St. Vincent and the Grenadines issued a revised circular on ship recycling compliance

Eda Zenic -

The St. Vincent and the Grenadines Maritime Administration has recently released updated Circular GEN 024 on Ship Recycling outlining compliance requirements for the safe and environmentally responsible recycling of ships. The circular is directed at shipowners, operators, managers, and ship masters under SVG's registry, detailing requirements from both the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) and the EU Ship Recycling Regulation (EU SRR). The purpose of these regulations is to protect human health and the environment from hazards associated with the disposal of ships.

Key Regulations and Dates:

  1. Hong Kong International Convention (HKC): Adopted in 2009, the HKC will take effect on June 26, 2025, and applies to ships over 500 gross tonnage (GT). It mandates that each ship maintains a certified Inventory of Hazardous Materials (IHM), which lists hazardous materials in the ship's structure and equipment. Existing ships must comply by 2030, while new ships built after June 2025 must comply upon delivery.
  2. EU Ship Recycling Regulation (EU SRR) No 1257/2013: Effective since December 31, 2020, the EU SRR applies to EU-flagged ships and also impacts non-EU flagged ships that call at EU ports, especially for end-of-life voyages starting from or passing through EU waters. Similar to the HKC, it mandates that ships carry a certified IHM and a Statement of Compliance confirming IHM verification.
  3. European Waste Shipment Regulation (EWSR) No 1013/2006: This regulation applies to non-EU-flagged vessels on their last journey from EU ports or through EU waters, enforcing strict hazardous waste management requirements for final ship recycling.

Inventory of Hazardous Materials (IHM) Requirements:

The IHM is a document that identifies hazardous materials present on a ship, broken down into three parts:

  • Part I lists hazardous materials in the ship’s structure and equipment. It is prepared during construction for new ships or during operation for existing ones.
  • Part II lists operationally generated wastes.
  • Part III lists stores on board that may contain hazardous materials.

The HKC requires that Part I of the IHM be continuously updated throughout a ship's life, particularly after repairs, conversions, or changes in ownership. IMO’s Resolution MEPC.379(80) provides guidelines on maintaining the IHM, with an emphasis on accuracy and record-keeping, especially during sales, flag changes, or operational transitions.

Roles and Responsibilities for Compliance:

  1. Shipowners and Operators are responsible for designating a person to maintain and update the IHM, especially when modifications are made. They should establish systems to track and update the IHM with any new hazardous materials installed. Shipowners must also ensure IHM continuity during sales, flag changes, or operational transitions, and are encouraged to contact EU port authorities in advance for compliance with EWSR when a ship's last voyage involves EU waters.
  2. Recognized Organizations (ROs) authorized by SVG can survey and verify IHM content, and issue Statements of Compliance for vessels. For SVG-flagged ships, ROs are permitted to ensure compliance with HKC and EU SRR requirements.
  3. St. Vincent and the Grenadines Administration has not signed the Hong Kong Convention but allows Recognized Organizations to inspect and issue Statements of Compliance upon shipowner request. The SVG administration does not offer extensions or exemptions for the EU SRR requirements, encouraging early IHM preparation to avoid delays.

Implementation Timeline and Recommendations:

SVG advises shipowners to prepare for IHM compliance early to meet deadlines under both the EU SRR and HKC. For EU compliance, preparation was recommended before December 2020 to meet IHM documentation requirements at EU ports. Ships must maintain systems to keep the IHM up-to-date with changes in ship structure or hazardous material additions, to ensure compliance throughout the ship’s operational life and before recycling.

Compliance and Enforcement:

Compliance with EU SRR is enforced by Port State Control (PSC) officers in EU waters. Shipowners must ensure their IHM is accurate, current, and ready for inspection, as PSC officers may refuse evidence of compliance in cases of non-compliance. SVG cannot issue exemptions from the EU SRR, so non-EU flagged ships must independently meet EU standards if they visit EU ports.

Annexed Guidelines:

The circular includes annexes that help shipowners comply with IHM requirements:

  • The full Hong Kong International Convention (HKC).
  • EU Regulation 1257/2013 text and its application.
  • IMO Guidelines (MEPC.269(68)) for IHM development and maintenance.
  • European Maritime Safety Agency (EMSA) guidance for IHM compliance in EU waters.
  • MEPC.379(80) Guidelines, detailing maintenance standards for IHMs.

Revision History:

The document is regularly updated, with Rev 3 expanding on specific paragraphs related to IHM maintenance, compliance processes, and including the latest IMO Resolution MEPC.379(80) on IHM management practices.