EMSA guidance on the enforcement of EU Ship Recycling Regulation (EU SRR)

Standard Club’s Akshat Arora, Senior Surveyor, has reported on the release by the European Maritime Safety Agency (EMSA) of a guidance on the inspections from the EU port States, in order to enforce provisions of the Ship Recycling Regulation.

Since the end of 2018 the EU’s Ship Recycling Regulation (EU SRR) came into force and since then new EU ships have had to carry a certificate for Inventory of Hazardous Materials (IHM), while existing EU ships will have to carry this certificate from December 31st 2020. Non-EU ships should only be requested to submit a statement of compliance (SoC), together with the IHM, from December 31st 2020.

The guide advises that the detention of a ship may be considered by PSC inspectors if the following non-compliances are noted:

  • Failure to carry a ship recycling-related certificate as appropriate
  • Failure to carry a valid ship recycling-related certificate, i.e. when the condition of the ship does not correspond substantially with the particulars of the certificate (except when Part I of the Inventory of Hazardous Materials has not been properly maintained and updated)
  • The Inventory of Hazardous Materials required by the EU SRR is not specific to the ship
  • The Inventory of Hazardous Materials required by the EU SRR has not been verified by the Flag State or an appropriate organisation authorised by it
  • The ship recycling plan does not properly reflect the information contained in the Inventory of Hazardous Materials
  • An EU ship is heading to a ship recycling facility not included in the European list of ship recycling facilities
  • Non-compliance with the control measures for Hazardous Materials listed in Annex I of the EU SRR