Reductions of the amount of ship recycling facilities available to the European shipping industry has left shipowners concerned about the capabilities to recycle decommissioned vessels. John Chillingworth discusses the upcoming plan and what steps EU ship owners need to take to achieve compliance.

 

In 2015, 78% of total dismantled shipping tonnage in the world was beached, with European shipowners accounting for one third*. Recent regulations following the Hong Kong Convention 2009 have been introduced to combat the number of ships being unsafely and unlawfully beached in South Asia.

With hundreds of large ships being dismantled each year, it is no surprise that the looming enforcement of the ban on EU flagged vessels being recycled in Chinese recycling facilities has caused a stir amongst EU ship owners.

 

When Does The Ban Come Into Force?

From 1st January 2019, EU ship owners will need to find alternative recycling facilities when the embargo comes into force, leaving ship owners fearing the drastic reduction in ship recycling facilities available to them.

This coincides with new regulations coming into force on 31st January 2018 where large commercial seagoing EU flagged vessels will only be able to recycle their decommissioned ships at safe and sound recycling facilities named in the European List of Ship Recycling Facilities, which was most recently updated in May 2018. Shipyards that fail to comply with the 2013 European Ship Recycling Regulation will be removed from the list of approved ship recycling facilities.

These regulations have been put in place in an effort to control ship recycling and curb the current practice of ship beaching on the beaches of South Asia whilst also protecting the environmental impact of ship breaking and hazardous materials.

 

Are The Regulations Feasible?

The Chinese ban on EU vessels being recycled within its facilities has caused fears over limited options and capacity for EU flagged ships to be recycled. Peter Sand, Chief Shipping Analyst of the Baltic and International Maritime Council ( BIMCO) has summarised China’s ban as ‘unhelpful’ stating that:

“The shipping industry is global, and so it should remain, I believe promoting the Hong Kong convention, which seeks to improve facilities globally, is the way to go forward”. Sand goes on to say;

“The move by China to limit the international owners from demolishing ships in China is a move in the wrong direction.”

As reported by Safety 4 Sea, the European Community of Shipowners Associations (ECSA) argues that whilst there is a list of approved ship recycling facilities available to EU ship owners, many of the facilities focus on ship repair and offshore works over ship recycling - a factor, the ECSA argues, not considered when calculating the capacity of EU ship recycling facilities.

The ECSA argues that the ratification of the Hong Kong Convention is imperative to improving the current conditions of the global ship recycling industry, concluding that:

“European shipowners strongly support the ratification of the Hong Kong convention as the best way to improve the working and environmental conditions of the global ship recycling industry. European shipowners, together with shipowners from all over the world, urgently ask governments that did not yet do so to ratify the Hong Kong Convention. In addition, as it is stated in the EU SRR, including non-EU facilities that meet the EU SRR requirements on the EU list will facilitate States to ratify the Hong Kong Convention.”

 

Are EU Ship Owners Overreacting?

Whilst many EU ship owners continue to argue that recycling capacity will be drastically limited some have disagreed. As reported by Ship Technology, the founder and director of the NGO Shipbreaking Platform, Ingvild Jenseen, who believes the current 21 EU based recycling facilities have enough capacity to meet demand despite the Chinese ban. Jenseen states:

“There is capacity in the EU to recycle ships properly, and the yards on the EU list can take in many more – and larger – vessels than what they recycle today.”

Jenseen argues that ship owners are spending too much time coming up with excuses not to properly recycle ships despite the agreed 2013 regulations that aimed to eradicate bad ship recycling practices and instil cleaner and safer practices.

 

What Are The Benefits Of These Regulations?

Whilst European ship owners may see the new regulations as unreasonable and limiting, the regulations will provide a foundation for managing healthy ocean environments.

As reported by the European Commission in the Science for Environment Policy, the benefits of ship recycling in reducing human and environmental impacts include:

• Recycling reduces the need for mining - An environmentally damaging practice.
• Some materials can be recycled infinitely.
• Contributes to the sustainable development of the shipping industry whilst minimising and reducing the current environmental impact on oceans and seas.
• Deters the practice of ‘beaching’ and protects workers from dismantling without using PPE.
• Control, monitor and reduce the impact of IHMs on local environments that disrupt biodiversity and can affect the surrounding environments impacting on wildlife, farming and communities.

 

Ship Owner Obligations And Compliance

It is imperative that ship owners plan how best to manage their current Ship Recycling Plan and update and maintain their Inventory of Hazardous Materials (IHMs) in order to comply with current regulations.

 

Ship Recycling Plans (SRP)

The 2011 guidelines for the Development of Ship Recycling Plans under the Hong Kong Convention 2009, and the EU Ship Recycling Regulations, ships that are to be recycled require a ship recycling plan. The plan should be approved and verified by a Competent Authority as well as being inclusive of the IHM before an International Ready for Recycling Certificate is issued.

In order to meet such compliance on time and before recycling can take place, it is vital that ship owners begin their plans well in advance of the ship reaching the recycling facility.

Want to know more about ship recycling plans? Discover more here: Ship Recycling Plans.

 

Inventory Of Hazardous Materials (IHM)

The Inventory of Hazardous Materials (IHM) is vital for all ship recycling plans to ensure hazardous materials are controlled and identified so as to protect anyone who could potentially be exposed. This includes shipyard workers both on and off ship. Introduced in the Hong Kong Convention 2009, the IHM aims to promote the safe and environmentally sound recycling of ships.

Whilst all ships which are to be recycled must currently have an IHM available for the use of the shipyard recycling facility, all ships weighing over 500GT will be required to have their Inventory of Hazardous Materials in place by December 2020.

Want to know more about IHMs:

• Who is responsible for commissioning the report?
• How often does the IHM need to be reviewed?
• What substances are reported in the IHM?
• What should I do if hazards are found on board?
• How much do IHM surveys cost?

Read our IHM FAQs here: Inventory Of Hazardous Materials FAQs.

 

Poor Recycling Decisions Damage Reputations

Making the right decisions about how best to recycle ships is key to protecting and building a trusted reputation. Positive brand recognition is essential to business success and changes in the public's perception of what brands make the cut when it comes to trust are largely educated by the media.

‘Getting it wrong’, cutting corners or looking for cost savings over adhering to regulations and compliance can cost a business not just financially in the short term but can result in permanent damage to an organisation’s reputation when negative reports reach customers and stakeholders, quickly undoing years of hard work.

With the new regulations looming, reports on companies ‘beaching’ their vessels in South Asia are rife along with media coverage relating to dangerous recycling practices and lack of controls.

Making responsible ship recycling and environmental decisions are of the utmost importance in protecting your organisation’s reputation and your team.

Read more about the importance of protecting your reputation here: Don’t Let Poor Recycling Decisions Damage Your Reputation.

 

Protection Is Paramount

The upcoming regulations that will impact European ship owners are all in aid to protect and ensure the safety of all those who could potentially become exposed to hazardous materials during the ship recycling process.

Knowing how to conduct and implement your Ship Recycling Plan and IHM is key to achieving compliance and negating liability and costly fines.

For further information about Ship Recycling Plans and IHMs please contact our globally available team here: Lucion Marine Team Contact.

Want to know more about ship recycling services, surveyor services and consultancy services? Explore the Lucion Marine Services range and discover how Lucion Marine can help you to achieve compliance: Lucion Marine Services.

*According to the European Commission - Thematic Issue: Ship recycling reducing human and environmental impacts 2016, Issue 55.

 

Further Reading

European List Of Recycling Facilities: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1525765784626&uri=CELEX:32018D0684

John Chillingworth - Don’t Let Poor Recycling Decisions Damage Your Reputation: https://www.lucionmarine.com/blog/dont-let-poor-recycling-decisions-damage-your-corporate-brand-reputation

Ship Technology - Ship recycling: can Europe clean up its own mess?: https://www.ship-technology.com/features/ship-recycling-can-europe-clean-mess/

Lucion Marine - IHM FAQs:

https://www.lucionmarine.com/blog/inventory-of-hazardous-materials-faqs

European Commission - Science For Environment Policy: http://ec.europa.eu/environment/integration/research/newsalert/pdf/ship_recycling_reducing_human_and_environmental_impacts_55si_en.pdf

Lucion Marine Services: https://www.lucionmarine.com/services

Safety 4 Sea - ECSA: More Capacity Is Needed On EU Recycling List: https://safety4sea.com/ecsa-more-capacity-is-needed-on-eu-ship-recycling-list/

Lucion Marine - Ship Recycling Plans: https://www.lucionmarine.com/service/ship-recycling-plans