Answer
With the Hong Kong International Convention (HKC) officially entering into force on June 26, 2025, port state controls are actively enforcing compliance. For an existing, 30-year-old vessel, you do not need to panic about immediate dismantling, but you must have the vessel certified to operate legally.
As the Chief Engineer, your practical focus is divided into two distinct parts: Maintaining the Operational IHM Certificate and Preparing the Vessel if it is Heading for the Recycling Yard.
Part 1: Operational Compliance (If the vessel is keeping on trading)
Existing ships have a grace period until June 26, 2030 to have a fully certified IHM on board, or it must be done at the first renewal survey after June 26, 2025.
1. The IHM Part I Book (Your Primary Responsibility)
The HazMat Survey: If not already done (for EU SRR compliance), the company must hire a class-approved HazMat Expert. They will come on board, take physical samples (gaskets, brake linings, insulation), and compile the Inventory of Hazardous Materials (IHM) Part I.
Where to find typical hazards on a 30-year-old ship:
Asbestos: Exhaust pipe insulation, flange gaskets, boiler cladding, gland packing, casing insulation.
PCBs (Polychlorinated biphenyls): Older transformer oils, capacitor banks, light ballasts, and heavy-duty paint primers.
Heavy Metals (Lead/Cadmium): Sacrificial anodes, old batteries, and electrical components.
2. Implementation into the SMS (Engine Room Management)
No New Asbestos / Prohibited Materials: Under Appendix 1 of the convention, installing new materials containing asbestos or ozone-depleting substances is strictly banned. You must ensure the crew does not bring old spares or unauthorized gasket sheets on board.
MD and SDoC Procurement: Every single time you order new machinery, components, valves, or re-order spares/coatings, you must request two documents from the supplier:
Material Declaration (MD)
Supplier’s Declaration of Conformity (SDoC)
Log Everything: Keep an "IHM Maintenance Log" in your office. If you replace an old auxiliary engine fuel pump with a new one, log the change, file the new MD/SDoC, and update the IHM inventory.
The Certificate: Once Class verifies the IHM Part I, they will issue the International Certificate on Inventory of Hazardous Materials (ICIHM). Keep this with the statutory certificates.
Part 2: If the Vessel is Heading for Final Recycling (Scrapping)
If the 30-year-old vessel is being sold for scrap, your job shifts significantly. You must transition the ship from an operational status to a "Ready for Recycling" status.
1. Compile Parts II and III of the IHM
While trading, you only needed Part I (fixed structure). For recycling, you must compile:
IHM Part II (Operationally generated waste): Log exact locations and quantities of sludge, bilge water, grey water, sewage, and garbage on board.
IHM Part III (Stores and Consumables): List all remaining lube oils, chemicals, paints, gases (refrigerants, oxygen, acetylene bottles), and spare parts.
2. Practical Tank & System Preparation (Engine Room)
De-sludging and Stripping: Pump out as much heavy fuel oil (HFO), diesel oil (MDO), and sludge to shore facilities as possible. Strip the double-bottom fuel tanks dry.
Oily Water & Bilges: Run the OWS or discharge bilge water to shore. Clean the engine room bilges and tank tops meticulously. Lingering oil creates a severe fire hazard when the yard begins torch-cutting the hull.
Refrigerant Management: Log and secure all hydrofluorocarbon (HFC) or CFC gases. Ensure there are no active leaks in the AC or provisions plants. The recycling yard will need to safely recover these.
3. The Final Certificates
Before the vessel sails on its final voyage to an authorized recycling yard (holding a valid DASR – Document of Authorization for Ship Recycling), you must have:
The Ship Recycling Plan (SRP): Developed by the chosen recycling yard, explicitly detailing how they will safely dismantle your specific vessel.
International Ready for Recycling Certificate (IRRC): Issued by your Flag State or Recognized Organization (Class) after a final survey on board to verify that the IHM is accurate and the ship is ready.
CE Exam Golden Rules (MEO Class 1 Focus)
Legislation: The Hong Kong Convention applies to all vessels > 500 GT.
Maintenance: My practical duty as CE is the continuous maintenance of IHM Part I via MDs and SDoCs for all incoming spares and machinery.
Prohibition: Zero tolerance for bringing asbestos-containing materials or prohibited ozone-depleting substances on board.
The One Document Found on All Ships to Use as a Baseline:
In formal IHM preparation, the General Arrangement Plan is normally the preferred overall base plan, supplemented by the Fire Control Plan, machinery arrangement, insulation plan and piping diagrams. The IMO guideline lists both tEvery ship has a GA plan prominently displayed and inside its stability booklet. This plan maps out every bulk compartment, tank, accommodation space, and machinery zone, allowing the surveyor to systematically plot where hazardous items are located and build the sampling matrix.