14 December 2013

UNEP Feasibility study on alternatives to the beaching method of ship recycling: Questions and Answers

Questions and Answers during the webinars on “Feasibility study on alternatives to the beaching method of ship recycling”. 08 and 10 October 2013

Q. During the feasibility study did you consult with the ship recycling facility owners in India? If yes, what was their reaction to the outcome of the study? Was there any positive feedback on their interest for planning an investment to improve their recycling processes, as foreseen in the study?

A. We tried to consult with the ship recyclers in South Asia during the course of the study. While conducting it, we experienced some reluctance as well as interest in how this could be done. But up to this point, we have not received any definitive feedback from ship breakers.

Some ship recyclers are more progressive and foresee, particularly in light of the European regulation that has been developed, that a more forward-looking policy has to be adopted in Asia, too. Of course we know that there are ship recyclers in many countries who, if they can’t conduct the industry on the beach, will not be willing to advance towards alternative facilities, but I do believe that there are some companies considering the matter. This study is particularly aimed at those companies. Unfortunately until now, there was not a lot of feedback from ship recyclers. Although over the years I’ve worked in the industry I noticed interest in this subject matter.

Q. We recently learnt of one project in the Indian state of Gujarat where a company has applied to get a permit to create a new ship recycling facility in the Mundra port area. This would be the first Indian facility using different ship breaking methods (i.e. other than beaching). I was wondering if you know about this project. (I am not referring to another project related to a dry dock)

A. The secretariat didn’t identify any project of this type during the study. But it would be important to disseminate information on such experience.

Q. Are there certification schemes for ship recycling yards that are complying with labour and environment standards apart from the ISO 14000 series?

A. Quite correctly, focusing on the Asian region, for example, ship recycling companies do seek to be ISO 9000 and 14000 compliant. In each location, there are facilities compliant with those standards. There is also another standard that has been developed and that is directly related to ship recycling. This is the ISO 30000 series, specifically a management standard which was developed to assist ship recycling facilities in implementing procedures to ensure environmental, safety, health, and labour standards so as to comply with national and international regulations.

Q. What more can you tell us about the Chang Jiang shipbreaking site in China?

A. The yard is located at Jiangyin city, near a town called Wuxi, a few hours west of Shanghai on the Yangtze River. This is the yard that a renowned shipping company partnered with to carry out improvements so that they could send their ships to be recycled in an environmentally sound manner.

Q. In terms of hazardous wastes, of potentially recyclable materials and scraps, do you know if studies were carried out and are available on which parts can be recycled in ships? Is there a material flow analysis of certain ship types available that may be suitable for planning and upgrading standards?

A. You will find a general analysis in a World Bank study available at: http://documents.worldbank.org/curated/en/2010/12/13695952/ship-breaking-recycling-industry-bangladesh-pakistan. On the basis of the inventories of hazardous materials that were made available for the study, this study contains these estimations on certain types of ships. General information on hazardous liquids and parts containing hazardous substances is also included in the Basel Convention Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships available at: http://www.basel.int/Portals/4/Basel%20Convention/docs/meetings/sbc/workdoc/techgships-e.pdf.  This information may also be available in publications or web sites of shipping companies or classification societies. In addition, a project that the Basel, Rotterdam and Stockholm conventions are conducting, and that should be starting within the next following months, will develop inventories of hazardous wastes in the Gadani - Hub area of Pakistan, as well as in the Chittagong region of Bangladesh, places where ship recycling and other industrial activities take place in these countries and that may produce hazardous wastes. The inventories to be developed are more localized and, clearly, most of the information will come from the ship recycling yards and from inventories of hazardous materials comprised in the ship. The objective of this study is to assist these countries in developing the requisite hazardous wastes management infrastructure which is, at the moment, is completely lacking.

Q. Referring to the abovementioned project, is this mentioned on the Basel Convention homepage? On the ship dismantling web page, next to the feasibility study, there is a paragraph on this project, but not much information is yet available.

A. On the Basel Convention website, the path to the mentioned project is: Implementation/Ship Dismantling/Capacity Building. This project has not yet commenced in earnest thus there is limited information available at this time. The project should start in the next month or two.

Q. Have you identified investors and do you think there is a willingness from countries or private donors to upgrade ship recycling facilities, according to the feasibility study?

A. We did not look into investors but they could basically be development banks, banks with interest in ship recycling. There is a clear interest to upgrade ship recycling facilities in some Asian Countries such as Pakistan, India and the Philippines - a country where, for the moment, domestic ships are recycled using slipway methods, but where there may be interest in future to accept vessels from other countries.

Q. When the ships get to the ports to be dismantled is there, in the Basel or Hong Kong Conventions, a requirement to have a lab test and make an inventory of hazardous chemicals, their qualification and their concentration?

A. The Hong Kong Convention is probably the most relevant in this area even though it has not yet entered into force. The guidelines for the development of the inventory of hazardous materials, developed under the framework of this convention, do talk about sampling of hazardous substances on board. The Convention requires that an inventory of the ships’ hazardous materials be made. It is left to the local administration to develop procedures to assert that this be done. In Bangladesh for example, following the ship building, breaking and recycling rule of 2011, they have developed procedures where personnel go on board and check whether the inventories are accurate. The Basel Convention Guidelines also provide information in this regard, and can be accessed through the Basel Convention website at: http://www.basel.int/Portals/4/Basel%20Convention/docs/meetings/sbc/workdoc/techgships-e.pdf. Of course, under the Basel Convention, the competent authorities may choose to undertake a sampling of the shipment if there is a question as to whether it matches what is indicated in the movement document. This can be particularly important if a ship is to be repatriated for example.

Q. This question is addressed, in particular, to a participant from a university, which is involved in a ship dismantling project with the Chinese Government. Can you tell us more about your project?

A. This project is funded by the European Commission, in the framework of a bilateral program that runs between the European Union and China called “the Environmental Sustainability Programme”. This is a three-year project that started at the beginning of August 2013. The kick-off meeting for the project will take place in Beijing, in October 2013. The basic idea of the project is to review environmental hazards to increase the recovery of recyclable materials and to include occupational health and safety issues in the current practices. One important module we have included aims, on one hand, to carry out a material flow analysis on certain ship types, on the other hand, to implement a third party inspection system. As shown in the presentation, this is closely related to the topic of how ship owners try to identify potentially certified ship recycling yards. With that third party inspection system developed, including indicators, the project aims to create a Chinese internal certifying system for these existing yards, in order to improve the competitiveness of the Chinese ship recycling sector. Some project components will conduct research on indicators that could make more visible potential improvements in the ship recycling process at the yards. The indicators will form the basis of a sustainability assessment which is also part of the project. The project also includes a policy dialogue module. This will be based on the whole project outcome, through this module we would like to open a dialogue on some national regulations/standards that may or would be implemented in China, in the future.

Q. A follow-up question: Will you implement the project in cooperation with the Chinese government and the ship recycling association in China?

A. Besides the ministry, the project will be implemented in cooperation with the ship recycling association as an associate partner. The project also aims to establish a China ship recycling network at a national level and to link this network with the existing international networks.

Q. In the presentation it was mentioned that one of the key challenges in ship recycling is to find ship yards that are working respecting ESM standards. Did you encounter any control systems in place on the matter? Did you identify the third-party that would carry out inspections in the framework of your project in China?

A. For China we did not yet identify it, although we met and talked with controlling officers that are out to overview the ship recycling yards’ compliance with national regulations. In the current situation, ship owners find it difficult to monitor the whole process and in some cases they had to allocate their own personnel to carry out quality assurance of the process.

Q. Will this feasibility study be presented at the upcoming meeting of the Open-ended Working Group? In the study, are there recommendations for further action from the Basel parties to work on? Will the study simply be presented there or will some kind of a programme of work emerge from that?

A. Actually this study was presented to the eleventh meeting of the Conference of the Parties to the Basel Convention, back in April-May 2013. It won’t be discussed again at next OEWG. At OEWG-9, the secretariat will be providing updates on the next project that we are undertaking on Inventories that was previously mentioned. In terms of recommendations resulting from this study and the case study, the secretariat is trying to assist parties in complying at ship recycling facilities with not only the Basel Convention but also the Hong Kong Convention. The entry into force of the Hong Kong Convention will certainly enhance the standards of the industries of this sector. Both the Basel and the Hong Kong conventions provide useful legal and policy frameworks to regulate this industry.  

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