From 31 December 2020 non-EU vessels calling at EU ports must carry an authorized Inventory of Hazardous Materials (IHM) and Statement of Compliance (SoC). The European Union (EU) Ship Recycling Regulation (EUSRR) is aimed at ensuring that ships, when being recycled, do not pose any unnecessary risk to human health and safety, or to the environment, and to ensure the proper management of hazardous materials on board ships throughout their lifecycle. The EUSRR is an early implementation of the International Maritime Organization’s (IMO’s) Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the “Hong Kong Convention”), which has yet to meet the criteria for its entry into force.
To support shipowners in meeting the EUSRR requirements, the Republic of the Marshall Islands (RMI) Registry has launched a new IHM verification service.
John Ramage, Chief Operating Officer of International Registries, Inc. and its affiliates (IRI), which provides administrative and technical support to the Republic of the Marshall Islands Maritime and Corporate Registries, commented:
“Preparing an IHM requires considerable planning and coordination, and we urge shipowners to take the required steps to meet the EUSRR requirements as soon as possible. We understand that regulatory requirements are continuing to become more complex for owners, and we want to do all that we can to help them manage their inspection and compliance procedures. Utilizing our team to verify the IHM and issue the SoC provides owners with a new option for receipt of the SoC.”
The ship specific IHM needs to be reviewed and verified by the RMI or one of the approved International Association of Classification Society (IACS) Recognized Organisations (ROs), and upon verification, an SoC issued to the vessel. While the EUSRR regulation seeks to prevent hazards during the recycling phase, the IHM and SoC must be maintained for the entire vessel lifecycle.
An IHM consists of pre-boarding research as well as onboard inspection and material sampling. The samples are then analysed in an accredited laboratory. Tests are performed to establish the presence of asbestos, polychlorinated biphenyl, mercury (compounds), cadmium (compounds), radioactive substances, and chromium-6, among others.
The RMI has partnered with CTI/POLY to carry out these onboard inspections and lab analysis and prepare the IHM, a partnership that will allow owners/operators to complete the process in a streamlined and seamless manner. The RMI also allows owners/operators to use other recognized third-party IHM experts for this work. The RMI will review the IHM prepared by CTI/POLY or any other recognized IHM expert and upon verification by the RMI, will issue the SoC.
The RMI Registry is one of the leading registries in the world surpassing 172 million gross tons and 4,674 vessels at the end of November. The RMI is white listed with the Paris and Tokyo Memorandums of Understanding and has also maintained United States Coast Guard QUALSHIP 21 status for 15 consecutive years, having achieved a 2016-2018 average detention ratio of 0.56%.
