New guidance helps operators with global ship recycling regulations

M.Aterials Declarations for Inventorys of Hazardous Materials are intended to clarify the exchange of information between shipowners and suppliers. This guide will help shipowners and suppliers understand the law, reduce the administrative burden for both parties and ensure that IHMs are properly drawn up.

Under both regulations, shipowners are required to create and maintain a Hazardous Materials Manifest (IHM) for each vessel they own. To support this, vessel suppliers are required to provide a Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) for the equipment delivered on board the vessel.

In an effort to comply with these requirements, shipowners have seen a significant increase in requests for material declarations from their suppliers, exceeding the amounts required and imposing a considerable administrative burden on these suppliers. doing. Likewise, the supplier’s unawareness of their responsibility to provide accurate material declarations upon request can also affect the accuracy of the IHM.

said the partner.

The Hazardous Substances Inventory Material Declaration includes a set of tables that show what should and should not be included in a material declaration, guides users on how to complete the form, and educates users about common mistakes.

Shipowners are understandably concerned about ensuring their inventories are as complete as possible. However, this has created confusion about what should be covered in material declarations and a level of anxiety from ship suppliers trying to meet sometimes impossible demands.

ISSA Director Sean Moloney said:

Material Declaration (MD) Request

A typical example of an MD request, often made when no MD is actually needed, is:

• tools (manual, mechanical, electric or diesel);
• TVs, PCs or related appliances, toasters, microwave ovens, refrigerators, etc. – all household electrical appliances.
• Replacement parts identical to existing machines.
• Uncoated metal parts such as ball bearings, piston rings, push rods and steel plates.
• clause;
• linen or clothes;
• ropes and lines;
• the expendables;
• food & drink.

Supplier liability

Upon receipt of MD and SDoC requests from shipowners or their representatives, the supplier shall identify if the materials listed in Tables A and B (and the two additional substances introduced by the EUSRR) are present above. and must be declared in MD. threshold.

If the required information is not available, the supplier should obtain it from a sub-supplier. The supplier to the vessel must take responsibility for the information provided to the shipowner and issue her own MD and SDoC. Suppliers must not pass on any documentation issued by sub-suppliers, but must retain all supporting documentation provided by sub-suppliers.

Under both EUSRR and HKC, suppliers are obliged to provide MD only if the item supplied requires MD. If MD requests are received for unwanted items, the supplier should notify the shipowner accordingly and refer to these guidelines.

dialogue and reporting

The MD and SDoC must be reviewed in relation to the vessel specific IHM after receipt by the shipowner or his representative.

If the form is not fully compliant, shipowners should provide reasons for rejection to the supplier in the spirit of cooperation in achieving effective compliance with the IHM requirements.

Cooperation between shipowners and suppliers in the development and maintenance of IHM Part I will promote the safe and environmentally sound recycling of ships and will be the foundation for broader efforts to reduce the environmental impact of ships.

Find out more in Recycling Regulation Guidance