Liberia issues note regarding inventory of hazardous materials and Ready for Recycling Certificate

The Liberia Maritime Authority has issued a marine operations note regarding inventory of hazardous materials and the Ready for Recycling Certificate.

This document has been issued on December 5th, 2022, and will enter into force on March 1st, 2023.

It is addressed to all shipowners, operators, recognized organizations, and masters.

This Marine Operations Note supersedes Marine Operations Note 01/2020.

The following changes have been included:

a) Statements and International Certificates of Compliance on inventories of hazardous materials (IHM) shall be issued by the Administration.

b) International Ready for Recycling certificates shall be issued by the Administration.

c) Added a section under Background requiring the IHM Statement of Compliance to be annotated to also cover the EU SRR and a copy of this Marine Operations Note should be presented to PSC officers upon request.

d) Revised section on Fees and added acceptance and reporting agreement to be signed by IHM Expert Companies with the Administration.

Purpose

This Marine Operations Note provides information and practical guidance for shipowners, operators, recognized organizations and masters on a cost-efficient, streamlined and quality focused approach to the development and maintenance of inventories of hazardous materials (hereinafter referred to as “the IHM”) in accordance with Regulation 5 of the Hong Kong Convention and Article 12 of the EU Ship Recycling Regulation (EU SRR); and issuance of the International Ready for Recycling Certificate in accordance with Regulation 11 of the Hong Kong Convention.

Background

The Hong Kong Convention was adopted in 2009 to effectively address, in a legally binding instrument, the environmental, occupational health and safety risks related to ship recycling, taking into account the particular characteristics of maritime transport and the need to secure the smooth withdrawal of ships that have reached the end of their operating lives.  

Upon entry into force, the Hong Kong Convention will require new ships and existing ships of 500 GT and above no later than 5 years after the entry into force of the Convention, or before going for recycling, if this is earlier, to have onboard a valid International Certificate on IHM.

The objectives of the IHM under the Hong Kong Convention is to document ship-specific information on the actual hazardous materials present on board in order to protect health and safety of the crew, and to protect health and safety of workers at ship recycling facilities and avoid environmental pollution when the ship is going for recycling.

The European Parliament formally adopted the EU SRR on 22 October 2013. The EU SRR entered into force on 30 December 2013.

The EU SRR requires all non-EU-flagged ships of 500 GT and above calling at EU ports; from 31 December 2020, to have onboard a valid IHM with a Statement of Compliance in the format specified in Appendix I of this Marine Operations Note.

The Statement of Compliance shall be annotated with a note that the IHM has been developed to cover also the requirements of EU Regulation No. 1257/2013 to confirm that due diligence and consideration has been given to how the IHM is developed and controlled to cover both the requirements of the Hong Kong Convention and the EU SRR.

Ships masters should be familiar with the requirements of this Note and should be able to present the same to Port State Control (PSC) officers when requested.

The EU SRR is aimed at facilitating early ratification of the Hong Kong Convention 2009 - both within the EU and in other countries outside the EU - by applying controls to ships and ship recycling facilities on the basis of the Hong Kong Convention.

Considering the EU SRR is nearly aligned with the Hong Kong Convention and includes various references to the Hong Kong Convention and related Guidelines, the Liberian Administration has determined there are efficiencies to be gained through combining compliance inspections to avoid unnecessary duplication and administrative burdens of multiple ship visits for Owners and Operators of Liberian flag ships.

This will also ensure that upon Liberia’s ratification or upon entry into force of the Hong Kong Convention, whichever is earlier, the Liberian Administration will issue the International Certificate on IHM which may not require an additional shipboard inspection/survey Upon entry into force of the Hong Kong Convention or earlier if requested, the Administration will also issue the International Ready for Recycling Certificate prior to recycling and upon completion of the final survey.

Shipowners with ships calling at ports in the EU are therefore required to develop the IHM for approval prior arrival at any EU port and for all other ships, shipowners are required to develop the IHM for approval upon entry into force of the Hong Kong Convention, but no later than 5 years after entry into force, or before going for recycling, if this is earlier...

To meet the requirements of the EU SRR there should be a reference in the Statement of Compliance stating that the IHM has been developed to cover also the requirements of the EU SRR.

This would entail that the IHM would include the classification of materials according to the IMO guidelines together with the addition of two hazardous materials (Perfluorooctane Sulfonic Acid -PFOS and Brominated Flame Retardant -HBCDD) required by the EU SRR.

RELEVANT DOCUMENT (AVAILABLE ONLY TO SUBSCRIBERS):

Inventory of Hazardous Materials and Ready for Recycling