International organisations offer a helping hand with recycling regulations
10 November 2022
The International Chamber of Shipping (ICS), the International Ship Suppliers’ Association (ISSA), BIMCO and the International HazMat Association (IHMA) have collaborated to develop a new guide to help both shipowners and ship suppliers comply with both the current EU Ship Recycling Regulations (EUSRR) and the Hong Kong Convention on Ship Recycling (HKC) where ratification is anticipated next year.
Under both sets of regulations, the shipowner must develop and maintain an Inventory of Hazardous Materials (IHM) for each vessel they own. In support of this, ship suppliers must provide material declarations (MDs) and Supplier’s Declarations of Conformity (SDoC) for equipment delivered to the ship.
Efforts to comply with these requirements have caused a significant increase in shipowners’ requests for material declarations from suppliers, in excess of what is required and placing a considerable administrative burden on these suppliers. In turn a lack of awareness by suppliers of their responsibilities in providing accurate material declarations on request can also impact on the accuracy of the IHM.
Materials Declarations for Inventories of Hazardous Materials aims to clarify the exchange of information between shipowners and suppliers. The guide helps shipowners and suppliers to understand the legislation, reduce the administrative burden for both parties, and ensure that the IHM is completed properly.
John Stawpert, Senior Manager (Environment and Trade) at ICS says: “The IHM requirements apply for the entire life cycle of a ship, and there are specific provisions relating to each stage in the ship’s life to ensure that hazardous materials can be identified as far as possible, and their disposal properly planned in the ship recycling process.
“We found that in their efforts to comply with regulations, shipowners were making exhaustive requests for materials declarations on items that did not need to be included in the IHM. Not only was this putting a huge administrative burden on ship suppliers but was also making the maintenance of the inventory by the owner significantly more complicated.”
Sean Moloney, ISSA Secretary adds: “Shipowners are rightly concerned about ensuring that the inventories are as complete as they possibly can be. However, this has caused confusion as to what should be covered by materials declarations and a level of anxiety from ship suppliers as they endeavour to fulfil what are, at times, impossible requests. This guidance aims at providing practical support to both shipowners and ship suppliers, ensuring that ship suppliers are only being asked for the things that the regulation and the convention actually requires them to provide.
Materials Declarations for Inventories of Hazardous Materials covers everything a shipowner or ship supplier needs to know to understand the process leading to completion of the IHM. It contains a series of tables clearly showing what should and should not be included in the materials declaration, demonstrates how to complete the paperwork and talks users through common mistakes. The guide has been written to relate to both shipowners and ship suppliers, and will provide a valuable tool for suppliers, superintendents, technical managers, and all who are responsible for complying with EUSRR and HKC regulations.
For further information and to download the publication, please visit ICS Publications.
About ICS: The International Chamber of Shipping (ICS) is the principal international trade association for merchant shipowners and operators, representing all sectors and trades and over 80% of the world merchant fleet.