## 1 Introduction
IMMs, specific to each ship, comprise Part I (a list of hazardous materials contained in the ship's structure and equipment with an indication of their location and approximate quantities), Part II (a list of operationally generated wastes), and Part III (a list of stores). IHM Part I preparation is the responsibility of the shipyard for new ships and the shipowner for vessels in operation. Part I of the IHM lists materials referred to in Annexes I and II (EU SRR, 15 hazardous substances) or Appendices I and II (Hong Kong Convention, 13 hazardous substances). Materials whose installation or usage is prohibited and/or restricted in shipbuilding covered by Appendix I are asbestos, ozone-depleting substances, polychlorinated biphenyls (PCBs), and anti-fouling compounds and systems (currently tributyltin and cybutryne). Annex I also covers perfluorooctane sulfonic acid (PFOS). Hazardous materials that are likely to lead to significant adverse effects on human health or the environment listed by Appendix II are cadmium and cadmium compounds; hexavalent chromium and hexavalent chromium compounds; lead and lead compounds; mercury and mercury compounds; polybrominated biphenyl (PBBs); polybrominated Diphenyl Ethers (PBDEs); polychlorinated naphthalenes (more than three chlorine atoms); radioactive substances; and certain short-chain chlorinated paraffins (alkanes, C10-C13, chloro). Annex II also lists brominated flame retardant (HBCDD). Short-chain chlorinated paraffins (SCCPs) are present onboard ships mostly as constituents of lubricants, paints, and flame retardants [8]. Most frequently, they can be found in equipment made of non-flammable plastics, and as mentioned above, they are listed in Annex II and Appendix II. They belong to chlorinated paraffins (CPs), a class of industrial chemicals synthesized through the chlorination of n-alkanes to a degree of 30-72%by weight. CPs are characterized by the general formula CnH2n+2-mClm and classified into short-chain (SCCPs, C\({}_{10-13}\)), medium-chain (MCCPs, C\({}_{14-17}\)), and long-chain (LCCPs, C\({}_{18-30}\)) CPs. SCCPs have been used as plasticizers or fire retardants in paints, cohesive, sealants, fat liquors for leather, plastics, lubricants, textiles, rubber, and polymeric materials [9]. SCCPs exhibit significant persistence in the air, allowing for long-range transport. They are also hydolytically stable, making them resistant to degradation. Many SCCPs can accumulate in organisms, leading to bioaccumulation. Given these properties, it is highly likely that SCCPs pose substantial risks to both the environment and human health due to their widespread distribution. Therefore, they have been listed in Annex A (Elimination) of the Stockholm Convention on Persistent Organic Pollutants (POPs) in 2017 [10]. Regulation 6 of the Hong Kong Convention outlines the procedure for proposing amendments to Appendices 1 and 2. As part of the procedure, a technical group established by the Marine Environment Protection Committee (MEPC) of the IMO evaluates whether the hazardous material in question is likely, in the context of the convention, to lead to significant adverse effects on human health or the environment such that the amendment of Appendix 1 or Appendix 2 is warranted. However, since the adoption of the Hong Kong Convention in 2009, the content of Appendices 1 and 2 has not been changed. Similarly, Annexes I and II of the EU SRR have remained the same since 2013. On the other hand, during this period, SCCPs have been included in the Stockholm Convention. Moreover, a growing body of knowledge indicates that they are present in all components of the environment and humans and pose a not negligible health risk [11]. Therefore, there is a need to evaluate whether the Hong Kong Convention's and the EU SRF's treatment of SCCPs provide sufficient protection for human health and environmental quality. The motivation and novelty of this paper lie in examining the extent to which SCCPs present in ships pose a threat to humans and the environment during the ship dismantling process.