22nd October 2019
1. The primary regulations impacting the inventory of hazardous materials are as follows:
a) The Hong Kong International Convention for the Safe and Environmentally Sound
Recycling of Ships, not yet in force, and
b) The European Regulation No. 1257/2013 on Ship Recycling (EU SRR), having already
entered into force in December 2016, regulates the safe and environmentally sound
recycling of EU flagged vessels but also expanding to cover non-EU flagged vessels of
their last voyage from EU waters.
2. The Hong Kong International Convention covers the design, construction, operation and
preparation of ships, to facilitate sustainable ship recycling without compromising safety and
operational efficiency. EU SRR closely follows the text of HKC and is designed to facilitate
early adoption of the Convention.
3. The Hong Kong International Convention for the Safe and Environmentally Sound
Recycling of Ships.
4. The Hong Kong Convention was adopted in May 2009. After the entry into force of the
Convention, the development and maintenance of an Inventory of Hazardous Materials (IHM),
which identifies the amount and location of hazardous materials onboard a ship, will be
required for all ships over 500 GT. Furthermore, ships shall only be recycled at ship recycling
facilities authorized in accordance with the Convention.
5. Essential to the implementation scheme of the Hong Kong Convention and the EU SRR is
the development and maintenance of a document referred to as the Inventory IHM, listing the
type and amount of hazardous materials and their location on board. An IHM must be thorough
and ship specific and updated throughout the life of a vessel to support an effective plan to
discard hazardous materials.
6. Upon entry into force of the Hong Kong Convention all vessels to which this circular applies
should be certified in accordance with the requirements of the Convention. This Administration
recommends the early preparation of the IHM in order to smoothly implement the requirements
of the Convention after its entry into force.
IHM should be completed taking into account the relevant IMO guidelines and it should be
verified by a Recognized Organization to this Administration.
7. The EU Regulation No 1257/2013 on Ship Recycling (EU SRR)
8. EU adopted Regulation (EU) No. 1257/2013 which brings into force an early implementation
of the requirements of the Hong Kong Convention for the development and maintaining IHM,
including requirements for foreign or non-EU flagged ships.
The EU SRR will affect the owners of non-EU-flagged vessels calling at EU ports or
anchorage earlier than the Hong Kong Convention.
9. This requires a foreign or non-EU-flagged vessels of 500 GT and more, including
submersibles, floating crafts, 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, calling at EU ports or anchorages, to have onboard
a verified IHM, that identifies at least the hazardous materials required by the EU
Regulation, and a Statement of Compliance at the earliest by 31 December 2020.
10. It is important to note that, currently, any non-EU flagged vessel having a last voyage that
either starts from an EU port, or transits through an EU port, is subject to EU Waste Shipment
Regulation (and not the EU SRR). Therefore owners are advised to contact relevant EU port
authorities well in advance of the last voyage their vessel for further information.
11. Ship owners/ Ship operators/Managers and masters are required to take note of the above.
It is strongly recommended that owners and operators of existing vessels with IHMs start
planning to comply with EU SRR well ahead of December 2020 in order to avoid delays.
Revision History: Rev 1; Paragraphs 2,3,4,6,7,8,9 and 10 have been revised.
ST. VINCENT AND THE GRENADINES CIRCULAR N° GEN 024 - Rev.1 (15.3 KiB, 952 hits)