Emissions, ballast water and other regulations were recent challenges for shipping and three important letters didn’t appear on the radar – IHM!
The Hong Kong Convention (HKC) of IMO and EU Ship Recycling Regulation (EU-SRR) apply to vessels of any age above 500GT. These regulations follow the cradle to grave approach for supporting safe and environmentally sound recycling of ships.
Ships need to have a certified and maintained Inventory of Hazardous Materials (IHM) onboard and maintain it, ship recyclers have to implement comprehensive HSE and management measures.
HKC has been adopted in 2009 but still has not entered into force. The EU-SRR entered into force in 2013 already! 7 years were given to existing ships with deadline set to December 31st 2020. From then on, any EU flagged as well as any EU visiting ship above 500GT, regardless of flag, has to have a certified and maintained IHM onboard.
In 2016 GSR Services presented to EMSA that even when IHM-Expert capacities triple annually, only half of the ships can be served in time. The capacities were increased more than that, but various shipowners planned their IHM-compliance only for 2020 and by this missed valuable time as unforeseeable impacts of COVID-19 crossed many plans. In addition, there was a significant lack of awareness and action by many owners as well. What will happen to them when PSC Officers in EU will ask for a certified and maintained IHM after January 1st 2021? The penalties are severe and a look at the numbers should be a clear signal that it´s time to act, now.
IHM in numbers
Around 35.000 ships are affected by EU-SRR and statistics indicate, that around 40% have not started with the IHM process plus another 15% which have only signed a contract. Each day 233 IHMs have to be finalized for meeting the deadline end of 2020. That´s impossible!
What is the process for getting certified IHMs? Preparing for a ship inspection takes from few hours to weeks (i.e. if class requires approval of “visual sampling and check plan”). The ship inspection is done in 1 to 2 days followed by analyses of samples in accredited laboratories. With lab-results the IHM and IHM-Report are finalized and sent to class or flag for review and initial survey prior to issuing IHM-certificate. Laboratories and classes require more time nowadays due to increased demand. Daily changing travel restrictions having an impact as well. Getting a certified IHM within 3 months requires “fortunate circumstances” and the deadline is closer.
The cost for IHM-development depends to a great extent on number of samples and application (not only accreditation) of analysis methods by laboratories. Owners often demand cheap IHMs as they´re not considered added value but a cost. This demand is served.
Asbestos is of particular concern due to the ban under SOLAS and if found, it can influence the asset value significantly. Knowledgeable IHM Experts are capable to advise on how to manage most of such finds and don´t push towards costly decontamination. Those experts who target decontamination as follow-up business often subsidize their IHM prices. The approach and capabilities of IHM-Experts for avoiding decontaminations should be used as KPI during selection process as decontamination costs can make a ship bankrupt.
The IHM is a technical file which, when being found inaccurate, may become an additional risk when ownership changes. Even penalties for incompliance from PSC are severe, the cost for incompliance with charterers´ orders when being banned from certain ports or detained are even more substantial.
Quality and Risks
It has additionally become the responsibility of IHM Experts to guide owners on good practice. Some classification societies have a proper and practicable approach, others have demands well beyond the requirements creating unnecessary costs or they certify any kind of list full of assumptions and inconsistencies. Pricing for IHM and certification is not an indicator for quality, but fortunately IHM-certification is independent of ships class and good IHM-Experts can guide owners. Only those IHM-Experts which have a clear focus on EU-SRR and HKC with the intention to remain in the market after the IHM-boom are likely to follow a quality approach. Others will disappear and with them their liabilities.
Once prepared, the IHM is to be maintained throughout a ship’s life. Sampling and inspection as for initial development of IHM is illegal and maintenance is to be based solely on Suppliers Declaration of Conformity (SDoC) and Material Declarations (MD) from suppliers. For an efficient maintenance the first step is to select only relevant order items (~20% of all orders) and request MDs & SDoC for them. Generally, guidance should be provided to suppliers as most of them are unaware. Once forms are provided by suppliers, formalities are checked for ensuring a legally sound and safe process for the owner. If documents have not been properly filled in, they are to be rejected. A very important but time-consuming task for ensuring timely and appropriate maintenance. Filled-in MDs are often declaring that no hazardous material is contained in the product (18% of all order items) and for only ~2% presence of a hazardous materials is declared. Such items need a follow-up by crew on when, where and how much of it has been installed onboard. This, in case of GSR Services, is fully supported by a specifically designed software tool which eases the entire process tremendously. A full IHM-Maintenance service for owners ensures minimization of gaps which would again influence asset value, operability and create easy targets for PSC and class.
Other approaches require owners to collect documents, with or without a software tool. A clear indication that overall costs, time and gaps will increase.
Postponement, control and enforcement
It´s evident that the demand for IHMs can´t be served in the time remaining, but there are potential ways out of the misery. Even though the IHM-deadline can´t be postponed, as this would require changing the EU-SRR, the remaining variable is control and enforcement by European PSCs. By end of November a guidance for EU- PSCs will be published, no doubt this is very late and leaving nearly no time to react. But latest rumours indicate that evidence for trying to become compliant in time on hand of a signed contract might be found sufficient by EU-PSCs.
IHM is a more complex issue than it seems in the beginning. Time remaining is very limited and if not done already, selecting and placing orders for IHMs with proper IHM-Experts is urgently required. Then looking at concepts for IHM-Maintenance will ensure cost-efficient services which will become part of operational costs in future.