SCHIFFSTECHNIK | SHIP SCHIFFSTECHNIK | SHIP TECHNOLOGY IHM maintenance: Better take it seriously The main challenge for Inventory of Hazardous Materials (IHM) maintenance is establishing effective systems in the supply chain, says Yuvraj Thakur, IHM General Manager, Verifavia Shipping Many voiced concerns over IHM preparation/certification capacities. How did it turn out towards the deadline? Yuvraj Thakur: Few providers of IHM services, have previously reported that only 30–40 % of the world market had completed and prepared its IHM certification by the end of 2020. At Verifavia, we’ve worked with almost 90 shipowners to ensure that they were preparing an IHM for all vessels throughout 2020. Compared to activity in 2020, numbers for IHM preparation have certainly reduced and we are experiencing a far bigger drive to organise the ongoing IHM maintenance aspect of the regulation, with the majority of the regulated industry already having completed or are in process of completing the initial IHM. In October 2020, the European Commission extended the deadline for IHM preparation for six months after the 31 December 2020 deadline (i.e. until 30 June 2021 ) in relation to specific Covid-19-related scenarios. However, the owner still needs to provide evidence that all possible measures were taken to undertake the work and achieve the required certification. What are the most common issues around certification and maintenance? Thakur: In 2020, the main challenge for IHM preparation and certification was getting an inspector onboard vessels during the pandemic. An experienced IHM surveyor is needed to ensure the preparation process is accurate and effective; this is not a task for the crew. Due to Covid-19, travel restrictions impacted the necessary surveys. However, having local Hazmat experts around the world ensured our 800+ vessel surveys were all completed onboard by highly-qualified professionals with seafaring experience. The main challenge for IHM maintenance is establishing effective systems in the supply chain. A lot of organisations do not have accurate procurement systems. We have seen a significant digital push over the last year which has helped ensure IHM maintenance is a smooth and efficient process. Shipowners and managers have also had to make decisions on whether IHM maintenance should be outsourced or maintained inhouse. At Verifavia, we use a digital real-time platform which can be connected to any system. There are real risks of vessel detention if the IHM is not maintained accurately, so outsourcing this ensures you have access to experienced and reliable teams to support compliance and guarantee confidence in shipping operations. However, a digital solution for IHM alone can never replace the need for marine knowledge and a genuine understanding of vessel operations and safety. When it comes to IHM, all hazmat experts are not equal – a maritime background that starts with education and training, developed by spending years onboard a vessel is essential to the delivery of a service that ship owners and operators can identify with and trust. Yuvraj Thakur © Verifavia How does IHM maintenance actually work, could you describe the process? Thakur: It is a detailed and time consuming process, involving a multitude of organisations. IHM certificates must be constantly up-to-date, requiring input from equipment suppliers, shipowners and class societies. A simple and reliable digital solution ensures efficiency and accuracy, and also helps to facilitate the renewal survey which is required every five years. The process itself involves suppliers listing all materials in their own and subsupplier’s products, and providing a Supplier’s Declaration of Conformity and Material Declaration along with purchase orders. The ship owner is responsible for keeping this up to date with any repair or conversion, painting or hull coating, or any machinery replaced, removed or added to. 456 maintenance dashboard, is one of the industry’s first online platforms providing shipowners, superintendents, vessels, and even Port State Control (PSC) and class with live access to the IHM maintenance status of the vessel. The dashboard can be connected to any procurement system, as well as the suppliers‘ data portal, and can function on IHM Part 1 prepared by any service provider across the globe. The system can automatically generate monthly or ad-hoc IHM maintenance reports to demonstrate implementation and compliance with regulations, and ensures vessels are prepared for PSC inspections. What is the experience so far regarding IHM and port state control? Answered by Alexander Schepers (SMS Bereederung), Verifavia’s Commercial Partner in Germany: Due to Covid-19, the total number of PSC inspections has come down by about 25–30 % on average. However, the industry is seeing that the quota of detentions has remained stable. They seem to be targeting specific vessels. We are certainly seeing that PSC is starting to ask questions about IHM, and we only expect this to increase. Normally, when new regulation comes into force, PSC make a concentrated inspection campaign. Given the European Commission’s extension to June 2021 , we expect to see – particularly for European PSC – a concentrated effort to target IHM later this year. We are seeing that all relevant parties such as class and flag are encouraging owners to ensure the IHM certificates are in order, so that evidence and documentation is clear in case of inspection. Interview: Felix Selzer 60 HANSA – International Maritime Journal 04 | 2021
SCHIFFSTECHNIK | SHIP TECHNOLOGY Confusion around IHM – Part 1 Not only due to the number of ships, but also Covid-19 restrictions made 2020 a busy year for IHM-experts. A structured approach is required but can only be achieved under certain conditions Until recently, the 2020-deadline for having a certified Inventory of Hazardous Materials Part I, covering hazardous materials in structure and equipment, ships visiting EU or flying an EU-flag was challenging. Most owners achieved compliance within the required time, but a certified IHM onboard is not the final goal as it also needs to be maintained to stay compliant. This entire IHM requirement is subject to frequent controls by PSC, EU-flags and class. The bureaucratic burden and penalties of IHM-incompliance are severe. A structured approach is required but can only be achieved when the scope of IHM including subsequent roles and responsibilities of manufacturers, suppliers, shipyards and shipowners are clear. Status Quo Demand for Material Declarations (MD) and Suppliers Declaration of Conformity (SDoC) from the shipowners’ side for maintaining the ship-specific Inventory of Hazardous Materials (IHM) grows rapidly. Suppliers need to prepare and provide those documents, but they struggle as required information from their own supply chains is often not available. Outsourcing this unwanted task is fully understandable for owners and suppliers alike. However, certain service approaches to circumvent responsibilities but offering »best prices« create a perfect complianceminefield and need to be approached with caution. Approaches for IHM maintenance Some »service approaches« require owners to collect suppliers’ documents and provide them to the service supplier once a month. In the same frequency ships are asked for onboardchanges relevant for maintaining the IHM. Consequently, most of the work, liabilities and time remains with the owner. The service fee and level is low, as is quality of IHM maintenance, but owners remain heavily involved. If this is the service supplier’s approach, it seems to be better for the owner to keep all in his own hands. Many service suppliers are not selecting relevant order items and copy entire order lists for requesting documents from suppliers. On average, we classify around 5 % of all order items as relevant and therefore avid 95 % of unnecessary requests. Any other approach increases the number of documentation gaps which are to be documented in the report on IHM maintenance. Such avoidable gaps will trigger problems during PSC-inspections and re-certification of the IHM in addition to an unnecessary workload for suppliers. Another approach is that order or ship-specific documents are requested for items. This increases the documentation efforts for suppliers tremendously and indicates a substantial lack of understanding IHM maintenance principles, as the SDoC is a supplierspecific and the MD a product-specific document. The worst case observed so far is a service supplier producing order data for each item of an order and ship-specific MD and SDoC, into which the scanned signature of the supplier is copied in. Such documents are sent to the shipowner, even when not requested or for non-relevant products. As it is done within few minutes it is obviously done without requesting information from sub-suppliers. It is only a matter of time until this approach, probably based on a simple software converter tool, will put at least the signatory before a court. Back to Basics The process flow Owners, manufacturers and suppliers face a new challenge for documenting presence and absence of hazardous materials in products and onboard ships. Other industries have developed principles for material compliance data exchange decades ago which can be applied for IHM maintenance as well. A sound understanding of such principles and adopting them is the key for efficient IHM maintenance. It´s not what IHM-experts have been certified or approved for and different approaches need to be applied. Authors: Henning Gramann, GSR Otto Klemke, NautilusLog How an efficient IHM Maintenance is achieved will be explained in the next issue of HANSA . © GSR HANSA – International Maritime Journal 04 | 2021 61
