As the EU Ship Recycling Regulation is to take effect in 2020, stakeholders should stand up to their responsibilities and IHM Service suppliers should create effective procedures to promote compliance, argues Consulting Engineer Stefanos Magoulas.
Summer’s out. 2019 is almost out. Which means that 2020 is approaching. And, inevitably, brings 2021 closer to us. And, as most of us should know, as per EU 1257/2013, the infamous but yet a bit neglected EU Ship Recycling Regulation, “…all existing ships above 500 GT, under EU-flag or any flag, when visiting EU-ports, are required to have an IHM onboard, until 30 Dec 2020…”.
Only by taking into consideration the clause “…ships above 500 GT, under EU-flag or any flag, when visiting EU-ports…” lays down a huge number of ships to be served. By 2017, it had been said that approximately 30.000 vessels are subjected to the application of EU SRR. So, by doing the math and being very optimistic, if 10.000 vessels have been covered since 2017, it means that by the end of 2020, approximately 40 ships per day have to be receiving an efficient and properly verified IHM.
The perception of this figure, taking into account all the other, very important issues that are occupying shipping companies i.e. Ballast Water Management systems, Sulphur Cap, Scrubbers etc., should make stakeholders at least a bit sceptic. It is agreed that the main worry should rest upon existing ships as every “…new ship shall have on board an inventory of hazardous materials, which shall identify at least the hazardous materials referred to in Annex II and contained in the structure or equipment of the ship, their location and approximate quantities…”, as of 31 December 2018, despite the fact that even new ships seem to present specialties of their own, regarding IHM, but this can be discussed in another article.
First of all, ship owners, which are primary responsible for preparing an IHM, should be adequately informed on the matter. Inventory is a technical file, that relies on utilization of knowledge, expertise and experience, by competent personnel. Although I am one, I am trying to avoid the use of term “HazMat Expert”. Expert has always been a very abstract term, though it should not be like that. I mean, Inventory of Hazardous Materials is all about materials. More or less, the same materials that could have been used on other application e.g. industrial facilities. To our advantage, these materials have been regulated, to a specific level, by International Instruments, such as Conventions and Protocols. So, to conclude on this, as “competent personnel”, we could agree that it should at least correspond to individuals or collaboration of such, with a solid scientific background, coherent to the very essence of Management of Hazardous Materials. Of course, accumulated experience can compensate instead of certified knowledge, but only up to a point and, certainly, for a little number of individuals.
Certified knowledge is another aspect someone should examine, when addressing to a third party for outsourcing such services. Certified knowledge can be related only to Certificates of Competence, such as Degrees or Diplomas, and, in our case, it should be backed up by competent experience. This can create the moderate certainty that the individual we have been receiving consulting, has the minimum efficient grasp of scientific knowledge, industry practices and applicable legislation. Of course, all aforementioned apply to every other sector someone needs the contribution of someone else. Or, to put it more simply, when you need a Captain, you get a licensed one. Of course, in the case of IHM, we are still lacking the application of universal and uniform practices, an issue discussed below, but this should not intimidate us from seeking and requesting efficient services. Approvals and certifications that are deriving as bi-products of commercial practices and agreement between parties of the sector can serve up to a point as indications that an entity has achieved a certain level of familiarization with the objective of IHM but more solid evidence should be sought.
Now, let’s address the issue of practices. 2015 MEPC IHM Guidelines – which are, at the moment, the only solid reference for IHM Compilation – refer to five, very specific steps, in order to come up with an IHM Part I, as following:
- collection of necessary information;
- assessment of collected information;
- preparation of visual/sampling check plan;
- onboard visual check and sampling check; and
- preparation of part I of the Inventory and related documentation
As 2015 MEPC Guidelines imply, none of the above steps can be avoided. What you know, you have to see. What you do not know, you have to sample. So, to cut short and answer to the question we have been receiving by ship owners but there seems to be a grey area, step 4 aka “Onboard visual check and sampling check” cannot be avoided. And, in order not wander around on a vessel, wasting time and money, neither step 3 can be avoided. A Visual/sampling check plan (VSCP) is the map of a surveyor, in order to perform a proper on-board survey. This leads us to steps 1 & 2. Collecting necessary information and assessing it properly is the very backbone of an IHM. Individual doing that is responsible for collecting only the necessary information, which can vary and include different material, and assessing it properly. Only by this, a well structured VSCP can occur. 2015 MEPC Guidelines provide with some important information but they are what they are name after: Guidelines. A well-structured VSCP should depict adequately that a person has properly collected necessary information, put them against Guidelines and checked them for consistency, enabling thus an efficient onboard visual check and sampling check. We have heard about 1-2 surveyors, staying on a vessel for 5-6 days, ending up with seven hundred (700) samples (!?!?). Even if these numbers go to half, this is not the case, for sure. If steps 1-4 have been taken carefully and in a structured way, time and work required should be significantly less.
Sampling, which should be expected in most cases, is another issue. It is understood that sampling is a destructive testing method. This means that, in order to take a sample from a homogeneous and compact materials and/or component of equipment, a piece has to be removed. It is therefore easy to understand that someone will not enter a vessel and start sampling at will, cutting pieces of insulation, gaskets, just because Guidelines mention them. On the contrary, sampling has to be preformed in a well-organized way, providing that the ship is still intact, after the On-Board Survey. And this is achievable only by applying an adequate VSCP during the on-board survey. There are practices, deriving from other industries, that can be applied and facilitate efficient sampling. A surveyor with adequate knowledge and experience can execute a well-made VSCP, coming up with a quite representative survey result. In a phrase, you need to know what you are searching for and where to find it.
Finally, attention should be raised specially to ship owners. Initially, IHM is not another manual. It takes time and work to be made while contribution of ship owner is required. Therefore, it should not be left to be done in the end. As time passes, demand will rise, time will be at shortage and these are not a good combination. It is proposed that ship owners should seek at least for adequate information, so that they know exactly what they are expected to have and, therefore, seek by an outsourcing entity.
Moreover, other requirements running currently i.e. Ballast Water Management systems, Scrubbers etc., are closely related to IHM. In fact, while a ship owner waits, procurement and supplies continue to run. And rest assured that procurement and supplies are very closely related to IHM as fixed equipment is being managed, ending installed on the vessel. Do take the initiative and take some steps regarding Procurement policy, in order to enable your company to be proactive against IHM, when you decide to do it.
Inventory of Hazardous Materials is here to stay; this is for sure. It is a statutory request, at least for EU vessels at the moment. Even so, it will be a Port State Control (PSC) object to be checked, for EU ports. This means that can have an impulse to other sectors, such as chartering, and, in any case, is a quite important issue, not to be overlooked.
Stakeholders should stand up to their responsibilities: shipowners should seek for all the info they can get while IHM Service suppliers should create effective procedures and mobilize competent resources so that efficiency, reliability and compliance is achieved.
The views presented hereabove are only those of the author and not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.
About Stefanos I. Magoulas
Stefanos I. Magoulas is an active and experienced Consulting Engineer, focused firmly on Environmental Protection issues, in matters of Legislation Compliance and Project Operations Consultancy. Actively involved in Maritime Environment, Health & Safety (EHS) sector, he has worked at different stakeholders of the shipping industry, serving as a Consulting Engineer for shipyards, equipment manufacturers, salvors and waste management companies. In 2016, he started Solix Engineering™, a firm of Environmental Protection Consulting Engineers, focused on Environmental Compliance, Protection & Awareness.