1. The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 was adopted in 2009 and aimed at ensuring that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risks to human health, safety and to the environment. The Convention has not yet entered into force.
2. However, the European Parliament formally adopted the EU Ship Recycling Regulation (SRR) on 22 October 2013. The EU SRR entered into force on 30 December 2013 and requires all non-EU-flagged ships of 500 GT and above calling at EU ports; from 31 December 2020, to have onboard a valid Statement of Compliance (SOC) supplemented by an Inventory of Hazardous Materials (IHM).
3. In view of above, Indian Administration has issued MS Notice No. 14 of 2020 providing instructions for the issuance of SOC, on its behalf by the Recognised Organizations, towards the compliance with the HKC. The MS Notice applies to any Indian ship to which the Convention applies and are calling at a port or anchorage of a EU Member State.
4. Accordingly, when requested by the Company, a SOC may be issued after satisfactory initial survey including verification that the IHM Part I meets the relevant requirements.
5. The IHM is to be ship-specific and must take into account IMO Resolution MEPC. 269(68) and relevant guidelines of EU-SRR. For an existing ship it is to identify, as a minimum, all the hazardous materials listed in Control of Hazardous Materials (Appendix I) which also includes Perfluorooctane sulfonic acid (PFOS).
6. Towards development of an IHM, a Visual & Sampling Check Plan (VSCP) is to be established by the Company describing the visual/sampling check by which the IHM is developed. Any laboratory used to carry out specific tests is to take into consideration the guidance in MEPC.269 (68), Appendix 9. In general, the “specific sampling” activity involves certain risks to personnel involved or to other persons on board. Therefore, sampling should only be undertaken by a Hazmat expert duly engaged through Hazmat expert company.
7. Furthermore, analysis of the samples should only be carried out by suitably accredited laboratories (i.e. in accordance with ISO 17025 or equivalent) using qualified and trained personnel, suitable testing methods and the necessary equipment. It is the responsibility of the Hazmat Expert Company/ Hazmat Expert to confirm that the laboratory is suitably accredited and which should be verified by the Recognized Organization. In case of ships built after 1st Jan’2021, shipyards may develop the IHM in lieu of Hazmat expert company.
8. Ship owners/ operators and masters of Indian flagged ships to which the Convention applies and are intended to call any EU Member ports/ anchorages are advised to be guided by above and act accordingly.
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.