The EU SRR requirements

The Hong Kong International Convention (hereinafter referred to as “HKC”) for the Safe and Environmentally Sound Recycling of Ships is not yet in force. It will enter into force 24 months after ratification of 15 Member States, representing 40% of world merchant shipping by GT, combined maximum annual ship recycling volume not less than 3% of their combined tonnage. Currently 15 Flag Administrations have ratified the Convention, representing the 29,62%.

 

Background

The European Union (EU) having in mind the HKC requirements and in order to boost its ratification from the Member States, has adopted the Regulation (EU) 1257/2013 of the European Parliament and of the Council of 20 November 2013 on ship recycling amending Regulation (EC) 1013/2006 and Directive 2009/16/EC (hereinafter referred to as “EU SRR”). The EU SRR is closely following the HKC’s structure, concepts and definitions. However, the Regulation also sets out a number of additional requirements that go beyond those set in the HKC.

 

Applicability

The Regulation applies to ships on international voyages, of 500 GT and above flying the flag of a Member State or the flag of a third country under the conditions of Article 12 of the Regulation. The Regulation applies to all vessels of any type whatsoever operating or having operated in the marine environment including submersibles, floating craft, floating platforms, self-elevating platforms, FSUs and FPSOs, as well as ships stripped of equipment or being towed.

It does not apply to any warships, naval auxiliary or other ships owned or operated by a state and used, for the time being, only on government non-commercial service. ‘New’ and ‘existing’ ships, ‘ships going for recycling’ as well as ‘ships flying the flag of a third country’ shall have on board an IHM in accordance with the relevant provisions of Article 5 or Article 12 of the Regulation.

The application date of the EU’s Ship Recycling Regulation (EU SRR) was 31 December 2018. From this date, new EU ships must carry a certificate for the Inventory of Hazardous Materials (IC) while existing EU ships shall only carry an IC from 31 December 2020. Non-EU ships should only be requested to submit a Statement of Compliance (SoC), together with the inventory of hazardous materials, from 31 December 2020.

 

Implementation

An Inventory of Hazardous Materials (hereinafter referred to as “IHM”) must be taking into account the IMO Resolution MEPC.269(68).

In accordance with Article 5 of the Regulation, all ships flying the flag of an EU Member State shall have on board an IHM. Furthermore, in accordance with Article 12 of the Regulation, all ships flying the flag of a third country shall also have on board an IHM when calling at a port or anchorage of an EU Member State.

The IHM consists of:

1. Part I: HM contained in ship structure or equipment and referred to in Annexes I and Annexes II of the SRR;
2. Part II: Operationally generated wastes; and
3. Part III: Stores.

In general, a ‘new’ ship shall have on board an IHM which shall identify at least the HM referred to in Annex II of the Regulation while an ‘existing’ ship or a ‘ship going for recycling’ before the final application date of the SRR, shall have on board an IHM which shall identify, at least, the HM listed in Annex I of the Regulation. Annex I of the Regulation lists five types of hazardous materials and Annex II lists the items of Annex I as well as an additional ten types of hazardous materials.

In all cases the IHM shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing any HM referred to in Annex II of the Regulation and relevant changes in the structure and equipment of the ship.

 

Survey and Certification

All ships flying the flag of a Member State shall be subject to a survey regime, as per Article 8 of the EU SRR and they shall carry on board a ship-specific ‘Inventory Certificate’ issued by the administration or a RO authorised by it and supplemented by Part I of the IHM.

When calling at a port or anchorage of a Member State, all ships flying the flag of a third country shall carry on board a ship-specific ‘Statement of Compliance’ issued by the relevant authorities of the third country whose flag the ship is flying or an organization authorised by them and supplemented by Part I of the IHM.

 

EMSA Guidance on the Inventory of Hazardous Materials & on Ship Recycling Port State Control inspections

The European Maritime Safety Agency (EMSA) has released a Best Practice Guidance on a harmonised approach to the development and maintenance of IHMs in accordance with Article 5 and Article 12 of the EU SRR.

EMSA released also the Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling, ‘Inspections from the EU port States to enforce provisions of the ship recycling Regulation.