08 July 2011

The ship Recycling Convention and Japan's Role:

When they come to the end of their operational life, superannuated ships are usually sent to be dismantled in developing countries, where labor costs are lower. In some countries, shipbreaking is frequently accompanied by fatalities, serious injuries or environmental pollution, creating a problem of worldwide concern. To address this problem, a Ship Recycling Convention is due to be adopted in May this year. As a world leader in ocean navigation and shipbuilding, Japan is expected to show leadership in this respect.

1. Introduction         

At one time, large ships were often dismantled in Japan, but the work has increasingly been passed to India, Bangladesh, Pakistan, China and other developing countries in recent years. In some of these countries, however, not enough attention is paid to issues like industrial safety and environmental protection. This frequently results in fatal accidents, injuries or environmental pollution, drawing international criticism. United Nations agencies have produced voluntary guidelines with a view to solving this problem, but they have made little headway in improving the situation. To achieve a quick solution, the International Maritime Organization (IMO) considers it imperative to introduce mandatory regulation. It has therefore started to draw up a "Convention for the Safe and Environmentally Sound Recycling of Ships" (Ship Recycling Convention), which is due to be adopted at a conference held in Hong Kong this May.

2. The Ship Recycling Convention

The purpose of the Ship Recycling Convention is to allocate clear responsibilities amongst all the parties involved, and to enforce a globally uniform discipline without loopholes.

As the actual mechanism of regulation, a system of inspection and certificates for ships and recycling will be introduced; ships meeting the standards may only be recycled in facilities that meet the standards. The Convention will cover ships weighing 500 tons or more in merchant shipping tonnage. Warships and government ships used only for non-commercial purposes are excluded, as are ships that are only navigated and recycled inside waters under the sovereignty or control of the registering country for the whole of their operational lives. However, even these exempted ships are expected to comply with the Convention within a range that is both reasonable and feasible. The Convention's requirements will also apply to the ships of non-signatory countries whenever necessary, such cases to be managed by port state control.

The installation or use of asbestos, PCB, and other "highly hazardous substances" will be prohibited or restricted on ships subject to the Convention, while a list ("inventory") specifying the location, type, estimated volume, and other details of these substances as well as lead, mercury, and other "substances deemed potentially harmful" will need to be created and kept. The inventory will ultimately be presented to the ship recycling yard as a tool for information on hazardous substances.

When a construction contract for a new ship is concluded after the Convention has come into effect, the shipyard is to create the inventory. Shipping manufacturers must create a "Material Declaration" specifying the content of hazardous substances in parts used in the ship, and submit this to the shipyard. For existing ships, an inventory must be created no more than five years after the Convention has come into effect, or, if the ship is recycled earlier than that, before recycling is carried out. In reality, however, it will be impossible to gain a correct and comprehensive assessment of hazardous substances to the same degree as in a new ship. Therefore, an expert (or group of experts) authorized as having the necessary knowledge and experience must create the inventory through documentary analysis, sampling, or other means.

Ship recycling yards will not be allowed to accept any ships other than those approved for recycling work. To prevent health hazards to workers and nearby residents, detrimental impacts on the environment are to be prevented, reduced, or minimized. Systems, procedures and techniques of management are to be established and approved by the government to nullify these impacts within a practicable range.

When a ship is to be recycled, the country of registration must be notified to that effect, and the inventory finalized (including specification of wastes arising during navigation and stored substances). Ship recycling yards are to determine methods of processing hazardous substances based on the inventory, and to create a "Ship Recycling Plan" in line with this. After obtaining the approval of the recycling country, the ship recycling yard will submit this Plan to the ship. The ship must submit the inventory and Ship Recycling Plan to the country of registration and undergo a final inspection. Only when these processes are complete will recycling be permitted. Ship recycling yards must also pass relevant information to the recycling country in advance, and must report to the recycling country and the country of registration when the recycling is complete.

3. Future tasks

Arrangement of legislation:
The likelihood is that the requirements for effectuation will be satisfied about two years after the Convention is adopted in May this year, and that the Convention will come into effect about a year after that in around 2012. Japan needs to ratify the Convention and arrange domestic legislation as soon as possible. Some areas of overlap between the Ship Recycling Convention and the Basel Convention have been pointed out, and these need to be demarcated as quickly as possible.

System for creating inventories:
In Europe, there are moves to establish internal regulations before the Convention takes effect, and Japan must also waste no time in developing a system for creating inventories. To create the inventory for a new ship, shipping manufacturers will have to submit a "Material Declaration" to the shipyard.

For this, PR activity is required not only in Japan but also abroad. Free "Inventory creation support software" is currently being developed, and this is expected to play a part in familiarizing the system.

While inventories for existing ships are to be created by approved experts (or groups of experts), the eligibility requirements need to be clarified and an international system for creation developed with some urgency. Also, to avoid a rush of requests for creation just before the start of application to existing ships, systematic steps will need to be taken to encourage the creation and retention of inventories.

To this end, we will also need a system for issuing "appraisals" that can be exchanged for Convention certificates after the Convention has come into effect.

Ensuring recycling capability:
It is not yet clear what level of recycling capability will be required of ship recycling yards under the Convention. If actual recycling demand exceeds the capacity of the yards, we could find disused ships being moored or abandoned. Therefore, the capacity of the world's ship recycling yards needs to be evaluated as a matter of urgency. If, as a result, a shortage of capacity is foreseen, ship recycling yards in developing countries should be given ODA and other support with a view to satisfying the Convention requirements. On the other hand, some countries, mainly in Europe, have started to think that a country's ships should be recycled within that country. Japan is also thought to be at a stage where it should consider recycling domestically, rather than simply entrusting the process to developing countries.

While Japan's part in the formulation of this Convention has been highly evaluated, this is largely due to experiments in creating inventories and other concerted efforts made by the Japan Ship Technology Research Association. These activities were in turn facilitated by a fund for ship recycling action established by the Nippon Foundation, a timely gesture indeed. In future, the government will push on to achieve early ratification and develop an appropriate environment.

However, it would befit Japan's role as a leader in navigation and shipbuilding for the private sector to play its part in promoting early compliance with the Convention.

World disposals by country of breaking (Lloyd's Register)

Keywords: IMO / Ship recycling / International Convention

Koichi Kato
Director, International Affairs Office, Shipbuilding and Ship Machinery Division, Maritime Bureau, Ministry of Land, Infrastructure, Transport and Tourism

Source: Ship & Ocean Newsletter / Selected Papers No.12 (Page 20 & 21). By Koichi Kato. January 2010

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