In an effort to help shipowners and operators better prepare for the upcoming deadline of IHM compliance, Lloyd’s Register issued frequently asked questions around the EU SRR regulation.
To remind, starting from 31 December 2020, ships above 500 GT and flying the flag of an EU/EEA member state, or third-party flagged vessels calling at European ports, must carry an Inventory Hazardous Materials (IHM) certificate on board.
Specifically, IHM is an inventory of any materials present in a ship’s structure, systems and fitted equipment that may be hazardous to human health and the environment.
In light of the situation, EU-flagged ships will require an Inventory Certificate and non-EU flagged ships will need a Statement of Compliance (SoC) against the regulation.
Therefore, shipowners and operators should have already started this process so as to ensure compliance before the deadline.
Although, for those who have not started yet, they are adivsed to start as soon as possible.
We recommend that shipowners who are yet to start the certification process do not delay this while awaiting their Flag to authorise ROs for this work (unless the Flag itself can commit to completing all work before thedeadline).
…as LR stated.
In order to support shipping industry for this change, Lloyd’s Register gathered major information and answered the most frequently asked questions:
Do I have to have an IHM and certification ahead of legislation entering into force?
Yes. In our experience, shipowners and operators need at least six weeks to compile a new IHM for an existing ship.
However, this is typically longer if the services of an expert company are employed to undertake hazardous material sampling on board (which LR recommends).
It then takes a month or so for ROs to carry out approval, verification and certification work.
For third country vessels not planning to call into the EU until later in 2021, certification only needs to be in place before this date. However, we still strongly recommend aiming to achieve this before the end of 2020 because:
- Trading routes are ever more likely to change, which could make the requirement more urgent
- The time it can take to achieve compliance, especially due to COVID travel restrictions
What is the likelihood of the EU SRR deadline being extended, in light of COVID-19?
Based on current feedback from the European Commission (EC), the likelihood of the EU SRR being extended is small.
We recommend that shipowners and operators concentrate on the elements within their control and ensure as a minimum that they have:
- contracted a HAZMAT specialist in good time to compile the sampling and IHM and make every effort to get the work completed
- contracted with the relevant Flag or RO to conduct the approval and verification work required for certification.
What information is needed to be provided to LR in order to get IHM certification?
For existing ships, LR will request the following documentation be provided as a minimum, ahead of the desktop approval, on-board IHM verification survey and ultimate certification:
- a completed IHM on the LR template
- a Hazardous Materials Expert Sampling report for all hazardous materials within the structure, system and fitted equipment of the vessel (if compiling the IHM initially for full HKC and EU SRR compliance)
- Asbestos-free certificate from build
- PCB-free certificate
- International Air Pollution Prevention (IAPP) Certificate and Supplement to IAPP Certificate (recording machinery and equipment containing Ozone Depleting Substances (ODS)) as required by MARPOL Annex VI
- Antifouling certificate
- Evidence of a procurement policy in place (restricting the hazards identified in the legislation from being brought on board)
How long after IHM approval does the on-board verification and certification have to be completed?
Upon satisfactory completion of the IHM approval, the IHM must be verified on board before a statement/certificate can be issued. While there is no limit of time stated in legislation between approval and onboard verification, it is recommended to complete the verification survey as soon as possible after the approval.
This minimises the likelihood of any repairs or modifications being made to the structure, equipment and fittings, which would then result in potential updates to/maintenance of the IHM.
How should the IHM be maintained?
In order to uphold IHM certification, the IHM itself must be maintained and updated during vessel operation using the official IHM template provided by LR.
If any items recorded in the IHM are added to, removed or replaced, or the hull coating is renewed, the IHM should be updated using information obtained from Material Declarations (MD) and Supplier Declarations of Conformity (SDoC) forms.
At LR, we are committed to supporting safe and environmentally sound ship recycling. IHM compliance is one part of our wider ship recycling services. We have in-depth knowledge of ship recycling legislation, standards and practices through our work at IMO, IACS and the International Ship Recycling Association (ISRA).
…as LR concluded.
