IHM and Ready for Recycling certificates

Inventory Certificate (IC) or IHM Certificate

As from 31 December 2018, new Norwegian vessels of 500 gross tonnage and upwards not solely engaged on domestic voyages are required to carry an IHM (Inventory of Hazardous Materials) Certificate with a completed Part I on board. For operating ships, the deadline is 31 December 2020, regardless of the renewal date. The certificate must be renewed every five years.

Ready for recycling certificate (RfRC)

All vessels to be recycled are required to have a n RfRC, and the recycling must take place at an approved ship recycling facility. Ships not having a valid IHM Certificate that are to be recycled must prepare IHM Part I, II and III. These will, together with an approved ship recycling plan, form the basis for the RfRC (which is the only certificate that will be issued).

Application for both certificates includes associated supervisions. Classed ships must submit their applications to RO and unclassed ships submit their applications to the Norwegian Maritime Authority. Unclassed ships shall submit a request for supervision via Altinn using the form KS-0115 Begjæring om tilsyn.

For classed ships it is important that the certificates state that they have been issued on behalf of the flag State in order to be valid.

Ser RSR 10-2018 and RSV 16-2020.

Regulations on recycling of ships and mobile offshore units

Regulations on Recycling of Ships and Mobile Offshore Units.  IHM and RRC.

The Regulations implement the EU Ship Recycling Regulation[1] in Norwegian legislation. The EU Regulation on ship recycling entered into force in the European Union on 30 December 2013. The Regulatuion was incorporated into the EEA Agreement on 6 December 2018 and made applicable to Norwegian ships from 31 December 2018.

The Ship Recycling Regulation applies to all ships flying the flag of a member State of the EU or EEA, and some requirements are applicable to ships flying the flag of a third country calling at an EEA port or anchorage.

The EU Regulation is based on the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention), which was adopted by the Iternational Maritime Organization (IMO) in 2009. The Convention has not yet entered into force.

Below is a summary of the applicable requirements that the companies need to comply with.

Scope of application

• Norwegian vessels of 500 gross tonnage and upwards not solely engaged on domestic voyages.
  
  
• A ship is defined as a vessel of any type whatsoever operating or having operated in the marine environment, and includes submersibles, floating craft, floating platforms,  self-elevating platforms, Floating Storage Units (FSUs), and Floating Production Storage and Offloading Units (FSPSOs), as well as a vessel stripped of equipment or being towed. 
  
  
• EU/EEA flagged ships must be recycled at an EU approved ship recycling facility.
  
  
• Exemption is made for ships of less than 500 gross tonnage, government-owned ships (warships, naval auxiliaries or other ships owned or operated by a state and used, for the time being, only on government non-commercial service), and ships operating throughout their life only in waters subject to the sovereignity or jurisdiction of the Member State whose flag the ship is flying.

• Ships engaged on domestic voyages only may, as per today, be exported at the end of their service life. When ships and installations not covered by the EU Ship Recycling Regulation  are being phased out, the Basel Convention and Regulation (EU) 2006/1013 (Waste Shipment Regulation) will continue to apply if the recycling is to be carried out outside Norway.
• Operating in waters within the jurisdiction of Norway throughout the ship's life generally means that the trading certificate determines whether the ship is required to carry certificates in accordance with the recycling legislation. Principally, if the ship has a trading certificate permitting the ship to leave areas under Norwegian jurisdiction, the ship is not exempt from the recycling rules. For fishing vessels certified for Bank fishing I/II or Deepsea fishing I/II, the NMA permits an added certificate restriction banning operation outside of Norwegian jurisdiction. It is up to the company to make such a decision. Should it, at a later time, be relevant to change the operational pattern with the result that the vessel is covered by the scope of the ship recycling legislation, an initial survey must be conducted and an IHM certificate issued.

Norwegian jurisdiction = within the Norwegian territorial border, the Norwegian economic zone and the fisheries protection zone near Svalbard. Ships may not go beyond this area or through international waters to the fisheries protection zone near Jan Mayen.

Deadlines

Inventory certificate (IC/IHM certificate) – IHM = Inventory of Hazardous Materials

A valid IHM certificate with a completed IHM part I is required on board new EU/EEA flagged ships from 31 December 2018 and on board existing ships from 31 December 2020 regardless of the certificate renewal date.

New EU/EEA flagged ship means a ship for which either: 

• the building contract was placed on or after 31 December 2018; or
• in the absence of a building contract, the keel is laid or the ship is a similar stage of construction six months after the date of application of this Regulation (30 June 2020) or later; or
• if the terms above are not known, the delivery takes place 30 months after the date of entry into force of this Regulation (30 June 2020) or later.

Ready for Recycling Certificate (RfRC)

Thre is no transitional arrangement for the RfRC. Ships that are to be recycled and don't have the IHM certification, must complete IHM Part I, II and III as part of the making of the RfRC (they only get this certificate).

Ships flying the flag of a third country that are calling at a port or anchorage of an EU/EEA Member State shall as of 31 December 2020 have on board a valid "Statement of Compliance" issued by the flag State.

Inventory of Hazardous Materials, IHM Part I, II and III

• A ship specific IHM shall be prepared stating the type and amount of hazardous materials listed in Annexes I and II of the Ship Recycling Regulations and their location on board (see table below).
  
  
• The IHM shall be prepared by an IHM competent person or company.
  
  
• The IHM shall be properly maintained throughout the ship's life so as to ensure that the inventory of hazardous materials is always up-to-date, reflecting changes in the equipment and environmental requirements.
  
  
• The company shall see to that the necessary procedures are in place to ensure compliance with these obligations, including decide who will be in charge of necessary maintenance and update of the IHM.
  
  
• An initial survey and a five-year renewal survey shall be carried out on the ship in order to verify that the IHM is correct and remains updated throughout the life cycle of the ship. We aim to make the five year renewal survey correspond to the renewal of the ship's main certificate.

The IHM is made up of three parts:

• Part I: Hazardous materials contained in the ship's structure and equipment
  
  
• Part II: Operationally gained waste
  
  
• Part III: Stores

These parts apply to different stages of a ship's lifecycle as shown in the table below:

HKC: Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships (2009)
EU SRR: EU Ship Recycling Regulation

In the construction phase, at the initial survey and at the five year renewal survey, the IHM Part I must be prepared, identifying the hazardous materials contained in the ship's structure and equipment.

The company is responsible for completing IHM Part I, II and III before a ship is recycled.

IHM for new ships

• The IHM quantifies and locates hazardous materials may pose possible risk to human health or harm the to the environment.
  
  
• In order to ensure safe and environmentally friendly handling of these materials, the companies prepare the ship-specific IHM based on supplier information. The information must be provided by the suppliers via the Supplier's Declaration of Conformity (SDoC) and the Material Declarations (MD).
  
  
• The shipyards must therefore follow these steps:

1. identify components and suppliers
2. request SDoC and MD from suppliers
3. collect the SDoC and MD documents
4. organise SDoC and MD according to localisation and quantity
5. prepare IHM Part I.

We recommend making a localisation list that covers all parts of the ship based on the ship drawings (such as general arrangement, machinery arrangement, places of accommodation and tank arrangement plans) as well as other documentation on board, including lists of certificates for equipment and spare part lists.

The localisation description should refer to locations such as decks and rooms in order to simplify the localisation. The names and localisations used in the IHM ans the associated ship drawings should be the same in order to secure consistency between the documentations.

• To be issued with a certificate, the company/shipyard must request IHM survey from the administration of the flag State for unclassed ships or from a recognised organisation (RO) for classed ships.

List of hazardous materials to be included in part I of the IHM (Inventory of Hazardous Materials)

1. Annex I EU SRR (prohibited on new ships) (EU Ship Recycle Regulation)

–      asbestos
–      ozone-depleting substances
–      polychlorinated biphenyl (PCB)
–      perfluorooctane sulfonic acid (PFOS)*
–      some antifouling compounds

2. Annex II of the EU SRR

–      cadmium and cadmium compounds
–      hexavalent chromium and chromium compounds
–      lead and lead compounds
–      mercury and mercury compounds
–      polybrominated biphenyl (PBB)
–      polybromnated diphenyl (PBDE)
–      polychlorinated naphtalenes (CI >=3)
–      radioactive substances
–      certain short chain chlorinated paraffins (alkanes, C10-C13, chlorine)
–      brominated flame retardands (HBCDD)* 
     

* Required for EU/EEA ships; not applicable for third country ships.

Only  substances from the list with a quantity exceeding the limit values for the materials to be contained in the IHM shall be included.

IHM for operating ships

Follow the same procedure as for new ships as far as practically possible to gather documentation and necessary tests to determine the presence and localisation of hazardous materials on board.

Which steps must be carried out to prepare IHM Part I?

 Step 1: Collecting necessary information/documentation
 Step 2: Assessing gathered information/documentation
 Step 3: Preparing a visual/sampling check plan (not everything can be controlled)
 Step 4: On board visual/sampling check (as far as possible)
 Trinn 5: Preparing IHM Part I with supporting documentation

It is important to map any replacement or modification of the ship after construction in order to be able to give the current/updated status.

Any location where the relevant materials were traditionally used at the time of construction/modification of the ship.

Also see EMSA’s Best Practice Guideance on the IHM and IMO guidelines. The EMSA and IMO guidelines are directional, not binding. They provide many tips and examples on how the Regulation can/should be followed. See for example the appendices to the IMO Guidelines regarding how IHM Parts I, II and III may be built and maintained.

Qualified person – IHM competent person

From the Regulations:

• Point 1.13 "competent person"  means a person with suitable qualifications, training, and sufficient knowledge, experience and skill, for the performance of the spesific work.
• For the purposes of point 13 of paragraph 1, a competent person may be a trained worker or a managerial employee capable of recognising and evaluating occupational hazards, risks, and employee exposure to potentially hazardous materials or unsafe conditions in a ship recycling facility, and who is capable of specifying the necessary protection and precautions to be taken to eliminate or reduce those hazards, risks or exposure.
• Also see EMSA’s Best PracticeGuideanceonthe IHM, 4.3

Duties of the company before ships are sent for recycling

• Enter an agreement with an approved ship recycling facility. Recycling must take place at a ship recycling facility listed on the "European List".
• Prepare the ship for recycling
• Request approval from the Norwegian Environment Agency of the recycling plan prepared by an authorised ship recycling facility included in the European list.
• Prepare IHM Part I, II and III
• Request and complete a final survey
• Have a Ready for Recycling Certificate (RfRC) issued before the ship os sent for recycling. The RfRC has a maximum validity of 3 months.
• Existing EU/EEA flagged ships that are sent for recycling before 31 December 2020 and that do not have the IHM certificate may have the initial and final survey at the sane time before the recycling certificate is issued.
• No recycling of vessels may take plave before RfRC and an approved recycling certificate is in place.

Other Norwegian ships

For other Norwegian ships than those covered by the scope of the new ship recycling legislation, the Waste Regulations will continue to apply issued under the Pollution Control Act. The Waste Regulations implement the Basel Convention and Regulation (EU) 1013/2006 regarding transboundary shipment of waste. Ships that are being taken out of service permanently are considered waste in accordance with this legislation, and ships are also covered by the prohibition imposed by this legislation in the export of hazardous substances out of the OECD area. It is therefore illegal to export ships from the OECD area to recycling facilities located in states that are not members of the OECD. Within the OECD area, the export of ships must be reported and requires consent from the authorities of both the exporting and the importing country.

The Norwegian Environment Agency handles waste export notifications when the ship is located in Norway, regardless of the ship's flag. For Norwegian ships outside of Norwegian waters, export shall be handled by the authorities in the state where the ship is located. Violations of the shipment legislation are punishable pursuant to Norwegian legislation, and pursuant to Article 50 of the Waste Shipment Regulation all EU Member States are under obligation to follow up violations of the legislation with sanctions.