Hazardous Materials in Vessels - EU Mandatory Regulations Must be Adhered To

EUROPE – WORLDWIDE – Whilst all shipping companies must by now be well aware of the inception of the Sulphur Cap which becomes mandatory on 1 January 2020, less well publicised is the fact that all existing ships sailing under the EU-flag and ships flying the flag of a third country calling at an EU port or anchorage, must have on board an inventory of hazardous materials (IHM) verified by the relevant authorities or a recognised organisation by 30 December 2020.

The EU implemented the EU Ship Recycling Regulation in 2013 giving owners and operators a 7 year period to comply, hence the abovementioned date. The regulation is a spin off from the IMO’s Hong Kong Convention which was adopted in May 2009 with the proviso it would enter mandatory service two years after ratification by 15 states representing at least 40% of global gross tonnage.

As is so often the case, and unlike the Sulphur Cap, that could be a very long time coming. We should stress the hazardous materials referred to are not cargo, these need to be manifested as usual, the regulation is for materials used within the fabric of the vessel and which may pose a risk when the ship is dismantled (or indeed suffer an accident such as fire at sea). New ships were required to have an IHM aboard if constructed after December 2015 whilst EU flagged vessels heading for destruction needed one from 2016.

The concern is that of the 30,000 or so vessels listed as being EU registered only a fraction so far are believed to have complied with the European regulations. In December we published the list of approved recycling facilities (ship dismantlers) from the EU and in the same article gave details of the online tool from the Sustainable Shipping Initiative (SSI) intended to improve industry practice. As of 1 January this year only one of those approved sites may be used to break up any EU registered vessel.

Those bodies which can verify an IHM include some, if not all, members of the International Association of Classification Societies (IACS) and one of these, the Korean Register of Shipping (KR) has just signed an agreement with the NSC Group, which operates a fleet with a full spectrum of vessels from container ships and car carriers to tankers and multipurpose vessels, to provide IHM services for the Hamburg based company.

Photo: The disgrace of uncontrolled destruction of ships, regardless of the cost in environmental terms or human lives needs to be brought to a halt with immediate effect.