IMMARBE Notice of Immediate Actions in Compliance with the Inventory of Hazardous Materials (IHM) for Ships Calling at EU Ports

The International Merchant Marine Registry of Belize (IMMARBE) in its Merchant Marine Notice 20-004 reminds all owners/operators that as of 31 December 2020, the EU Ship Recycling Regulation requires all existing non-EU flagged ships calling to an EU port or anchorage to carry on-board a statement of compliance for the Inventory of Hazardous Materials (IHM). 

However, due to the Covid-19 pandemic and the associated difficulties in the surveying of ships, the European Union launched Official Journal of the European Union C 349 with common guidelines to ensure a harmonized approach towards enforcement by the EU port States authorities during ship inspections as of 1 January 2021. Two temporary options have been made available for vessels that are not in compliance with the IHMs requirement due to Covid-19 restrictions:

Scenario 1. Vessels without a valid IHM and/or accompanying certificate

In this case, the vessel may arrive at an EU port after 31 December 2020 without carrying on board a valid IHM and/or accompanying certificate (Inventory Certificate or Ready for Recycling certificate for EU flagged vessel or Statement of Compliance for non-EU flagged vessel) and the shipowner/master claims that this non-compliance is due to the Covid-19 situation.

Scenario 2. Vessels with a semi-completed IHM with an associated approved Inventory Certificate or Ready for Recycling Certificate (for EU flagged ships) or the Statement of Compliance (for non-EU Flagged ships), that does not contain onboard (either targeted or random) sampling.  

In this case, the vessel may call at an EU port or anchorage after 31 December 2020 with an IHM and associated certificate on-board, but the IHM was prepared remotely without any on-board sampling. This situation may arise as the on-board surveys that should have been undertaken to support the IHM could not be done because of the restrictions on inspecting a vessel during the Covid-19 pandemic.

Actions required

In either case, the owner/operator shall provide evidence that all possible measures were taken to undertake the work and get the certification required. Such evidence of compliance efforts may include a service contract for sampling or a survey. It may also include a justification for why it was not possible to obtain a semi-completed IHM and associated certificate. Where the IHM has been semi-completed, a conditional statement of compliance valid for 3 months shall be issued by the RO responsible.

In all cases, every effort shall be made to ensure that all vessels not yet in compliance with the IHMs are properly surveyed and certified no later than 31st March 2021.

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