to be kept onboard the ship.
(6) The inventory, especially the location of hazardous materials, is consistent with the
arrangement, structure and equipment of the ship (confirm by visual inspection on board)

2.3.4 Issue of statement or certificate, and Class Notation

If the Society confirms from the results of the audit in 2.3.3 above that the latest version of
Inventory complies with the requirements of these Guidelines, the Society will issue the
“Statement of compliance” for the Inventory taking account of with regulation 11 of the
annex to the Convention and assign the class notation “Inventory of Hazardous Materials”
(abbreviated IHM). If there are special provisions in the rules of the flag state of the ship, they
shall be applied,

2.4 Additional Survey

2.4.1 General
During Additional Survey, the status of the Inventory existing on the ship is to be checked,
and the Inventory is to be confirmed to ensure that necessary amendments have been made for
changes, replacements or significant repairs, and it is being appropriately maintained
according to the provisions of Chapter 3 of these Guidelines.

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2.4.2 Submission of documents

An application and the documents listed below are to be submitted to the Society.
(1) Valid statement or certificate
(2) The latest version of the Inventory
(3) Material Declaration and Supplier’s Declaration of Conformity regarding changes,
updates, or major repairs of structures, equipment, systems, appendages, arrangements
and materials made since the last survey.
(4) Documents certifying changes in the items to be described in the statement or certificate
(if any)
(5) Other documents deemed necessary by the Society

2.4.3 Survey items

The following items are to be confirmed during Additional Survey:
(1) A person as responsible for maintaining and updating the inventory is designated.
(2) System to ensure the necessary updating of the inventory is establish and supervised by
the designated person.
(3) The inventory is properly maintained, and necessary updates are made for changes,
replacements or significant repairs according to the system.
(4) Relevant documents, such as material declarations and supplier declarations of conformity,
are retained appropriately for changes, replacements or significant repairs.
(5) Statement or certificate for IHM is to be kept onboard the ship.
(6) The inventory, especially the location of hazardous materials, is consistent with the
arrangement, structure and equipment of the ship (confirm by visual inspection on board)

2.4.4 Endorsement or re-issue of statement or certificate

-1. If the Society confirms from the results of the audit in 2.4.3 above that the latest version of
the Inventory complies with the requirements of these Guidelines, the Society will endorse the
“Statement of compliance” for the Inventor. If there are special provisions in the rules of the
flag state of the ship, they shall be applied.
-2. If there is a change in the items described in the statement or the certificate, the
endorsement specified in the above -1 shall be made for the re-issued statement or the
certificate.

2.5 Occasional Survey

2.5.1 General
During Occasional Survey, the status of the Inventory existing on the ship is to be checked,
and the Inventory is to be confirmed to ensure that necessary amendments have been made

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and it is being appropriately maintained according to the provisions of Chapter 3 of these

Guidelines.
In particular, if there are changes in the items described in the statement or certificate for
the Inventory, it is confirmed that the related descriptions in the inventory have been changed
appropriately. If there is a change in the ship owner, it is confirmed that the Inventory has
been taken over from the previous owner.

2.5.2 Submission of documents

An application and the documents listed below are to be submitted to the Society.
(1) Valid statement or certificate
(2) The latest version of the Inventory (If there is a change in the owner of the ship, it is to be
the inventory that has been taken over from the previous owner and is to be updated.)
(3) Material Declaration and Supplier’s Declaration of Conformity regarding changes,
updates, or major repairs of structures, equipment, systems, appendages, arrangements
and materials made since the last survey. (If there is a change in the ship owner, the
material declaration and the supplier declaration of conformity are to be the ones those
have been taken over from the previous owner.)
(4) Documents certifying changes in the items to be described in the statement or certificate
(if any)
(5) Other documents deemed necessary by the Society

2.5.3 Survey items

The following items are to be confirmed during Additional Survey:
(1) A person as responsible for maintaining and updating the inventory is designated.
(2) System to ensure the necessary updating of the inventory is establish and supervised by
the designated person.
(3) The inventory is properly maintained and necessary updates are made for changes,
replacements or significant repairs according to the system.
(4) Relevant documents, such as material declarations and supplier declarations of conformity,
are retained appropriately for changes, replacements or significant repairs.
(5) Statement or certificate for IHM is to be kept onboard the ship.
(6) The inventory, especially the location of hazardous materials, is consistent with the
arrangement, structure and equipment of the ship (confirm by visual inspection on board)

2.5.4 Endorsement or re-issue of statement or certificate

If the Society confirms from the results of the audit in 2.5.3 above that the latest version of
Inventory complies with the requirements of these Guidelines, the Society will re-issue the
“Statement of compliance” for the Inventory taking account of with regulation 11 of the
annex to the Convention and assign the class notation “Inventory of Hazardous Materials”

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(abbreviated IHM). If there are special provisions in the rules of the flag state of the ship, they
shall be applied,

2.6 Duration and validity of statements or certificates

2.6.1 General
-1. Validity of a statement or certificate shall be harmonized with the Classification
Certificate. However, if there are special instructions from the administration of the flag state
of the ship, it shall be applied.
-2. The statement or certificate is invalid in the following cases.
(1) When the ship's condition is considerably different from what is stated in the inventory
and the statement or certificate. This includes cases where inventory is not properly
maintained and updated to reflect changes in ship structure and equipment.
(2) When the Renewal Survey is not completed within the period specified in 2.1.2
(3) When endorsement by Additional Survey is not made
(4) When a ship is transferred to another flag country.

2.6.2 Issuance of certificates after transfer of flag state

-1. In the case that the statement or the certificate that has become invalid due to the transfer
of the flag state of the ship, new statement or certificate shall not be issued before it is
sufficiently confirmed by the Society that the inventory is properly maintained and that there
is no change in the structure, organization or equipment. When it is confirmed through the
survey that the inventory is properly maintained and there are no unauthorized changes, the
Society will accept the initial and subsequent surveys conducted by the previous
Administration or its RO to maintain the harmony of the inspection and issue a new statement
or certificate that has the same expiry date as the certificate that was invalidated due to the
change of ship's flag.
-2. If there are additional requirements in the rules of new flag state of the ship, the Society
will issue a new statement or certificate after confirming the compliance with the additional
requirements.

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Chapter 3 Inventory

3.1 General

3.1.1 Materials to be listed in the Inventory

(3.2 of Guidelines for the Development of the Inventory of Hazardous Materials of the Convention
adopted by IMO Resolution MEPC.379(80) (hereinafter referred to as “Convention Guidelines”)
-1. The materials to be listed in the Inventory are to be as given in Table 3.1A and Table
3.1B. However, materials A-5 and B-10 in the tables do not need to be listed in the
inventory, except for ships that are registered in flag states, such as EU member states,
that have special provisions regarding the entry of such substances.
For materials in this table with no threshold value, quantities occurring as unintentional
trace contaminants should not be listed in Material Declarations and in the Inventory.
-2. For loosely fitted equipment, there is no need to list in part I of the Inventory. Such
equipment which remains on board when the ship is recycled should be listed in part III.
-3 Those batteries containing lead acid or other hazardous materials that are fixed in place
should be listed in part I of the Inventory. Batteries that are loosely fitted, which includes
consumer batteries and batteries in stores, should be listed in part III of the Inventory.
-4 Similar materials or items that contain hazardous materials that potentially exceed the
threshold value can be listed together (not individually) on the IHM with their general
location and approximate amount specified there (hereinafter referred to as "Bulk
Listing"). An example of how to list those materials and items is shown in Table 4.1 of
Appendix 4."

3.1.2 Revision to threshold values

(3.5 of the Convention Guidelines)
Revised threshold values in Table 3.1A and Table 3.1B should be used for IHMs developed
or updated after the adoption of the revised values and need not be applied to existing IHMs
and IHMs under development. However, when materials are added to the IHM, such as
during maintenance, the revised threshold values should be applied and recorded in the IHM.

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Table 3.1A Materials listed in Appendix1 of the Convention Guidelines and Annex I of EU Regulation
No. Materials Threshold value

A-1 Asbestos 0.1% 1

A-2 Polychlorinated biphenyls（PCBs） 50 mg/kg
A-3 CFCs
Halons
Other fully halogenated CFCs
Carbon tetrachloride
Ozone-depleting 1,1,1-Trichloroethane (Methyl chloroform) No threshold value 2
substances Hydrochlorofluorocarbons
Hydrobromofluorocarbons
Methyl bromide
Bromochloromethane
A-4 Anti-fouling systems containing organotin compounds as a biocide 2,500 mg total tin/kg
Anti-fouling systems containing cybutryne 1,000 mg/kg5
A-5 Perfluorooctane sulfonic acid (PFOS) 10mg/kg (0.001% by weight 3)
(Note) Substances A-5 is listed in EU Regulation Annex I.

Table 3.1B Materials listed in Appendix 2 of the Convention Guidelines and Annex II of EU
Regulation
No. Materials Threshold value

B-1 Cadmium and cadmium compounds 100mg/kg

B-2 Hexavalent Chromium and hexavalent chromium compounds 1,000mg/kg
B-3 Lead and lead compounds 1,000mg/kg
B-4 Mercury and mercury compounds 1,000mg/kg
B-5 Polybrominated biphenyl（PBBs） 50 mg/kg
B-6 Polybrominated diphenyl ethers（PBDEs） 1,000mg/kg
B-7 Polychlorinated naphthalenes (more than 3 chlorine atoms) 50 mg/kg
B-8 Radioactive substances No threshold value 4
B-9 Certain shortchain chlorinated paraffins (Alkanes, C10-C13, chloro) 1%

1 If 1% is applied, this threshold value should be recorded in the Inventory and, if available,

the Material Declaration and can be applied instead of 0.1% 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.
2 Unintentional trace contaminants should not be listed in the Material Declarations and in

the Inventory.
3 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
4 All radioactive sources should be included in Material Declarations 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 9.
5 When samples are directly taken from the hull, average values of cybutryne should not be

present above 1,000 mg of cybutryne per kilogram of dry paint.

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 Guidelines for the Inventory of Hazardous Materials

B-10 Brominated Flame Retardant (HBCDD) 100mg/kg (0.01%)

(Note) Substances B-10 is listed in EU Regulation Annex II.

3.1.3 Standard format of the Inventory of Hazardous Materials

(3.4 of the Convention Guidelines)
-1. The Inventory should be developed on the basis of the standard format set out in
Appendix 3. From the materials listed in Table 3.1A and Table 3.1B, the existence of those
materials with no threshold values and the approximate quantity are to be listed in the
Inventory, while in case of materials with threshold values, the existence, approximate
quantity, and whether materials are below the threshold values are to be listed in the
Inventory.
-2. In the cover of the inventory and other necessary parts, the names of the rules applied in
the development of the inventory should be described clearly.

3.1.4 Exemptions - Materials not required to be listed in the Inventory

(3.3 of the Convention Guidelines)
-1 Materials listed in Table 3.1B that are inherent in solid metals or metal alloys, such as
steels, aluminums, brasses, bronzes, plating and solders, provided they are used in general
construction, such as hull, superstructure, pipes, or housings for equipment and machinery,
are not required to be listed in the Inventory.
-2 Although electrical and electronic equipment is required to be listed in the Inventory, the
amount of hazardous materials potentially contained in printed wiring boards (printed
circuit boards) installed in the equipment does not need to be reported in the Inventory."

3.1.5 Description of location of Hazardous Materials on board

(4.6 of the Convention Guidelines)
The locations of Hazardous Materials on board should be described and identified using the
name of location (e.g., second floor of Engine-room, Bridge DK, APT, No.1 Cargo Tank,
Frame number) given in the plans (e.g., General Arrangement, Fire and Safety Plan,
Machinery Arrangement or Tank Arrangement).

3.1.6 Description of approximate quantity of Hazardous Materials

(4.7 of the Convention Guidelines)
In order to identify the approximate quantity of Hazardous Materials, the standard unit used
for the Hazardous Materials should be kg, unless other units (e.g., m3 for materials of liquid or
gases, m2 for materials used in floors or walls) are considered more appropriate. An
approximate quantity should be rounded up to at least two significant figures.

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Guidelines for the Inventory of Hazardous Materials

3.2 Development of the Inventory

3.2.1 General
(4.1.1 of the Convention Guidelines)
The Inventory should include the Hazardous Materials listed in Table A and Table B, and
should be developed based on Material Declarations and the Supplier’s Declarations of
Conformity. The list of items in the Inventory of Hazardous Materials of Table B should be
as deemed appropriate by the Society.

3.2.2 Development of the Inventory

(Related to 4.1.2 to 4.1.4 of the Convention Guidelines)
-1. For equipment and systems provided on the ship and their locations, the Material
Declarations specified in section 3.6 furnished by the suppliers in the shipbuilding supply
chain should be collected.
-2. In addition to the collected Material Declarations, the Supplier’s Declaration of
Conformity specified in section 3.7 should be collected.
-3. During the development of the Inventory, paints used in machinery, equipment, materials
and coatings comprising the hull should be examined and checked to ensure that the
Hazardous Materials listed in Table A are not contained in them. If necessary, quantities and
locations of the Hazardous Materials in Table 3.1A should be listed in the Inventory. If these
materials have been used within the limitations of the Convention, the same should be
mentioned in the Inventory.
-4. During the development of the Inventory, if the paints used in the machinery, equipment,
materials and coatings on board the ship contains Hazardous Materials indicated in Table B
in excess of the threshold value established in Table 3.1B, the quantities and locations of the
products should be listed in the Inventory.
-5. The checking of materials specified in -3. and -4. above should be based on the “Material
Declarations” furnished by the suppliers in the shipbuilding supply chain (e.g., equipment
suppliers, parts suppliers, material suppliers).

Appendix 4 shows a typical example of development process of the Inventory.

3.2.3 Alternative Inventory development method

If the method of developing Inventory according to subsections 3.2.1 and 3.2.2 above is
difficult, the procedure described in section 3.3 may be used as an alternative Inventory
development method.

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3.3 Development of Inventory by information analysis

3.3.1 General
(4.2. of the Convention Guidelines)
-1. The Inventory should be related to the Hazardous Materials listed in Table A. The
development of the Inventory should be implemented by experts, as far as possible.
-2. The Inventory should be developed according to the development flow diagram of Fig. 3.1
and subsections 3.3.2 to 3.3.6.
Step 1 Collection of necessary information;
Step 2 Assessment of collected information;
Step 3 Preparation of visual/sampling check plan;
Step 4 Onboard visual check and sampling check; and
Step 5 Preparation of the Inventory and related documentation.
-3. In cases where a ship already possessing the Inventory is converted or repaired, or new
equipment, etc., is fitted accompanying the changes in the Inventory, the preparation of
changed locations in the Inventory should be according to section 3.2.

3.3.2 Collection of necessary information [Step 1]

(4.2.5 of the Convention Guidelines)
-1. The ship owner should identify, research, request, and procure all reasonably available
documentation regarding the ship.
-2. Documents in -1. above, should include maintenance, conversion, and repair documents;
certificates, manuals, ship’s plans, drawings, and technical specifications; product information
data sheets (such as Material Declarations); and Hazardous Material inventories or recycling
information from sister ships.
-3. Potential sources of information could include previous ship owners, the ship builder,
historical societies, classification society records, and ship recycling facilities with experience
working with similar ships.

3.3.3 Assessment of collected information [Step 2]

(4.2.6 of the Convention Guidelines)
-1. The ship owner or expert requested by the ship owner (hereinafter referred to as the
“Inventory developer”) should assess the collected information in subsection 3.3.2 above.
-2. The assessment should cover all materials listed in Table A; materials listed in Table B
should be assessed as far as practicable. The results of the assessment should be reflected in
the visual/sampling check plane. (Appendix 5 shows a typical example of development
process of the Inventory by information analysis.)

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Guidelines for the Inventory of Hazardous Materials

Fig. 3.1 Flow diagram of the development of the Inventory by information analysis

3.3.4 Preparation of visual/sampling check plan [Step 3]

(4.2.7 of the Convention Guidelines)
-1. To specify the location and estimated quantity of the materials listed in Table A, the
Inventory developer should prepare a visual/sampling check plan taking into account the
collected information and any appropriate expertise.
-2. The visual/sampling check plan should consist of the following three lists:
(1) List of equipment, system and/or area for visual check
Any equipment, system and/or area specified regarding the presence of the materials
listed in Table A by document analysis should be entered in the list of equipment,
system and/or area for visual check
(2) List of equipment, system and/or area for sampling check
Any equipment, system and/or area which cannot be specified regarding the presence
of the materials listed in Table A by document or visual analysis should be entered in
the list of equipment, system and/or area as requiring sampling check. A sampling
check is the taking of samples to identify the presence or absence of Hazardous
Material contained in the equipment, systems, and/or areas, by suitable and generally

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accepted methods such as laboratory analysis.

(3) List of equipment, system and/or area classed as “potentially containing Hazardous
Materials”
Any equipment, system and/or area which cannot be specified regarding the presence
of the materials listed in Table A by document analysis may be entered in the List of
equipment, system and/or area classed as “potentially containing Hazardous
Materials” without the sampling check. However, the prerequisite for this
classification is a comprehensible justification such as to the impossibility of
conducting sampling without compromising the safety of the ship and its operational
efficiency.
-3. Visual/sampling checkpoints should be all points where:
(1) The presence of materials to be considered for the Inventory as listed in Table A is
likely;
(2) The documentation is not specific; or
(3) Materials of uncertain composition were used.

3.3.5 Onboard visual/sampling check [Step 4]

(4.2.8 of Convention Guidelines)
-1. The onboard visual/sampling check should be carried out in accordance with the
visual/sampling check plan. The sampling check should be carried out drawing upon expert
assistance.
-2. When a sampling check is carried out, samples should be taken and the sample points
should be clearly marked on the ship plan, photographs, and so on, and the sample results
referenced.
-3. Materials of the same kind may be sampled in a representative manner. Such materials are
to be checked to ensure that they are of the same kind.
-4. Any uncertainty regarding the presence of Hazardous Materials should be clarified by a
visual/sampling check. Checkpoints should be documented in the ship’s plan and may be
supported by photographs.
-5. If the equipment, system and/or area of the ship are not accessible for a visual check or
sampling check, notwithstanding -1. to -4. above, visual check or sampling check need not be
performed. In this case, such equipment, system and/or area of the ship should be classified as
“potentially containing Hazardous Materials (PHCM)” .The prerequisite for such
classification should be the same prerequisite as in subsection 3.3.4-2.(3).
-6. Any equipment, system and/or area classed as “potentially containing Hazardous Material
(PHCM)” may be investigated or subjected to a sampling check at the request of the ship
owner during a later survey (e.g., during repair, refit or conversion).

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3.3.6 Preparation of the Inventory and related documentation [Step 5]

(4.2.9 of the Convention Guidelines)
If any equipment, system and/or area are classed as either “containing Hazardous Material”
or “potentially containing Hazardous Material (PHCM),” their approximate quantity and
location should be listed in the Inventory. These two categories should be indicated separately
in the remarks column of the Inventory of Hazardous Materials.

3.3.7 Testing methods

(4.2.10 of the Convention Guidelines)
-1 Samples may be tested by a variety of methods. "Indicative" or "field tests" may be used
when:
• the likelihood of a hazard is high;
• the test is expected to indicate that the hazard exists; and
• the sample is being tested by "specific testing" to show that the hazard is present.
-2 Indicative or field tests are quick, inexpensive and useful onboard the ship or on site, but
they cannot be accurately reproduced or repeated, and cannot identify the hazard specifically,
and therefore cannot be relied upon except as "indicators".
-3 In all other cases, and in order to avoid dispute, "specific testing" should be used.
Specific tests are repeatable, reliable and can demonstrate definitively whether a hazard exists
or not. They will also provide a known type of the hazard. The methods indicated are
found qualitative and quantitative appropriate and only testing methods to the same effect can
be used. Specific tests are to be carried out by a suitably accredited laboratory, working to
international standards 5 or equivalent, which will provide a written report that can be relied
upon by all parties.
-4 Specific test methods for appendix 1 materials are provided in Appendix 9.

3.3.8 Diagram of the location of Hazardous Materials on board a ship

(4.2.11 of the Convention Guidelines)
Preparation of a diagram showing the location of the materials listed in Table 3.1A is
recommended in order to help Ship Recycling Facilities gain a visual understanding of the
Inventory.

3.4 Maintaining and updating the Inventory during operations

3.4.1 General
(4.3.1 of the Convention Guidelines)

5For example ISO 17025

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The Inventory should be appropriately maintained and updated, especially after any repair
or conversion or sale of a ship.

3.4.2 Updating of the Inventory in the event of new installation

(4.3.2 of the Convention Guidelines)
The Inventory should be updated according to the requirements prescribed in subsection
3.2.2 in case of the items listed below. However, updating is not required if identical parts or
coatings are installed or applied.
(1) If any machinery or equipment is added to, removed or replaced
(2) If the hull coating is renewed.

3.4.3 Continuity of the Inventory

(4.3.3 of the Convention Guidelines)
The Inventory should belong to the ship and the continuity and conformity of the
information it contains should be confirmed, especially if the flag, owner or operator of the
ship changes.

3.5 Requirements for ascertaining the conformity of the Inventory

3.5.1 Design and construction stage

(5.1 of the Convention Guidelines)
The conformity of the Inventory at the design and construction stage should be ascertained
by reference to the collected “Supplier’s Declaration of Conformity” described in section 3.7
and the related “Material Declarations” described in section 3.6, and collected from suppliers.

3.5.2 Operational stage

(5.2 of the Convention Guidelines)
Shipowners should implement the following measures in order to ensure the conformity of
the Inventory:
(1) Designate a person as responsible for maintaining and updating the Inventory (the
designated person may be employed ashore or on board);
(2) In order to implement subsection 3.4.2, the designated person should establish and
supervise a system to ensure the necessary updating of the Inventory in the event of
new installation;
(3) Maintain the Inventory including dates of changes or new deleted entries and the
signature of the designated person (for instance, preparation of Revision History and
attaching to the Inventory); and
(4) Provide related documents as required for the survey or sale of the ship.

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3.6 Material Declaration (MD)

3.6.1 General
(6.1. of the Convention Guidelines)
Suppliers to the shipbuilding industry should identify and declare whether or not the
materials listed in Table A or Table B are present and in their product (for instance,
machinery, equipment, materials and paints) and their approximate quantity. The suppliers
should also declare whether their product exceeds the threshold value or not in case of those
materials listed in Table 3.1A and Table 3.1B for which threshold values have been
mentioned. However, this provision does not apply to chemicals which do not constitute a
part of the finished product.

3.6.2 Information required in the declaration

(6.2 of the Convention Guidelines)
-1 At a minimum the following information is required in the Material Declaration:
(1) Date of declaration;
(2) Material Declaration identification number;
(3) Supplier’s name;
(4) Product name (common product name or name used by manufacturer);
(5) Product number (for identification by manufacturer);
(6) Declaration of whether or not the materials listed in Table 3.1A and Table 3.1B of
these Guidelines are present in the product above the threshold value stipulated in the
said tables; and
(7) Mass of each constituent material listed in Table 3.1A and Table 3.1B of these
Guidelines, if present above threshold value.

-2 An example of a Material Declaration is shown in Appendix 6.

3.7 Suppliers Declaration of Conformity (SDoC)

3.7.1 General
(7.1.1 of the Convention Guidelines)
The purpose of the Supplier’s Declaration of Conformity is to provide assurance that the
related Material Declaration conforms to subsection 3.6.2, and to identify the responsible
entity.

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3.7.2 Requirements
(7.1.3 of the Convention Guidelines)
The supplier compiling the Supplier’s Declaration of Conformity should establish a
company policy 6. The supplier should establish and maintain the company policy on the
management of the chemical substances in products which the supplier manufactures or sells
and the policy should cover:
(1) Compliance with law
The regulations and requirements governing the management of chemical substances
in products should be clearly described in documents which should be kept and
maintained; and
(2) Obtaining of information on chemical substance content
In procuring raw materials for components and products, suppliers should be selected
following an evaluation, and the information on the chemical substances they supply
should be obtained.

3.7.3 Contents and format of Supplier’s Declaration of Conformity

(7.2 of the Convention Guidelines)
-1 The Supplier’s Declaration of Conformity should contain the following:
(1) Unique identification number;
(2) Name and contact address of the issuer;
(3) Identification of the subject of the Supplier’s Declaration of Conformity (for instance,
name, type, model number, of product and/or other relevant supplementary
information);
(4) Statement of conformity;
(5) Date and place of issue; and
(6) Signature (or equivalent sign of validation), name and function of the authorized
person(s) acting on behalf of the issuer.

-2 An example of the Supplier’s Declaration of Conformity is shown in Appendix 7.

6A recognized quality management system may be utilized.

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Guidelines for the Inventory of Hazardous Materials

List of appendices
Appendix 1: Example of Statement of Compliance for the Convention
Appendix 2: (Void)
Appendix 3: Standard Format of the Inventory
Appendix 4: Example of typical development process of the Inventory
Appendix 5: Example of typical development process of the Inventory by Information
analysis
Appendix 6: Form of Material Declaration
Appendix 7: Form of Supplier's Declaration of Conformity
Appendix 8: Examples of Tables A and B materials with CAS numbers
Appendix 9: Specific test methods
Appendix 10: Examples of radioactive sources

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 Guidelines for the Inventory of Hazardous Materials

Appendix 1 Example of Statement of Compliance for the Convention

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 Guidelines for the Inventory of Hazardous Materials

Appendix 3 Standard Format of the Inventory7

(Appendix 2 of the Convention Guidelines)

Part I Hazardous Materials contained in ship’s structure and equipment

1.1 Paints and coating system containing materials listed in Table 3.1A and Table 3.1B

No. Application of paint Name of paint Location Materials Approximate Remarks

quantity

1 Anti-drumming Primer, XX Co., Hull Part Lead 35.00 kg

compound xx primer #300

2 Antifouling xx Co. xx coat Underwater TBT 120.00 kg

#100 parts

1.2 Equipment and machinery containing materials listed in Table 3.1A and Table 3.1B

N Name of equipment and Location Material Parts where Approximate Remarks

o. machinery used quantity

1 Switch board Engine Cadmium Housing 0.02 kg

control room coating

Mercury Heat gauge <0.01 Kg Less than 0.01kg

2 Diesel Engine, xx Co., xx Engine room Lead Starter for 0.02 kg

#150 blower

3 Diesel Engine, xx Co., xx Engine room Lead Starter for 0.01 kg Revised by XXX

#200 blower on Oct., xx 2008

(revoking No.2)

4 Diesel Generator (× 3) Engine room Lead Ingredient of 0.01 kg

copper

compounds

5 Radioactive level gauge No.1 Cargo Radioactive Gauge 5 Ci Radionuclides:

tank substances (1.8E+11) (Bq) 60Co

1.3 Structure and hull containing materials listed in Table 3.1A and Table 3.1B

No. Name of structural Location Material Used location Approximate Remarks

7 Examples of how to complete the Inventory are provided for guidance purposes only in
accordance with paragraph 3.4 of the Convention Guidelines.

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Guidelines for the Inventory of Hazardous Materials

element quantity

1 Wall panel Accommodation Asbestos Insulation 2,500.00 kg

2 Wall insulation Engine control Lead Perforated plate 0.01 kg Cover of insulation

room material

Asbestos Fire protection 25.00 kg Under perforated

plates

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 Guidelines for the Inventory of Hazardous Materials

Appendix 4 Example of Typical Development Process of the Inventory

(Appendix 3 of the Convention Guidelines)

1 Objective of the typical example

This example has been developed to give guidance and to facilitate understanding of the
development process of the Inventory of Hazardous Materials.

2 Development flow for the Inventory

The Inventory should be developed using the following 3 steps. However, the order of
these steps is flexible and can be changed depending on the schedule of shipbuilding:
Step 1 Collection of Hazardous Materials information
Step 2 Utilization of Hazardous Materials information
Step 3 Preparation of the Inventory (by filling out standard format)

3 Collection of Hazardous Materials information

3.1 Data collection process for Hazardous Materials

Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) for
equipment, materials and paints (hereinafter called “products”) from suppliers (tier 1
suppliers) should be requested and collected by the shipbuilding yard. Tier 1 suppliers may
request from their suppliers (tier 2 suppliers) the relevant information if they cannot develop
the MD based on the information available. Thus the collection of data on Hazardous
Materials may involve the entire shipbuilding supply chain. (Fig. 4.1)

MD ･･･ MD
回答 ････ MD
List
回答 回答
････

Request Request
MD
MD 回答
回答
MD
回答
Shipbuilder Submit Equipment Supplier Submit Equipment Supplier

(Tier 1) (Tier 2)
造船所 ････
MD MD MD
回答 回答 回答
･･･ ･･･

Fig. 4.1 Process of MD (and SDoC) showing involvement of supply chain

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Guidelines for the Inventory of Hazardous Materials

3.2 Declaration of Hazardous Materials

Suppliers should declare whether or not the Hazardous Materials listed in Table A and
Table B in the MD are present in concentrations above the threshold values specified for each
“homogeneous material” in a product. If present, they should declare their approximate
quantities in the MD. If Hazardous Materials are absent, the same should be declared in the
MD.
(1) Materials listed in Table A
If one or more materials listed in Table A are found to be present in concentrations above
the specified threshold value according to the MD, the products which contain these
materials shall not be installed on a ship. However, if the materials are used in a product in
accordance with an exemption specified by the Convention (for example, new
installations containing hydrochlorofluorocarbons (HCFCs) before 1 January 2020), the
product should be listed in the Inventory.
(2) Materials listed in Table B
If one or more materials listed in Table B are found to be present in concentrations above
the specified threshold value according to the MD, the products should be listed in the
Inventory.

3.3 Example of homogeneous materials

Figure 4.2 shows an example of four homogeneous materials which constitute a cable. In
this case, sheath, intervention, insulator and conductor are all individual homogeneous
materials.

Sheath Intervention Insulator (Conductor)

(PVC) (Paper) (Rubber) (Copper)

Fig. 4.2 Example of homogeneous materials (cable)

4 Utilization of Hazardous Materials information

Products which contain Hazardous Materials in concentrations above the specified
threshold values should be clearly identified in the MD. The approximate quantity of the
Hazardous Materials should be calculated if the mass data for Hazardous Materials are
declared in the MD using a unit which cannot be directly utilized in the Inventory.

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 Guidelines for the Inventory of Hazardous Materials

5 Preparation of the Inventory (by filling out standard format)

The information received for the Inventory, as contained in Table 3.1A and Table 3.1B of
these Guidelines, ought to be structured and utilized according to the following categorization
for developing the Inventory:
1.1 Paints and coating systems;
1.2 Equipment and machinery; and
1.3 Structure and hull.

5.1 “Name of equipment and machinery” column

(1) Equipment and machinery
The name of each item of equipment or machinery should be entered in this column. If
more than one hazardous material is present in the equipment or machinery, the row
relating to that equipment or machinery should be appropriately divided such that all of
the hazardous materials contained in the piece of equipment or machinery are entered. If
more than one item of equipment or machinery is situated in one location, both name and
quantity of the equipment or machinery should be entered in the column. Examples are
shown in rows 1 and 2 of Table 4.1.
For identical or common items, such as but not limited to bolts, nuts and valves, there is
no need to list each item individually (see Bulk Listing in paragraph 3.1.1.-4 of these
Guidelines). An example is shown in row 3 of Table 4.1.

Table 4.1 Example showing more than one item of equipment or machinery situated in one location
Name of equipment and Approximate
No. Location Material Parts where used Remarks
machinery quantity

Lead Piston Pin Bush 0.75 kg

Thermometer
1 Main Engine Engine Room
Mercury charge air 0.01 kg

temperature

2 Diesel Generator (x 3) Engine room Mercury Thermometer 0.01 kg

Throughout Lead and lead

3 FC valve (x100) 20.5 kg
the ship compounds

(2) Pipes and cables

The names of pipes and of systems, including electric cables, which are often situated in
more than one compartment of a ship, should be described using the name of the system
concerned. A reference to the compartments where these systems are located is not

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Guidelines for the Inventory of Hazardous Materials

necessary as long as the system is clearly identified and properly named.

5.2 “Approximate quantity” column

The standard unit for approximate quantity of solid Hazardous Materials should be “kg.” If
the Hazardous Materials are liquids or gases, the standard unit should be either m3 or guan
approximate quantity should be rounded up to at least two significant figures. If the
Hazardous Material is less than 10 g, the description of the approximate quantity should read
“<0.01 kg”. An example is shown in Table 4.2.

Tale 4.2 Example of a switchboard

Name of equipment Approximate
No. Location Material Parts where used Remarks
and machinery quantity

Cadmium Housing coating 0.02 kg

Engine Control
1 Switch Board
Room
Mercury Heat gauge <0.01 kg less than 0.01kg

5.3 “Location” column

(1) Example of a location list
It is recommended to prepare a location list which covers all compartments of a ship
based on the ship’s plans (e.g., General Arrangement, Engine-room Arrangement,
Accommodation and Tank Plan) and on other documentation on board, including
certificates or spare parts’ lists. The description of the location should be based on a
location such as a deck or room to enable easy identification. The name of the location
should correspond to the ship’s plans so as to ensure consistency between the Inventory
and the ship’s plans for the ship owner in the future. Examples of names of locations are
shown in Table 4.3. For bulk listings, the locations of the items or materials may be
generalized. For example, the location may only include the primary classification such as
"Throughout the ship" as shown in Table 4.3.

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 Guidelines for the Inventory of Hazardous Materials

Table 4.3 Examples of names of locations

(A) Primary (B) Secondary (A) Primary (B) Secondary
(C) Name of location (C) Name of location
classification classification classification classification

Throughout the ship

Hull Part Fore Part Bos'n Store Engine Room Engine Room

… Machinery Part Main Floor

Cargo Part No.1 Cargo Hold/Tank 2nd Floor

No.1 Garage Deck …

… Generator Space/Room

Tank Part Fore Peak Tank Purifier Space/Room

No.1 WBT Shaft Space/Room

No.1 FOT Engine Casing

… Funnel

Aft Peak Tank Engine Control Room

Aft Part Steering Gear Room

Emergency Fire Pump

Space Pump Room Pump Room

… …

Superstructure Accommodation Exterior Part Superstructure Superstructure

Compass Deck Upper Deck Upper Deck

Nav. Bridge Deck Hull Shell Hull Shell

… Bottom

Wheel House Under Waterline

Engine Control Room …

Cargo Control Room

Deck House Deck House

(2) Description of location of pipes and electrical systems

Locations of pipes and systems, including electrical systems and cables situated in more
than one compartment of a ship, should be described for each system concerned. If they

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Guidelines for the Inventory of Hazardous Materials

are situated in a number of compartments, the more practical of the following two options
should be used:
(a) Listing of all components in the column; or
(b) Description of the location of the system using an expression such as those
shown under “primary classification” and “secondary classification” in Table
4.3.
A typical description of a pipe system is shown in Table 4.4.

Table 4.4 Example of description of a pipe system

Name of equipment Approximate
No. Location Material Parts where used Remarks
and machinery quantity

Engine room,
Water Ballast Pipe
Hold parts

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 Guidelines for the Inventory of Hazardous Materials

Appendix 5 Example of the typical development process of the Inventory by

information analysis
(Appendix 5 of the Convention Guidelines)

1. Introduction
In order to develop the Inventory of Hazardous Materials by information analysis,
documents of the individual ship as well as the knowledge and experience of specialist
personnel (experts) is required. An example of the development process of the Inventory of
Hazardous Materials is useful to understand the basic steps as laid out in the Guidelines and to
ensure a unified application. However, attention should be paid to variations in different types
of ships 1).
Compilation of the Inventory of Hazardous Materials involves the following 5 steps which
are described in 3.3 of these Guidelines.
Step 1: Collection of necessary information;
Step 2: Assessment of collected information;
Step 3: Preparation of visual/sampling check plan;
Step 4: Onboard visual/sampling check;
Step 5: Preparation of Part I of the Inventory and related documentation.

1) The example of a 28,000 gross tonnage bulk carrier constructed in 1985 is used in this Appendix.

2. Step1: Collection of necessary information

2.1 Necessary documents

A practical first step is to collect detailed documents for the ship. The ship owner should
try to collate documents normally retained onboard the ship or by the shipping company as
well as relevant documents that the shipyard, manufacturers, or classification society may
have.

The following documents should be used when available:

Ship’s specifications
General arrangement drawing
Machinery arrangement
Spare parts and tools list
Piping arrangement
Accommodation Plan
Fire control plan
Fire protection plan
Insulation plan

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Guidelines for the Inventory of Hazardous Materials

International Anti-Fouling System Certificate

Related manuals and drawings
Information from other inventories and/or sister or similar ships, machinery,
equipment, materials and coatings
Results of previous visual/sampling checks and other analysis
If the ship has undergone conversions or major repair work, it is necessary to identify as far
as possible the modifications from the initial design and specification of the ship.

2.2 Indicative list

It is impossible to check all equipment, systems, and/or areas on board the ship to
determine the presence or absence of Hazardous Materials. The total number of parts on board
may exceed several thousand. In order to take a practical approach, an “Indicative list” should
be prepared that identifies the equipment, system, and/or area on board that is presumed to
contain Hazardous Materials. Field interviews with the shipyard and suppliers may be
necessary to prepare such “Indicative lists.” A typical example of an “Indicative list” is shown
below.

2.2.1 Materials to be checked and documented

Hazardous materials, as identified in Table 3.1A and Table 3.1B of these Guidelines,
should be listed in the Inventory. Table 3.1A and Table 3.1B of the Guidelines contain all the
materials concerned. Table 3.1A shows those which are required to be listed and Table 3.1B
shows those which should be listed as far as practicable.

2.2.2 Materials listed in Table A

Table A lists the following five materials: asbestos, polychlorinated biphenyls (PCBs),
ozone depleting substances, anti-fouling systems containing organotin compounds as a
biocide, perfluorooctane sulfonic acid (PFOS). PFOS applies only to all ships specified in 1.2
(2) and ships specified in the national rules of the flag state among the ships specified in 1.2.
(3).

2.2.2.1 Asbestos
Field interviews were conducted with over 200 Japanese shipyards and suppliers regarding
the use of asbestos in production. “Indicative lists” for asbestos developed on the basis of this
research are shown below.

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 Guidelines for the Inventory of Hazardous Materials

Table 5.1 “Indicative lists” for asbestos

Product and/ or Component

equipment

Propeller shafting Packing with low pressure hydraulic piping flange

Packing with casing

Clutch

Brake lining

Synthetic stern tubes

Diesel engine Packing with piping flange

Lagging material for fuel pipe

Lagging material for exhaust pipe

Lagging material for turbocharger

Turbine engine Lagging material for casing

Packing with flange of piping and valve for steam line, exhaust line and drain line

Lagging material for piping and valve for steam line, exhaust line and drain line

Boiler Insulation in combustion chamber

Packing for casing door

Lagging material for exhaust pipe

Gasket for manhole

Gasket for hand hole

Gas shield packing for soot blower

Packing with flange of piping and valve for steam line, exhaust line, fuel line and drain line

Lagging material for piping and valve for steam line, exhaust line, drain line and fuel line

Exhaust gas economizer Packing for casing door

Packing with manhole

Packing with hand hole

Gas shield packing for soot blower

Packing with flange of piping and valve for steam line, exhaust line, fuel line and drain line

Lagging material for piping and valve for steam line, exhaust line, drain line and fuel line

Incinerator Packing for casing door

Packing with manhole

Packing with hand hole

Lagging material for exhaust pipe

Auxiliary machinery Packing for casing door and valve

(pump, compressor, oil Gland packing

purifier, crane) Brake lining

Heat exchanger Packing with casing

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Guidelines for the Inventory of Hazardous Materials

Gland packing for valve

Lagging material and insulation

Valve Gland packing with valve, sheet packing with piping flange

Gasket with flange of high pressure and/or high temperature

Pipe, duct Lagging material and insulation

Tank (fuel tank, hot Lagging material and insulation

water, tank, condenser),

other equipment (fuel

strainer, lubricant oil

strainer)

Electric equipment Insulation material

Airborne asbestos Wall, ceiling

Ceiling, floor and wall in Ceiling, floor, wall

accommodation area

Fire door Packing, construction and insulation of the fire door

Inert gas system Packing for casing, etc.

Air conditioning system Sheet packing, lagging material for piping and flexible joint

Miscellaneous Ropes

Thermal insulation materials

Fire shields/fire proofing

Space/duct insulation

Electrical cable materials

Brake linings

Floor tiles/deck underlay

Stern/water/vent flange gaskets

Adhesives/mastics/fillers

Sound damping

Moulded plastic products

Sealing putty

Shaft/valve packing

Electrical bulkhead penetration packing

Circuit breaker arc chutes

Pipe hanger inserts

Weld shop protectors/burn covers

Fire fighting blankets/clothing/equipment

Concrete ballast

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 Guidelines for the Inventory of Hazardous Materials

2.2.2.2 Polychlorinated biphenyls (PCBs)

Worldwide restriction of PCBs began on 17 May 2004 as a result of the implementation of
the Stockholm Convention, which aims to eliminate or restrict the production and use of
persistent organic pollutants. In Japan, domestic control began in 1973, with the prohibition
of all activities relating to the production, use and import of PCBs. Japanese suppliers can
provide accurate information concerning their products. The “Indicative list” of PCBs has
been developed as shown below.

Table 5.2 “Indicative list” of PCBs

Product and/ or equipment Component

Transformer Insulating oil

Condenser Insulating oil

Fuel heater Heating medium

Electric cable Covering, insulating tape

Lubricating oil

Heat oil Thermometer, sensor, indicators

Rubber/felt gaskets

Rubber hose

Plastic foam insulation

Thermal insulating materials

Voltage regulators

Switches/reclosers/bushings

Electromagnets

Adhesives/tapes

Surface contamination of machinery

Oil-based paint

Caulking

Rubber isolation mounts

Pipe hangers

Light ballasts (component within

fluorescent light fixtures)

Plasticizers

Felt under septum plates on top of hull

bottom

2.2.2.3 Ozone depleting substances

The “Indicative list” for Ozone depleting substances is shown in Table 5.3. Ozone
depleting substances have been controlled according to the Montreal Protocol and MARPOL

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Convention. Although almost all substances have been banned since 1996 due to production
restrictions based on the Montreal Protocol, HCFC can still be used at least until 2020. Under
the Montreal Protocol, certain production of HCFC is permitted only to supplement existing
equipment until the end of 2029. In Japan, it will be abolished in 2020.
However, for ships flying the flag of the EU member states, new installations which
contain HCFC is already prohibited. For this reason, new installations which contain HCHC
will not be allowed for non-EU ships if the ships wish to have Part I of the Inventory
complying with Article 5 of the EU Regulation.

Table 5.3 “Indicative list” of ozone depleting substances

Material Component Period for use of ODS

in Japan

CFCs(R11, R12) Refrigerant for refrigerators Up to 1996

CFCs Urethane formed material Up to 1996

Blowing agent for insulation of LNG carriers Up to 1996

Halons Firefighting media Up to 1994

Other fully halogenated CFCs The possibility of usage in ships is low Up to 1996

Carbon tetrachloride The possibility of usage in ships is low Up to 1996

1,1,1-Trichloroethane (Methyl chloroform) The possibility of usage in ships is low Up to 1996

HCFC(R22, R141b) Refrigerant for refrigerating machines Can be used until 2020

HBFC The possibility of usage in ships is low Up to 1996

Methyl bromide The possibility of usage in ships is low Up to 2005

2.2.2.4 Organotin compounds

Organotin compounds include Tributyl tins (TBT), Triphenyl tins (TPT) and Tributyl tin
oxide (TBTO). Organotin compounds have been used as anti-fouling paint on ships’ bottoms
and the International Convention on the Control of Harmful Anti-Fouling Systems on Ships
(AFS Convention) stipulates that all ships shall not apply or re-apply organotin compounds
after 1 January 2003, and that, after 1 January 2008, all ships shall either not bear such
compounds on their hulls or shall bear a coating that forms a barrier preventing such
compounds from leaching into the sea. The above-mentioned dates may have been extended
by permission of the Administration bearing in mind that the AFS Convention entered into
force on 17 September 2008.

2.2.2.4.1 Cybutryne
Cybutryne has been used as biocide in anti-fouling systems, and the International
Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS Convention, as
amended) stipulates that all ships shall not apply or reapply cybutryne after 1 January 2023,

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and that ships bearing an anti-fouling system that contains this substance in the external
coating layer of their hulls or external parts or surfaces on 1 January 2023 shall either remove
the anti-fouling system or apply a coating that forms a barrier to this substance leaching from
the underlying non-compliant anti-fouling system at the next scheduled renewal of the
anti-fouling system after 1 January 2023, but no later than 60 months following the last
application to the ship of an anti-fouling system containing cybutryne.

2.2.2.5 Perfluorooctane sulfonic acid (PFOS) (related to EU regulations)

Perfluorooctane sulfonic acid (PFOS) is required to be listed in the inventory for ships
flying the flag of the EU member states according to EU regulations. The indicative list is
specified in Annex C of the EMSA ’s Best Practice Guidance on the Inventoty of Hazardous
Materials issued in October 2016 as follows.

Table 5.4 Indicative list for Perfluorooctane sulfonic acid (PFOS)

- AFFF (Aqueous film-forming foams): used for aviation, marine and shallow spill fires developed in the 1960s

- FFFP (Film-forming Fluor-protein foams): used for aviation and shallow spill fires

- AR-AFFF (Alcohol-resistant aqueous film-forming foams): multi-purpose foams

- AR-FFFP (Alcohol-resistant film-forming flour-protein foams): multipurpose foams developed in the 1970s

- Hydraulic fluids

- Cable sheath

- Coatings

- Adhesives.

2.2.3 Materials listed in Table B

It is not obligatory for materials listed in Table B to be listed in the Inventory. However, if
they can be identified in a practical way, they should be listed in the Inventory, because the
information will be used to support ship recycling processes. The “Indicative list” of materials
listed in Table B is shown in Table 5.4.

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Table 5.4 “Indicative list” of materials listed in Table B

Materials Components of equipment

Cadmium and cadmium compounds Plating film, bearing

Hexavalent chromium compounds Plating film

Mercury and mercury compounds Fluorescent light, mercury lamp, mercury cell, liquid-level switch,

gyro compass, thermometer, measuring tool, manganese cell, pressure

sensors, light fittings, electrical switches, fire detectors

Lead and lead compounds Corrosion-resistant primer, solder (almost all electric appliances

contain solder), paints, preservative coatings, cable insulation, lead

ballast, generators)

Polybrominated biphenyl (PBBs) Non-flammable plastics

Polybrominated diphenyl ethers (PBDE) Non-flammable plastics

Polychlorinated naphthalenes Paint, lubricating oil

Radioactive substances Refer to appendix 10

Certain shortchain chlorinated paraffins Non-flammable plastics

Brominated Flame Retardant (HBCDD)＊ - Switch plug cover

- Electrical extension cover

- Polymer material of switch board

- Fire sensor/alarm cover

- Light cover, cable sheath

- Polymer made fire resistance insulation

- Coatings

- Flooring material.

*Referred to EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials

3. Step 2: Assessment of collected information;

Preparation of a checklist is an efficient method for developing the Inventory in order to
clarify the results of each step. Based on collected information including the “Indicative list”
mentioned in Step 1, all equipment, systems, and/or areas onboard assumed to contain
Hazardous Materials listed in Tables A and B should be included in the checklist. Each listed
equipment, system, and/or area on board should be analyzed and assessed for its Hazardous
Materials content.
The existence and volume of Hazardous Materials may be judged and calculated from the
spare parts and tools list and the manufacturer’s drawings. The existence of asbestos
contained in floors, ceilings and walls may be identified from Fire Protection Plans, while the
existence of TBT in coatings can be identified from the International Anti-Fouling System
Certificate, coating scheme and the history of paint. Examples are shown Table 5.5.
When a component or coating is determined to contain Hazardous Materials, a “Y” should

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 Guidelines for the Inventory of Hazardous Materials

be entered in the column for “Result of document analysis” in the checklist, to denote
“Contained”. Likewise, when an item is determined not to contain Hazardous Materials, the
entry “N” should be made in the column to denote “Not contained”. When a determination
cannot be made as to the Hazardous Materials content, the column should be completed with
the entry “Unknown”.

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 Guidelines for the Inventory of Hazardous Materials

Table 5.5 Example of weight calculation

No. Hazardous Location/Equipment/Compartment Reference Calculation

Material

1.1-2 TBT Flat Bottom/Paint History of coatings

1.2-1 Asbestos Main Engine/Exh. Pipe packing Spare parts and tools list 250g×14 sheet = 3.50 kg

1.2-3 HCFC Ref. provision plant Manufacturer’s drawings 20kg×1 cylinder = 20 kg

1.2-4 Lead Batteries Manufacturer’s drawings 6 kg×16 unit = 96 kg

1.3-1 Asbestos Engine room ceiling Accommodation plan

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 Checklist (Step 2) Analysis and definition of scope of assessment for sample ship

No. Table Hazardous Location Name of Component Quantity Manufacturer's Result of Check Check Reference/
2 Materials equipment Weight No. Total name assessment procedure Result Dwg. No.
A/B *1 (kg) (kg) Product name of doc. *2 *3 *4
[Inventory Part I-1]

1 A TBT Top Side Painting & A/F Paints Nil Paints Co. N On Aug.,200X,

coating /Marine P1000 sealer coat applied

2 A TBT Flat Bottom 3000 Unknown AF Unknown all over submerged

㎡ area before tin free

coating

[Inventory Part I-12]

1 A Asbestos Lower Deck Main engine Ex. pipe 0.25 14 Diesel Co. Y M-100
packing
2 A Asbestos 3rd Deck Aux. boiler Lagging 12 Unknown Unknown M-300
lagging
3 A Asbestos Engine Piping/flange Packing PCHM
room
4 A HCFC 2nd Deck Ref. plant Refrigerant 20.00 1 Reito Co. Y Maker’s DWG

（R22）
5 B Lead Nav. Bri. Deck Batteries 6 16 Denchi Co, Y E-300

[Inventory Part I-13]

1 A Asbestos Upper Deck Back deck E/R 20 ㎡ Unknown Unknown O-25

ceilings ceilings Ceiling

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Remarks
*1 Hazardous Materials: Classification of Hazardous Materials
*2 Result of document analysis: Y = Contained; N = Not contained, Unknown; P C H M = Potentially containing Hazardous Material.
*3 Check procedure: V= Visual check, S= Sampling check, PHCM = Yes. For PHCM, the value is approximately estimated weight.
*4 Result of check: Y= Contained, N= Not contained, PHCM

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4. Step 3: Preparation of visual/sampling check plan

-1 Each item classified as “Contained” or “Not contained” in Step 2 should be subjected to a
visual check on board, and the entry “V” should be made in the “Check procedure” column to
denote “Visual check”.
-2 For each item categorized as “unknown”, a decision should be made as to whether to apply
a sampling check. However, any item categorized as “unknown” may be classed as
“potentially containing Hazardous Material” provided comprehensive justification is given, or
if it can be assumed that there will be little or no effect on disassembly as a unit and later ship
recycling and disposal operations. For example, in the following checklist, in order to carry
out a sampling check for “Packing with aux. boiler,” the shipowner needs to disassemble the
auxiliary boiler in a repair yard. The costs of this check are significantly higher than the later
disposal costs at a Ship Recycling Facility. In this case, therefore, the classification as
“potentially containing Hazardous Material” is justifiable.
-3 Before any visual/sampling check on board is conducted, a “visual/sampling check plan”
should be prepared. An example of “visual/sampling check plan” is shown in Table 5.6
-4 To prevent any incidents during the visual/sampling check, a schedule should be
established to eliminate interference with other ongoing work on board. To prevent potential
exposure to Hazardous Materials during the visual/sampling check, safety precautions should
be in place onboard. For example, sampling of potential asbestos containing materials could
release fibers into the atmosphere. Therefore, appropriate personnel safety and containment
procedures should be implemented prior to sampling.
-5 The items in the visual/sampling check plan should be arranged in a sequence such that
checks can be implemented rationally on board the ship. (For instance, bottom to top or
forward to aft, and so on)

- 50 -
Guidelines for the Inventory of Hazardous Materials

Table 5.6 Example of visual/sampling check plan

Name of Ship XXXXXXXXXX

IMO Number XXXXXXXXXX

Gross tonnage 28,000GT

L×B×D xxx.xx × xx.xx × xx.xx m

Date of delivery dd.mm.1987

Owner XXXXXXXXXX

Contact point XXXXXXXXX

(Address, Tel., Fax, E-mail) TEL: XXXXXXXX

FAX: XXXXXXXX

E-mail: [email protected]

Check schedule Visual check: dd, mm, 201X

Sampling check: dd, mm, 201X

Site of check XX shipyard, No. DOCK

In charge of check XXXXXXX

Check engineer XXXXXX, YYYYYYYYY, ZZZZZZZ

Sampling engineer Person with specialized knowledge of sampling

Sampling method and anti-scattering Wet the sampling location prior to cutting and allow it to harden after cutting to

measure for asbestos prevent scatter.

Notes: Workers performing sampling activities shall wear protective

equipment.

Sampling of fragments of paints Paints suspected to contain TBT should be collected and analyzed from load

line, directly under bilge keel and flat bottom near amidships.

Laboratory QQQQQQ

Chemical analysis method ISO/DIS 22262-1 Bulk materials—Part 1: Sampling and qualitative

determination of asbestos in commercial bulk materials and

ISO/DIS 22262-1 Bulk materials—Part 2: Quantitative determination of

asbestos by gravimetric and microscopic methods

ICP luminous analysis

Location of visual/sampling check Refer to lists for visual/sampling check

- 51 -
 Guidelines for the Inventory of Hazardous Materials

Listing for equipment, system and/or area for visual check

See attached “Analysis and definition of scope of investigation for sample ship”

List of equipment, system and/or area for sampling check

Result of doc.
Location Equipment, machinery and/or zone Name of parts Materials
checking
Upper Deck Back deck ceilings Engine room ceiling Asbestos Unknown

Engine Exhaust gas pipe Insulation Asbestos Unknown

room
Engine Pipe/flange Gasket Asbestos Unknown
room

Refer to attached “Analysis and definition of scope of investigation for sample ship” and “Location plan of
Hazardous Materials for sample ship”

List of equipment, system and/or area classed as PCHM

Result of
Location Equipment, machinery and/or zone Name of part Material doc.
checking
Floor Propeller cap Gasket Asbestos PCHM
Engine room Air operated shut-off valve Gland packing Asbestos PCHM

Refer to attached “Analysis and definition of scope of investigation for sample ship” and “Location plan of
Hazardous Materials for sample ship”

This plan is established in accordance with the guidelines for the development of the Inventory of
Hazardous Materials

Prepared by： XXXX XXXX

T E L ： YYYY-YYYY
E-Mail： [email protected]

・Document check・date/place：
dd, mm, 200X at XX Lines Colt

・Preparation date of plan：dd. mm, 200X

- 52 -
 Checklist (Step 3) Analysis and definition of scope of assessment for sample ship
No. Table Hazardous Location Name of Component Quantity Manufacturer's Result of Check Check Reference/
2 Materials equipment Weight No. Total name assessment procedure Result Dwg. No.
A/B *1 (kg) (kg) Product name of doc. *2 *3 *4
[Inventory Part I-1]

1 A TBT Top Side Painting & A/F Paints Nil Paints Co. N V On Aug.,200X,

coating /Marine P1000 sealer coat applied

2 A TBT Flat Bottom 3000 Unknown AF Unknown S all over submerged

㎡ area before tin free

coating

[Inventory Part I-2]

1 A Asbestos Lower Deck Main engine Exh. pipe 0.25 14 Diesel Co. Y V M-100
packing
2 A Asbestos 3rd Deck Aux. boiler Lagging 12 Unknown Unknown S M-300
lagging
3 A Asbestos Engine Piping/flange Packing PCHM V
room
4 A HCFC 2nd Deck Ref. plant Refrigerant 20.00 1 Reito Co. Y V Maker’s DWG

（R22）
5 B Lead Nav. Bri. Deck Batteries 6 16 Denchi Co, Y V E-300

[Inventory Part I-13]

1 A Asbestos Upper Deck Back deck E/R 20 ㎡ Unknown Unknown S O-25

ceilings ceilings Ceiling

-53-
Remarks
*1 Hazardous Materials: Classification of Hazardous Materials
*2 Result of document analysis: Y = Contained; N = Not contained, Unknown; P C H M = Potentially containing Hazardous Material.
*3 Check procedure: V= Visual check, S= Sampling check, PHCM = Yes. For PHCM, the value is approximately estimated weight.
*4 Result of check: Y= Contained, N= Not contained, PHCM

-54-
船舶に搭載される有害物質一覧表に関するガイドライン

5. Step 4: Onboard visual/sampling check

-1 The visual/sampling check should be conducted according to the plan. Check points should
be marked in the ship’s plan or recorded with photographs.
-2 A person taking samples should be protected by the appropriate safety equipment relevant
to the suspected type of Hazardous Materials encountered. Appropriate safety precautions
should also be in place for passengers, crew members and other persons on board, to
minimize the potential exposure to Hazardous Materials. Safety precautions could include the
posting of signs or other verbal or written notification for personnel to avoid such areas
during sampling. The personnel taking samples should ensure compliance with relevant
national regulations.
-3 The results of visual/sampling checks should be recorded in the checklist. Any equipment,
systems and/or areas of the ship that cannot be accessed for checks should be classified as
“potentially containing Hazardous Material.” In this case, the entry in the “Result of check”
column should be “PCHM.”

6. Step 5: Preparation of the Inventory and related documentation

6.1 Development of the Inventory

The results of the check and the estimated quantity of Hazardous Materials should be
recorded on the checklist. The Inventory should be developed with reference to the checklist.

6.2 Development of location diagram of Hazardous Materials

With respect to the Inventory, the development of a location diagram of Hazardous Materials
is recommended in order to help the Ship Recycling Facility gain a visual understanding of
the Inventory.

- 55 -
 Checklist (Step 4 and Step 5) Analysis and definition of scope of assessment for sample ship

No. Table Hazardous Location Name of Component Quantity Manufacturer's Result of Check Check Reference/
2A/B Materials *1 equipment Weight No. Total name assessment proced Result Dwg. No.
(kg) (kg) Product name of doc. *2 ure *3 *4
[Inventory Part I-1]

1 A TBT Top Side Painting & A/F Paints Nil Paints Co. N V N On Aug.,200X,

coating /Marine P1000 sealer coat applied

2 A TBT Flat 0.02 3000 60.00 Unknown AF Unknown S Y all over submerged

Bottom ㎡ area before tin free

coating

[Inventory Part I-2]

1 A Asbestos Lower Main engine Exh. pipe 0.25 14 3.50 Diesel Co. Y V Y M-100
Deck packing
2 A Asbestos 3rd Deck Aux. boiler Lagging 12 Unknown Unknown S N M-300
lagging
3 A Asbestos Engine Piping/flange Packing PCHM V PCHM
room
4 A HCFC 2nd Deck Ref. plant Refrigerant 20.00 1 20.00 Reito Co. Y V Y Maker’s DWG

（R22）
5 B Lead Nav. Bri. Batteries 6 16 96.00 Denchi Co, Y V Y E-300

Deck

[Inventory Part I-13]

1 A Asbestos Upper Back deck E/R 0.19 20 ㎡ 3.80 Unknown Unknown S Y O-25
Deck ceilings ceilings Ceiling

-56-
Remarks
*1 Hazardous Materials: Classification of Hazardous Materials
*2 Result of document analysis: Y = Contained; N = Not contained, Unknown; P C H M = Potentially containing Hazardous Material.
*3 Check procedure: V= Visual check, S= Sampling check, PHCM = Yes. For PHCM, the value is approximately estimated weight.
*4 Result of check: Y= Contained, N= Not contained, PHCM

-57-
 Example of the Inventory developed by information analysis

Inventory of Hazardous Materials

For “Sample Ship”

Particular of the “Sample Ship”
Distinctive number or letters : ････････
Port of registry : Port of World
Type of vessel : Bulk carrier
Gross Tonnage : 28,000GT
IMO number : ･････････
Name of shipbuilder : ○○ Shipbuilding Co. Ltd
Name of shipowner : □□ Maritime S.A.
Date of delivery : MM/DD/1998

This inventory was developed in accordance with the guideline for the development of the Inventory
of Hazardous Materials
Attachment:
1: Inventory of Hazardous Materials
2: Assessment of collected information
3: Location diagram of Hazardous Materials
*
Prepared by ○○○○ (Name & address) (mm/dd/20XX)

*1 If the other regulation such as Article 5 of EU-SRR is applied in addition to IMO Guidelines, it should be indicated clearly.

-58-
 Inventory of Hazardous Materials : “Sample Ship”

Part I HAZARDOUS MATERIALS CONTAINED IN THE SHIP'S STRUCTURE AND EQUIPMENT

I-1 Paints and coating systems containing materials listed in Table A and Table B of the guidelines
Materials
No. Application of paint Name of paint Location *1 Approx. quantity Remarks
(classification in appendix 1)

1 AF paint Unknown paints Flat bottom TBT 60.00 kg Confirmed by sampling

2
3

I-2 Equipment and machinery containing materials listed in Table A and Table B of the guidelines
Materials
No. Name of equipment and machinery Location *1 Parts where used Approx. quantity Remarks
(classification in appendix 1)

1 Main engine Lower floor Asbestos Exh. pipe packing 3.50 kg

PCHM(potentially containing Hazardous
2 Aux. boiler 3rd deck Asbestos Unknown packing 10.00 kg
Material)
3 Piping/flange Engine room Asbestos Packing 50.00 kg PCHM
4 Ref. provision plant 2nd deck HCFC Refrigerant (R22) 20.00 kg
5 Batteries Navig. Bridge deck Lead 96.00 kg

I-3 Structure and hull containing materials listed in Table A and Table B of the guidelines
Materials
No. Name of structural element Location *1 Parts where used Approx. quantity Remarks
(classification in appendix 1)

Back deck ceiling Engine room ceiling

1 Upper deck Asbestos 3.80 kg Confirmed by sampling
(A class)
2
3
*1 Each item should be entered in order based on its location, from a lower level to an upper level and from a fore part to an aft part.

-59-
Example of Location map of Hazardous Materials

-60-
 Appendix 6 Form of Material Declaration
(Appendix 6 of the Convention Guidelines)
Date of Declaration
Date

<MD ID No.> < Supplier (Respondent) Information >

MD- ID-No. Company Name
Division Name
< Other information > Address
Remarks 1 Contact Person
Remarks 2 Tel No.
Remarks 3 FAX No.
E-mail address
SDoC ID No.

< Product Information >

Delivered unit
Product Name Product No. Product Information
Amount Unit

< Materials Information >

Unit
This materials information shows the amount of Hazardous Materials contained in 1 (Unit: No., kg, m, m2, m3, etc.) of the product.

Present above If YES, material

Table Material name Threshold value threshold value mass If YES, information on where it is used
YES/NO Mass Unit
Asbestos Asbestos 0.1%1
Polychlorinated biphenyls Polychlorinated biphenyls
50 mg/kg
(PCB) (PCB)
Chlorofluorocarbons (CFCs)

Halon
Other fully halogenated CFCs

Carbon tetrachloride
Ozone-depleting 1,1,1-Trichloroethane No threshold
substances (Methyl chloroform) value
Table A
(materials Hydrochlorofluorocarbons

Hydrobromofluorocarbons

Methyl bromide
Bromochloromethane

Anti-fouling systems
2500 mg total
containing organotins
tin/kg
compounds as a biocide

Anti-fouling systems
1,000 mg/kg2
containing cybutryne

Present above If YES, material

Table Material name Threshold value threshold value mass If YES, information on where it is used
YES/NO Mass Unit
Cadmium and cadmium compounds 100 mg/kg
Hexavalent chromium and hexavalent chromium
1,000 mg/kg
compounds
Lead and lead compounds 1,000 mg/kg
Table B
(materials Mercury and mercury compounds 1,000 mg/kg
listed in
Polybrominated Biphenyls (PBBs) 50 mg/kg
appendix 2
of the Polybrominated Diphenyl Ethers (PBDEs) 1,000 mg/kg
Convention) Polychlorinated naphthalenes (Cl >= 3) 50 mg/kg
Radioactive Substances No threshold value
Certain Short-chain Chlorinated Paraffins (Alkanes,
1%
C10-C13, chloro)
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 United Nations 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

-61-
 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.
2. When samples are directly taken from the hull, average values of cybutryne should not be present above 1,000 mg of cybutryne per kilogram of dry paint.

SUPPLEMENT TO THE IMO FORM OF MATERIAL DECLARATION

<SUPPLEMENT attached to MD-ID-No:>

MD- ID-No.
Date

<Materials information>
Unit
This materials information shows the amount of hazardous materials contained in 1 (unit: piece, kg, m, m2, m3, etc.) of the product.。

Present above If yes, material

Annex of EU threshold value mass
Material name Threshold value If yes, information on where it is used
SRR
Yes / No Mass Unit

Annex I
(materials
Perfluorooctane sulfonic acid (PFOS) and its derivatives 10 mg/kg (0.001%
listed in
by weight2)
annex I of the
EU SRR)

Annex II
(materials
100 mg/kg (0.01%
listed in Brominated Flame Retardant (HBCDD)
by weight)
annex II of the
EU SRR)

2. 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

-62-
 Appendix 7 Form of Supplier’s Declaration of Conformity
(Appendix 7 of the Convention Guidelines)

Supplier’s Declaration of Conformity for Material Declaration Management

1) SdoC ID No.:

2) Issuer’s Name:

Issuer’s Address:

3) Object(s) of the Declaration:

4) The object(s) of the declaration described above is in conformity with the following

Document No.: Title: Edition/Date of Issue

5) Additional Information:

6) Signed for and on behalf of:

Name, designation

Name, designation of authorized person Signature of authorized person

Place of issue Date of issue

-63-
Appendix 8 Examples of Table A and Table B Materials with CAS Numbers
(Appendix 8 of the Convention Guidelines)
* This list is developed with reference to Joint Industry Guide No.101.

* This list is not exhaustive. It represents examples of chemicals with known CAS numbers and may require periodical updating.

1. Materials listed in Table A

A. Asbestos
Material CAS Number

Asbestos 1332-21-4

Actinolite 77536-66-4

Amosite 12172-73-5

Anthophyllite 77536-67-5

Chrysotile 12001-29-5

Crocidolite 12001-28-4

Tremolite 77536-68-6

B. Polychlorinated biphenyls (PCB)

Material CAS Number

Polychlorinated biphenyls 1336-36-3

Aroclor 12767-79-2

Chlorodiphenyl (Aroclor 1260) 11096-82-5

Kanechlor 500 27323-18-8

Aroclor 1254 11097-69-1

C. Ozone-depleting substances (they may contain isomers that are not listed here)
Material CAS Number

Trichlorofluoromethane (CFC-11)) 75-69-4

Dichlorofluoromethane (CFC-12) 75-71-8

Chlorotrifluoromethane (CFC 13) 75-72-9

Pentachlorofluoroethane (CFC 111) 354-56-3

Tetrachlorodifluoroethane (CFC 112) 76-12-0

Trichlorotrifluoroethane (CFC 113) 354-58-5

1,1,2 Trichloro-1,2,2 trifluoroethane 76-13-1

-64-
Dichlorotetrafluoroethane (CFC 114) 76-14-2

Monochloropentafluoroethane (CFC 115) 76-15-3

Heptachlorofluoropropane (CFC 211) 422-78-6, 135401-87-5

Hexachlorodifluoropropane (CFC 212) 3182-26-1

Pentachlorotrifluoropropane (CFC 213) 2354-06-5, 134237-31-3

29255-31-0
Tetrachlorotetrafluoropropane (CFC 214)
2268-46-4

Trichloropentafluoropropane (CFC 215) 1599-41-3

1,1,1-Trichloropentafluoropropane 4259-43-2

1,2,3-Trichloropentafluoropropane 76-17-5

Dichlorohexafluoropropane (CFC 216) 661-97-2

Monochloroheptafluoropropane (CFC 217) 422-86-6

Bromochlorodifluoromethane (Halon 1211) 353-59-3

Bromotrifluoromethane (Halon 1301) 75-63-8

Dibromotetrafluoroethane (Halon 2402) 124-73-2

Carbon tetrachloride (Tetrachloromethane) 56-23-5

1,1,1, - Trichloroethane (methyl chloroform) and its isomers except 1,1,2-trichloroethane 71-55-6

Bromomethane (Methyl bromide) 74-83-9

Bromodifluoromethane and isomers (HBFC’s) 1511-62-2

Dichlorofluoromethane (HCFC 21) 75-43-4

Chlorodifluoromethane (HCFC 22) 75-45-6

Chlorofluoromethane (HCFC 31) 593-70-4

Tetrachlorofluoroethane (HCFC 121) 134237-32-4

1,1,1,2-tetrachloro-2-fluoroethane (HCFC 121a) 354-11-0

1,1,2,2-tetracloro-1-fluoroethane 354-14-3

Trichlorodifluoroethane (HCFC 122) 41834-16-6

1,2,2-trichloro-1,1-difluoroethane 354-21-2

Dichlorotrifluoroethane(HCFC 123) 34077-87-7

Dichloro-1,1,2-trifluoroethane 90454-18-5

2,2-dichloro-1,1,1-trifluroethane 306-83-2

1,2-dichloro-1,1,2-trifluroethane (HCFC-123a) 354-23-4

1,1-dichloro-1,2,2-trifluroethane (HCFC-123b) 812-04-4

2,2-dichloro-1,1,2-trifluroethane (HCFC-123b) 812-04-4

Chlorotetrafluoroethane (HCFC 124) 63938-10-3

2-chloro-1,1,1,2-tetrafluoroethane 2837-89-0

1-chloro-1,1,2,2-tetrafluoroethane (HCFC 124a) 354-25-6

Trichlorofluoroethane (HCFC 131) 27154-33-2;(134237-34-6)

-65-
1-Fluoro-1,2,2-trichloroethane 359-28-4

1,1,1-trichloro-2-fluoroethane (HCFC131b) 811-95-0

Dichlorodifluoroethane (HCFC 132) 25915-78-0

1,2-dichloro-1,1-difluoroethane (HCFC 132b) 1649-08-7

1,1-dichloro-1,2-difluoroethane (HFCF 132c) 1842-05-3

1,1-dichloro-2,2-difluoroethane 471-43-2

1,2-dichloro-1,2-difluoroethane 431-06-1

Chlorotrifluoroethane (HCFC 133) 1330-45-6

1-chloro-1,2,2-trifluoroethane 1330-45-6

2-chloro-1,1,1-trifluoroethane (HCFC-133a) 75-88-7

Dichlorofluoroethane(HCFC 141) 1717-00-6; (25167-88-8)

1,1-dichloro-1-fluoroethane (HCFC-141b) 1717-00-6

1,2-dichloro-1-fluoroethane 430-57-9

Chlorodifluoroethane (HCFC 142) 25497-29-4

1-chloro-1,1-difluoroethane (HCFC142b) 75-68-3

1-chloro-1,2-difluoroethane (HCFC142a) 25497-29-4

Hexachlorofluoropropane (HCFC 221) 134237-35-7

Pentachlorodifluoropropane (HCFC 222) 134237-36-8

Tetrachlorotrifluropropane (HCFC 223) 134237-37-9

Trichlorotetrafluoropropane (HCFC 224) 134237-38-0

Dichloropentafluoropropane, (Ethyne, fluoro-) (HCFC 225) 127564-92-5; (2713-09-9)

2,2-Dichloro-1,1,1,3,3-pentafluoropropane(HCFC 225aa) 128903-21-9

2,3-Dichloro-1,1,1,2,3-pentafluoropropane (HCFC 225ba) 422-48-0

1,2-Dichloro-1,1,2,3,3-pentafluoropropane (HCFC 225bb) 422-44-6

3,3-Dichloro-1,1,1,2,2-pentafluoropropane (HCFC 225ca) 422-56-0

1,3-Dichloro-1,1,2,2,3-pentafluoropropane (HCFC 225cb) 507-55-1

1,1-Dichloro-1,2,2,3,3-pentafluoropropane(HCFC 225cc) 13474-88-9

1,2-Dichloro-1,1,3,3,3-pentafluoropropane (HCFC 225da) 431-86-7

1,3-Dichloro-1,1,2,3,3-pentafluoropropane (HCFC 225ea) 136013-79-1

1,1-Dichloro-1,2,3,3,3-pentafluoropropane(HCFC 225eb) 111512-56-2

Chlorohexafluoropropane (HCFC 226) 134308-72-8

Pentachlorofluoropropane (HCFC 231) 134190-48-0

Tetrachlorodifluoropropane (HCFC 232) 134237-39-1

Trichlorotrifluoropropane (HCFC 233) 134237-40-4

1,1,1-Trichloro-3,3,3-trifluoropropane 7125-83-9

Dichlorotetrafluoropropane (HCFC 234) 127564-83-4

Chloropentafluoropropane (HCFC 235) 134237-41-5

-66-
1-Chloro-1,1,3,3,3-pentafluoropropane 460-92-4

Tetrachlorofluoropropane (HCFC 241) 134190-49-1

Trichlorodifluoropropane (HCFC 242) 134237-42-6

Dichlorotrifluoropropane (HCFC 243) 134237-43-7

1,1-dichloro-1,2,2-trifluoropropane 7125-99-7

2,3-dichloro-1,1,1-trifluoropropane 338-75-0

3,3-dichloro-1,1,1-trifluoropropane 460-69-5

Chlorotetrafluoropropane (HCFC 244) 134190-50-4

3-chloro-1,1,2,2-tetrafluoropropane 679-85-6

Trichlorofluoropropane (HCFC 251) 134190-51-5

1,1,3-trichloro-1-fluoropropane 818-99-5

Dichlorodifluoropropane (HCFC 252) 134190-52-6

Chlorotrifluoropropane (HCFC 253) 134237-44-8

3-chloro-1,1,1-trifluoropropane (HCFC 253fb) 460-35-5

Dichlorofluoropropane (HCFC 261) 134237-45-9

1,1-dichloro-1-fluoropropane 7799-56-6

Chlorodifluoropropane (HCFC 262) 134190-53-7

2-chloro-1,3-difluoropropane 102738-79-4

Chlorofluoropropane (HCFC 271) 134190-54-8

2-chloro-2-fluoropropane 420-44-0

D. Organotin compounds (tributyl tin, triphenyl tin, tributyl tin oxide)

Material CAS Number

Bis(tri-n-butyltin) oxide 56-35-9

Triphenyltin N,N'-dimethyldithiocarbamate 1803-12-9

Triphenyltin fluoride 379-52-2

Triphenyltin acetate 900-95-8

Triphenyltin chloride 639-58-7

Triphenyltin hydroxide 76-87-9

Triphenyltin fatty acid salts (C=9-11) 47672-31-1

Triphenyltin chloroacetate 7094-94-2

Tributyltin methacrylate 2155-70-6

Bis(tributyltin) fumarate 6454-35-9

Tributyltin fluoride 1983-10-4

Bis(tributyltin) 2,3-dibromosuccinate 31732-71-5

Tributyltin acetate 56-36-0

-67-
Tributyltin laurate 3090-36-6

Bis(tributyltin) phthalate 4782-29-0

Copolymer of alkyl acrylate, methyl methacrylate and tributyltin methacrylate(alkyl; C=8) -

Tributyltin sulfamate 6517-25-5

Bis(tributyltin) maleate 14275-57-1

Tributyltin chloride 1461-22-9

Mixture of tributyltin cyclopentanecarboxylate and its analogs (Tributyltin naphthenate) -

Mixture of tributyltin 1,2,3,4,4a, 4b, 5,6,10,10 adecahydro-7-isopropyl-1,

-
4a-dimethyl-1-phenanthlenecarboxylate and its analogs (Tributyltin rosin salt)

Other tributyl tins & triphenyl tins -

D-2. Anti-fouling systems containing cybutryne

Material CAS Number

Cybutryne 28159-98-0

E. Perfluorooctane sulfonic acid (PFOS) and its derivatives

Annex B of EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials is to
be referred.

2. Materials listed in Table B

A. Cadmium/cadmium compounds
Material CAS Number

Cadmium 7440-43-9

Cadmium oxide 1306-19-0

Cadmium sulfide 1306-23-6

Cadmium chloride 10108-64-2

Cadmium sulfate 10124-36-4

Other cadmium compounds -

B. Chromium VI compounds
Material CAS Number

Chromium (VI) oxide 1333-82-0

Barium chromate 10294-40-3

Calcium chromate 13765-19-0

Chromium trioxide 1333-82-0

Lead (II) chromate 7758-97-6

-68-
 Sodium chromate 7775-11-3

Sodium dichromate 10588-01-9

Strontium chromate 7789-06-2

Potassium dichromate 7778-50-9

Potassium chromate 7789-00-6

Zinc chromate 13530-65-9

Other hexavalent chromium compounds -

C. Lead/lead compounds
Material CAS Number

Lead 7439-92-1

Lead (II) sulfate 7446-14-2

Lead (II) carbonate 598-63-0

Lead hydrocarbonate 1319-46-6

Lead acetate 301-04-2

Lead (II) acetate, trihydrate 6080-56-4

Lead phosphate 7446-27-7

Lead selenide 12069-00-0

Lead (IV) oxide 1309-60-0

Lead (II,IV) oxide 1314-41-6

Lead (II) sulfide 1314-87-0

Lead (II) oxide 1317-36-8

Lead (II) carbonate basic 1319-46-6

Lead hydrocarbonate 1344-36-1

Lead (II) phosphate 7446-27-7

Lead (II) chromate 7758-97-6

Lead (II) titanate 12060-00-3

Lead sulfate, sulphuric acid, lead salt 15739-80-7

Lead sulphate, tribasic 12202-17-4

Lead stearate 1072-35-1

Other lead compounds -

D. Mercury/ mercury compounds

Material CAS Number

Mercury 7439-97-6

Mercuric chloride 33631-63-9

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 Mercury (II) chloride 7487-94-7

Mercuric sulfate 7783-35-9

Mercuric nitrate 10045-94-0

Mercuric (II) oxide 21908-53-2

Mercuric sulfide 1344-48-5

Other mercury compounds -

E. Polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs)

Material CAS Number

Bromobiphenyl and its ethers 2052-07-5 (2-Bromobiphenyl)

2113-57-7 (3-Bromobiphenyl

92-66-0 (4-Bromobiphenyl)

101-55-3 (ether)

Decabromobiphenyl and its ethers 13654-09-6

1163-19-5 (ether)

Dibromobiphenyl and its ethers 92-86-4

2050-47-7 (ether)

Heptabromobiphenylether 68928-80-3

Hexabromobiphenyl and its ethers 59080-40-9

36355-01-8

(hexabromo-1,1’-biphenyl)

67774-32-7 (Firemaster FF-1)

36483-60-0 (ether)

Nonabromobiphenylether 63936-56-1

Octabromobiphenyl and its ethers 61288-13-9

32536-52-0 (ether)

32534-81-9 (CAS number used

Pentabromobidphenyl ether (note: commercially available PeBDPO is a complex reaction
for commercial grades of
mixture containing a variety of brominated diphenyloxides)
PeBDPO)

Polybrominated Biphenyls 59536-65-1

Tetrabromobiphenyl and its ethers 40088-45-7

40088-47-9 (ether)

Tribromobiphenyl ether 49690-94-0

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F. Polychlorinated Naphthalenes
Material CAS Number

Polychlorinated naphthalenes 70776-03-3

Other polychlorinated naphthalenes -

G. Radioactive substances
Material CAS Number

Uranium -

Plutonium -

Radon -

Americium -

Thorium -

Cesium 7440-46-2

Strontium 7440-24-6

Other radioactive substances -

H. Certain short-chain chlorinated paraffins (with carbon length of 10-13 atoms)

Material CAS Number

Chlorinated paraffins (C10-13) 85535-84-8

Other Short-chain Chlorinated Paraffins -

I. Brominated Flame Retardant (HBCDD)

Annex B of EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials is to
be referred.

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 Appendix 9 Specific test methods
(Appendix 9 of the Convention Guidelines)

1 Asbestos
Types to test for: as per Convention Guidelines; Actinolite CAS 77536-66-4 Amosite
(Grunerite) CAS 12172-73-5 Anthophyllite CAS 77536-67-5 Chrysotile CAS 12001-29-5
Crocidolite CAS 12001-28-4 Asbestos Tremolite CAS 77536-68-6.

Specific testing techniques: Polarized Light Microscopy (PLM), electron microscope

techniques and/or X-Ray Diffraction (XRD) as applicable.

Specific reporting information: The presence/no presence of asbestos, indicate the

concentration range, and state the type when necessary.

Notes:
.1 The suggested three kinds of testing techniques are most commonly used
methods when analyzing asbestos and each of them has its limitation.
Laboratories should choose the most suitable methods to determine, and in
most cases, two or more techniques should be utilized together.
.2 The quantification of asbestos is difficult at this stage, although the XRD
technique is applicable. Only a few laboratories conduct the quantification
rather than the qualification, especially when a precise number is required.
Considering the demand from the operators and ship recycling parties, the
precise concentration is not strictly required. Thereby, the concentration
range is recommended to report, and the recommended range division
according to standard VDI 3866 is as follows:
• Asbestos not detected
• Traces of asbestos detected
• Asbestos content approx. 1% to 15% by mass
• Asbestos content approx. 15% to 40% by mass
• Asbestos content greater than 40% by mass
Results that specified more precisely must be provided with a reasoned
statement on the uncertainty.
.3 As to the asbestos types, to distinguish all six different types is time consuming
and in some cases not feasible by current techniques; while on the practical
side, the treatment of different types of asbestos is the same. Therefore, it is
suggested to report the type when necessary.

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2 Polychlorinated biphenyls (PCBs)
Note: there are 209 different congeners (forms) of PCB of it is impracticable to test for all.
Various organizations have developed lists of PCBs to test for as indicators. In this instance
two alternative approaches are recommended. Method 1 identifies the seven congeners used by
the International Council for the Exploration of the Sea (ICES). Method 2 identifies 19
congeners and 7 types of aroclor (PCB mixtures commonly found in solid shipboard materials
containing PCBs). Laboratories should be familiar with the requirements and consequences for
each of these lists.

Types to test for: Method 1: ICES7 congeners (28, 52, 101, 118, 138, 153, 180). Method 2:
19 congeners and 7 types of aroclor, using the US EPA 8082a test.

Specific testing technique: GC-MS (congener specific) or GC-ECD or GC-ELCD for

applicable mixtures such as aroclors. Note: standard samples must be used for each type.

Sample Preparation: It is important to properly prepare PCB samples prior to testing. For
solid materials (cables, rubber, paint, etc.), it is especially critical to select the proper extraction
procedure in order to release PCBs since they are chemically bound within the product.

Specific reporting information: PCB congener, ppm per congener in sample, and for
Method 2, ppm per aroclor in sample should also be reported.

Notes:
.1 Certain field or indicator tests are suitable for detecting PCBs in liquids or
surfaces. However, there are currently no such tests that can accurately
identify PCBs in solid shipboard materials. It is also noted that many of these
tests rely on the identification of free chlorine ions and are thus highly
susceptible to chlorine contamination and false readings in a marine
environment where all surfaces are highly contaminated with chlorine ions
from the sea water and atmosphere.
.2 Several congeners are tested for as "indicator" congeners. They are used
because their presence often indicates the likelihood of other congeners in
greater quantities (many PCBs are mixes, many mixes use a limited number of
PCBs in small quantities, therefore the presence of these small quantities
indicates the potential for a mix containing far higher quantities of other
PCBs).
.3 Many reports refer to "total PCB", which is often a scaled figure to represent
likely total PCBs based on the sample and the common ratios of PCB mixes.
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 Where this is done the exact scaling technique must be stated, and is for
information only and does not form part of the specific technique.

3 Ozone Depleting Substances

Types to test for: as per Appendix 8 of these guidelines all the listed CFCs, Halons, HCFCs
and other listed substance as required by Montreal Protocol.

Specific testing technique: Gas Chromatography-Mass Spectrometry (GC-MS), coupled

Electron Capture Detectors (GC-ECD) and Electrolytic Conductivity Detectors (GC-ELCD).

Specific reporting information: Type and concentration of ODS.

4 Anti-fouling systems containing organotin compounds as a biocide and/or

cybutryne
4.1 Anti-fouling systems containing organotin compounds as a biocide
Types to test for: Anti-fouling compounds and systems regulated under Annex I to the
International Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001
(AFS Convention), including: Tributyl tins (TBT), Triphenyl tins (TPT) and Tributyl tin oxide
(TBTO).

Specific testing technique: As per resolution MEPC.356(78) (2022 Guidelines for brief
sampling of anti-fouling systems on ships), adopted on 10 June 2022, using ICPOES, ICP, AAS,
XRF, GC-MS as applicable.

Specific reporting information: Type and concentration of organotin compound.

Note: For "field" or "indicative" testing it may be acceptable to simply identify presence of tin,
due to the expected good documentation on anti fouling systems.

4.2 Anti-fouling systems containing cybutryne

Types to test for: Anti-fouling systems containing cybutryne regulated under Annex 1 to the
International Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001 (AFS
Convention, as amended).

Specific testing technique: As per resolution MEPC.356(78) (2022 Guidelines for brief
sampling of anti-fouling systems on ships), adopted on 10 June 2022, using ICPOES, ICP, AAS,
XRF, GC-MS as applicable.

Specific reporting information: Concentration of cybutryne.

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4.3 Simplified approach to detect organotin compounds or cybutryne
Types to test for: Anti-fouling systems containing organotin compounds as biocides and/or
cybutryne regulated under Annex 1 to the International Convention on the Control of Harmful
Anti-fouling Systems on Ships, 2001 (AFS Convention, as amended).

Specific testing technique: As per resolution MEPC.356(78) (2022 Guidelines for brief
sampling of anti-fouling systems on ships), adopted on 10 June 2022, using GC-MS.

Specific reporting information: Concentration of organotin compound and/or cybutryne.

5. Perfluorooctane sulfonic acid (PFOS) (related to EU regulations)

If standards are established by the European Commission on Standards (CEN), the standards
should be applied. Until then, the tests should be conducted with reference to Annex C of
EMSA ’s Best Practice Guidance on the Inventory of hazardous Materials published in October
2016.

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 Appendix 10 Examples of radioactive sources
(Appendix 10 of the Convention Guidelines)

The following list contains examples of radioactive sources that should be included in the
Inventory, regardless of the number, the amount of radioactivity or the type of radionuclide.

Examples of consumer products with radioactive materials

Ionization chamber smoke detectors (typical radionuclides 241Am; 226Ra)
Instruments/signs containing gaseous tritium light sources (3H)
Instruments/signs containing radioactive painting (typical radionuclide 226Ra)
High intensity discharge lamps (typical radionuclides 85Kr; 232Th)
Radioactive lighting rods (typical radionuclides 241Am; 226Ra)

Examples of industrial gauges with radioactive materials

Radioactive level gauges ∗
Radioactive dredger gauges*
Radioactive conveyor gauges*
Radioactive spinning pipe gauges*

∗
Typical radionuclides: 241Am; 241Am/Be; 252Cf; 244Cm; 60Co; 137Cs; 153Gd; 192Ir; 147Pm;
238Pu; 239Pu/Be; 226Ra; 75S; 90Sr (90Y); 170Tm; 169Yb.
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