With factors such as Covid-19 delaying IHM compliance, experts at a Riviera webinar reviewed the difficulties of conducting IHM surveys and the likelihood meeting the regulation’s deadline
From 31 December 2020, vessels calling at an EU port must have an Inventory of Hazardous Materials’ (IHM) certificate onboard.
With the requirement for vessels to be IHM-compliant looming, Interorient Marine Services head of marine DDPA/DCSO Capt Deepak Gupta said his company began planning in mid-2018 and created a project team specifically for meeting IHM compliance.
The company’s original timeline was for the schedule of ship surveys to be completed in six months per ship, providing sufficient slack before IHM implementation to deal with contingencies. Of course, one contingency that could not be foreseen was Covid-19.
The other factor delaying the process, he said, has been the contaminated materials found during testing samples from ships.
“The delay was also due to detecting contaminated material, which was not accounted for when we set out the plan,” said Capt Gupta.
One of these materials in question is asbestos, which comes under the SOLAS code. Asbestos is expected to be found in more that 40% of vessels surveyed for IHM.
In the long-term, the flag state can allow the shipowner up to three years to remove the asbestos, and the cost-effective approach is to remove this during the vessel’s next special survey.
But the short-term impact on the IHM timeline is significant for removing asbestos found during the IHM surveys. Capt Gupta related that in early January 2020, it was difficult to find experts who knew how to deal with asbestos. Although the situation has now eased somewhat, availability remains one potential practical hurdle for shipowners to overcome in the race for compliane.
Looking further ahead, Capt Gupta described the sometimes convoluted set of maintenance procedures IHM requires of shipowners.
“The onus is put on the shipowner. How do we maintain Material Declaration (MD) if the supplier, which can be a recognised and accepted supplier, does not supply the required document? They (the suppliers) are causing confusion in the implementation of IHM,” he said.
IRI/The Marshall Islands Registry maritime operations specialist Vangelis Moutafis provided the flag state perspective. He noted that in late 2019, the EU issued a press release ahead of the one-year implementation of IHM compliance and the requirement to have a Statement of Compliance (SoC) onboard. It estimated 35,000 vessels required the compliance and one-third had yet to begin the compliance process, begging the question: if one-third of the fleet 12 months ago had yet to start the IHM compliance procedure, what are the chances of the whole fleet being in compliance on 31 December 2020?
A survey of webinar attendees showed that very few (6%) thought between 75% to 100% of the fleet would comply by the IHM deadline. Nearly half (42%) thought between 50% and 74% of the fleet would be in compliance, and 29% believed that between 25% and 49% of the fleet would be in compliance. Nearly a quarter however (23%) said that IHM compliance would be as low as 0% to 24%.
“The impact of Covid-19 was a partial cut in the supply of services and limitations on available surveyors,” following the introduction of lockdowns and other travel inhibitors, Mr Moutafis said.
In 2019, IRI/The Marshall Islands Registry trained and introduced worldwide IHM specialists in its 28 offices.
It also teamed with IHM specialists and independent laboratories worldwide and had approved remote surveys for Part I of IHM on a case-by-case basis.
In a survey, 65% agreed remote initial verification surveys are a viable alternative for a surveyor attending a vessel (35% disagreed).
Verifavia Shipping IHM general manager Yuvraj Thakur related the Covid-19 impact on a supplier of inspection and verification services and the actions the company had taken.
“Covid-19 worked in an opposite way for us. Before, we were conducting 40 to 50 surveys a month. Now we are conducting 80 to 100 surveys each month. We had to react fast to the demands of our clients,” said Mr Thakur. “We have stopped marketing IHM surveys,” he said, to service contracted clients.
Of the vessels under contract, he noted “750 vessels are under contract. 560 surveys have been completed. Only 200 to go, which we expect to complete by November and 450 IHM reports have been sent to classification societies – without one rejection.”
The next issue on the horizon regarding IHM compliance is not so much the deadline, but IHM maintenance. Once the SoC is onboard, it needs to be updated by the shipowner every time a new piece of equipment or material is added to the fabric of the ship.
As the webinar heard, there are significant issues in potentially hazardous materials coming on board. Suppliers should provide SoC for products and materials alongside all purchase orders, but even the most respected names are failing to do so.
How widespread is this problem? In a survey, 48% found they were able to obtain MD and SoC from supplies, while 52% replied they were not able to.
“The onus on testing the supply chain should not be on the owners,” said Mr Thakur. “The aim of the regulation was not to have any hazardous material reaching the ship-breaking yards.”
To track and trace the hazardous material in the supply chain is a huge task for a shipowner, but for a company already with familiar with the procedure, it is a problem that can be solved.
“We have a solution – a dashboard which Verifavia Shipping, acting as the designated person, maintains for the shipowner,” said Mr Thakur.
Verifavia Shipping reviews all purchase orders, scans for potential hazardous materials and quantifies and locates the material on the ship. The product, HAZinvent, connects via API, and provides the shipowner with an updated IHM on demand.
In a survey, over 70% expect to outsource IHM maintenance to third parties.
Panellists (left to right): Capt Deepak Gupta (Interorient Marine Services), Vangelis Moutafis (IRI/The Marshall Islands Registry, Yuvraj Thakur (Verifavia Shipping)