The Republic of the Marshall Islands (RMI) Maritime Administrator issued a Technical Circular conveying its exceptional agreement for remote surveys/sampling to be conducted onboard RMI-flagged vessels with respect to the Inventory of Hazardous Materials (IHM) required under EU Regulation 1257/2013, when, due to COVID-19 restrictions, onboard attendance is not possible.
1.When, due to COVID-19 restrictions, onboard attendance is not possible by an IHM Expert Company for the purposes of conducting the sampling portion of the IHM Part I preparation, the Administrator agrees to sampling by the ship’s crew under the remote guidance and direction of the IHM Expert Company.
This is on the condition that documented training and qualification records are provided for the crew which cover the sampling procedures, hazard awareness, and safety measures to be implemented, including the requisite personal protective equipment (PPE).
The IHM Expert Company is to ensure that onboard visual and sampling checks are carried out in accordance with the visual and sampling checks plan prepared by the IHM Expert Company. The samples are then to be packaged and sent ashore to the IHM Expert’s appointed laboratory, and the IHM Part I process completed in the normal manner.
2. Where a vessel has a semi- or partially-completed IHM with an associated approved Statement of Compliance that does not contain on board (either targeted or random) sampling, the Administrator exceptionally accepts remote surveys provided that documentation is kept on board the ship indicating when it will be feasible for qualified samplers to complete the IHM with respect to limitations caused by the COVID-19 pandemic.
3. When, due to Covid-19 restrictions, onboard attendance is not possible and where an IHM Part I has been prepared fully, the Administrator agrees to Recognized Organizations (ROs) conducting remote initial IHM surveys subject to their satisfaction with the contracted IHM Expert Company’s experience, and that the IHM Part I complies fully with the EU Ship Recycling Regulation requirements and the guidelines contained in International Maritime Organization Resolution MEPC.269(68).
Confirmatory verification on-board will be carried out at the next scheduled statutory survey where physical attendance of the RO surveyor is possible.