31 August 2011

Clarification for SYBAss Members Regarding Recycling Convention:

Management Summary:

In order to decrease the environmental impact of shipbreaking and to enhance health and safetycircumstances of shipbreaker personnel, new legislation has been developed. This legislation not only considers recycling of ships, but also impacts ship operation and ship building.

On May 15th, 2009, “The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships”, (Ship Recycling Convention) was adopted. When the Convention would become effective, all new ships larger than 500 GT have to be provided with an Inventory of Hazardous Materials. Development of the information streams needed for this Inventory requires careful consideration by shipyards. This requirement applies not only to large commercial ships but also to superyachts.

Documenting hazardous materials is, however, not totally new to the superyacht industry. Various classification societies already offer formats for documenting information with regard to materials known to be potentially hazardous utilized in the construction of the ship, its equipment and systems. These documents should be maintained throughout the life cycle of the yacht. But in the case of the convention, realizing such a material inventory would be a difficult challenge for the superyacht industry.

The Convention will become effective two years after the moment it has been ratified by 15 countries (with some constraints to the type of country having ratified). Although it is impossible to predict the speed of ratification, some experts mention 2013, others mention the period 2015 – 2017 as the moment when the Convention will become effective. However, it is still possible the convention will eventually not be ratified at all.

Due to the special nature of a superyacht (custom design, exceptional systems and features), development of information systems on chemical composition of superyacht parts may be very complex and different from the complexity of getting the information for e.g. a bulk-carrier. Desk research and shipyard interviews indicate that having material information or substance information coming with all of the shipyard’s purchases is not possible yet. SYBAss-members are advised to consider Convention-related issues timely and careful in order to be prepared when the Convention becomes effective. The latest edition of the convention can be found on the IMO website: www.imo.org.

Some substances mentioned in the Convention are applied in the production processes of other materials. Because of this, traces of these substances inevitably appear and complete avoidance of prohibited substances is impossible. Shipyards are advised to make a thorough inquiry into these matters. Possible strategies are to act on an individual basis, or to start a collective action or to do nothing and wait for the Convention ratification process to develop.

Since ratification of the Convention by all 15 states remains uncertain, there are no urgent precautions suggested. However, appendix 1 of the convention contains requirements for existing yachts. This would affect not only shipyards but also ship owners.  Because the Inventory has to be updated when ships are refitted, converted or otherwise significantly changed, in time shipyards performing refits will also have to deal with the new  rules. According to the convention, existing yachts have to comply within 5 years after ratification. The yachts that are currently being built, will be existing yachts when the convention would enter into force. It could be worthwhile for SYBAss members to check the requirements of appendix 1 for their new builds. Note that in most cases new yachts already comply with requirements listed in appendix 1 due to stricter building requirements by existing legislation.

Report Outline:
1 Introduction
2 Agreement and Laws
2.1 Introduction
2.2 International Maritime Organisation
2.3 The Basel Convention on the Control of Transboundary Movements of
Hazardous Wastes and Their Disposal
2.4 U.S., European and National Legislation in IMO-Member States
2.5 Practicability of Ship Recycling Convention
3 Scenarios and Strategies
4 Inventories, Certification / Auditing
5 Existing Systems and Best Practices for Registering and/or Banning Substances in the Car Industry

Report published online on: 4 August 2011

  1. P.C. Kuiper MSc
  2. Drs .H. Timmers
  3. K. Zom MSc
Author(s) Affiliation(s): ARN Advisory, Amsterdam, The Netherlands.

Link to the pdf copy of the report: (Accessed on 30 August 2011)

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