With the Hong Kong Convention on ship recycling likely to enter into force in the next few years, this has important implications for selecting a class society to validate the Inventory of Hazardous Materials
With India`s ratification and that of China likely to follow, the Hong Kong Convention on ship recycling looks likely to enter into force in 2023. This has important implications for selecting a class society to validate the Inventory of Hazardous Materials (IHM).
The Hong Kong International Convention for the safe and environmentally sound recycling of ships, known as the Hong Kong Convention for short, was adopted in 2009 on the understanding it would enter into force once ratified by at least 15 countries, representing 40% of world merchant shipping by gross tonnage, and on average 3% of recycling tonnage for the previous 10 years.
At the time of writing, 13 ratifications have been received, four of which were within the past year (Malta, Japan, Germany and the Netherlands).
CTI Marine Services is a Singapore-headquartered organisation that has already been involved in producing thousands of IHM projects. It is the maritime specialist arm of Centre Testing International (CTI), a China-headquartered international conglomerate that provides a range of testing, environmental safety and material reliability services spanning industrial products, consumer goods and maritime hazardous materials management. We spoke with CTI Marine Services business manager Andreas Lougridis and senior vice president of global maritime business Captain Herbert Soanes about how the two instruments are related, and how complying with the SRR will benefit vessel owners once the Hong Kong Convention enters into force.
“EU requirements are higher than the Hong Kong Convention’s requirements as the Hong Kong Convention requires investigation of 13 hazardous materials, but the EU’s SRR requires investigation of 15, the 13 hazardous materials from the Hong Kong Convention plus two more,” said Mr Lougridis.
“So, once you comply with the EU SRR, by default you comply with the Hong Kong Convention as well,” he added.
Capt Soanes noted that the EU’s regulations are “open class,” meaning that a vessel owner can choose any IACS class society to verify the IHM and issue the Statement of Compliance (SoC), and this does not have to be the vessel’s regular class society.
Mr Lougridis added “We are able to comply with all class society requirements, but some have stricter requirements around the number of samples that must be collected, and also the presence of an inspector during the sampling process,” he said, adding “The cost to the owner is higher because they have to pay the surveyor to be there and they have to pay the IHM company higher fees because the number of samples is bigger than other class societies.”
“The more intense the requirements, the more expensive the costs for the shipowner, for accommodating class and accommodating the hazardous material company as well,” added Capt Soanes.
But selecting a class society to ratify the IHM and award the SoC should not be based on short-term costs alone, he noted, explaining “When the Hong Kong Convention gets ratified – and our expectation is that this will probably be by 2023 – these Statements of Compliance will need to be converted to Certificates of Compliance.”
This means it is important to ensure that even if the Statement of Compliance is issued by a different class society, the IHM inspector should be approved by the vessel’s regular class society, as otherwise owners risk being in a situation where the vessel’s class society may not give much value to the IHM report and may insist it needs to be produced again and approved by that class society, Capt Soanes noted.
This article is the third and final in a series of three looking at issues surrounding the IHM process and what shipowners need to be aware of. The previous articles offer a walkthrough of what the IHM is and how it is produced, and guidance on selecting a provider and timescale from start to finish for production of the IHM.
CTI Marine Services and Riviera Maritime Media are jointly hosting a webinar on the Inventory of Hazardous Materials, detailing what every vessel operator needs to know and do by 2020, on 10 December 2019 at 9:30am GMT. Book here to register for the webinar.