Keeping an up-to-date Inventory on board a ship throughout its life-cycle is a key requirement laid down in both the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships and the Regulation. The Regulation’s requirements for the development of the Inventory are in fact almost entirely based on the respective requirements of the Convention.
An Inventory of Hazardous Materials developed in accordance with the Regulation must be compiled taking into account the relevant IMO guidelines. Nevertheless, EU legislation sets a few more requirements for the Inventory than the Convention does. Therefore, it is essential that the development and maintenance of the Inventory of Hazardous Materials in pursuance of the Ship Recycling Regulation is done
a) in a harmonised and comprehensive manner in the light of the international knowledge and experience as reflected most notably in the relevant IMO guidelines, while
b) taking into account the specificities of the EU legislative context, in particular of the Regulation itself.
The Hong Kong International Convention (HKC) covers the design, construction, survey, certification, operation and recycling of ships to facilitate safe and environmentally sound recycling. In accordance with Regulation 5 of the Annex of the HKC, each ship shall have on board an Inventory of Hazardous Materials. It shall be verified either by the Administration or by any person or organisation authorised by it.
In the wake of the adoption of the HKC, the IMO has published a number of guidelines on ship recycling. As per the Regulation, the IMO guidelines, in their updated form, shall be taken into account when compiling the Inventory of Hazardous Materials, preparing a Visual/Sampling Check Plan, conducting flag State surveys or detailed inspections of the port State. In this respect, this guidance document is complementary to the relevant IMO guidelines. It is to be regarded in the light of these guidelines with a view to provide a comprehensive framework for the practical implementation of the relevant provisions of the Regulation.
Regulation (EU) No 1257/2013 of the European Parliament and of the Council of 20 November 2013 ‘on ship recycling and amending Regulation (EC) 1013/2006 and Directive 2009/16/EC’ was published in the Official Journal of the EU on 10 December 2013. It entered into force on 30 December 2013. Its articles will apply at various stages, as detailed in article 32 of the Regulation. The 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, including on inventories of hazardous materials. In this regard, EMSA’s guidance is based on the EU specific requirements when these requirements go
beyond those set in the HKC.
Full details can be found in the EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials by clicking below image.