On October 20, 2020, the European Commission (EC) has issued guidelines on the enforcement of obligations under the EU Ship Recycling Regulation relating to the Inventory of Hazardous Materials of vessels operating in European waters (2020/C 349/01) acknowledging reports from industry stakeholders that COVID-19 restrictions have led to significant difficulties in surveying ships and producing certified IHMs.
Specifically, the guidelines call the EU port State authorities to gasp the challenges the industry is dealing with, and apply a harmonised approach temporarily for a limited period of 6 months after the entry into force of the IHM-related obligations for existing EU-flagged vessels and non-EU flagged vessels calling at EU ports, until 30 June 2021.
According to the EU, the vessels arriving at European ports after 31 December 2020 without carrying on board a valid IHM or semi-completed IHM will have to provide evidence of all the measures that were taken to undertake the IHM work and obtain the required certification and documentation.
In addition, EU member states are called to assess specific circumstances of each ship owner and the degree to which this case might apply. If the PSC inspector decides to accept the evidence provided by the owner/master, then the IHM should be completed and approved within 4 months of that inspection.
In case the plans are amended further after the inspection, due to continuing travel or access restrictions, then the owner/master needs to provide sufficient written evidence from the IHM inspectors that it has not been feasible to meet the initial plans.
It will then be for the PSC inspector undertaking the next inspection to decide whether this evidence is acceptable on a case-by-case basis depending on the specific circumstances of the vessel in question and using his/her professional judgement.
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