The EU Regulation on Ship Recycling entered into force on 30th December 2013. According to the EU Regulation, EU flagged new ships are required to have an Inventory of Hazardous Materials (IHM) onboard from 31 December 2018 on the latest, and EU flagged existing ships and Non-EU flagged ships that may call at a port or anchorage of EU Member State are required to have an IHM onboard from 31 December 2020. PSC is imposed on both EU Flagged ships and Non-EU flagged ships at the port or anchorage of EU Member States. It will be basically confirmed through PSC whether the IHM onboard the ship is properly maintained and updated, and a valid statement of compliance (SOC) issued by the Flag or the RO is kept onboard. Please be aware that the shipowners should complete to retain the examined IHM and the SOC onboard all the ships applicable by the deadline.

Details of the above are found in our Technical information TEC-0978 (dated on 15 January 2014) and TEC-1051 (dated on 27 October 2015), but, we are informing to the persons concerned again with this technical information so that the necessary preparation of IHM etc. could be re-confirmed since the deadline is approaching,
In particular, with regard to the ships in-service, a considerable period is necessary to prepare an examined IHM since the expert method should be taken for the development of IHM, and it consists of the following steps: 1) Meeting with the shipping company by the expert, 2) Collection of information and investigation of documents and drawing by the expert, 3) Preparation of visual sampling check plan (VSCP) by the expert and review by ClassNK, 4) Onboard visual and sampling check by the expert with ClassNK surveyor's attendance, 5) Sample analysis at the laboratory if applicable, 6) Development of IHM Part I and related documents by the expert based on the onboard visual and sampling check, and 7) Examination of IHM by ClassNK.
Taking into consideration the voyage schedule and the dock schedule for the ships, please plan to prepare the examined IHM and the SOC for the ship by the deadline. It is expected that the requests for experts will concentrate in the period just before the deadline. Situations where preparation cannot proceed as planned are also assumed. Therefore, we would like to recommend shipowners to take earlier response to prepare IHM and SOC for the ships.

(To be continued)