Application: Ship owners/Managers, Masters, Approved Inspectors and Recognised Organisations
1. This Bulletin provides instructions on the issue of Statements of Compliance on Inventory of Hazardous Materials (IHM) under the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (Hong Kong Convention) and the European Union (EU) Ship Recycling Regulation (EU) No. 1257/2013 (EU SRR). It applies to any ship requesting a Statement of Compliance on IHM under the Hong Kong Convention or EU SRR.
2. On request by the Owner/Manager, a Statement of Compliance may be issued by any Barbados Recognised Organisation after satisfactory initial survey including verification that the IHM Part I meets the relevant requirements.
(i) The IHM is to be ship-specific and take into account IMO Resolution MEPC.269(68). For an existing ship it shall identify, as a minimum, the hazardous materials listed in Appendix I of the Convention or Annex I of the EU SRR, as appropriate.
(ii) A plan shall be established by the Owner/Manager describing the visual/sampling check by which the IHM is developed.
(iii) The IHM shall be properly maintained and updated throughout the ship’s life. It must reflect new installations that contain hazardous materials referred to in Appendix II of the Convention or Annex II of the SRR, as appropriate, and relevant.
3. Separate Statements of Compliance shall be issued for the EU SRR and Hong Kong Convention.
4. The Hong Kong Convention
(i) The Hong Kong Convention was adopted in 2009, however it has not yet reached the conditions for entry into force. Barbados is not a signatory to the Hong Kong Convention currently but Barbados Recognised Organisations are being authorised to survey ships and issue voluntary Statements of Compliance on behalf of Barbados when requested by the Owner/Manager.
(ii) Ships shall be surveyed in accordance with Regulation 10 of the Convention.
(iii) A Statement of Compliance may be issued following an initial or renewal survey. The renewal survey shall take place at intervals not exceeding five years.
(iv). The initial and renewal surveys should be harmonised
(v) The issuance and endorsement of the Statement of Compliance shall be in accordance with Regulation 11 of the Convention and the Statement of Compliance shall be based on the format of the International Certificate specified in Appendix 3 of the Convention.
(vi) An additional survey may be conducted at the request of the shipowner to ensure that any change, replacement, or significant repair made to the structure, equipment, systems, fittings, arrangements and material continues to comply with the Convention requirements.
(vii). A final survey shall be conducted prior to the ship being taken out of service and before the recycling of the ship has started. In accordance with Regulation 11.1, the initial and final surveys for existing ships are conducted at the same time.
(viii) The validity of a Statement of Compliance is five years, subject to the conditions set out in Regulation 14 of the Convention. The Convention requires ratifications by 15 States, representing 40% of the world merchant shipping.
5. EU Ship Recycling Regulations
(i) Article 12 of the EU SRR requires ships flying the flag of a third country (i.e. a non-Member State), when calling at a port or anchorage of an EU Member State, to have on board a Statement of Compliance and IHM that complies with Article 5(2) of SRR from 31 December 2020.
(ii) Barbados Recognised Organisations have been authorised to survey ships and issue voluntary Statements of Compliance on behalf of Barbados Flag when requested.
(iii) A ship flying the flag of a third country may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of an EU Member State in the event that it fails to submit to the relevant authorities of that Member State a copy of the Statement of Compliance in accordance with paragraphs 6 and 7 of Article 12, together with the IHM, as appropriate and on request from those authorities.
5.4. Failure to update the IHM shall not constitute a detainable deficiency, but any inconsistencies in the IHM will be reported to Barbados Maritime Ship Registry by the Member State.
5.5. The EU SRR does not establish a period of validity for the Statement of Compliance, unless so specified by the flag State. Barbados Maritime Ship Registry has concluded that the validity of Statements of Compliance with the Hong Kong Convention and EU SRR shall have a five-year validity, therefore initial, renewal and additional surveys, as applicable, will need to be conducted for Barbados ships under the EU SRR.
5.6. The Statement of Compliance shall be in the format specified in Annex 3 of the European Maritime Safety Agency document “Guidance on inspection of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling, inspections from the EU port States to enforce provisions of the ship recycling Regulation” dated 27 September 2019.