Thank you Mr. Chairman and good morning to you all.
With this submission Greenpeace International and Friends of the Earth International submits to the Conference what has been obvious to the vast majority of ship recycling experts and waste management authorities. That is, that the “beaching method” whereby ships are run aground on ocean beaches for cutting and breaking apart in the intertidal zone can never be accomplished in a manner which is environmentally sound or protective of human health.
Careful analysis of the intrinsic characteristics of beaching operations are conclusive that no amount of prescriptive improvements or protections can remedy the four fatal characteristics of intertidal beaching operations:
1. First there is the impossibility of containing pollutants on a tidal beach where hulls of ships are often breached accidentally or by cutting, or toxic paints erode or are abraded sending persistent organic pollutants, heavy metals and oils onto the beach and into the seawater;
2. Second, due to a shifting and soft wet tidal sand surface, there is the impossibility of rapidly bringing emergency response equipment, including fire-fighting equipment and vehicles, ambulances and cranes along side the ship, to assist or remove persons hurt inside the hull;
3. Third, the impossibility of allowing cranes to work alongside to lift heavy cut sections of a ship and thereby preventing heavy cut sections from being subject to gravity, shifting or falling directly into workers or into the marine environment; and
4. Finally, there is the absolute incompatibility of conducting hazardous waste management operations (which is what they are as long as ships contain hazardous wastes) in the ecologically delicate and vital coastal zone.
These fatal flaws of the beaching method inevitably will result in causing avoidable death and pollution and thus make a mockery of the application of Regulation 19 of this Convention. No amount of band-aid guidelines and criteria can cure the malignancy inherent in beaching operations. To ask Parties to prevent adverse effects to human health and the environment from massive toxic ships on an intertidal beach already makes the fulfillment of this objective impossible. However the worst outcome is that by not drawing a clear line at the outset, this fatally flawed method will be legitimized, millions of dollars will be thrown into trying to mitigate the inherently inappropriate and dangerous working platform and the IMO will have succeeded in perpetuating death and pollution for many years to come.
Mr. Chairman, today we have brought to this important meeting and which will be made available to you all as an Information Document, a Statement of Concern, signed by the leaders of 107 civil society organizations in over 30 countries. The list includes 4 winners of the prestigious Goldman Environmental Award including Rizwana Hasan who is with us today. Today we do not represent simply Greenpeace International, and Friends of the Earth, nor the greater NGO Platform on Shipbreaking alone. Today, we are bringing you the voice of the vast body of civil society environmental, development human rights, and labor organizations that have come together unanimously to sign a statement condemning this Convention as an historical failure, if it cannot muster the political courage to cease the scandalous pretense that scrapping aged ships containing hazardous wastes and oils on ocean beaches in the intertidal zone might be somehow a viable way to achieve the safe and environmentally sound recycling of ships.
The IMO member states cannot continue to put their head in the sand and say that they will be “method neutral” as such a statement is “science deficient”. And indeed such a statement is morally deficient -- for to be “method neutral” is to be neutral on actual matters of life and death, for it is on the beaches of
South Asia that approximately 50 workers per year are killed. How many of these deaths could have been prevented were proper equipment such as cranes, fire fighting vehicles, and ambulances been made accessible to the fallen workers? The fact that countries such as Norway, member States of the EU, the United States, and Japan can, within this august body pretend that this method is viable is in fact the height of hypocrisy, as such operations would be banned in those countries in an instant for violations of coastal zone management laws, occupational safety and health laws, and hazardous waste management laws.
With this submission we as the civil society stakeholder voice in these proceedings call for a prohibition on the beaching method, by amending Article 19 to include the following text:
Ship Recycling Facilities authorized by a Party shall establish and utilize procedures to:
New Paragraph One: ensure that ship recycling operations taking place on intertidal flats, or ocean beaches or other working platforms which prevent:
§ rapid access to ships by emergency equipment;
§ the ability to utilize cranes and lifting equipment at all times alongside vessels; and
§ the possibility of full containment of pollutants during all cutting and stripping operations, are prohibited;
Additionally, we are proposing that a conference resolution on an implementation mechanism be agreed upon in Hong Kong, which shall include provisions for technical assistance to countries where the beaching method is used with an aim to directing funds toward phasing-out this breaking method and replacing it with dockside, slip, or dry dock platforms as a matter of urgency and global responsibility.
Finally, we are calling on Conference delegations to develop a Conference Resolution calling for the creation of such a fund for pre-cleaning during the useful life of a ship and prior to its final voyage and for safe recycling – applying established the principles of producer responsibility, polluter pays, and cost internalization.
We as civil society, believe that if the distinguished delegates take a moment to recall who and what this Convention is really for, the beleaguered marine environment and disempowered and desperate workers, they will then find the courage to take the vital steps we have proposed.
Thank you Mr. Chairman.
Delivered by Jim Puckett
13 May 2009,
Hong Kong, International Conference on the Safe and Environmentally Sound Recycling of Ships
Source: The NGO Shipbreaking Platform.