ICS, the International Shipsuppliers & Services Association (ISSA), BIMCO and the International HazMat Association (IHMA) have collaborated to develop a new guide to help both shipowners and ship suppliers comply with both the current EU Ship Recycling Regulations (EUSRR) and the Hong Kong Convention on Ship Recycling (HKC) where ratification is anticipated next year.
aterials Declarations for Inventories of Hazardous Materials aims to clarify the exchange of information between shipowners and suppliers. The guide helps shipowners and suppliers to understand the legislation, reduce the administrative burden for both parties, and ensure that the IHM is completed properly.
Under both sets of regulations, the shipowner must develop and maintain an Inventory of Hazardous Materials (IHM) for each vessel they own. In support of this, ship suppliers must provide material declarations (MDs) and Supplier’s Declarations of Conformity (SDoC) for equipment delivered to the ship.
Efforts to comply with these requirements have caused a significant increase in shipowners’ requests for material declarations from suppliers, in excess of what is required and placing a considerable administrative burden on these suppliers. In turn a lack of awareness by suppliers of their responsibilities in providing accurate material declarations on request can also impact on the accuracy of the IHM
the partners said.
Materials Declarations for Inventories of Hazardous Materials contains a series of tables showing what should and should not be included in the materials declaration, demonstrates how to complete the paperwork and talks users through common mistakes.
Shipowners are rightly concerned about ensuring that the inventories are as complete as they possibly can be. However, this has caused confusion as to what should be covered by materials declarations and a level of anxiety from ship suppliers as they endeavour to fulfil what are, at times, impossible requests
Sean Moloney, ISSA Secretary, stated.
Material Declaration (MD) Requests
Some typical examples of MD requests that are often made, where no MD is in fact necessary, include:
- Tools (whether hand, mechanical, electrical or diesel powered);
- Televisions, PCs or related equipment, toaster, microwave, fridge etc – all household-like electrical equipment;
- Identical replacement parts for existing machinery;
- Uncoated metal parts like ball bearings, piston rings, push rods, steel plates;
- Linen or clothing;
- Ropes and lines;
- Food & beverages.
Responsibility of the supplier
On receipt of a request from a shipowner or their representative for an MD and SDoC, suppliers should identify and declare in an MD whether or not the materials listed in Table A and Table B (and the two additional substances introduced by EUSRR) are present above the threshold value.
If the required information is not available, the supplier should obtain it from its sub-supplier. The supplier to the vessel shall be responsible for the information provided to the shipowner and must issue its own MD and SDoC. The supplier shall not pass on documents issued by its sub-suppliers, but should retain all supporting documents provided to him by its sub-suppliers.
Under both the EUSRR and the HKC the supplier is only obliged to provide an MD where the item supplied is one that requires an MD. Where an MD request is received for an item that does not require one then the supplier should advise the shipowner accordingly and reference these guidelines.
Dialogue and Reporting
MDs and SDoCs should be reviewed by the shipowner or its representative in the context of the ship specific IHM once they have been received.
Where the forms are not fully compliant, the shipowner should provide the supplier with the reasons for their rejection in the spirit of a collaboration to achieve effective compliance with the IHM requirements.
Collaboration between shipowners and suppliers in the development and maintenance of IHM Part I is fundamental to facilitating safe and environmentally sound ship recycling, and the wider effort to reduce the environmental impact of shipping.