Refers to: Ship Owners / Managers / Operators of Panamanian flagged vessels, PHRS Surveyors / Representatives
Action Date: 01 Jan. 2021
As already circulated from PhRS, European Union Regulation (EU) No 1257-2013 (EU SRR) on the Inventory of Hazardous Materials, Regulation will enter to force on January 1, 2021 and concerns the implementation of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (hereinafter referred to as the HKC, 2009), mainly, its regulation 5 - Inventory of Hazardous Materials (IHM), to ships calling at a port or anchorage of any country of the European Union (EU), on or after January 1, 2021, as well as the issuance of the Statement of Compliance on Inventory of Hazardous Materials and Part I of the Inventory of Hazardous Materials.
Panama flag has published clarification on the application of the MMC-386 “Inventory of Hazardous Materials (IHM) for ships calling at EU ports”.
As it is known, the IHM must be prepared by visual checking and sampling on board by the Hazmat Expert, nevertheless and considering the current international scenario, it couldn’t be made on site according the provisions of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 and EU SRR; whereby, this Administration has adopted measures aligned to the Guidelines issued by the EU (please refer to PhRS Newsletter NL 240/20 which is available here).
Pursuant to the EU guidelines and by virtue of MMC-386, a Conditional Statement of Compliance (SoC) on IHM, may be issued only in cases of semi-completed IHM (the IHM was prepared remotely without any onboard sampling by the Hazmat Expert), due to impossibility to get to the ship, because of the International restrictions imposed by many countries because of the COVID-19 pandemic.
For those cases where the Hazmat Expert confirm unavailability for boarding the ship and confirm that the IHM has been prepared remotely, the Recognized organization (RO) acting on behalf of the Flag will request an authorization from Panama Maritime Authority (PMA) to issue a Conditional SoC on IHM, pending to be completed on board by the Hazmat Expert, valid for a period no longer than 90 days.
Under no circumstances the validity of the Conditional SoC granted, will exceed June 30, 2021 and it will be subject to fees stated in our MMC-324.
The Commission Notice Guidelines can be found here, in full detail.
Do not hesitate to contact us for more information you may need on the above.
December 14th, 2020 - PHRS Head Office