## 4 Discussion
Nevertheless, the breach of existing rules owing to the illegal trafficking of waste ships has been achieved by selling end-of-life vessels to so-called cash buyers acting as intermediaries for South Asian shipbreaking yards [89]. The current treatment of SCCPs under the Hong Kong Convention and the EU SRR allows the installation or use of products containing them on ships. This implies that ships can be a source of SCCPs that will significantly contribute to the contamination of shipbreaking areas in countries with weaker environmental protection/worker health standards well into the future. Moreover, shipbreaking operations are not the only source \begin{table}
\begin{tabular}{c c} \hline \hline
**Materials and Products** & **Maximum SCCP** \\  & **Content (mg/kg)** \\ \hline Soft plastic items made of PVC (electrical cable sheathing, & \\ plumbing, conveyor belts, imitation leather, flooring, & 100,000 \\ signage, inflatable products, etc.) & \\ \hline Rubber products (conveyor belts, cables, hoses, seals, & 70,000 \\ gaskets, coatings, bearings, etc.) & \\ \hline Waterproofing and fire-retardant pains and coatings & \\ (anti-corrosive coatings for metal surfaces, tank coatings, & 200,000 \\ decorative pains for internal and external surfaces, & \\ intumescent coatings, etc.) & \\ \hline Adhesives and sealants (structural adhesives, adhesives for & \\ teak decking, pipe and flange sealants, anti-vibration & 300,000 \\ sealants, tank sealants, etc.) & \\ \hline Flame-retarding, water-repelling, and rot-preventing textile & \\ finishes (furniture upholstery, seating upholstery, interior & 150,000 \\ textiles, etc.) & \\ \hline Lubricants (main engines and auxiliary engines, gearboxes, & \\ bearings, hydraulic systems, pumps, etc.) & 700,000 \\ \hline \hline \end{tabular}
\end{table} 
Table 1: Maximum concentrations of SCCPs in products that can be found on ships (based on data from [86] adapted for this work). of the emissions. A considerable proportion of waste electric and electronic equipment originating from end-of-life vessels is dismantled improperly, worsening pollution in other areas too [90]. The presence of SCCPs on existing ships poses a potential risk to human health and the environment even if dismantling is performed in recycling facilities compliant with requirements. Specifically, ships destined for recycling require a ship-specific IHM to assist recycling facilities in developing ship recycling plans. However, the specific requirements for developing Part I of the IHM differ between new and existing ships. For new ships, the IHM must be developed during the design and construction phases, ensuring that information on hazardous materials is integrated into the ship's design and construction process. For existing ships whose building contracts were placed before the entry of the regulations into force, the IHM must be developed within five years following the regulations' effective date or before the ship is sent for recycling, whichever occurs sooner. Yet, once an IHM becomes mandatory (for all existing EU-flagged ships and non-EU ships calling at an EU port or anchorage since 31 December 2020), materials listed in Annex/Appendix II do not need to be listed in Part I of the IHMs of existing ships. This means that, according to current requirements, existing ships can be sent for recycling without any data on the location and quantities of SCCPs, which opens the possibility of unintentional discharge. Furthermore, while the Hong Kong Convention and the EU SRR are designed to address issues related to ship recycling, the inclusion of materials listed in Appendices/Annexes I and II also impacts the exposure of ship crews during routine operations, maintenance, or accident-related scenarios. To the best of the author's knowledge, there is no published data on the levels of SCCPs aboard ships. Nonetheless, due to strict fire safety requirements, elevated levels compared to residential and office environments can be expected.