Liberia’s Maritime Authority Issues Guidance on Compliance vs Conformance in Ship Recycling
In an effort to streamline compliance with international regulations, Liberia’s Maritime Authority has issued a Marine Operations Note providing guidance on the development and maintenance of inventories of hazardous materials (IHM) for ships registered or registering with the flag state.
Compliance vs Conformance: The Distinction
The note clarifies the distinction between compliance and conformance in ship recycling, emphasizing the importance of ensuring that ships meet both regulatory requirements and industry standards. Compliance refers to meeting specific regulations, such as those set by the International Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS Convention). Conformance, on the other hand, involves adhering to industry-recognized guidelines, like those outlined in Resolution MEPC.379(80).
Inventory of Hazardous Materials (IHM)
The IHM is a critical component of ship recycling, as it helps identify and manage hazardous materials onboard. The inventory must be maintained throughout the operational life of the ship, with updates required whenever machinery or equipment is added, removed, or replaced.
Importance of Accuracy and Transparency
- Suppliers should provide Material Declarations (MD) to shipowners and operators.
- MDs are documents that identify whether the materials listed in Appendices 1 and 2 of the Hong Kong Convention are present in a product above the threshold value.
Verification and Validation
To ensure compliance, the Maritime Authority recommends including clauses in contracts with suppliers requiring them to deliver Material Declarations at the design and construction stage. Additionally:
- Builders’ and operators’ purchase departments should verify the accuracy of MDs before accepting delivery of equipment, systems, or installations.
- Shipowners and operators are advised to maintain continuity and conformity of the information in Part I of the IHM, even if the flag, owner, or operator changes.
Procedure for Determining Part I of the IHM
The guidance outlines the procedures for determining Part I of the IHM, which includes:
- Collecting necessary information
- Assessing collected data
- Preparing a Visual/Sampling Check Plan (VSCP)
- Conducting onboard checks
- Preparing related documentation
Conclusion
The Liberian Maritime Authority’s guidance on compliance vs conformance in ship recycling aims to promote a safer and more environmentally friendly industry by ensuring that ships meet both regulatory requirements and industry standards. The move is seen as a significant step towards improving the overall sustainability of the shipping sector.