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EU Ship Recycling Regulation

Vessels over 500gt in EU waters will be required to carry a verified Inventory of Hazardous Materials on board…

Facilitating ratification of the IMO’s Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, the EU Ship Recycling Regulation (EU SRR) aims to regulate the ship-recycling industry to ensure that end-of-life vessels are dismantled safely, with minimum impact to human health and the environment.

The regulation requires that any ship of 500gt and above, of any flag calling at an EU port or anchorage, will require a Certificate of Compliance (if EU flagged) or Statement of Compliance (if non-EU flagged) supplemented by a verified Inventory of Hazardous Materials (IHM) by the 31 December 2020.

The Certificate of Compliance means, among other things, that the vessel shall only be sent to recycling facilities included in the European List of Ship Recycling Facilities at the end of its life. The IHM provides ship-specific information on the actual hazardous materials present on board in order to protect health and safety and to prevent environmental pollution at ship-recycling facilities.

Many flag states have delegated the authority for the verification of compliance to their respective classification societies. As such, Lloyd’s Register has been supporting stakeholders throughout the recycling supply chain to ensure all activities are environmentally sound, compliant and safe.

Lloyd’s has reported an enormous uptake in on-board IHM certification as a consequence of the regulation and states that the demand put on certified material samplers will grow significantly in the near future. However, Lloyd’s advises that those requiring certification should make sure there is no conflict of interest, which has become apparent with some offerings of IHM certification.

“Flag and port states might be wary of IHM certification or statements, particularly when the required sampling of materials and certification is done by the same company – it is recommended to keep these clearly separate,” explains Engel de Boer, yacht segment manager at Lloyd’s Register.

 

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Inventory of Hazardous Materials (IHM)

While much of the shipping world’s attention is focused on IMO’s sulphur cap entering into force on 1 January 2020, there is another important date for shipping coming up in the diary in 2020!

December 2020 will be a key month for the EU’s Ship Recycling Regulation (SRR). Adopted in 2013 and aimed at reducing negative environmental impacts associated with recycling ships flying the flags of EU member states, the regulation sets out requirements that ships and recycling facilities must fulfil.

A key element of this is the Inventory of Hazardous Materials (IHM), which since 31 December 2018 has been required for newly contracted vessels with a gross tonnage of 500 or more flying the flags of EU member states. From 31 December 2020, this requirement will be expanded to the existing EU fleet. But owners of non-EU flagged vessels also need to have an understanding of the SRR and IHM process as, from 31 December 2020, equivalent non-EU flagged vessels calling at EU ports or anchorages will also be required to carry and maintain an IHM.

The elements of the SRR relating to vessels coming to the end of their working life, applying to ships flying the flag of EU being sent for recycling, have been in force since 31 December 2016. Before delivery to a recycling facility, vessels should have parts 1, 2 and 3 of the IHM completed in order to receive an International Ready for Recycling Certificate from their class society.

The IHM covers fifteen substances and is aimed at controlling and documenting hazardous materials on board ships. It requires expert knowledge to compile and will be produced by a third-party inspection specialist and validated by class.

Inventory of Hazardous Materials (IHM)

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