Type of Surveys
All ships to which the Hong Kong Convention and/or the EUSSR applies shall be subject to a survey regime in accordance with Article 8 of the EUSRR or in Chapter 2, Part C, Reg. 10 of the Annex to the Hong Kong Convention, as applicable.
Ships shall carry on board a ship-specific ‘Inventory Certificate/SoC’ issued by the administration or an RO authorised by it and supplemented by Part I of the IHM.
These ships shall be subject to the following surveys, taking into account the relevant IMO guidelines (MEPC.222(64) “2012 Guidelines for the survey and certification of ships under the HKC”:
(a) an initial survey
(b) a renewal survey
(c) an additional survey
(d) a final survey
There is no annual survey scheme defined in the HKC/EUSRR. The initial and renewal surveys should be harmonized with the surveys required by other applicable statutory instruments of IMO.
Initial and renewal surveys must verify that the IHM Part I complies with the requirements of the HKC/EUSRR.
The initial survey takes place prior to the ship being put into service for new builds, or prior to the issuing of the Certificate/SoC on Inventory of Hazardous Materials for existing ships. After the initial survey, the Certificate/SoC on Inventory of Hazardous Materials can be issued.
The initial survey is to be carried out with an Inventory that has been reviewed by INSB Class without outstanding technical comments. The survey is to verify that the Inventory, especially the location of hazardous materials, is consistent with the arrangements, structure and equipment of the vessel through an onboard visual inspection.
For all ships flying either a flag of a EU Member
State or a flag of a third country, subject to EUSRR,
particular attention should be given when verifying the IHM
during an initial inspection or before the issuance of the SoC
respectively, to address the requirements of the EUSRR.
The renewal survey takes place at intervals specified by the flag Administration, but not exceeding five years. The renewal survey verifies that Part I of the IHM complies with the requirements of the HKC/EUSRR, through an onboard visual inspection and in effect ensures that any changes that have occurred since the previous survey have been properly recorded.
Additional surveys must ensure that any change, replacement, or significant repair of the structure, equipment, systems, fittings, arrangements and material, which has an impact on the IHM, has been made in a manner that ensures that the ship continues to comply with the requirements of the HKC/EUSRR, through an onboard visual inspection and that Part I of the IHM is amended as necessary.
The additional survey is to be carried out with an updated Inventory or an supplementary Inventory that has been reviewed by Engineering Dpt without outstanding technical comments. The survey is to verify that the updated Inventory or additional supplements to the Inventory, especially the location of hazardous materials, is consistent with the arrangements, structure and equipment of the vessel through an onboard visual inspection.
The final survey takes place prior to the ship being taken out of service and before the beginning of recycling. Final surveys must verify that the IHM (Parts I, II and III) and the ship recycling plan properly reflects the information contained in the IHM and comply with the requirements of the HKC/EUSRR and that the ship recycling facility where the ship is to be recycled is included in the European List or holds a valid authorisation in accordance with the IMO Convention depending on the case.
Ships flying the Flag of a Third Country (Non-Eu Country)
All ships flying the Flag of a Third Country, when calling at a port or anchorage of a Member State, shall carry on board a ship-specific ‘Statement of Compliance (SoC)’ issued by the relevant authorities of the third country whose flag the ship is flying or an organisation authorised by them and supplemented by Part I of the IHM.
INSB Class issues Statement of Compliance (SoC) for Part I of the IHM developed in compliance with EUSRR / HKC. As regards the HCK SoC will be smoothly converted into an International Certificate on Inventory of Hazardous Materials after the entry into force of the Convention.
The SoC shall be issued after verification of the IHM, in accordance with in accordance with EUSRR/HKC and any national requirements.
Particular attention should be given when verifying the IHM during an initial inspection or before the issuance of the SoC respectively, to address the requirements of the EUSRR.
Validity of certificate/Statement of compliance
An International Certificate on Inventory of Hazardous Materials / IHM Statement of Compliance is to be issued for a period specified by the Administration or INSB, which is not to exceed five years.
An inventory certificate / SoC shall cease to be valid in any of the following cases:
- if the condition of the ship does not correspond substantially with the particulars of that inventory certificate, including where Part I of the inventory of hazardous materials has not been properly maintained and updated, reflecting changes in ship structure and equipment, taking into account the relevant IMO guidelines;
- where the renewal survey is not completed within the specified intervals
The International Certificate on Inventory of Hazardous Materials / IHM Statement of Compliance will cease to be valid upon transfer of the ship to the flag of another State.
Format of Certificate/Statement of Compliance
For ships applying for the issuance of certificate or Statement of Compliance in compliance with the Hong Kong Convention, the Certificate / Statement of Compliance is to be issued respectively based on the format specified in the Appendix 3 of the Hong Kong Convention.
For ships applying for the issuance Statement of Compliance of certificate or in compliance with Regulation (EU) No 1257/2013, the certificate/ Statement of Compliance is to be issued based on the format specified in In Annex 3 of the EMSA Guidance.
Vessels going for recycling
The EU regulation requires that if an EU, Norway or Iceland flagged vessel will be sent for recycling, it must obtain a Ready for Recycling certificate and shall be sent to facilities listed in the European List.
Prior to recycling, the IHM shall, in addition to the properly maintained and updated Part I, incorporate Part II for operationally generated waste and Part III for stores and be verified by the administration or an RO authorised by it.
The ship owner shall send the IHM to the selected ship recycling facility for the preparation of the ship recycling plan (SRP). During the final survey, the IHM and SRP will be verified on board and a Ready for Recycling certificate with the validity not exceeding three months will be issued by the surveyor.
If a non-EU/EEA- flagged vessel sails towards recycling from a European port, the EU Waste Shipment Regulation will apply which states that such vessels shall only be recycled within the member states of the EU or OECD. It is important to note that even if the vessel doesn’t sail to a recycling facility directly from a European port, or if the decision for recycling is given when the vessel was still trading in European waters, the EU Waste Shipment Regulation will still be applicable.
The main tasks of the shipowners for sustainable ship recycling include:
- Prepare an agreement with the SRF for the recycling of the ship as per the HKC and/or the EUSRR
- Notify the flag state of the intention to recycle a ship under the HKC and/or EU schemes
- Compile the ship-specific inventory of hazardous materials (IHM, Parts I, II and III)
- Provide all required information, such as ship data, drawings and IHM, to the SRF for preparation of the ship recycling plan (SRP)
- Ensure minimum cargo residues, remaining fuel oil and ship-generated wastes.
- Arrange the final survey before the start of recycling
- Obtain an International Ready for Recycling Certificate (IRRC) and provide it to the SRF
- Comply with criteria for safe entry and safe for hot work
- Require Statement of Completion (SoC) from the SRF