Inventory of Hazardous Materials (IHM) Archives - Page 6 of 10 - SHIP IP LTD

The recovery of fracking operations in the US is happening largely thanks to an unusually high inventory of drilled but uncompleted wells (DUCs), which is strong enough to sustain the current level of fracking without the industry adding more rigs to expand drilling deep into 2021, a Rystad Energy analysis shows. After DUCs run out, however, rig activity in the five key oil regions needs to be in the 280-300 range to maintain flat oil output.

Actual rig activity today is almost 50% lower than that requirement, but the industry still has about two to three quarters of leverage, based on the current DUC count, to achieve a smooth transition from a DUC-driven activity phase to a regular operations mode.

The Permian Basin, where the recovery in fracking has been most pronounced, can still accommodate 13 months of activity at last month’s pace. With a normal DUC-to-fracking ratio of about five months, it implies that Permian operators are carrying an inventory that is equivalent to eight months of fracking at the current pace.

Thus, even if drilling operations in the basin stop completely, Permian fracking can be maintained at about 200-250 wells per month through the first half of next year before the inventory size returns to normal. The nationwide DUC inventory reached a peak of about 5,800 wells before starting to decline in July.

Drilling activity fell across all major oil basins – Permian, Eagle Ford, Bakken, Niobrara and Anadarko – in the March to May period. Fracking hit a bottom in May and stayed at that low in June before recovering sharply in July. As the rig count fell steadily through to early July, and with no material efficiency gains realized in the first months of the downturn, total depth count posted a sequential decline in July with just above 200 wells drilled in all oil basins combined.

The oil basin inventory increased by about 650 horizontal wells between February and June, subsequently declining by about 140 in July. It is expected that the declining trend will last through the rest of this year, reaching pre-Covid numbers across all regions before the end of the year. Still, given that fracking remains far below the pre-Covid level, the size of the existing inventory is much higher than what should be expected for the current level of activity.

The inventory-to-fracking-run-rate ratio hovered at about five months through 2018 and 2019, widely considered a normal level based on the cycle time of a typical unconventional drilling and completion operation. In the second quarter, this ratio increased to an unprecedented level of two-three years of fracking at the current pace in all oil basins. Even after the recovery in activity in July, the inventory is equivalent to 13 months of fracking in the Permian Basin and 22 months across the rest of the regions.

The oil DUC inventory structure today is very different from how it looked just a year ago. In the Permian Basin, the share of DUCs drilled less than six months ago declined to 55% in July from 72% in the same month a year earlier. The share of DUCs drilled six to 11 months earlier increased to 24% from 9% in the same period. Hence, there are more than 700 Permian DUCs that were drilled in the second half of last year that remain uncompleted as of today – an unprecedented number in the basin’s history.

A similar picture is evident in other oil basins where the share of young wells (drilled less than six months ago) declined from 62% to 36% with many wells drilled in second half of last year remaining uncompleted. Besides the Permian Basin, there is also a material increase in the share of DUCs that were drilled 12-23 months ago, from 3% to 13%. These DUCs, however, faced an unusual challenge of persistent gas infrastructure bottlenecks in the Niobrara region in 2018-2019.

“Fracking activity for the rest of this year and early 2021 will be supported by the existing, abnormally high level of DUCs, though not all DUCs will be brought online quickly. Large, well-established operators will stay committed to capital discipline, only increasing their completion spend gradually in the current price environment,” says Artem Abramov, Rystad Energy’s Head of Shale Research.

But as the DUC inventory gets depleted, we estimate that about 190 rigs will be needed in Permian, out of the nationwide total of about 280-300, to maintain flat production next year compared with its current count of about 125 rigs.

As new well performance remains at a record high, maintenance activity requirement will follow the base decline trend. In early 2020, the industry had to put on production more than 850 horizontal wells, across the five major oil regions, to keep production flat. We anticipate that the maintenance activity requirement will fall to 450-500 wells by mid-2021.

Meanwhile, a large group of shale-focused E&Ps face financial distress or have already filed for Chapter 11 bankruptcy protection. A vast majority of these companies will not be able to return to a reasonable capex and activity level before their debt restructuring is finalized, which typically takes about six to 12 months.

For more analysis, insights and reports, clients and non-clients can apply for access to Rystad Energy’s Free Solutions and get a taste of our data and analytics universe.

Source: Rystad Energy

Vietnam oil importers are offering domestic retailers a commission on diesel sales, in an unusual tactic to clear high inventories built up as the coronavirus pandemic has slashed demand, two sources familiar with the matter told Reuters.

The move underscores difficulties they face in moving the industrial fuel in emerging economies such as Vietnam which has posted the lowest second-quarter economic growth in decades.

“Diesel demand is almost dead because it has been strongly disrupted in industrial factories where activity has been killed by COVID-19,” a Vietnam-based oil industry source said.

“So importers are offering sales commission bonus to retailers to digest the huge inventory but they still failed to sell.”

Refineries in Vietnam, which meet about 70% of the country’s fuel demand, usually have term contracts with retailers and traders, who, in turn, typically fill the demand-supply gap by importing fuels.

Last week, the importers offered a sales commission of about 2,500 Vietnam dong ($0.1079) per litre of diesel, a second source said. The pump price of diesel in Vietnamese cities is around 12,000 dong per litre.

Diesel, which accounts for about 30% to 40% of a refinery’s output, is used to fuel heavy machines and generators.

A source with Nghi Son refinery in Thanh Hoa province told Reuters that its operations are being maintained at normal levels, though its fuel inventory has been higher recently.

“This is because Dung Quat refinery has suspended its production for maintenance and many importers have scaled down their imports,” he said, referring to the 130,000-barrels-per-day refinery in the central province of Quang Ngai which is currently undergoing major maintenance.

A spokesman at Nghi Son refinery did not immediately respond to a request for comment. The sources declined to be named as they are not authorised to speak with media.

Slow diesel sales in the region also caused middle distillates inventories at Asia’s oil hub Singapore to rise to over a 9-year high.

Benchmark Asian diesel margins are currently languishing 75% lower than their historical average for this time of year, Refinitiv Eikon data showed.

Vietnam’s gasoline demand has also been dented by fewer vehicles plying the streets, the sources said.
Source: Reuters (Reporting by Jessica Jaganathan in Singapore and Khanh Vu in Hanoi; Additional reporting by Koustav Samanta; Editing by Muralikumar Anantharaman)

Source: hellenicshippingnews

Over the last decade, numerous articles have highlighted how the beaching method of ship recycling in South Asian yards results in ‘dirty, toxic and dangerous scrapping’ with ‘dire working and living conditions for workers’. Many proponents of this view vehemently oppose the beaching of ships for recycling in South Asian countries. These institutions conclude that poor working conditions, with no infrastructure, low wages, compromised labour rights and environmental standards, are the only reason why end-of-life ships fetch more money when sold to recycling yards operating in the Indian sub-continent when compared with recycling yards in Europe and Turkey.

In the last four years, nearly 80 ship recycling yards in India (out of 120 working yards) have achieved Statements of Compliance (SoC) with the Hong Kong Convention by various IACS class societies – including ClassNK, IR Class, Lloyd’s Register, and RINA. In addition, a yard in Chattogram, Bangladesh has become the first to achieve a SoC by ClassNK (in January 2020), having first achieved a RINA SoC in 2017.

To encourage growth among India’s ship recycling sector, in November 2019 the Government of India acceded to the Hong Kong Convention for Safe and Environmentally Sound Recycling of Ships and became the only South Asian country and major ship recycling destination to take such a step.

Additionally, major blue-chip shipowners, including Maersk, China Navigation, Teekay, Transocean, MOL, NYK, and several other major Japanese and Norwegian owners have visited and vetted yards in Alang. They have determined that Indian yards are a viable destination to recycle their end-of-life tonnage.

“The ship recycling yards in South Asia not only boost their respective local economies, but also create direct job opportunities”

Twenty Indian ship recycling yards have submitted applications to the European Commission to audit their recycling facilities for inclusion in the EU’s list of approved ship recycling yards; several of these yards are currently undergoing EU-audits. This demonstrates that they must have passed the preliminary requirements to merit a possible inclusion under the EU Ship Recycling Regulation (EUSRR).

Ship recycling yard owners have made massive investments to upgrade their recycling facilities, including: 100% impervious floors with drainage systems; heavy-lift cranes; yard- and vessel-specific training for workers; and the development and implementation of Ship Recycling Facility Plans and Ship Recycling Plans (as per IMO’s guidelines in Resolutions MEPC.210(63) and MEPC.196(62)).

Tremendous improvements

The institutions that have been critical of South Asia’s yards have remained blind to the tremendous improvements that have taken place. Such large-scale development cannot be shrugged-off with baseless statements that the beaching method is toxic, or with incorrect statements that all yards in South Asia are the same, irrespective of their level of advancement.

There can only be two logical reasons for this criticism: the critics view these certificates as being not good enough and believe that the yards continue to operate in the same manner as they were operating before obtaining their HKC certification; or in the minds of the critics, the Hong Kong Convention may be an inadequate standard to regulate the recycling of ships.

In response to the first point, it would be unwise to question the integrity and professionalism of reputed classification societies with IACS memberships. Regarding the second point, it is true that critics of the beaching method are also critics of the Hong Kong Convention because it does not ban the beaching of vessels.

Nevertheless, it should be remembered that the Hong Kong Convention was developed by many countries under the aegis of IMO, a United Nations Specialised Agency. IMO decided that banning the beaching method (which is currently used for over 92% of recycled tonnage) would be wrong as well as counterproductive.

It is important to explore the reasons why South Asian countries recycle over 92% of end-of-life ships.

The value of end-of-life ships varies from country to country, as it depends on the availability and demand of downstream markets for the products derived from a vessel. The main products of ship recycling include ferrous scrap, non-ferrous scrap, and machinery. In some cases, residual fuel on-board also adds to the value. The value of the recoverable ferrous scrap largely determines the price which can be offered to a shipowner. Scrap steel is traded at different prices in different countries and it is the major factor which dictates the variation in the price offered by the various recycling locations. The major use of scrap steel in every recycling country is in steel making. However, the technology used differs among counties.

The two main steel-making processes are: (1) production from iron ore in a blast furnace-basic oxygen furnace (BF-BOF), which also uses some amount of scrap steel during the refining process; and (2) production from scrap steel in an electric arc furnace (EAF)/or induction furnace (IF). Globally, around 75% of new steel is produced by the BOF method, while the remaining 25% is produced by the EAF method.

According to The National Institution for Transforming India (NITI Aayog): “Recycling of one tonne of scrap saves 1.1 tonne of iron ore, 06-0.7 tonne of coking coal and around 0.2-0.3 tonne of fluxes. Specific energy consumption for production of steel through BF-BOF (primary) and EAF and IF (secondary routes) is 14 MJ/Kg and 11.7 MJ/ Kg, respectively. Thus, it leads to savings in energy by 16-17%. It also reduces the water consumption and GHG emission by 40% and 58% respectively.”

NITI Aayog states: “Local factors dictate the scrap steel pricing, which eventually leads to lower overall offer prices for end-of-life ships. Interestingly, amongst the major ship recycling nations, the percentage BF-BOF/EAF-IF mix in 2019 showed contrasting results. For example, in India, BF-BOF route caters to around 45% of India’s steel making whereas the remaining 55% is through EAF & IF route.”

For Turkey, it was approximately 30% steel making through BF-BOF and the remaining 70% through EAF and IF. Turkey has 24 electric arc furnace mill plants (EAF), five induction furnace plants and three BOF plants. “Because of the Turkish steel industry’s heavy reliance on EAF, the country is the world’s largest scrap importer by volume. In 2018, Turkey imported a total of 20.7 Mt of material. Overall, Turkey was the recipient of around 22.4% of total world scrap exports”.

Higher imports

These numbers clearly show the higher imports of scrap steel into Turkey and how they contribute to the local factors that dictate the scrap steel price, which eventually leads to lower overall offer prices for end-of-life ships.

To compare South Asian countries with Turkey, it is important to understand that when a ship is recycled in countries like India, Bangladesh and Pakistan, the irregular pieces of steel obtained are earmarked as melting scrap, which is fed into EAFs. This type of steel scrap is only about 15-20% of the total weight of the ship’s steel. The remaining 70-75% is derived in the form of plates, profiles, beams, girders, and angle bars which are generally re-rolled in South Asia and sold at a premium when compared to melting scrap. However, this is not the case in Turkey, where most of the scrap steel is considered as melting scrap. The re-rolling process is simpler and less energy consuming and that is why re-rolled steel products fetch more money than the melting scrap.

The ship recycling yards in South Asia not only boost their respective local economies, but also create direct job opportunities to over 15,000 people and indirect opportunities to over 500,000 people (source: Gujarat Maritime Board). The ship recycling industry in South Asia is associated with a huge downstream market for second-hand goods, such as furniture, machinery, joinery, electrical equipment, household appliances, home décor, paints and hardware items.

“Critics of South Asia’s yards have remained blind to the tremendous improvements that have taken place there”

This supports industrial ecology and industrial symbiosis, as the output from ship recycling yards are utilised as inputs to small-scale industries working to refurbish items which are eventually traded in the second-hand market. All this is in addition to the steel re-rolling mills and steel melting mills which utilise ferrous scrap from end-of-life ships to produce steel goods such as bars, ingots, pipes and plates. The entire localised industry that has developed due to ship recycling yards is a major boost to the local economy, as it assists in the flourishing trade of second-hand goods, ferrous scrap, and non-ferrous scrap.

To compare the labour and hazardous waste(s) management costs for yards in Turkey and India, consider the recycling of a 10,000 light displacement tonnage (ldt) container ship. A typical 10,000 ltd container vessel will have about a 5% weight loss due to corrosion, loss during recycling, as well as wear and tear over the operational period of the vessel. In addition, nearly 0.5% non-ferrous, 4% machineries and 0.5% reusables (like furniture and fixtures) are recovered by recycling; the remaining 90% is ferrous. In the case of South Asian countries, nearly 75% of the remaining 90% ferrous goes to re-rolling mills as steel plates, including direct use of steel plates to make flanges, girders, and pipes; 15% of the remaining 90% goes for melting, which includes irregular size scrap. In the case of Turkey and other EU recycling yards, most of the remaining 90% ferrous goes directly for melting and a fraction of it goes for re-rolling.

The daily wages paid to laborers is prescribed by the respective recycling country, based on the socio-economic conditions of the country. The prescribed wage in South Asian countries for unskilled labour is between US$4/day and US$6/day. Wages in Turkey are US$16/day to US$17/day for unskilled laborers. The difference of US$12/day equates to US$36,000/month (considering 100 workers per yard with paid leave). For recycling of a 10,000 ldt container vessel in Turkish yards, which takes about four months to completely recycle, these wages add up to US$144,000. This means US$15/ldt of additional costs on wages when compared to recycling the same vessel in sub-continent countries.

Looking at the environmental costs, the removal and disposal of each tonne of asbestos costs US$800 in Turkey, whereas in India it costs US$300 (as the waste disposal facility is owned by the Government of Gujarat). Considering 10 tonnes of asbestos for a given vessel (a higher value), it costs about US$8,000 for disposal in Turkey. Disposal of paint chips generated during the recycling cost US$500/tonne in Turkey, whereas in India it costs about US$200/tonne.

In summary, we can consider US$150,000 as the environmental cost, or waste management costs, in Turkey for all types of waste identified in an Inventory of Hazardous Materials (IHM), developed as per IMO’s Resolution MEPC.269(68) guidelines. This adds up to an additional US$15/ldt for hazardous waste management, if recycled in Turkey when compared to India.

The higher cost of wages and hazardous waste management are not necessarily related to a higher quality of work. For example, heavy metal contamination levels at the coast of Aliaga (Turkey) ship recycling zone exceed the prescribed limits and are considered heavily polluted.

Including labour and hazardous waste management costs, Turkey should offer US$30/ldt to US$35/ldt less than the price offered in India (or any South Asian recycling country). But Turkey consistently offers US$90/ldt to US$160/ldt less than India (or any South Asian recycling country) as the value of steel generated from recycling is less when compared with South Asian countries. The European ship recycling yards offer even lower prices – US$200/ldt to US$300/ldt less than the sub-continent.

All the factors discussed and the significant improvements undertaken by South Asian recycling facilities over the last few years should be acknowledged and appreciated by the global maritime community, rather than criticised and demeaned because of the use of beaching as a method of docking/grounding/landing ships for recycling.

The contribution of the ship recycling industry towards sustainability is immense; it helps decarbonise the atmosphere.

To conclude, irresponsible recycling is possible across all methods of recycling. However, to associate such practices only with a particular region, or a particular method of recycling, is incorrect. The landing method practiced in Turkey is really not different to the beaching method practiced in South Asian countries. What matters is how a given ship is recycled safely and in an environmentally sound manner after beaching or landing.

This article is adapted from the series of Thought Leadership pieces published by GMS on its website.

Source: rivieramm

As a subset of media ethics, ‘journalistic ethics’ is comprised of principals of ethics and good practice that apply to journalists across various types of news mediums.  Codes may vary from one organization to another, however, most share common themes of adherence to accuracy, objectivity, impartiality, and fairness in their efforts to maintain unbiased views and provide newsworthy information to the public. For many, the British Broadcasting Corporation (BBC) is looked to in order to provide its readers with unbiased, accurate, and truthful reporting in accordance with these principals.

It would appear as though the journalistic code of ethics was not closely practiced during the BBC’s recent ‘report’ titled, “Breaking Bad: Uncovering the Oil Industry’s Dirty Secret.” Throughout the coverage, the BBC feeds readers inaccuracies and negatively spun out-of-context views on ship recycling yards in Alang, India.

Following the onslaught of misinformation and incorrect views of the ship recycling industry portrayed by the BBC, our principals have found it necessary to address some falsified items and misleading perspectives depicted in the report.

A GRAVEYARD OF SHIPS:

The article bears several intentionally misleading sub-headlines such as “Constant Danger” & “Toxic Hotspot” when referring to Alang as “a graveyard of ships.”

This glaringly intentional misdirection by the article betrays the reality on the ground in Alang, India, where nearly 80 ship recycling yards (out of 120) have achieved over 105 Hong Kong Convention SoC (Statement of Compliance) certifications, including multiple certifications by single yards from various IACS class societies – including ClassNK, IR Class, Lloyd’s Register, and RINA.

The reporters have chosen to place at center stage, the opinions of NGOs and other biased stakeholders that have vested interests in bolstering negative agendas against the ship recycling industry in Alang.  Yet the article fails to include a single interview from any individual or organization who would present a counterpoint to dispute the negative claims made in the report. GMS had chosen to provide formal written responses to questions raised by the BBC, most of which do not seem to have been taken into account.

Perhaps most concerning is the journalist’s failure to acknowledge the findings of reputable classification societies that have independently visited, vetted, and verified the operations, codes of conduct, and worker & environmental safety standards and procedures that are currently in place at most yards in Alang.  These class societies have placed their reputations on the line by issuing SoC certificates to recycling yards in Alang.  It is these SoC certificates that have become one of the fundamental building blocks in the decision-making process of blue-chip ship owners to responsibly select which yards will become the final resting place for their assets.

BIASED INTERVIEWEES:

It is important to understand that over 1,000 foreign nationals have visited Alang over the last five years alone.  The vast majority of these visitors have been “auditors” (e.g., class auditors, ship owners, owner’s reps, brokers, capital providers, diplomats, bureaucrats, policymakers, NGOs, underwriters, marine surveyors, scientists, naval architects, engineers, students, etc.).  The focus of these auditors is generally to: (1) determine if the negative stories they have seen about Alang are real, and (2) to decide if they believe that Alang can recycle ships in a safe and environmentally sound manner per international guidelines.

After reading the report, it is obvious how many of these 1,000+ visitors and auditors were interviewed in order to voice their opinions.  It would appear that these people were left out of the report intentionally.  Out of the people interviewed, the report fails to convey how many have ever been to Alang themselves, and if they have ever visited, how recently they have been there in order to give their statements and views legitimacy.

In addition, out of over 100,000+ industry workers, only two obviously disgruntled and biased brothers who are yard laborers were interviewed and referenced in the report.  It is impossible to obtain a fair and balanced view of the yard worker’s perspective from only two employees.

In an attempt to validate what would appear to be preconceived biases against the industry, the BBC chose to interview Ms. Ingvild Jenssen (founder and director of the NGO Shipbreaking Platform) who has unrelentingly targeted the ship recycling sector.  Throughout the years, Ms. Jenssen has used the platform’s position to spread inaccuracies and misrepresentation of facts in an effort to invalidate the hard work and improvements made by an industry that has earned a reputation as a reliable source for safe and environmentally conscious ship recycling.

Adding to the list of suspects or potentially biased sources, the BBC also chose to rely on the opinions of an attorney from a law firm that specialises in human rights cases when it came to seeking information about Ship Recycling.  The attorney seemed to give his opinion about the business of Cash Buying and the Ship Recycling industry at large, offering his views on some practices without appearing to adequately understand or articulat the correct inner workings and structures of the industry.  In general, people who lack the basic understanding of the reasons for why the shipping industry employs flags of convenience (FoCs) or specific corporate structures should not be relied on for their professional opinions about the space.

The BBC seems determined to link the ownership of the rigs in Scotland to GMS via the following statements: “Throughout its dealings with Sepa and the BBC, GMS denied it was the owner of any of the vessels it bought from Diamond Offshore – insisting it was only acting as an agent for other, unnamed companies.”

What the BBC or its interviewees failed to highlight is that Cash Buyers generally act as “agents” on behalf of principals and have no legal relationship to the ownership of assets.

The article goes on to quote Ms. Jenssen, claiming that over 137 lives have been lost between 2009 and 2019.

While any death is tragic, we are pleased to advise that in the history of the GMS Responsible Ship Recycling Program (RSRP), not a single vessel negotiated by GMS under this program has suffered a fatality.

Data collected from official sources would indicate that, sadly, 63 deaths were reported in Alang between 2014 – 2019.  This would mean roughly 10.5 deaths per annum.  It is estimated that 100,000+ total people work in the ship recycling industry in Alang (including those who work in the actual yards and downstream ship recycling-related jobs in Alang).  According to the Gujarat Maritime Board, with all direct and indirect related jobs, this figure could be as high as 500,000 ancillary jobs being related to the industry.

While the goal is to bring this fatality number down to ZERO, last month (Feb 2020), Business Insider published an article using info from the US Bureau of Labor Statistics (2018 data), that looks at the number of deaths per 100,000 people in an industry.

According to this data, in the United States, logging is the most dangerous job with 97.6 deaths per 100,000 workers, followed closely by fishing (and fishing-related workers) at 77.4 deaths per 100,000, and coming in third are aircraft pilots and flight engineers who had 58.9 deaths per 100,000 workers.  The list of deadly jobs in the USA is extensive, and as you go down the line, refuse and recyclable material collectors (i.e., garbage men) have 44.3 deaths per 100,000. In comparison, truck drivers and sales workers are 26 deaths per 100,000, farmers and ranchers are 24.7 per 100,000, and structural iron and steel workers are 23.6 deaths per 100,000.  Regular construction laborers in the USA have a fatality rate of 13 per 100,000 (this is only # 17 most dangerous on the list), and operating engineers and other construction equipment operators (#20 on the USA most dangerous jobs list) have a fatality rate of 10.6 per 100,000 workers. Professional athletes come in at #24 on the list with 7.6 per 100,000 while taxi cab drivers and chauffeurs are #26 with 6.7 per 100,000 – the list goes on.

These statistics are not being mentioned to minimalize the danger of any jobs or to downplay the tragedy of even one death or injury, but rather to put into perspective the risks and hazards that are felt across all industries throughout the world.

Finally, perhaps the most egregious misrepresentation in the article states that there “is only one small clinic in Alang and more seriously injured workers have to travel to the city hospital in Bhavnagar – a 30-mile journey on unpaved roads which takes more than an hour.”

A simple search on Google will list three hospitals in Alang that are currently operational 24 hours a day. Those facilities include:

1. Alang Hospital, located at South Side Road, Alang, Gujarat 364150, India.
2. GMB Multispeciality Hospital Alang, located at South Side Road-Alang, Alang, Gujarat 364150, India.
3. Redcross Hospital of Alang, located: Near Mahadev Temple, South Side Road-Alang, Alang, Gujarat, 364150, India.

The editors of the article use hyperbole to over-inflate claims such as “Documents filed by GMS show significant amounts of waste aboard all three vessels, including the poisonous heavy metals cadmium and mercury,” Other examples include “The Ocean Princess alone contains an estimated 428 tonnes of waste, including about a tonne of asbestos” and “An inventory for the Ocean Vanguard lists PCB, a highly toxic chemical which was used as an electrical coolant and insulator until its production was banned worldwide”.

In reality, mercury was only found in thermometers and lighting fixtures, while cadmium and lead were found in batteries on-board. These are materials that can be routinely found in everyday household items (albeit in smaller quantities), let alone ocean-going vessels or a 15,000-ton rig.

Moreover, the Inventory of Hazardous Materials (IHMs) prepared by Lloyd’s approved specialists confirm that only 6.3 tons of waste were on board the Ocean Princess, including the aforementioned thermometers and lighting fixtures.

The IHM of the Ocean Vanguard (in fact, on all three rigs) confirms that none of the three rigs have any PCBs on board and samples tested from various areas of the rigs for the presence of PCBs, all tested negative.

To encourage the positive growth of India’s vital ship recycling sector, the Government of India acceded to the Hong Kong Convention for Safe and Environmentally Sound Recycling of Ships, and became the only South Asian country and major ship recycling destination to take such a positive step.

Moreover, major blue-chip and stock listed ship owners of the world including but not limited to American, European, and Asian based ship owners have spent significant amounts of time and money in an effort to conduct proper due diligence in the yards and have subsequently decided to recycle their end-of-life tonnage at recycling facilities in Alang.

Twenty ship recycling yards have filed applications with the European Commission for the audit of their recycling facilities for inclusion in the EU’s list of approved ship recycling yards, and several of these yards are currently undergoing full EU-audits.  These efforts demonstrate the amount of work that has gone into improving the yards and shows that they pass at least the preliminary measures to be considered for possible inclusion under the EU Ship Recycling Regulation (EUSRR) – a fact conveniently omitted by the BBC.

Ship recycling yard owners have made massive investments into upgrading their recycling facilities and safety infrastructure, starting with small yet essential items such as routine use of safety gear, masks, gloves, hard hats, and boots, to significant improvements including 100% impervious floors with drainage systems, heavy lift cranes, yard and vessel-specific training for workers and Ship Recycling Facility Plan(s) as per MEPC 210 (63) and Ship-Specific Recycling Plans as per MEPC 196 (62).

Over the years, the Gujarat Maritime Board (GMB), in association with Ship Recycling Industries Association (SRIA), has implemented many developmental programmes at Alang, such as:

1. The GMB developed a Safety Training and Labour Welfare Institute at Alang in 2003. This is a 12-day mandatory training programme for fresh workers joining the industry, followed by an oral/written examination conducted by IR Class (an IACS member). Only successful candidates are eligible for employment in the yards. Over 140,000 workers have been trained to date in the Safety Training and Labour Welfare Institute at Alang. Several refresher trainings are conducted on an ongoing basis, for previously trained and certified workers.
2. As stated above, three hospitals are currently in operation at Alang, including one that is operated by the Indian Red Cross Society and financially supported by the GMB. There are two full-time ambulances in service and an additional 10 ambulances that are privately owned by yards in an effort to comply with EUSRR requirements.  A multi-specialty hospital and a mobile hospital with a certified doctor is also in operation by the Ship Recycling Association. In addition, a full-fledged hospital with 30 beds was constructed by the GMB and will be operational shortly by ESIC. About 15,000 labourers are currently registered with ESIC and have been provided with a smart card.
3. In association with the SRIA, the GMB developed a Labour colony in order to provide residences for local labourers. Phase-I of this colony has been constructed for 1008 labours working at local yards. Along with addressing basic requirements, such as water supply, sanitation, electrification, etc., supplemental facilities such as canteens, offices, and local shops are also provided. Finally, as per ILO standards at Alang, several recycling yard owners have themselves constructed labour colonies for their own workers, which also accommodate nearly 800 yard employees.
4. Firefighting arrangements for local yards are under the supervision of the GMB. The fire fighting force is headed by a fire officer and operational staff, which includes one Station Officer, two Pump Operators / Drivers, two Junior Officers, and thirteen supporting firemen.
5. To support local yards, an HGL Sump of 2.5 million litres has been constructed at Trapaj Head-works, to draw water from the Mahi-Pariej line and directed to Alang & Sosiya yards. In addition, separate storage and internal distribution systems have been developed for a water supply network for ship breaking plots in both areas:

In Alang: an overhead tank with 1.2 Million litres and underground sump with over 1 Million litres.

In Sosiya: an overhead tank with 700K litres and an underground sump with 600K litres.

The ship recycling yards in Alang serve the nation by producing about 4.5 million tons of re-rollable steel per year, without exploiting any natural resources. The labour wages are as per standards set by the Government, and several yards have invested in jetties and heavy cranes in order to directly lift steel and other heavy items from vessels, without touching the inter-tidal zone and subsequently placing them on the impervious cutting floor of the recycling yard.

In the near future, the world’s largest stretch of ship-breaking beaches at Alang-Sosiya, in Gujarat’s Bhavnagar district, will be upgraded through a $76 million loan from the Japan International Cooperation Agency (JICA). The loan will be used to further upgrade 70 recycling yards over the next few years.

Many yards are already upgraded, and these improvements will introduce increased environmentally sound and safer ship recycling practices to even more yards and will help enable additional ship recyclers to adopt processes in accordance with international practices. The project will conduct additional capacity development training courses for stakeholders at various levels. The training courses will continue to cover key aspects of recycling, including safety and environmental protection.

LANCE (Ex-OCEAN ALLIANCE) was recycled at Hariyana Ship Demolition Pvt. Ltd., (Plot # V4) in Alang.  With over three decades of experience, the Hariyana Group is known for its legacy of high standards in the Ship Recycling industry throughout Asia. Hariyana Ship Breakers Ltd is a close client of GMS and is listed on India’s leading financial exchange, i.e., the Bombay Stock Exchange (BSE), as the only listed and dividend-paying company in the industry for over eight years.

Throughout their years of working together, GMS and the Hariyana Group have demonstrated their commitment towards worker safety and to the environment as dominant players through maintaining excellent track records for worker safety and environmental protection, while abiding by the most stringent national and international protocols.

Hariyana Ship Demolition Pvt. Ltd., is a member of the Treatment Storage Disposal Facility (TSDF) site at Alang and has a HKC statement of compliance from RINA Class and is currently working for a HKC SOC from ClassNK.

Please see below a few photos that were captured in the yard during the roughly the same time that the BBC was visiting Alang. Regrettably, selective and out of context pictures were used by the BBC in their report.

Here are some FACTS to help foster an understanding of the real situation surrounding the recycling of “LANCE” (EX OCEAN ALLIANCE).

The vessel received beaching permission on December 8, 2018, and cutting permission was granted by the authorized regulatory body on February 19, 2019. The vessel was recycled entirely on January 3, 2020, i.e. 22,263 tons were recycled over a period of about 13 months in a safe and environmentally friendly manner with “zero accidents.”

The total greenhouse gas (GHG) emissions from all activities involved in recycling LANCE was estimated through various calculations and compared to the GHG emissions that would have come from the production of an equivalent amount of iron ore, should it have been mined.  For example, LANCE (Ex-OCEAN ALLIANCE) had a LDT of 22,263 MT.

For clarity, a total of 10,436.76 MT of steel bars and 7,260.35 MT of steel ingots were produced from recycling LANCE (Ex-OCEAN ALLIANCE) using re-rolling and electric arc furnace processes respectively. The total GHG emission from complete recycling of the rig (beaching to the production of steel bars and steel ingots) was estimated to be about 7,360.53 MT CO2-e. The same amount of steel bars and steel ingots, if produced using conventional mining processes, would result in an estimated total GHG emission of about 30,251.47 MT CO2- e.

As such, by recycling LANCE (Ex-OCEAN ALLIANCE), a grand total of about 22,890.94 MT CO2-e GHG emissions was saved, protecting the ozone layer from further depletion.

It should be noted that under GMS’s Responsible Recycling Program (RSRP), work-at-height trainings were conducted for the workers at Hariyana yard on November 17, 2018, before the work on LANCE had commenced. As a result of GMS training, a total of about 16 tons of potentially hazardous / non-hazardous wastes generated during the recycling process of LANCE were saved from landing in the intertidal zone and were subsequently submitted to the dedicated authorized disposal facility at Alang.

For transparency, the actual details of waste streams from LANCE (in chronological order) are given below.

We hope that this release has helped to foster a better understanding of the current status of ship recycling in Alang and that readers recognize the importance of taking the time to understand recycling industry facts vs. biased opinions.  While it would be impossible for everyone reading this commentary to visit Alang, we have made a sincere effort to invite and host as many auditors and sceptics as possible to strap on work boots and tour the yards themselves.  Nearly all critics who have spent time in Alang and taken the opportunity to properly understand the industry and massive efforts that have been made towards improving it, have come back converts who support the hard work and efforts that GMS has been cultivating in India and other countries for many years.  It is difficult as the better the industry develops, the louder many naysayers become in an effort to try to outshine the achievements that have been made and to protect their own advocacy positions.

At GMS, we pride ourselves as being responsible leaders in an industry that is vital to the shipping supply chain.  Over the years, we have made it our mission to improve the safety and quality of working and living standards across the industry.  The advancements that have been made in the environmental standards and long term sustainability throughout the ship recycling industry and in the geographic areas that house it have been immense, and GMS considers it an honour to be at the forefront of these developments.

Please fee free to contact GMS at info@gmsinc.net with any comments or questions that you might have.

LANCE waste stream details:

TOTAL= 16.63 MT

Pictures from within Hariyana Ship Recycling during December 2019 – February 2020:

GMS RSRP

1. Conducted more than 90 safety training programmes at Alang and Bangladesh together over the last three years
2. Conducted 20 train-the-trainer programmes in association with IRClass in Alang
3. Recycled more than 65 ships under GMS RSRP and developed more than 40 IHM reports.

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Source: gmsinc

New Regulation
The new European Ship Recycling Regulation (EUSRR) entered into force at the end of 2013, and the Hong Kong International Convention for the safe Environmentally Sound Recycling of Ships (HKC) was adopted in MAY 2009. Both of these regulations place responsibility on Shipowners, Shipbuilders, suppliers, recycling facilities and national authorities to ensure the safe environmentally viable management of HazMats as well as the sustainable recycling of Ships.
A fundamental requirement of these regulations is the documentation of Hazardous Materials onboard ships. New and existing ships of 500 GT and above will have to carry an Inventory of Hazardous Materials (IHM) and the related International Certificate of Inventory of Hazardous Materials (ICIHM) onboard. This means that over 50,000 ships will have to comply with regulation.

The IHM Consists of three (3) Parts:
PART I: Hazardous materials contained in the Ship’s Structure and equipment
PART II: Operationally generated wastes
PART III: Stores
(PART II & III Should be prepared only prior Recycling)

• • EU-Flagged Newbuildings are required to have onboard a verified IHM with a statement of Compliance at the latest by 31 December 2018.
• • Existing EU-Flagged vessels are required to have onboard a verified IHM with statement of compliance at the latest by 31 December 2020
• • Non-EU-Flagged vessels calling EU ports are also required to have onboard a verified IHM with a statement of compliance at the earliest by 31 December 2020

M&C GROUP provided services
To ensure smooth compliance and certification, we offer expert solutions for drawing up your IHM.
Our firm is fully approved service provider by BV and LR and has official authorization by the Administrations of LIBERIA and MARSHALL ISLANDS for IHM preparation.
Company’s Naval Architects / Engineers have been certified as “Approved Hazmat Experts” by DNV-GL and RINA and may assist you to be among the first Shipping Companies with an effective process for generation correct IHMs.

• • Investigation and Collection of Necessary information / Documentation from Shipping Company
• • Assessment of all collected information / documents / plans, etc
• • Preparation of Visual/Sampling Check Plan
• • Onboard Inspection, Visual & sampling Check Survey
• • Preparation of IHM Part I with associated documentation, plans, photos, laboratory analysis tests, etc
• • IHM Part I shall be checked and certified by Shipowners selected Classification Society

Source:  mcgroup

IHM Deadlines

Ships over 500GT flying the flag of a Member State or the flag of a third country calling on European Ports, must carry on board a ship-specific Inventory of Hazardous Materials (IHM) and a valid certification which will be subject to Port State controls. Specifically,

• Existing ships, by 31^st December 2020
• New ships, by 31^st December 2018

In both cases, the IHM shall be properly maintained and updated, reflecting new installations and relevant changes in the structure and equipment of the ship.

• For EU flagged ships to be recycled, the IHM should be on board from the date when the European list of ship recycling facilities was first published, 19 December 2016.

Why have an IHM?

Identifying hazardous substances onboard vessels is imperative to ensure crew’s health and safety, the vessel’s sustainability throughout the operational life and respect to the environment when it needs to be recycled.

Yet to be adopted, the Hong Kong Convention (HKC) covers the design, construction, survey, certification, operation and recycling of ships to facilitate safe and environmentally sound recycling. In accordance with Regulation 5 of the Annex of the HKC, each ship shall have on board an IHM.

The EU SRR regulation 1257/2013 on ship recycling sets a few more requirements for the Inventory than HKC does, and makes IHM necessary in accordance with Article 5 and Article 12 of the Regulation (EU) 1257/2013 of the European Parliament and the Council on ship recycling.

The Inventory of Hazardous Materials (IHM) requirements of the EU regulation concerning ship recycling enters into effect on 31 December 2018 for EU-flagged newbuildings.

For existing EU-flagged vessels and for non-EU-flagged vessels, the effective date is 31 December 2020.

An Inventory of Hazardous Materials developed in accordance with the Regulation must be compiled taking into account the relevant IMO guidelines. Nevertheless, EU legislation sets a few more requirements for the Inventory than the Convention does. For guidance, you can visit the link here.

The deadlines that you must meet for the preparation and verification of IHM are the following:

1. EU-flagged newbuildings are required to have onboard a verified IHM with a Statement of Compliance by 31 December 2015 and before 31 December 2018.
2. Existing EU-flagged ships are required to have onboard a verified IHM with a Statement of Compliance by 31 December 2020.
3. Non-EU-flagged ships calling at EU ports are also required to have onboard a verified IHM with a Statement of Compliance by 31 December 2020.

The IHM for existing ships:
The IHM shall consist of three parts:

1. Part I: a list of hazardous materials referred to in Annexes I and II of EU SRR, in accordance with the provisions of paragraphs 1 and 2 of Article 5 of EU SRR, and contained in the structure or equipment of the ship, with an indication of their location and approximate quantities.
2. Part II: a list of the operationally generated waste present on board the ship.
3. Part III: a list of the stores present on board the ship.

Source: maritimecyprus

Protect people and property onboard ship, and meet mooring requirements, with an inventory of hazardous materials (IHM) from SGS.

An IHM is an integral part of the Hong Kong Convention, adopted by the International Maritime Organization (IMO) in 2009. Though not yet in effect, this convention stipulates that every ship must have an inventory of hazardous materials onboard. This convention was designed to make certain that ships and offshore platforms are dismantled without any risk to people or the environment. The IHM has the added advantage of improving safety while vessels are in use.

What are the benefits of an IHM?

SGS experts can perform full Inventory of Hazardous Materials for your vessel(s), enabling you to:

• Ensure a safe workplace for your employees
• Identify any dangerous substances on a ship, such as asbestos, mercury, lead-containing paints or polychlorinated biphenyls (PCBs)
• Be compliant to current and future regulations, such as SOLAS and MARPOL
• Take further actions, promoting the safety, usability and durability of your ship

About the inventory

An Inventory of Hazardous Materials (IHM) not only states which hazardous materials are present on board a ship, but also in what quantities and their specific properties. For example, tests are performed to establish the presence of asbestos, PCBs, mercury (compounds), cadmium (compounds), radioactive substances and hexavalent chromium. As well as onboard testing, an IHM includes research, during which a certified surveyor collects samples for analysis in an accredited laboratory. An IHM report is “dynamic”, meaning the report eventually covers the entire life cycle of a vessel: in the building stage, in the operational stage and in the recycling stage. For more detailed information about IHMs, please download the brochure and infographic.

How can we help?

Flexible, fast and independent, our experts are certified to perform IHM analyses. We are on standby 24 hours a day and, if needed, we can fly our surveyor to your ship so that analyses can be performed as you continue your journey while the samples are analyzed in our own laboratory. This means that the results can be made available to you in the shortest time.

We can support the maritime sector across the full spectrum of environmental, safety and health related shipping issues. We offer a variety of environmental studies and analyses to support your operations, ranging from an IHM to scrubber analyses and the testing of ballast water. With presence in all major ports around the world, our services are available whenever and wherever you need them.

Source: sgssearch