Coalition offers ship recycling guidance

Four industry organizations have collaborated to develop a new guide designed to help ship owners and ship suppliers comply with the current EU Ship Recycling Regulations (EUSRR) and the Hong Kong Convention on Ship Recycling (HKC). Ratification of that treaty is anticipated next year.

The organizations involved are: the London-based International Chamber of Shipping (ICS); the International Ship Suppliers’ Association (ISSA), also based in London; Denmark-based ship owners’ association BIMCO; and the International HazMat Association (IHMA).

The coalition says under both sets of regulations, the ship owner “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 the requirements have caused “a significant increase in ship owners’ requests for material declarations from suppliers, in excess of what is required and placing a considerable administrative burden on these suppliers,” the consortium says.

The coalition’s new Materials Declarations for Inventories of Hazardous Materials “aims to clarify the exchange of information between shipowners and suppliers,” the ICS says in a news release. The guide helps ship owners and suppliers understand the legislation, reduce the administrative burden for both parties, and ensure an IHM can be completed properly.

John Stawpert, a senior manager with 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, ship owners were making exhaustive requests for materials declarations on items that did not need to be included in the IHM," he continues. "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.”

ISSA Secretary Sean Moloney adds, “This guidance aims at providing practical support to both ship owners 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.”

The Materials Declarations for Inventories of Hazardous Materials 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,” ICS says.

The guide has been designed to “provide a valuable tool for suppliers, superintendents, technical managers, and all who are responsible for complying with EUSRR and HKC regulations,” the organization adds.

Those interested in downloading the publication can go here.