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Inventory of hazardous substances in container vessels: another necessary but bureaucratic burden for carriers

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The European Union is working very hard to make ship recycling greener and safer in the future. It is quite clear that the dismantling of ships in many parts of South Asia in a way it is being done is not acceptable, either from an environmental or a social point of view.

The ship recycling regulations, adopted seven years ago, are finally gathering pace now. In particular, the Regulation firstly prohibits or restricts the installation and use of hazardous materials such as asbestos or ozone depleting substances on board ships..

In addition, as early as the end of this year, from 31 December 2020, in accordance with the European Union Ship Recycling Regulations (EUSRR), ships of 500 gross tonnage and upwards with the European Union (EU) member state flag and all other ships, regardless of flag, will be required to keep an inventory of hazardous substances and materials (IHM) when visiting an EU or European Economic Area (EEA) port.

New European ships and EU-flagged ships which are being dismantled must have this list of hazardous materials (IHM), inspected by the relevant administration or authority, indicating the location and approximate quantity of these materials.

However, as a result of the COVID-19 pandemic, many ship-owners may not be able to complete the required inventory of hazardous materials (IHM) before the deadline. To this end BIMCO* recommends that its members firstly develop an IHM on older ships. Older ships are usually recycled more quickly, and such planning will show that ship-owners are proactive in meeting the requirements of the new EU regulation.

In addition, as members of BIMCO, we have already written to the European Commission and asked for favourable conditions for all parties concerned regarding the deadlines for shipping companies to complete the IHM process while dealing with COVID-19 limitations and outages.

The letter also includes a set of industry guidelines on compliance with European Union ship recycling regulations and the establishment of an inventory of hazardous materials, which BIMCO members are encouraged to use.

It is now known that the new regulation will affect approximately 137 (58%) of the 236 BIMCO member vessels. It is already known that only 33 ships have completed their homework, while the rest are in various stages of development in meeting the requirements.

We are propounding streamlining of the system, but we also want it to be a reasonably achievable condition for all market participants and for the new bureaucratic burden not to further restrict companies which are already crisis-hit.


*BIMCO – The world’s largest direct-membership organisation for ship-owners

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