By Joseph Fonseca, Mumbai
Friday, December 21, 2012

Industry May Keep Tryst with Doomsday

The new IMO convention on Ship Recycling and the EU Proposal for Regulation of Ship Recycling are being viewed with concern by ship recyclers in Alang, India. If these come into force it is possible this world’s biggest grave yard for ships will have to close down.  
Alang is considered natures’ gift to the Indian ship recycling industry. Located in Gujarat, on the West coast of India, the shipyards in Alang recycle approximately half of all ships salvaged around the world. Having come into existence in June 1983, Alang, today encompasses over 180 ship yards stretching across 11 km of the coast line and is presently engaged in dismantling over 150 ships simultaneously. During 2011-12, Alang had achieved a record 415 ships’ demolition.  Though highly regulated the ship breaking industry has often been at the receiving end of environmentalists, international organizations and authorities. With the ship recycling convention of the International Maritime Organization (IMO) awaiting implementation and the European Union’s proposal for Regulation on Ship Recycling likely to become mandatory in January 2015 the industry is bracing up for another bout of regulatory dictates which players in the field fear could well spell its doom.  
The ‘beaching’ method of recycling in Alang is considered to be not only the most economical as well as the cleanest. What makes ship breaking a productive and attractive venture for India is that 99% of the demolished ship finds reuse according to a study carried out by Prof. (Dr.) Shyam R. Asolekar Center for Environmental Science and Engineering Indian Institute of Technology, Bombay. Among other products the industry generates around 4 million tonnes of steel alone. “It is not just the major components like main engine, gear boxes, auxiliary engines, fire pumps, etc., that fetch a good premium but even nuts and bolts, wires, cables, furniture and fixtures, kitchen utensils, et al,” says Prof. Asolekar. “In fact just outside the Alang yard one can see over 800 shops spread for miles around doing roaring business mainly from material generated from these demolition yards.”  
India had like some other South Asian countries become a favored destination in the early eighties because of the availability of cheap labor. But it is the high tidal range, firm seabed, gentle seaward slope that eventually gave Alang the edge over others thus making it the first major Indian ship breaking yard to have come into existence. Ideally Alang can be said to have all the makings for the best ship recycling destination.  
“This labor intensive industry provides direct employment to over 35,000 workers,” asserts Ulhas S Kalghatgi, Chief Surveyor and Senior Vice President of the Indian Register of Shipping. “It provides spin-off to other industries, including re-rolling mills, suppliers of oxygen and liquefied petroleum gas, scrap processors and also to traders involved in selling second-hand products such as furniture and fittings etc. More than 90% of ship breaking in the world is taking place in India, Bangladesh, Pakistan, China and Turkey.”
Safety and environmental concerns have tormented the industry since the past two decades following reports of workers’ casualty and death. Following a spate of allegations by environmentalists and Greenpeace organizations, a 15-member delegation from IMO consisting of representatives from the World Bank and the European Commission visited the Alang ship-breaking yard from January 7-10, 2008, and inspected the safety and environmental safeguards at the facility.
Again another delegation numbering 20 members and headed by IMO implementation officer for marine environment division Nikos E. Mikelis visited Alang on 25th February 2009. It included members from Bank of International Settlement Convention Secretariat, International Labor Organization, World Bank and European Commission and belonged to countries like Greece, Japan, UK, France, Denmark, Norway, USA, Germany, Bulgaria and New Zealand.
As reported by the Gujarat Maritime Board the two teams expressed satisfaction after witnessing the class room training being imparted on various operations of ship recycling, on safety and waste management. The teams approved the techniques adhered to in the removal of asbestos containing material from ship’s parts and pipes in negative pressure chamber. They also visited the asbestos handling unit, incinerator, analytical laboratory, medical clinic, modern workmen utility area and an adequate workman training facility within the yard.
They also inspected the area dedicated to waste management and the landfill sites for disposal of asbestos and glass wool waste and hazardous wastes. The delegates were informed about the legislative requirement of construction aspects of landfill and operational aspect under the frame work of Central Pollution Control Board Criteria. They approved of the dedicated landfill facilities for disposal of the wastes generated from Alang yard.
Prof. Asolekar informs that it is the training of the laborers engaged in various jobs of ship recycling on safety and waste management that has brought about a sea-change. Courses including basic safety, cutter-men training, fire-fighting, gas cutting welding, etc., resulted in raising the standards of occupational health and safety followed at the ship dismantling yards.
“Persistent efforts in putting workers through the training programs has helped in increased use of personal protective equipment by the laborers, implementation of protective and safety measures, and developing skill sets,” Prof Asolekar states. “This has helped Alang achieve ‘Zero Fatal Accidents’ and is able to develop green environment in Alang to the extent that no deaths have occurred during the period from January 1, 2012 to August 31, 2012 (lowest accident rate of any major labor intensive industry).
Shashank Agrawal, Group Legal Advisor to Wirana Shipping Corporation (Cash Buyers based in Singapore) points out that ship recycling in India is heavily regulated. “There are more than 22 licensing bodies and every recycler has to comply with the various regulations. Around 100 yards are already certified under ISO 14001/9001 and OHSAS 18001. There are at least 55 yards with ISO 30000 certification.
The industry stakeholders have to comply with various legal requirements under the Factories Act, LPG Storage License, and GMB Notification 2003. Recyclers have to compulsorily provide for workers insurance, register landfill sites and obtain authorization from the Pollution Control Board. The overseeing governing bodies are the Gujarat Maritime Board, Gujarat Pollution Control Board, the Indian Customs and the statutory bodies for Atomic and Explosives. 
The president of Ship Recycling Industries' Association (India), V.K. Gupta considers the occasional public outcry against recycling as an attempt to create adverse publicity. “Just to sensationalize, an undue hue and cry about environment pollution is being made,” he claims.
He goes on to explain that the issues of PCB (Polychlorinated biphenyls), Asbestos and TBT (Tributyltin) paint are temporary phenomena, as their use is already banned. This is a transitory issue. For the disposal and treatment of hazardous wastes, a secured landfill site has been constructed at Alang. Asbestos which was used as insulation material is getting replaced by glass wool. So in future handling of glass wool will be a crucial issue.
P.S. Nagarsheth, President of the Iron Steel Scrap & Shipbreakers’ Association of India (ISSAI) strongly denounces the wrong impression being propagated by NGOs about ship recycling industry being hazardous. “20% of ship cutting is done on board the ship,” he maintains, remaining 80% at the yard similar to any other fabricating activity. During the entire process of breaking, the ship remains afloat and sea water does not enter the ship. So there is no seepage of oil. No tanker is permitted to be beached without the certificate for gas-free for hot work as directed by the Supreme Court. Secondly, no ship is permitted to be demolished without the removal of remaining bunker and while being dismantled the ship remains afloat and no water is permitted to enter the ship.”
Though it has not been smooth sailing for the industry the future appears bleak and they expect more turbulence once the International Convention on Ship Recycling known as Hong Kong Convention comes into force after India ratifies it. Industry experts say that the intention of IMO convention is not ‘green ship recycling’ as originally intended, but to pass the entire responsibility on to ship recyclers from the ship owners. 
Adding fuel to fire the European Union has proposed their Regulations for Ship Recycling. Nagarsheth informs that EU has interpreted Basel Convention as ships meant for demolition to be hazardous waste. “The European Union (EU) has not been able to implement its own Regulation 1013/2006,” says Nagarsheth. “Ships were sold to cash buyers, registered in tax haven countries and then routed to ship recycling countries or sold under the pretext of trading purpose and then diverted to ship recycling countries. EU In its own admission stated: “at present, most of the trade of ships for recycling is illegal considering the provisions of Regulation No. 1013/2006.”
Ship recyclers impress upon the fact that instead of plugging the loopholes in their regulations to safeguard their ship owners/nationals, EU has proposed a new regulation for ship recyclers in countries outside the EU which is not at all acceptable ‘as they are to be implemented by countries other than those of EU’.
“The EU regulation requires ship recycler to be registered with EU, bypassing even the government where he operates from,” Nagarsheth describes. “It goes on to state that such registered ship recycler shall accept a ship flying the flag of a European member state only for recycling and restricts the recycling facility from importing ships from any other flag states. The contract under the regulation between the ship owner and ship recycler shall be effective until recycling is complete. In other words this allows the ship owner to interfere and control the recycling process which is done in a country outside the EU even though the ship owner’s financial involvement is zero.”
The proposed guidelines are an attempt to discourage the beaching method which is being followed at Alang fears Nagarsheth. The crucial issue that needs to be highlighted is the point of time a ‘ship under recycling’ ceases to be a carrier and is converts into ‘cargo’. Once a ship ceases to be a carrier, the ship breaking activity should come under nation’s own regulations based on ILO guidelines. “By accepting IMO Convention and EU guidelines, ship recycling in India will not be feasible,” says Nagarsheth. 

(As published in the December 2012 edition of Maritime Reporter -

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