ClassNK has issued Technical Information TEC – 0978 regarding the new EU Regulation on Ship Recycling which entered into force on December 30, 2013. The Regulation requires the development of Inventory Hazardous Material (IHM) for both EU flagged ships and non- EU flagged ships. TEC 0987 provides a summary of the Regulation as follows:
The Regulation is basically in line with the Hong Kong Convention. Requirements are applied to:
2) ship recycling facilities (SRFs), and
3) procedure when ships are recycled
The regulation is applicable for both ships flying the flag of a Member State (EU flagged ships) and ships of a third country calling at a port or anchorage of a Member State (non-EU flagged ships). However, applicable ships are limited to the commercial ships more than 500 gross tonnage (GT). Also, the requirements for non-EU flagged ships are limited to having on board an IHM and acceptance of Port State Control (PSC).
The installation or use of hazardous materials referred to in table below on ships shall be prohibited or restricted. Perfluorooctane sulfonic acid (PFOS) is newly added to those of the Hong Kong Convention.
|Prohibited or restricted materials||Asbestos|
|Ozone- depleting substances|
|Polychlorinated biphenyls (PCB)|
|Perfluorooctane sulfonic acid (PFOS / is not applicable for non- EU flagged ships|
|Anti- fouling compounds and systems|
Ships shall have on board an IHM, which is properly maintained and updated throughout the operational life of the ship. Prior to recycling, IHM shall be finalized and provided to a ship recycling facility. Hazardous materials to be listed in an IHM are specified in table below. Brominated Flame Retardant (HBCDD) is newly added to those of the Hong Kong Convention. Regarding the materials except for those listed in prohibited or restricted materials, existing ships shall comply, as far as practicable, with this requirement.
|List of Items for the IHM|
|Any hazardous materials listed in first table, Cadmium and Cadmium Compounds, Hexavalent Chromium and Hexavalent Chromium Compounds, Lead and Lead Compounds, Mercury and Mercury Compounds, Polybrominated Biphenyl (PBBs), Polybrominated Diphenyl Ethers (PBDEs), Polychlorinated Naphthalenes (more than 3 chlorine atoms), Radioactive Substances, Certain Shortchain Chlorinated Paraffins (Alkanes, C10-C13, chloro) and Brominated Flame Retardant (HBCDD)|
Time to develop part I of an IHM and have it onboard
|Applicable Ships||Definition of the ships||Time to develop part I of an IHM and to have it on board|
|EU flagged new ships||An EU flagged ship for which either:
(a) the building contract is placed on or after the date of application of this Regulation;
(b) in the absence of a building contract, the keel is laid or the ship is at a similar stage of construction six months after the date of application of this Regulation or thereafter; or
(c) the delivery takes place thirty months after the date of application of this Regulation or thereafter
|Before put in service after the application date of the Regulation
(As for the application date, please refer to “2. Application of the EU Regulation”.)
|EU flagged existing ships||EU flagged ships which is not “EU flagged new ships”||Before 31 December 2020 (If a ship is recycled before 31 December 2020, IHM shall be prepared prior to recycling.)|
|Non-EU flagged ships||Ships of a third country calling at a port or anchorage of a Member State||Before 31 December 2020|
In addition to control of hazardous materials and IHMs, ship owners shall ensure that the ships destined to be recycled are only recycled at the recycling facilities included in the European List, which is the list of authorised ship recycling facilities in accordance with the Regulation.
A ship-specific ship recycling plan shall be developed prior to any recycling of a ship by the operator of the ship recycling facility. Surveys of ships shall be carried out by officers of the administration, or of a recognised organisation authorised by it. Port State Control (PSC) is applicable for both EU flagged ships and non EU flagged ships.
Requirements for Non-EU flagged ships
Non-EU flagged ships shall have on board an IHM when calling at a port or anchorage of a Member State. The statement of compliance (SOC) shall be issued after verification of the IHMs by the relevant authorities of the third country whose flag the ship is flying or an organisation authorised by them, in accordance with the national requirements. PSC are imposed upon both EU Flagged ships and Non-EU flagged ships at the port of a Member State.
Requirements for ship recycling facilities (SRFs)
A SRF shall comply with the following requirements in addition to those required by the Hong Kong Convention
- demonstration of the control of any leakage, in particular in intertidal zones
- handling of hazardous materials, and of waste generated during the ship recycling process, only on impermeable floors with effective drainage systems
Requirements for waste management facility
- demonstrate that the waste management facility which receives the waste will be operated in accordance with human health and environmental protection standards that are broadly equivalent to relevant international and Union standards
Dates of Applicability
- The provisions for the requirements for ship recycling facilities to be included in the European List , and for EU to establish the European List (Article 13, 14, 15, 16, 25, and 26) from 31 December 2014 (According to this provision, the European List might be established on 31 December 2014 at the earliest. After the European List is established, the IHM shall be required for the recycling of EU flagged ships at the ship recycling facility included in the European List.)
- The provisions for keeping IHM on board for EU flagged existing ships and non-EU flagged ships calling at a port or anchorage (the part of Article 5 and Article 12) from 31 December 2020
Two hazardous materials newly added in the Regulation
(1) Perfluorooctane sulfonic acid (PFOS)
PFOS is a substance which has been used mainly for surfactants. There is a report it was used for fire fighting foams of the type AFFF (Aqueous Film Forming Foams) on board ships. In May 2009, PFOS was banned on production and use in principle by the Stockholm Convention on persistent organic pollutants by the Fourth Conference of Parties. In Japan, PFOS is banned on production and use under the Chemicals Substances Control Law in April 2010.
(2) Brominated Flame Retardant (HBCDD)
HBCDD (Hexabromocyclododecane) is a brominated flame retardant used in expanded polystyrene (EPS) and textile. The main application on board ships is considered to be EPS used for cryogenic insulation, such as for liquefied gas tanks (LGT) and for refrigerator areas. In April 2013, HBCDD was banned on production and use in principle by the Stockholm Convention on persistent organic pollutants by the Sixth Conference of Parties. In Japan, PFOS will be banned on production and use under the Chemicals Substances Control Law in 2014.
|Statement of Fact for the IHM issued by ClassNK
Concerning List of Items for the IHM, the EU regulation adds two substances of PFOS and HBCDD to the one provided in the Ship Recycling Convention. For the Statement of Fact (SOF) issued by ClassNK, the following is ClassNK’s recognition and measures taken.
EU Flagged ships
For ClassNK issued SOFs for the IHMs of EU-flagged existing ships, checking on PFOS shall be required to comply with the EU Regulation (PFOS is applicable only for EU flagged ships and HBCDD should be checked as far as practicable). The related procedures will be informed later.
Non-EU flagged ships
For ClassNK issued SOFs for the IHMs of non-EU flagged ships, they are considered to have complied with the EU Regulation as requirements on PFOS are not applicable to them. Regarding issuance of the inventory certificate and statement of compliance (SOC) required by the Regulation, ClassNK is researching on details to the Flag States so that the SOF which ClassNK has already issued can be utilized effectively. The results will be informed later.
Also, view REGULATION (EU) No 1257/2013 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC by clicking at TEC- 0897 issued by ClassNK