From 31 December 2020, the European Union’s Ship Recycling Regulations (EUSRR) will require ships of 500 GT and above flying the flag of countries in the European Union (EU), and all other ships regardless of the flag, to carry an inventory of hazardous materials (IHM) when visiting an EU or European Economic Area (EEA) port.
In May 2020, BIMCO asked its members if the COVID-19 pandemic outbreak had presented challenges to shipowners, who were in the process of completing their IHM and obtaining the necessary documentation prior to the compliance deadline of 31 December 2020. The responses showed that approximately 137 (58%) of the 236 ships operated by the respondents would be affected by the new regulation. Out of the affected ships, 33 (24%) had completed the process, while the rest were at various stages of compliance. The IHM process of almost all the respondents had been affected by the COVID-19 pandemic.
Taking this situation into consideration, BIMCO and other shipping organisations have signed a letter addressed to the EU Commission, in which the challenges posed by COVID-19 to the involved parties, especially shipowners are outlined. The letter requests the EU Commission to consider a time-limited implementation or grace period to enable shipping companies to complete the IHM process whilst coping with the COVID-19 restrictions and interruptions. The letter also includes a set of Industry Guidelines on European Union Ship Recycling Regulation Compliance and Developing Inventories of Hazardous Materials that BIMCO members are encouraged to use.
If the 31 December 2020 deadline cannot be met, BIMCO recommends the development of IHMs on the oldest ships first. Old ships are in general more likely to be recycled and such a risk based planning will demonstrate how shipowners are working proactively in accordance with the spirit of the new EU regulation.