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Wednesday, March 18, 2020 

According to DNV GL, from 31 December 2020, the EU Ship Recycling Regulation (EU SRR) will be applicable for vessels of 500gt and above flying the flag of an EU/EEA member state, or third-party-flagged vessels calling at European ports.

Those vessels will be required to carry an Inventory Hazardous Materials (IHM) on board which must be certified. DNV GL is authorised by most flag states to verify IHMs, taking into account the MEPC.269(68) IHM guidelines.

The ship owner is responsible for the IHM Part I preparation of vessels in operation and may draw upon assistance from a hazmat expert, who can either be an individual from a third-party hazmat expert company or an employee of the ship owner who has received the proper training. The hazmat experts take samples and make visual checks on board based on the collected information. It may take up to one month to generate the IHM Part I report for a single vessel due to long waiting times between each step of preparation. The ship owner is responsible for the maintenance of IHM Part I throughout the life of the ship; DNV GL supports this task by organizing IHM and maintenance workshops.

If any machinery or equipment or component is added, removed or replaced, or if the hull coating is renewed, the Material Declaration (MD) or Supplier’s Declaration of Conformity (SDoC) forms provided by the suppliers shall be properly filled out and Part I of the IHM shall be updated. The IHM procedure should be integrated into the safety management system.

The IHM Part I certificate / SoC (Statement of Compliance) will be issued after the initial survey and then be subject to periodical checks by the flag states or ROs during the five-yearly renewal surveys and by port state controls during the PSC inspections.

The EU regulation requires that if an EU, Norway or Iceland flagged vessel will be sent for recycling, it must obtain a Ready for Recycling certificate and shall be sent to facilities listed in the European List. Prior to recycling, the IHM shall, in addition to the properly maintained and updated Part I, incorporate Part II for operationally generated waste and Part III for stores, and be verified by the administration or an RO authorised by it. The ship owner shall send the IHM to the selected ship recycling facility for the preparation of the ship recycling plan (SRP).

As IHM preparation can be time-consuming, DNV GL recommends starting the process now n order to submit the IHM for approval before end-October 2020.

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