EU Ship Recycling Regulation (EU SRR)

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The EU SRR will enter into force on 31 December 2018 and a certified IHM (Inventory of Hazardous Material) is required

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  • Author: Panos Mouratidis

The IMO Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships – Hong Kong Convention (HKC) was adopted in 2009.  During 2013, the EU SRR entered into force and is mostly aligned with the requirements of the HKC.

The HKC addresses all related issues around ship recycling (including the fact that ships sold for scrapping may contain environmentally hazardous substances) as well as concerns about the environmental and working conditions of the ship recycling locations.

The objective of EU SRR is to prevent, reduce or eliminate adverse effects on human health and environment caused by the recycling, operation and maintenance of ships flying the flag of a Member State.

Additionally, the EU SRR objective is to (i) reduce disparities between operators in the Union, in OECD countries and in relevant third countries in terms of health and safety at the workplace and environmental standards and (ii) direct ships flying the flag of a Member State to ship recycling facilities that practice safe and environmentally sound methods of dismantling ships instead of directing them to substandard sites, which is the current practice.

To maintain an inventory of hazardous materials on board throughout the ship’s life-cycle is a key element in the Hong Kong Convention and the EU SRR. The objectives of the Inventory of Hazardous Materials are to provide ship-specific information on the actual hazardous materials (types and amounts) present on board in order to protect health and safety and to prevent environmental pollution at ship recycling facilities.

As per European regulation (1257/2013), new vessels flying the flag of an EU member state are required to have on board a certified IHM (Inventory Hazardous Material) starting from 31 December 2018. For vessels in operation and flying the flag of an EU member state, the certified IHM is required to start from 31 December 2020. Additionally, non-European flagged vessels calling at a port or anchorage of an EU member state shall have a certified IHM starting from 31 December 2020.

An IHM compliance program and related certification process should be implemented by shipping operators as part of their quality management system.

Source: Regulation (EU) No 1257/2013, MEPC.269(68)

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