Leaving it to the last minute could be a risky gamble, with about 12,000 vessels still in need of an Inventory of Hazardous Materials (IHM) and laboratory capacity for analysis limited
There is just over a year to go until the EU’s Ship Recycling Regulation requirement mandating all EU-flagged vessels or vessels calling at EU ports have an IHM with a Statement of Compliance (SoC) comes into force.
At the time of writing, the IHM requirement was applicable to approximately 20,000 vessels. Of these, approximately 8,000 – 40% – already have an IHM, leaving the majority of the affected fleet, some 60%, or 12,000 vessels, needing to produce an IHM in the coming year.
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 Capt Herbert Soanes about what operators need to consider when selecting an IHM provider, and what sort of timeframe should be allowed to produce the survey.
Some operators may delay compliance until as close to 31 December 2020 as possible, Mr Lougridis noted. In some cases, this may be to ease the burden on a shipowner’s technical staff, who may already have their hands full dealing with ballast water treatment systems or sulphur cap compliance strategies such as exhaust gas cleaning systems that are seen as more pressing requirements. “Something that is not due until the end of next year is not front and centre for them to pay attention to,” said Capt Soanes.
Alternatively, operators may wish to ease the burden on the company’s finances by delaying in hopes of reduced prices, or improved cash flow depending on the sector.
However, such delaying tactics could prove risky, Mr Lougridis and Capt Soanes noted. The closer to the compliance deadline production of the IHM is left, the less leeway owners have should the process take longer than expected, for example if the SoC is rejected, or there are delays in laboratory analysis, class production of the SoC, or undertaking the inspection itself. This then raises the possibility of an operator’s asset not being in compliance once the regulatory deadline passes.
And while there is no shortage of suppliers offering to produce the IHM for owners, as well as carrying out the actual audit, samples require analysis in laboratories and class societies must issue an SoC to validate the IHM.
“The bottleneck is not in how many companies or inspectors can produce the IHM,” said Mr Lougridis, “the bottleneck is first of all in the class societies that can issue the Statement of Compliance, and in the laboratories that are qualified to analyse all 15 hazardous materials.”
Preparation ahead of the inspector coming on board will be essential. Capt Soanes noted that while CTI’s inspectors can acquire all required samples in a couple of days, auditors in the industry are known to take three to four days if they do not have sufficient experience or a plan has not been properly prepared in advance.
And in terms of laboratories, IHM providers will have to compete for the services of facilities capable of analysing all 15 hazardous materials covered in the EU’s regulations, and the potential for time delays and cost increases. “Let’s say an owner is choosing to do the IHM with a small service supplier, they can never be sure about the quality of analysis and response time, and total costs by the end of the project,” said Mr Lougridis.
CTI Marine Services circumvent the laboratory bottleneck by having their own inhouse labs, accredited by class and with ISO quality standards for completing IHM analysis, said Mr Lougridis. This means that operators will have transparency over laboratory costs, and an idea of the time it will take – approximately 10 days – for lab analysis to be completed.
This article is the second in a series of three looking at issues surrounding the IHM process and what shipowners need to be aware of. In the next article in this series, we will look at what shipowners need to be aware of regarding the IHM and how it relates to the Hong Kong Convention on ship recycling.
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.