Onderwerp: Bezoek-historie

ItoS – Inventory of Hazardous Materials and Ship Recycling
Geldigheid:11-02-2025 t/m Versie:◀2/2vergelijk
Vergelijk versie 2 met:
Status: Geldig vandaag

Dit onderwerp bevat de volgende rubrieken.

Legend / Explanation of abbreviations:

  • EU: European Union

  • EVOA: 'Europese Verordening Overbrenging Afvalstoffen'

  • HazMat: Hazardous Material

  • HKC: Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships

  • MD: Material Declaration

  • NSI: Netherlands Shipping Inspectorate

  • IHM: Inventory of Hazardous Materials

  • SDoC: Supplier Declaration of Comformity

  • SRR: EU 1257/2013 Regulation on Ship Recycling

1 General

Reference is made to ItoRO no. 33 - Inventory of Hazardous Materials and Ship Recycling.

For ships to which the HKC (entering into force on 26 June 2025) and SRR applies, ItoRO no.33 applies;

For all other ships, the NSI recommends compliance with ItoRO. No.33 .

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2 Inventory of Hazardous Materials

In accordance with article 5 of the SRR and regulation 5 of the HKC, the IHM of a ship should be compiled taking into account the IMO guidelines for the development of the Inventory of Hazardous Materials (Resolution MEPC.379(80)).

2.1 Information about hazardous materials

Information about hazardous materials is foreseen to be provided to the ship owner by suppliers using standardized documents.

Noting article 5 of the SRR, the NSI considers that other solutions ensuring reliable information on the presence of listed hazardous materials on board ships can be accepted. Such solutions could include the use of purchase order procedures which require suppliers to provide SDoC and MD in the applicable formats whenever the supplied item contains specifically listed materials, in addition to the use of general declarations from suppliers.

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2.2 IHM designated person

The shipowner shall designate a person that is responsible for maintaining and updating the IHM.

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2.3 IHM Maintenance

A procedure shall be implemented on board the ship for the maintenance of Part I of the Inventory of Hazardous Materials (further: 'IHM Maintenance')

With reference to article 5 of the SRR and regulation 5 of the HKC only items that are part of the following categories are to be included in the IHM Maintenance:

  • Part I-1 Paints and coating systems;

  • Part I-2 Equipment and machinery; and

  • Part I-3 Structure and hull

Bear in mind that consumables and items that are not nail-bound to the ship do not need to be inventoried. It shall however be noted that when a spare part of a machinery & equipment is installed, it becomes a fixed item, and thus falls into the scope of IHM Part I.

After the delivery of the ship by the yard, the shipowner is responsible for collecting, processing and storage of the IHM related information.

The NSI considers that collecting SDoCs and MDs for all items included in the IHM Maintenance cannot be regarded as an absolute requirement, however the responsibility for the shipowner is also laid down in article 5.6 of the SRR and regulation 5.3 of the HKC.

The NSI therefore requires that:

  1. the ship owner requires and ensures that suppliers identify and declare, when relevant, the presence of hazardous materials which exceed the relevant threshold values, using the applicable formats.

  2. the ship owner's practices for developing and maintaining the IHM be supported by the ship owner's general procedures and quality management, i.e. by:

    1. using standardized text in ship owner purchase orders;

    2. accepting applicable declarations (i.e. SDoCs and MDs) from suppliers; and

    3. implementing specific verification procedures (e.g. sampling, see par.3. ItoRO.24).

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2.4 Change of owner or management

With reference to paragraph 4.3.3 of Res.MEPC.379(80), as the inventory of hazardous materials shall be properly maintained and updated throughout the operational life of the ship, in case of change of ownership or change of ship management precautionary measures shall be in place to ensure an up to date IHM.

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3 Ship recycling

3.1 Ships operating throughout their life only in waters of the Netherlands

With regard to article 2.2.c of the SRR and article 3, sub 3 of the HKC, a ship operating throughout their life only in waters subject to the sovereignty or jurisdiction of the Kingdom of the Netherlands whose flag the ship is entitled to fly, shall:

  1. in case the ship is intended to be recycled and to be exported from the Netherlands to a third country, comply with 'Regulation (EU) 2024/1157 on shipment of waste'; reference is made to the 'EVOA-procedure' as well.

  2. in case the ship is intended to be recycled at a ship recycling facility located in the Netherlands, comply with the 'Besluit melden bedrijfsafvalstoffen en gevaarlijke afvalstoffen' and the 'Regeling melden bedrijfsafvalstoffen en gevaarlijke stoffen'; reference is made to Landelijk Meldpunt Afvalstoffen.

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