Section 5.5 Inspection and Certification of Hold Cleanliness

After the arduous process of cleaning cargo holds to the presumed required standard, the critical moment of truth arrives: the hold inspection. This is where the vessel’s efforts are evaluated, typically by one or more independent parties, to determine if the holds are indeed fit to receive the next intended cargo. Passing this inspection is paramount; failure can lead to costly delays, re-cleaning efforts, and disputes. For the Master, successfully navigating the inspection process requires not only ensuring the holds are genuinely clean but also understanding the dynamics of the inspection itself and the significance of any certification issued.

1. The Purpose and Importance of Hold Inspections:

Hold inspections are conducted to:

Verify Cleanliness Standards: Confirm that the cargo holds meet the specific cleanliness standard required by the charter party, shipper, or for the particular cargo (e.g., grain clean, hospital clean).

Prevent Cargo Contamination: Ensure that no residues from previous cargoes, loose rust or paint, odors, or insect infestation will contaminate or damage the next cargo.

Confirm Fitness to Load: Determine if the holds are, in all relevant aspects (cleanliness, dryness, structural integrity in way of cargo, freedom from infestation), suitable and safe to receive the nominated cargo.

Satisfy Contractual Requirements: Fulfill clauses in charter parties or sales contracts that mandate an independent inspection and certification of hold cleanliness before loading can commence.

Protect Interests:

Shipper/Cargo Owner: To ensure their cargo will not be compromised.

Charterer: To ensure the vessel they have chartered is fit for the intended trade and to avoid claims from cargo owners.

Shipowner: To demonstrate due diligence in providing a suitable vessel, to avoid off-hire situations, and to have evidence of hold condition prior to loading in case of subsequent cargo claims.

P&I Clubs: Interested in minimizing cargo claims, often recommending or requiring such inspections for certain cargoes.

2. Types of Hold Inspections and Attending Surveyors:

Several parties may conduct or attend hold inspections:

A. Internal Inspections by Ship’s Staff:

Who: Master and/or Chief Officer, sometimes accompanied by the Bosun or other senior crew.

When: Conducted before presenting the holds to external surveyors. This is a critical self-assessment.

Purpose: To ensure the crew’s cleaning efforts have met the target standard and to identify and rectify any deficiencies before external parties come onboard. This internal “pre-inspection” can save considerable time and embarrassment.

B. Independent Surveyor Inspections: These are the formal inspections that determine whether the vessel will be accepted for loading.

Shipper’s Surveyor: Appointed by the cargo shipper to ensure the holds are suitable for their specific cargo. Their standards are often very high, particularly for sensitive or high-value commodities.

Charterer’s Surveyor: Appointed by the vessel’s charterer to confirm the vessel meets the cleanliness and condition requirements stipulated in the charter party.

Independent Cargo Surveyor (General): May be appointed jointly or by one party to provide an objective assessment.

Agricultural / Quarantine Inspectors (e.g., USDA, AQIS, Canadian Grain Commission): Government-appointed inspectors specifically for grain and other agricultural commodities. They focus intensely on freedom from previous organic residues, insects (live or dead), and odors. Their word is often final for loading such cargoes.

Owner’s P&I Club Surveyor: While less common for routine pre-loading cleanliness inspections (unless a known problem exists or a very high-risk cargo is involved), P&I surveyors might attend if disputes are anticipated or to provide guidance.

National Cargo Bureau (NCB) Surveyor (USA): In the US, NCB surveyors often conduct hold inspections for fitness to load various cargoes, including grain and dangerous goods in bulk.

It’s common for multiple surveyors representing different interests to attend the inspection simultaneously.

3. The Inspection Process:

A. Preparation by the Ship:

Confirm Required Standard: Re-confirm the exact cleanliness standard required with the agent, charterer, or shipper.

Thorough Internal Pre-Inspection: As mentioned above, this is vital.

Safety Arrangements:

Ensure safe access to the holds (e.g., ladders secure, adequate lighting).

Comply with enclosed space entry procedures if holds have been sealed or unventilated for a period (test atmosphere for oxygen, flammable/toxic gases).

Have necessary safety equipment ready (e.g., harnesses if surveyors need to enter difficult areas, though surveyors usually have their own basic PPE).

Lighting: Provide good quality portable lighting (e.g., cluster lights, powerful torches) as hold lighting alone may not be sufficient for detailed inspection of all areas.

Documentation: Have relevant documents ready (e.g., previous cargo details, cleaning records, any communications regarding cleanliness standards).

Personnel: The Chief Officer should be readily available to accompany the surveyor(s), answer questions, and arrange for minor touch-ups if immediately rectifiable.

B. What Surveyors Look For: Surveyors will conduct a systematic and thorough examination of each hold presented. Their focus includes:

Overall Cleanliness: The general visual appearance of the hold.

Previous Cargo Residues: Meticulously checking all surfaces for any traces of the previous cargo – tank top, hopper plates, side frames (especially behind them in single-hull ships), underdeck beams, stringers, inside hatch coamings, access ladders, pipe guards, manhole covers, and especially bilge wells.

Loose Rust Scale and Paint Flakes: Any loose material that could detach and contaminate the cargo. Firmly adhering paint and surface rust are usually acceptable, but not flaking conditions.

Odors: Any lingering odors from previous cargoes or cleaning chemicals.

Infestation: Any signs of live or dead insects, larvae, pupae, rodent droppings, or bird lime (especially critical for agricultural cargoes).

Dryness: Holds must generally be dry, especially for moisture-sensitive cargoes like grain, cement, or fertilizers. No standing water, damp patches, or excessive condensation.

Structural Integrity (Relevant to Cargo): While not a full structural survey, surveyors will look for obvious damage that could affect cargo containment or safety (e.g., holes in plating, significantly bent frames that could snag cargo or impede discharge, damaged bilge well covers).

Bilge Well Condition: Clean, dry, strum boxes clear, suctions tested (sometimes requested).

Hatch Cover Sealing Surfaces (Coamings): While not strictly part of “hold” cleanliness, surveyors may comment on the condition of coaming compression bars if they are heavily corroded or damaged, as this affects weathertightness.

C. Tools Used by Surveyors:

High-Powered Flashlights/Torches: Essential for illuminating dark corners and recesses.

Mirrors (often on telescopic handles): To inspect behind frames and in other inaccessible areas.

Scrapers or Spatulas: To gently probe surfaces for loose material or test the adherence of residues.

Cameras: To document the condition of the holds (both good and bad).

White Gloves/Clean Cloths: For “wipe tests” to check for fine dust or residues, especially when a “hospital clean” standard is required.

Sample Bags/Containers: If they suspect contamination or need to take samples of residues.

Moisture Meters: Occasionally used for checking dampness of surfaces or residues.

Magnifying Glass: For inspecting for small insects or fine cracks.

4. Criteria for Passing or Failing an Inspection:

Meeting the Specified Standard: The primary criterion is whether the hold meets the pre-agreed or industry-accepted standard for the next intended cargo.

Subjectivity vs. Objectivity: While standards like “grain clean” have fairly well-defined criteria, there can still be an element of subjectivity in a surveyor’s assessment, especially for terms like “normal clean” or the very highest standards. The surveyor’s experience and the specific sensitivities of the cargo play a role.

Common Reasons for Failure:

Visible previous cargo residues (especially in corners, on frames, underdeck).

Loose rust scale or paint flakes.

Presence of insects (even a single live insect can cause failure for grain).

Strong residual odors.

Dampness or wet patches when dryness is required.

Dirty bilge wells.

Generally poor standard of cleaning that doesn’t inspire confidence.

“Fit to Load”: Passing the inspection generally means the surveyor deems the hold “fit to load” the specified cargo.

5. Certificates of Hold Cleanliness / Fitness to Load:

Issuance: If the inspection is satisfactory, the attending surveyor(s) will issue a “Certificate of Hold Cleanliness,” “Certificate of Fitness to Load,” or a similar document. If multiple surveyors attend, each may issue their own certificate, or they may issue a joint certificate.

Content: The certificate typically states:

Name of the vessel.

Port and date of inspection.

Holds inspected (e.g., Holds No. 1, 2, 3, 4, 5).

The standard of cleanliness to which they were inspected (e.g., “found clean, dry, and free of previous cargo residues, suitable for the loading of [specified cargo]”).

Any remarks or minor recommendations (though usually, for a pass, there are no significant negative remarks).

Name, signature, and stamp of the surveyor/survey company.

Significance:

Provides formal evidence that the holds were inspected and found suitable at a particular time.

Often required by shippers before they will commence loading.

Essential for protecting the shipowner’s interests in case of subsequent cargo claims (it demonstrates the condition of the hold before loading).

Limitations:

The certificate reflects the condition of the hold at the time of inspection. Conditions can change if, for example, it rains into an open hold after inspection but before loading.

It does not usually guarantee the cargo itself will be free from issues, only that the hold was fit to receive it.

6. Dealing with Failed Inspections:

Consequences:

Off-Hire: The vessel may be declared off-hire by charterers until the holds are re-cleaned and pass re-inspection. This is a direct financial loss.

Delays: Significant delays to the vessel’s schedule.

Re-cleaning Costs: Costs for additional crew overtime, cleaning materials, or even hiring shore labor for re-cleaning.

Re-inspection Fees: Surveyors will charge for re-attending.

Damage to Reputation: Repeated failures can damage the vessel’s and company’s reputation.

Master’s Actions:

Understand the Reasons: Obtain clear, specific reasons for the failure from the surveyor(s). Request they point out the deficient areas.

Document: Record the surveyor’s findings and the reasons for failure in the ship’s log and a Letter of Protest if appropriate (e.g., if the Master believes the surveyor’s assessment is unreasonable or the standard demanded is beyond what was agreed).

Liaise with Company and Charterers: Immediately inform the company (DPA, technical department) and charterers of the failure and the required rectification.

Plan and Execute Re-Cleaning: Promptly organize and supervise the re-cleaning of the deficient areas.

Request Re-Inspection: Arrange for the surveyor(s) to re-attend once confident the issues are resolved.

7. The Master’s Role in the Inspection Process:

The Master’s proactive involvement is key to a smooth inspection process.

Champion Thorough Preparation: Instill in the Chief Officer and crew the importance of meticulous cleaning and a rigorous internal pre-inspection. “Inspect to pass, not just to present.”

Professional Presentation: Ensure the vessel is presented in a professional manner – safe access, good lighting, cooperative crew.

Accompany Surveyors (or delegate to Chief Officer): Be present during the inspection (or ensure the C/O is) to answer questions, understand any concerns immediately, and potentially address minor issues on the spot if feasible and agreeable to the surveyor.

Constructive Communication: Maintain a professional and constructive dialogue with surveyors, even if there are disagreements. Avoid becoming confrontational.

Protect Owner’s Interests: While aiming to pass, also ensure that unreasonable demands are not made or that standards beyond what was contractually agreed are not imposed without justification. If necessary, issue a Letter of Protest.

Review Certificates: Carefully review any certificates issued before the surveyor leaves, ensuring all details are correct.

Successfully passing hold inspections consistently is a hallmark of a well-managed and efficient bulk carrier. It requires a combination of diligent work by the crew, meticulous planning and supervision by the officers, and a clear understanding of the standards and expectations involved, all under the ultimate responsibility of the Master.