Ship Recycling – An Overview

This week we will examine one of the four major environmental challenges facing shipowners over the forthcoming years – ship recycling.

An extract from our exclusive free e-book, titled “The Four Major Environmental Challenges Facing Shipowners,” this article is aimed at providing owners and operators with a comprehensive overview of the ship recycling legislation, its applicability, compliance options and key dates to bear in mind.

Our exclusive e-book includes a comprehensive overview of the four major environmental challenges facing shipowners, including:

  • Ballast Water Management
  • Exhaust Gas Cleaning
  • MRV & CO2 Reduction
  • Ship Recycling

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Introduction

Since the end of World War II, when significant quantities of old warships required scrapping to free up steel for construction, ship recycling has been an important sub-industry of the global shipping industry. In the 1940’s and 50’s, much of the ship recycling was done in the UK, Italy and Japan, however, as shipbuilding moved predominantly to Asia, so did ship recycling.

It wasn’t until the 1990’s that the safety and environmental issues associated with ship recycling were investigated in detail, which led, ultimately, to the establishment of the “Industry Code of Practice on Ship Recycling” in August 2001. This code of practice is still in use today, and was the first glimpse of the “Green Passport,” or Inventory of Hazardous Materials, as it is known today.

In 2009, after much dedication of MEPC and IMO member states, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) was adopted, but, at the time of writing, has yet to be ratified.

In December 2013, the EU adopted its own Ship Recycling Regulations (SRR), which, whilst loosely similar to those of the HKC, placed additional requirements on owners and operators. Crucially, the EU legislation was not subject to ratification, and immediately affected vessels flagged under an EU member state, or trading within the EU.

 

The Requirements

The HKC is aimed at covering the following:

  • The design, construction, operation and preparation of vessels to facilitate safe and environmentally sound recycling
  • The operation of ship recycling facilities – ensuring safety and environmentally sound practices
  • The establishment of an enforcement mechanism for ship recycling

Once ratified, the HKC will enter into force 24 months later, and will require all new and existing vessels carry an Inventory of Hazardous Materials, specific to each individual vessel. The production of this inventory will require a physical vessel survey, to test and verify the hazardous materials onboard. Additional, ongoing, surveys will be required throughout the life of the vessel, particularly when upgrades and/or modifications are made.

The HKC will require ship recycling facilities produce vessel specific “Ship Recycling Plans” for each vessel it intends on recycling – addressing how it will deal with the specific hazardous material found onboard – as listed in the vessel’s Inventory of Hazardous Material. The HKC will require member states take effective measure to ensure ship recycling facilities comply with the requirements of the HKC.

The EU SRR apply similar requirements to vessels as the HKC – specifically requiring an Inventory of Hazardous Materials be developed and maintained onboard throughout the life of the vessel. Where the SRR differs from the HKC, is that it is already in force and has specific dates that owners and operators will be required to meet, namely:

 

For “New EU Flagged Vessels,” an Inventory of Hazardous Materials is broadly required:

  • Before entering into service, after the date of application of the Regulation, and
  • Surveyed and certified by the flag or an authorized RO

 

For “Existing EU Flagged Vessels,” an Inventory of Hazardous Materials is broadly required:

  • Before 31st December 2020, or
  • Priot to recycling, if recycled on/after the date of publication of the “European List” of ship recycling facilities, but before 31st December 2020
  • With a plan describing the visual or sampling check by which the inventory of hazardous
  • materials is developed and taking into account the relevant IMO guidelines; and
  • Surveyed and certificated by the flag or an authorized RO

 

For “Non-EU Flagged Vessels,” which covers vessels calling at a port or anchorage of an EU member state, an Inventory of Hazardous Materials is broadly required:

  • Before 31st December 2020
  • With a plan describing the visual or sampling check by which the inventory of hazardous
  • materials is developed and taking into account the relevant IMO guidelines; and
  • Surveyed and certificated with a Statement of Compliance by the flag or an authorized RO

The SRR also requires a small number of additional hazardous materials be surveyed and documented, compared to those outlined in the HKC.

 

Implications for Vessel Owners & Operators

With the EU SRR applying not only to new and existing vessels flagged under an EU member state, but also to any vessels calling at a port or anchorage of an EU member state, the implications for owners are significant. With 2020 fast approaching, owners and operators will be required to commence the production of Inventory of Hazardous Materials imminently.

The entire process of carrying out surveys onboard, testing hazardous materials, obtaining lab results, and developing the final Inventory or Hazardous Material documentation, can be a time consuming process. For owners with large fleets, it is wise to begin planning for completion of these in due course – and engaging an independent consultant to assist.

Whilst the HKC is yet to be ratified, it recently gained a major signatory in Panama – adding a significant percentage to the ratified tonnage and, more crucially, putting some significant political weight behind the convention. It is highly likely that a significant percentage of the vessels in the world will be impacted by this convention, and owners should remain aware of the developments over the forthcoming years.