Inventory of Hazardous Materials – EU SRR compliance.
21 April 2020
Applicability: shipowners, ship operators, ship managers, ship masters and relevant for all ship types.
Further to Class News 21/2018. EMSA have published new Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling. This guidance clearly states that by 31 December 2020, any ship on or over 500 GT, of any flag, calling at an EU port or anchorage, will need to have onboard:
- An EU SRR-compliant IHM on board; and
- Either a valid certificate (for EU flagged ships) or statement of compliance (for non EU flagged ships) issued on behalf of flag.
It is strongly recommended that owners and operators of existing vessels with IHMs comply with EU SRR well ahead of December 2020 due to the vast number of ships that will require compliance at the same time.
Your next steps
1. Plan – now is the time for planning for IHM EU SRR compliance. Speak with your local LR contact to better understand the process that you will need to implement to achieve IHM certification ahead of the 31 December 2020 deadline.
2. Prepare – most likely you will have decided to either:
a. Employ the expertise of a hazardous material expert (LR’s best practice advice). LR maintains a list of hazardous material experts who will (i) review your paperwork, (ii) attend your vessel(s) undertaking representative sampling for hazardous materials, (iii) analyse the samples and (iii) review the data and compile the IHM accordingly.
Note: check for relevant flag state instructions / publications - some flags maintain their own list of third-party experts and request that you use one of those.
b. Prepare the IHM in-house – collating existing paperwork from time of build to the current date to provide a full evidence base, detailing what is (and is not) onboard your vessel.
3. Request certification services from LR (or other RO) – once a contract is in place and the IHM and all supporting evidence has been received we can undertake a desktop approval, followed by an onboard verification survey, carried out at the next mutually convenient port, ahead of the 31 December 2020 deadline.
4. Certification – upon successful completion of the onboard verification survey, certification (valid for 5 years) can be issued. Where LR is authorised, either:
a. An EU SRR certificate will be issued on behalf of flag to EU flagged ships, or;
b. An EU SRR Statement of Compliance will be issued on behalf of flag to non-EU flagged ships
For ships of any flag where LR is not authorised:
c. An EU SoC will be issued on behalf of LR
Note: When compliant with the EU SRR additional Hong Kong Convention statements of compliance can also be issued (when requested) for no additional fee when obtained at the same time as EU SRR certification.
5. Maintenance – to ensure that certification can be renewed your IHM will need to be maintained. You should ensure your internal procurement policies request any item supplied to the ship (which will/may be part of the ships structure and fitted equipment) has an accompanying Material Declaration and Supplier Declaration of conformity. The IHM should be updated for any hazards documented as present above the threshold values.
Further guidance on LR's IHM service offering and how we can support and work with you can be found here.