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Class News 21/2018

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Statutory alert: Inventory of Hazardous Materials - Early compliance with EU Ship Recycling Regulation.

17 September 2018

Applicability: All ship types

Under the requirements of the EU Ship Recycling Regulation (EU SRR), every new-build ship* on or over 500 GT, contracted on or after 31 December 2018, and flying the flag of an EU member state will need to have an EU SRR-compliant Inventory of Hazardous Materials (IHM).

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 an EU SRR-compliant IHM on board.

Non-EU flagged vessels can comply with the EU SRR by complying with and being certified against the Hong Kong Convention.

The IMO Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (known as the Hong Kong Convention (HKC)) was adopted in 2009 and will have global applicability once in force. In 2013, the regional EU SRR entered into force, but without immediate impact. It has requirements for EU-flagged ships and any ships, regardless of flag, calling at an EU port or anchorage, and is mostly aligned with the requirements of the HKC.

A key element of the HKC and EU SRR is the maintenance of an IHM. The format of Lloyd’s Register’s template IHM has been updated to ensure compliance with HKC and EU SRR. Owners should ensure that their vessel’s IHM is updated to this format for continued compliance with HKC and EU SRR

What should shipowners and operators do now?

It is strongly recommended that owners and operators of existing vessels with IHMs start planning to comply with EU SRR well ahead of December 2020 due to the vast number of ships that will require compliance at the same time. Some more guidance can be found here.

*EU SRR defines ‘new ships’ as ships for which either
(a) the building contract is placed on or after 31 December 2018;
(b) in the absence of a building contract, the keel is laid or the ship is at a similar stage of construction on or after 30 June 2019; or
(c) the delivery takes place on or after 30 June 2021

For further information contact your local office

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