Mandatory Future for Ship Recycling

Elements of the voluntary Guidelines on Ship Recycling will now be considered for mandatory implementation following a decision made by the International Maritime Organization’s (IMO) Marine and Environment Protection Committee (MEPC).

After some general discussion on the issue of ship recycling, the Committee established a working group and asked this group to identify elements of the IMO Ship Recycling Guidelines which may be suitable for mandatory implementation. This would also require an assessment of the mechanism by which the IMO would implement such requirements. Discussion on the latter issue progressed from talks of amending current IMO Conventions such as SOLAS and MARPOL, on to an agreement that a mandatory scheme may be required to cover all the aspects listed for mandatory consideration.

This may be seen as the starting point for the development of a stand-alone Convention on Ship Recycling.

In its examination of the voluntary Guidelines, the Committee agreed that the following issues were worthy of further consideration in terms of their mandatory application:

Ship recycling facilities should be licensed with ship owners required to use only ‘approved/licensed’ recycling facilities; A ship reporting system to be implemented involving the ship owner, flag state, recycling facility and recycling yard; States to start assessing and reducing the use of potentially hazardous materials in new ships; Shipbuilders to provide a Green Passport with a new building, while ship owners should develop and provide to the recycling facility a hazardous materials inventory (HMI); Shipowners and recycling facilities to arrange for the gas-freeing for hot work of ships during their recycling; Shipowners to hand over the Continuous Synopsis Record to the recycling facility.

INTERTANKO and the other members of the Industry Working Party on Ship Recycling have noted the extensive preparatory work which would be required to see these aspects become mandatory. They will continue to stress the importance of practical and workable requirements which also contribute to providing a solution to the problems identified in the ship recycling industry.

Some of those issues noted above have already been progressed by the Committee this week, along with some additional issues, not least the adoption of a model Ship Recycling Plan (SRP). The SRP is to be developed by the recycling facility drawing on information provided by the shipowner. It covers worker health and safety, environmental and operational aspects associated with the breaking process. The final version of the SRP will be published later this year as an MEPC Circular.

An outline of a reporting system was also devised. It will be subject to further assessment by an inter-meeting Correspondence Group. At present, the ship owner will be requested to report to the flag state and the recycling state on the finalisation of the contract between himself and the yard. This contract will indicate the registered shipowner from whom the ship has been purchased and the name of the recycling facility responsible for executing the contract. Additionally, the shipowner should also work with the recycling facility to draw up the recycling plan and agree on its content.

Understandably, the justification for such a reporting system is still unclear and industry representatives have continued to press for further clarification and justification, not least because of the commercial sensitivity of a ship recycling contract.

Uniformity for the hazardous materials inventory was also a key focus for the Committee, which agreed on a basic format and level of detail for this document. Substantial work is still required before the next session, and the Correspondence Group will be tasked to further develop the inventory between now and MEPC 53 in July 2005.

Significantly for the industry representatives present in the working group, a joint industry paper noting concerns on, and suggesting amendments to, the current Guidelines was, in general, supported by the Committee. These suggestions will be incorporated into a re-assessment of the Guidelines over the coming 12 months prior to the next Assembly meeting in November 2005, where the amended Guidelines may be approved.

With the new mandatory direction on this issue, the Committee has agreed to stage an inter-sessional meeting of the working group on the basis that those issues described above are still in their embryonic stage and need further deliberation and consideration before they can be forwarded to IMO’s more specialist technical sub-committees.

Source: Intertanko