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Technical Notices
Technical Notice No SR 05-2019 – EMSA Guidance on Ship Recycling Port State Control inspections
The European Maritime Safety Agency (EMSA) released the publication: Guidance on inspections 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.
The application date of the EU’s Ship Recycling Regulation (EU SRR) was 31 December 2018. From this date, new EU ships must carry a certificate for the Inventory of Hazardous Materials (IC) while existing EU ships shall only carry an IC from 31 December 2020. Non-EU ships should only be requested to submit a statement of compliance (SoC), together with the inventory of hazardous materials, from 31 December 2020.
Initial inspection PSC Directive regime
During each inspection of a ship initiated under the PSC Directive regime, the PSCO, as a minimum, must check the inventory certificate (IC) or a ready for recycling certificate (RfRC) or a statement of compliance (SoC) as applicable is kept on board and report this in THETIS.
It should be noted that, any initial check of the SR certificates or the PSCO’s observations of the ship may reveal clear grounds to imply that the ship is not in compliance with the SRR. In this case, the PSCO will continue the inspection under the SRR regime.
Ships flying a flag of an EU Member State
Ships flying the flag of an EU Member State (EU ships) are expected to have an IC (Existing ships as from 31 Dec 2020) or a RfRC as applicable. These documents shall be issued by or on behalf of the Flag State.
Ships flying the flag of a third country
Non-EU ships are expected to have a SoC as from 31 Dec 2020. These documents shall be issued by or on behalf of the Flag state.
Detailed inspection (ships flying a flag of an EU Member State)
If, during the initial inspection, the inspector’s general impressions or observations on board reveal clear grounds (see section 6.2.2) which in his professional judgement warrant a detailed inspection under the SRR of an EU ship, the inspector may proceed to further investigate if the ship substantially meets the relevant requirements of the SRR.
Control of the Statement of Compliance (ships flying the flag of a third country)
Reference can be made to sections 6.2.2 (which covers EU and non-EU ships) and 6.2.3 (including paragraph 6.2.3.1 for sampling check during a detailed inspection) by analogy in order to facilitate the control of the Statement of Compliance (SoC) for non-EU ships and for the inspector to decide on the proper actions to ascertain the ship’s compliance with the requirements of the SRR.
The PSC Guide advises inspectors that the detention of a ship may be considered if the ship recycling non-compliances involve:
- Failure to carry a ship recycling – related certificate as appropriate;
- failure to carry a valid ship recycling-related certificate, i.e. when the condition of the ship does not correspond substantially with the particulars of the certificate (except when Part I of the Inventory of Hazardous Materials has not been properly maintained and updated);
- the Inventory of Hazardous Materials required by the EU SRR is not specific to the ship;
- the Inventory of Hazardous Materials required by the EU SRR has not been verified by the Flag State or an appropriate organisation authorised by it;
- the ship recycling plan does not properly reflect the information contained in the Inventory of Hazardous Materials;
- an EU ship is heading to a ship recycling facility not included in the European list of ship recycling facilities;
- non-compliance with the control measures for Hazardous Materials listed in Annex I of the EU SRR.
Attachments:
The European Maritime Safety Agency (EMSA) released the publication:
Guidance on inspections 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.