Inventory of Hazardous Materials: New requirements from 2025
The Hong Kong Convention was first adopted in 2009 to address, in a legally binding instrument, the environmental, occupational health and safety risks related to ship recycling, taking into account the particular characteristics of maritime transport and the need to secure the smooth withdrawal of ships that have reached the end of their operating lives.
The updated Hong Kong Convention will enter into force on 26 June 2025. It will require new ships and existing ships of 500 GT and above - no later than 5 years after the entry into force of the Convention, or before going for recycling, if this is earlier - to have onboard a valid International Inventory of Hazardous Materials (IHM) certificate.
The objective of the IHM under the Hong Kong Convention is to document ship-specific information on the actual hazardous materials present on board to protect the health and safety of the crew and workers at the ship recycling facilities thus avoiding environmental pollution when the ship is going for recycling.
The European Parliament formally adopted the EU SRR on 22 October 2013. The EU SRR entered into force on 30 December 2013. The EU SRR requires all non- EU-flagged ships of 500 GT and above calling at EU ports; from 31 December 2020, to have onboard a valid IHM with a Statement of Compliance/International Certificate. The Statement of Compliance/International Certificate shall be annotated with a note that the IHM has been developed to cover also the requirements of EU Regulation No. 1257/2013 to confirm that due diligence and consideration has been given to how the IHM is
developed and controlled to cover both the requirements of the Hong Kong Convention and the EU SRR. Ships masters should be familiar with the requirements of this Note and should be able to present the same to Port State Control (PSC) officers when requested.
Considering the EU SRR is nearly aligned with the Hong Kong Convention and includes various references to it and related Guidelines, it is determined that there are efficiencies to be gained through combining compliance inspections to avoid unnecessary duplication and administrative burdens of multiple ship visits for Owners and Operators vessels. Upon entry into force of the Hong Kong Convention or earlier if requested, the Flag Administration will also issue the International Ready for Recycling Certificate prior to recycling and upon completion of the final survey.
Shipowners with ships calling at ports in the EU are therefore required to develop the IHM for approval prior to arrival at any EU port and for ships calling ports around the world other than ports in the EU, shipowners are required to develop the IHM for approval prior to entry into force of the Hong Kong Convention on 26 June 2025; or before going for recycling, if this is earlier. To meet the requirements of the EU SRR there should be a reference in the International Certificate on IHM stating that the IHM has been developed to cover also the requirements of the EU SRR. This would entail that the IHM would include the classification of materials according to the IMO guidelines together with the addition of two hazardous materials (Perfluoro octane Sulfonic Acid -PFOS and Brominated Flame Retardant -HBCDD) required by the EU SRR.
THE REPORT | DEC 2023 | ISSUE 106 | 71
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