BIMCO noted the pandemic will cause problems in preparing the inventory of hazardous materials (IHM) that European ports will require from December, and has provided guidance on the issue
From 31 December 2020, all ships above 500 gt must carry an IHM when calling at a port or anchorage of an EU or EEA member state. Failure to do so may result in penalties.
Noting the restrictive circumstances caused by the Covid-19 pandemic, BIMCO said having IHM service providers and surveyors on board is “limited” and recommended that owners and operators of existing ships who trade in EU and EEA countries plan well in advance to comply with European Union’s Ship Recycling Regulation (EUSRR) IHM requirements by the 31 December 2020 deadline.
BIMCO said for existing ships, the IHM should be based on visual and sampling checks and include the approximate quantity and location of specified hazardous materials on board. While the IHM can be generated by the shipowner, BIMCO noted that external service providers and classification societies offer these services.
BIMCO noted that when external companies are used, visual and sampling checks require IHM service providers to board each ship. This process may take months depending on the size and construction of the ship and the owner’s preparation of the desktop review.
Non-EU/EEA flagged ships must produce a statement of compliance in addition to the IHM. The IHM provided must be compliant with the EUSSR.
Port state control officers will control the certificate and the quality of the IHM and in case of non-compliance, ships may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of a member state.
BIMCO also made advisory documents published by ICS, IMO and European Maritime Safety Agency available. In March, solicitors HFW warned shipowners to treat the upcoming IHM surveys with caution, outlining potential problems.
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