How IHM Part I is documented under the Hong Kong Convention for ships in operation; scope of IHM Part I; the Basel Convention; and how Basel differs from the Hong Kong Convention.

(1) Documentation of Inventory of Hazardous Materials (IHM) Part I under the Hong Kong Convention.

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009) requires ships to carry an Inventory of Hazardous Materials (IHM). For an existing ship in operation (a ship already built before the Convention's entry into force, recycling facility commencement), Part I of the IHM is the "Inventory of Hazardous Materials" of the ship which lists the hazardous materials used in the ship's structure and equipment. Documentation:

• The IHM Part I is developed on the basis of a "pre-verification" and is to be verified and certified: the shipowner/operator, assisted by the ship's builder (for new ships) or a competent/recognised party, prepares a preliminary IHM which is then refined following the actual survey of the ship ("SAM" - sampling and audit?) - the IHM Part I is prepared by the shipowner and verified by the Administration or a recognised organisation (RO).
• For ships engaged in international voyages, the IHM Part I must be verified by the flag Administration/RO and an International Certificate on Inventory of Hazardous Materials (ICIHM) is issued (for new ships the certificate is endorsed at initial survey; existing ships are given a period after entry into force, e.g. 5 years, to comply and be certified; ships being recycled need an IHM approved by the recycling State).
• The IHM Part I should list, at a minimum, the hazardous materials (with their locations) that are to be recycled; it must be kept on board and updated whenever there is a change (installation/removal) of the relevant materials; it is reviewed at surveys.
• Content: at a minimum, the IHM Part I required to be developed must account for the appendix items: asbestos, polychlorinated biphenyls (PCBs), ozone-depleting substances (ODS), antifouling compounds (organotin), plus those in Appendix 1 (such as lead, mercury, cadmium, chromium VI, PFOS etc.) as applicable; the Extended analysis identifies other potentially hazardous materials where required.
• The IHM Part I is the essential document exchanged to the ship recycling facility as the basis for the Ship Recycling Plan and Safe- for-hot-work/void- certified work; it supports the recycling certificate and the statement of completion.

(2) Scope of IHM Part I.

• IHM Part I is designed to identify, for the in-service ship, all the hazardous materials used in the construction, outfitting and systems of the ship, together with their approximate quantities and locations.
• It covers the ship's structure (hull, bulkheads, deck), machinery and equipment, piping, insulation, flooring, cables, paints/coatings and all items that will be recycled - so that when the ship is eventually recycled, the facility knows what hazardous materials are present (and where) so they can be handled/recovered safely.
• It must be updated for the life of the ship to reflect changes, and the exact location and quantity recorded.

(3) Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.

The Basel Convention (1989, in force 1992) is a global environmental treaty that controls the transboundary movements (exports/imports/transit) of hazardous wastes and their disposal. It aims to reduce the generation of hazardous waste, ensure environmentally sound management (ESM), and prevent the transfer of hazardous wastes from developed to developing ("illegal traffic") states. It requires prior informed consent (PIC): the exporting State must notify the importing (and transit) States, obtain consent, and the movement must be documented with a movement document; hazardous wastes cannot be exported to non-parties (without agreement) or to states unable to manage them; it establishes the principle that hazardous waste should be disposed of as close as practicable to the place of generation. Once a ship becomes a "waste" (is recycled/end-of-life), the ship and its hazardous materials fall under the Basel regime for transboundary movements and recycling.

(4) How the Basel Convention differs from the Hong Kong Convention.

• Scope: Basel deals with the transboundary movement and disposal of hazardous wastes generally (including end-of-life ships being exported for recycling); Hong Kong Convention deals specifically with the safe and environmentally sound recycling of ships, their design, construction, operation, preparation for recycling, and recycling facilities.
• Approach/regulatory instrument: Hong Kong is a maritime convention under IMO regulating ship recycling design/operations and providing for certificates (ICIHM, IRC for facilities, SOC), while Basel (UNEP) governs the export/import of hazardous waste requiring consent between States.
• The ship/hazardous nexus: under Basel an end-of-life ship (if it contains hazardous wastes) is subject to the transboundary controls so it may only be exported to a State with an authorised recycling facility and with consent; Hong Kong sets out the technical and certification requirements for the ship and the recycling yard, and directs that the ship should not be "dumped" as waste but recycled in an environmentally sound manner (it regulates the recycling, not just the movement).
• Hong Kong requires an IHM (hazardous materials inventory) and ship recycling plans, and issues certification; Basel requires a movement document and prior informed consent for export. In practice, when the IHM (Hong Kong) verifies and the quantities are in line, the export can be permitted either under Basel PIC or under the "supported recycling facility" — the two instruments are complementary: Basel for transboundary consent, Hong Kong for the safe recycling operations and certification. Hong Kong is limited to ships registered by and recycling facilities certified by parties; Basel governs waste export worldwide and includes also the right of importers to refuse.

(Note: A "green recycling" ship that complies with Hong Kong has the IHM confirming hazardous materials are within acceptable limits, which interacts with Basel compliance.)