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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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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.
1/2

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, 63 hits)

 

 


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Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling Inventory of hazardous materials Overview IHM

 

The purpose of Regulation (EU) No 1257/20131 on ship recycling (hereinafter the “SRR”) is to prevent, reduce, minimise and, to the extent practicable, eliminate accidents, injuries and other adverse effects on human health and the environment caused by ship recycling. The Regulation is also designed to enhance safety, the protection of human health and of the Union marine environment throughout a ship′s life-cycle; in particular to ensure that hazardous waste from such ship recycling is subject to environmentally sound management. The Regulation also lays down rules to ensure the proper management of hazardous materials on ships.

The aim of this EMSA guidance is to assist the Member States and their designated inspectors in their efforts to fulfil the requirements of SRR and PSC Directive, in relation to inspections covering the respective requirements of these two instruments. It is a reference document that provides both technical information and procedural guidance thus contributing to harmonised implementation and enforcement of the provisions of the SRR and the PSC Directive.

Inventory of hazardous materials Overview IHM

During each inspection of a ship initiated under the PSC Directive regime, the port State control inspector (PSCO), as a minimum, must check the inventory certificate s (IC) or a ready for recycling certificate (RfRC) or a statement of compliance (SoC) as applicable is kept on board and report this in THETIS.
The IC and RfRC formats, which have been established, respectively, under Commission Implementing Decisions (EU) 2016/2325 and 2016/2321 can be found in Annexes 4 and 5 of this guidance document. A model of a SoC that may be used for ships flying the flag of a third country is provided in Annex 3 of this guidance document.
It should be noted that, any initial check of the SR certificates or the PSCO’s observations of the ship may reveal clear grounds to imply that the ship is not in compliance with the SRR. In this case, the PSCO will continue the inspection under the SRR regime.

Before boarding, relevant information about the ships in port may be obtained from THETIS or THETIS-EU and other sources (e.g. from AIS, NGOs, port Authorities etc). This may include information on ship particulars, last and next port of call, arrival and departure times, port stay duration, possible intention to send the ship for recycling etc. Further information may directly be obtained through the port Authorities or the ship’s agent

The general application date of the SRR was 31 December 2018. From thereon, new EU ships6 have to carry a the inventory certificate (IC) and EU ships going for recycling have to carry a ready for recycling certificate (RfRC).
However, it should be noted that existing EU ships7 shall only carry a certificate on the inventory of hazardous materials (IC) from 31 December 2020.
Moreover, non-EU ships should only be requested to submit a statement of compliance (SoC), together with the inventory of hazardous materials, from 31 December 2020.

Inventory of hazardous materials Overview IHM

  INSPECTIONS FROM THE EU PORT STATES TO ENFORCE PROVISIONS OF THE SHIP RECYCLING REGULATION INVENTORY OF HAZARDOUS MATERIALS OVERVIEW IHM (2.8 MiB, 49 hits)


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