Inventory Hazardous Materials
No risk for people and the environment
The EU Ship Recycling Regulations (SRR) came into effect in early 2021. This regulation requires that every ship has an Inventory of Hazardous Materials (IHM) on board and that it is kept up to date. This updating takes place by means of material declarations (MD) and supplier certificates (SdoC) from suppliers. The IHM provides insight into the presence of hazardous substances on board a ship and must ensure that ships that are scrapped do not pose any risk to people and the environment.
In practice, however, much is still unclear. Many requests are made for declarations without proper consideration being given to whether a declaration is required for the delivery in question. With many good intentions, this causes unnecessary work for ship and suppliers. Most deliveries from a ship supplier fall outside the requirement to issue MDs! This is because the most frequently supplied items are not part of the ship's construction or equipment, or are covered by one of the many exceptions that exist within the SRR. The exceptions are, for example, loosely mounted equipment, metal and metal alloys, regular consumer products, printed circuit boards and spare parts.
Providing good MDs is not easy. The risk of many questions is therefore that documents are provided that are not accurate or contain incorrect information. It is therefore important that only the documents are requested for items for which they are actually needed. For suppliers, the message is that MDs should be supplied only to ensure that the contents of the MD can be properly confirmed.
Source: An article that appeared in the latest issue of The Ship Supplier, written by ISSA legal expert Bruce Hailey