To remind, as of 31 December 2020, the EU Ship Recycling Regulation (1) requires all existing EU flagged ships and non-EU flagged ships calling to an EU port or anchorage to carry on-board an Inventory of Hazardous Materials (IHM) with a certificate or statement of compliance as appropriate.
Given the COVID-19 pandemic and the lockdown restrictions, the EU recognized the difficulties arising for the surveyors to go on-board ships to undertake surveys and to produce certified IHMs. It is estimated that several thousand ships are likely to be unable to comply with the IHM obligations and to have the required certification by 31 December 2020.
Therefore, they issued a notice, providing guidance to Member States on how to approach to enforcing obligations stemming from the EUSRR in two specific Covid-19 related scenarios, and agreed a temporary qualified extension of 6 months to the 31 December 2020 deadline (i.e. until 30 June 2021).
The two scenarios are:
- Vessels without a valid IHM and/ or accompanying certificate
According to the guidance, the owner/master will need to provide evidence that all possible measures were taken to undertake the work and get the certification required. Such evidence may include e.g. a service contract for sampling or a survey. It may also include a justification as to why it was not possible to obtain a semi-completed IHM and associated certificate as referred to below, including evidence of impossibility to comply with other elements of the certification. Simply claiming that this non-compliance is due to the Covid-19 situation will not suffice.
- Vessels with a semi-completed IHM with associated approved Certification that does not contain an on-board sampling
In all such cases, a remote survey/ sampling could be exceptionally accepted if there is evidence that the flag State has agreed to this. There will also have to be documented plans and arrangements kept on-board the ship indicating when it will be feasible for qualified samplers to complete the IHM. It is then for the inspector to decide whether this evidence is acceptable on a case-by-case basis. If the inspector is satisfied with the evidence provided, the Owner will be given another 4 months from the date of the inspection to complete the IHM and to get the same approved.
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