The EU Ship Recycling Regulation (EUSRR) calls all vessels calling at EU ports from non-EU countries to carry an IHM identifying all the hazardous materials on board.
EU Regulation on Ship Recycling
The absence of one international and uniformly applicable convention for ship recycling can make this a difficult field to navigate for operators, causing even reputational and financial damage.
BIMCO reports that COVID-19 impacts the smooth implementation of the new inventory of hazardous materials requirements, which is due to December 31, 2020.
The NGO Shipbreaking Platform launched its Asia quarterly update, reporting that during the first quarter of 2020, a total of 166 ships were reported, from which 126 were sold to the beaches of South Asia.
The USCG issued a Marine Safety Information bulletin concerning the impact of the EU ship recycling regulation on US flagged ships, to boost owners/operators of affected vessels to take early action to comply with the regulation.
Part I of the IHM shall remain with a vessel throughout its operational life, and be updated as all new installations enter the ship, as these may potentially contain hazards. The presence of the inventory will then ensure the safety of crew members during the vessel’s operational life.
Liberia Maritime Authority issued practical guidance to shipping on the development and maintenance of inventories of hazardous materials (IHM), in line with Regulation 5 of the Hong Kong Convention and Article 12 of the EU Ship Recycling Regulation (EU SRR).
The entry into force of the sulphur cap in the beginning of 2020 is – and will be – the highlight of the year. However, at the end of 2020, ships must comply with another very important requirement. Specifically, 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. To shed light on this matter, DNV GL hosted a webinar, providing more information about the subject.
During the second SAFETY4SEA Singapore Forum, Mrs. Ina Lutchmiah, Specialist Counsel (Solicitor, England & Wales), Wikborg Rein Singapore Pte Ltd opened the second panel by sharing key challenges with respect to the regulatory framework for transboundary movements for recycling. Touching upon the Hong Kong Convention and the Basel Convention, she moved forward by presenting compliance challenges and legal implications associated with transboundary movements for recycling originating from the EU and outside the EU.
During the last SAFETY4SEA Hamburg Forum, Gunther Zeitzmann, Ship Recycling Engineer and member of the International HazMat Association (IHMA), highlighted the importance of preparation, certification and maintenance of an Inventory of Hazardous Materials (IHM) for compliance with the requirements of Hong Kong Convention and EU-Ship Recycling Regulation. He further referred to key steps for effective development of IHM and certification; the operations and maintenance of the IHM and the importance of control with flags, classes and PSC.
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