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IHM and ship recycling

August 25, 2020 Inventory of Hazardous Materials (IHM)

In view of an increased concern about various environmental issues, the focus on the use of non-hazardous materials in ship design, building and operation is also increasing. Two regulations are presently governing these issues:

  • Regulation (EU) No. 1257/2013 of the European Parliament and of the Council of 20 November 2013 on Ship Recycling (EU SRR)
  • Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC)
IHM and EU Ship Recycling - DNV GL Maritime
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EU SRR vs IMO HKC

The EU SRR and the HKC, both statutory requirements, place responsibility on ship owners, ship builders, suppliers, recycling facilities and national authorities to ensure the safe and environmentally viable management of hazardous materials (hazmats) as well as the sustainable recycling of ships. A fundamental requirement of these regulations is the documentation of hazardous materials on board ships, the so-called Inventory of Hazardous Materials (IHM), and the authorization of ship recycling facilities.

The table below provides an overview of the requirements from the two regulations in terms of their scope and certification:

EU SRR vs IMO HKC

COMPARISON
EU SRR
IMO HKC

Entry into Force

31 Dec 2018

  • for EU/EEA flagged new* ships; and
  • for EU/EEA flagged ships going for recycling

31 Dec 2020 for all EU/EEA flagged ships and third part ships visiting EU/EEA ports and anchorages

Not yet ratified

Applicability

EU/EEA flagged ships ≥ 500 gross tonnage (GT)Ships ≥ 500 gross tonnage (GT) calling any EU/EEA ports/anchorages

Ship Recycling Facilities (SRFs) (European List)

Ships ≥ 500 gross tonnage (GT)Ship Recycling Facilities

Excluded

any warships, naval auxiliary, or other ships owned or operated by a Party and used, for the time being, only on government non-commercial service;ships of less than 500 GT; or

ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly.

any warships, naval auxiliary, or other ships owned or operated by a Party and used, for the time being, only on government non-commercial service; ships of less than 500 GT; or

ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly.

IHM

IHM Part I investigates 15 hazardous materials listed in Annex I & II

IHM Part I investigates 13 hazardous materials listed in Appendix I & II
IHM Certification done by

Flag states or ROs

  • IC (IHM Certificate) for EU/EEA flagged ships
  • SoC (Statement of compliance) for third party flagged ships

Flag states or ROs

  • ICIHM – International Certificate on IHM
SRF authorization
European Commission through site inspections accept SRFs to «European List»
Competent authority of each party authorizes its SRFs

According to EU SRR, “new ship” means ships; building contract is signed on or after 2018-12-31, or in the absence of building contract, if keel is laid on or after 2019-06-01, or delivery date is after 2021-06-01.

“Ship” means a vessel of any type whatsoever operating or having operated in the marine environment and includes submersibles, floating craft, floating platforms, self elevating platforms, Floating Storage Units (FSUs), and Floating Production Storage and Offloading Units (FPSOs), including a vessel stripped of equipment or being towed.

Source: dnvgl