Ever since China banned the recycling of foreign ships on its shores at the end of 2018, there has been an increasing call in the shipping community to allow the work to resume. Now, it is understood that Beijing is close to reversing its two-year-old decision.

The move will give ship owners better green ship recycling alternatives concerning other South Asian yards, which have been plagued by allegations of pollution and poor labor conditions.

The ban had caused many ships from Chinese companies to land on the shores of Indian yards for recycling, especially Alang. At the time the ban came into effect, China was the fourth-largest shipbreaking nation in the world, with most of the Chinese yards being among the world’s greenest when it came to handling pollutants.

These yards have had to rely on domestic tonnage for business, with the ban causing them to lose much of the market share to Indian and Bangladeshi shipbreaking yards.

“The ban had an enormous impact on the operations of shipbreaking yards in China,” said Xie Dehua, director of the China National Shiprecycling Association (CNSA). When the ban entered into force, he warned that “China’s shipbreaking industry will face turbulent years ahead,” adding that many of the yards would have to pivot to other sectors to stay afloat.

Most of the Chinese yards comply with the Hong Kong Convention and Inventory of Hazardous Materials (IHM) requirements, and some may now be able to apply for certification under the EU Ship Recycling Regulation (SRR).

“Since the IMO started to discuss ship recycling regulations, a number of Chinese ship recycling facilities have upgraded and invested in their facilities enormously,” said Bernard Veldhoven, secretary general of the International Ship Recycling Association (ISRA). “This made these yards the first in the world to recycle ships at the highest standards available on health, safety and environment.”

 

Source: maritime-executive


Inventories of rebar across Chinese steelmakers and social warehouses stood at 8.35 million mt as of January 28, up 15.7% from a week ago.

inventories at Chinese steelmakers rose 205,200 mt on the week and stood at 3.3 million mt. Inventories at social warehouses rose 928,200 mt on the week and stood at 5.06 million mt, up 22.48% from a week ago and 27.1% higher from a year ago.

Nickel ore inventories across all Chinese ports decreased 520,000 wmt from January 22 to 8.09 million wmt as of January 29, showed SMM data. In Ni content, the stocks fell 4,200 mt to 63,800 mt.

Aluminium billet stocks across the five major consumption areas- Foshan, Wuxi, Huzhou, Changzhou and Nanchang — in China built up 16,400 mt from a week ago to 100,700 mt as of January 28. Stocks in Foshan increased the most, reaching 10,100 mt, followed by Wuxi (increased 3,100 mt).

Average operating rate of blast furnaces (BFs) at Chinese steel mills dipped 0.7 percentage point from the previous week to 86.8% as of January 28. Some steel mills had to reduce production this week as transport of raw materials was affected by lockdown measures.

Operating rates across licensed smelters of secondary lead in Jiangsu, Anhui, Henan and Guizhou averaged 46.2% in the week, down 1.3 percentage points from the previous week, an SMM survey showed. The average operating rates remained unchanged on the week at 47.1%, 70.2% and 33.3% in Anhui, Henan and Jiangsu respectively.

 

Source: hellenicshippingnews


Norway has played a key role in the development of binding international legislation ship recycling and was the first country to address the problem of unacceptable conditions in the ship scrapping industry in the UN’s International Maritime Organization (IMO) in 1999.

In 2009, the IMO adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. Its aim is to, as far as practicable, eliminate accidents, injuries and other unwanted health and environment effects from ship scrapping.

As the first country in the world, Norway ratified the Convention in June 2013. The Convention will enter into force 24 months after it has been ratified by 15 Member States or 40% of the IMO’s member tonnage.

The Convention is not expected to enter into force until 2020 at the earliest.

Facts about shipbreaking

The recycling of ship material is, in principle, environmentally friendly, but there are two major issues with the way scrapping is carried out today: poor working conditions and pollution.

High degree of recycling Most ships have a life expectancy of a few decades before wear and the need for expensive repairs make further operation unprofitable. Every year, between 600 and 700 ships are scrapped. In recent years there have been significantly more due to the phasing out of single-hull ships. In line with the massive growth of the shipping industry over the last five decades, an increasing number of ships are being constructed, which will be scrapped after they have done their job.

Ship scrapping and recycling mean that ship material is reused. This primarily applies to steel, but only a small percentage by weight of the large ship construction cannot be reused or repurposed. Virtually all parts of the hull, machinery and furniture on board are kept.

Contributing to sustainable development

Shipping is in many cases the most environmentally friendly way of transporting goods. Moreover, the fact that materials are recycled and reused after a ship has made its last voyage contributes to sustainable development. Millions of tons of steel are derived from the shipbreaking industry every year. In India, the recycled steel actually supplies 7% of the country’s steel demand. Melting of steel consumes only a third of the energy compared to that consumed during steel production. This means significantly lower fuel consumption and hazardous gas emissions. In a global perspective, shipbreaking is therefore an environmentally friendly industry that contributes to sustainable development.

Cheap labour

Traditionally, ships were dismantled near the shipyards in Europe and North America where they were built, where this was a fairly advanced mechanical industry. However, as the industry became more global and the costs of maintaining a high environmental and safety standard increased, the industry was gradually moved to poor Asian countries.

Today, the largest shipbreaking countries are India, Bangladesh and Pakistan, which account for more that 90 percent of the world’s ships. In addition, large-scale shipbreaking takes place in Turkey and China.  These countries are well suited for this industry with empty ship yards, lots of cheap labour and shallow beaches with a large tidal difference where ships can be driven onto the beach. So far, there has also been poorly developed legislation and bad systems for monitoring environmental protection and the working environment.

Alang on the west coast of India has since 1983 developed into one of the world’s leading centres for shipbreaking. About half of all ships that are recycled are dismantled here.  Large supertankers, car ferries and container ships are driven straight onto the beach at high tide and when the tide runs out, hundreds of workers start cutting the ships into small pieces.

Around 40,000 people are employed in the recycling yards in Alang. In Chittagong in Bangladesh, the conditions are largely the same, and close to 25,000 people work there.

Environmental challenges

Most of the ships dismantled today were built in the 1970s, that is prior to the banning of many hazardous materials. Ships that are to be dismantled may contain oil residues, environmental toxins, PCBs, asbestos and other hazardous waste.  Even if every small piece that can be utilised is used, a small percentage by weight of a large tanker, bulk or passenger ship will amount to several tonnes of waste that is difficult and risky to handle. Without being treated or properly collected and stored, the toxic waste is discharged directly into the shipbreaking area. The result could be severe pollution of soils, rivers and streams as well as local coastal areas. The scrapping countries are inflicted with serious environmental problems that will last for a long time.

Poor working conditions

Workers in the shipbreaking industry are exposed to significant risks. To mention one, remnants of gas in the ship’s tanks or cargo holds can explode when cutting torches are used to part the wreck. Accidents happen every day, and many workers are injured or killed in explosions or hit by falling heavy steel plates.  Many work without any kind of protective equipment. They literally take the ship apart with their bare hands.

There is also a significant risk of developing cancer as a result of inhaling asbestos dust, but this is actually more of a theoretical problem, since it takes time for cancer to develop. Many of these people live in such poor conditions that they die from other things before they get cancer. In some places, life expectancy is as low as 40 years.

Key source of income

On the other hand, it is important to keep in mind that shipbreaking and ship recycling give poor countries an opportunity to obtain much-needed income and raw materials. Tens of thousands of jobs with good wages compared to the local standard give the local population the opportunity to feed themselves and their families. For such poor countries, shipbreaking represents an opportunity for trade and economic growth.

EU status

In the EU, work is underway to prepare a Regulation on ship recycling. The EU is currently developing a directive on ship recycling which contains proposals for a tightening of the Hong Kong Convention for EU/EEA countries, introducing an explicit ban on so-called “beaching” for EU/EEA registered tonnage. (“Beaching” implies that ships are driven onto shallow beaches at high tide and scrapped there.)

This will make it difficult to have EU/EEA-flagged ships dismantled at scrapping yards in India and Bangladesh if these countries do not change their legislation significantly. The Regulation has not been adopted, and changes must be expected.

You can read more about this on the EU’s own website.

The Hong Kong Convention

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention) aims to, as far as practicable, eliminate accidents, injuries and other adverse effects of shipbreaking on human health and the environment. The Convention lays down rules for ship design, construction, operation and preparation to facilitate safe and environmentally friendly recycling without compromising the ship’s operational safety and efficiency. The Convention shall also facilitate the safe and environmentally friendly operation of the scrapping yards and establish appropriate systems for enforcing the rules. This includes certification and reporting requirements.

Ships that are sent for recycling must have a certificate that provides an overview of hazardous materials on board. An appendix to the Convention provides an overview of the hazardous materials that are prohibited or have limited legality for use in shipyards, repair yards and ships participating in the Convention. Ships will need a preliminary inspection to verify the list of hazardous materials on board. There will be other inspections throughout the lifecycle of the ship and a final inspection before scrapping and recycling.

Scrapping yards will be required to present a plan for the scrapping of each ship specifying how it will be handled depending on the individual list of inventory. The parties must introduce efficient means to ensure that the scrapping yard under their jurisdiction complies with the requirements of the Convention.

Norwegian initiative

Norway was the first country to address the problem of unacceptable conditions in the shipbreaking industry in the IMO.

The conditions in the shipbreaking industry were made known to the public in Norway through the media in the summer of 1998, after a visit by the newspaper Bergens Tidende to Alang in India and the beaches outside Chittagong in Bangladesh. They reported very poor working conditions. The report attracted a lot of attention, and both shipowners and the responsible authorities said that something had to be done to improve the conditions.

The Ministry of the Environment therefore requested the Norwegian Maritime Authority to make sure the topic was put on the agenda in the IMO’s Marine Environment Protection Committee (MEPC). The topic was discussed for the first time at the MEPC’s 42nd meeting in the autumn of 1998, and was presented as a proposal for a separate agenda item at the following meeting in the spring of 1999 (MEPC 43).

Norway also raised the issue in the Basel Convention, which regulates the handling and export of hazardous waste internationally.

The process leading up to the Convention

In 2001, the industry itself took the initiative to develop ship recycling guidelines. (Industry Code of Practice on Ship Recycling)

From 2002 to 2004, the ILO (International Labour Organization), IMO and the Basel Convention prepared guidelines that looked at the most important processes in ship recycling; working conditions, the environment surrounding scrapping sites and the relationship between shipping and the recycling industry.

In 2003, the IMO Assembly adopted a resolution setting out the guidelines for ship recycling. The resolution called on the member states to follow the guidelines and report on their experience to the IMO.

However, voluntary guidelines will not be sufficient to ensure broad support and a level playing field, so further work was done to gain acceptance to develop binding rules under the auspices of the IMO.

In 2004, Norway took over the coordination responsibility for the correspondence group and the leadership responsibility for the working group in the IMO, and on 1 December 2005, the IMO’s 24th session adopted the assembly resolution A.981(24), instructing the MEPC to prepare a draft binding instrument. Norway presented a draft of a new convention on ship recycling at MEPC 54 in 2006, which was then further developed by the Committee.

The Convention on the Safe and Environmentally Sound Recycling of Ships was adopted at a diplomatic conference in Hong Kong in 2009. It is therefore referred to as the Hong Kong Convention.

Detailed guidelines

The Convention for the Safe and Environmentally Sound Recycling of Ships is comprehensive and imposes requirements on both ships, shipbreaking countries and scrapping yards.

For ships, the Convention has requirements that apply to the entire lifecycle of the ship, as well as requirements for ships that are being prepared for scrapping. One of the requirements is that a list must be kept of hazardous substances and materials on the ship. This list must state the locations and quantities. Ships shall also have certificates attesting that they meet the requirements of the Convention, both when in operation and being recycled.

An initial survey, a renewal survey, an additional survey (if significant changes that have implications for compliance with the Convention have been done to the ship), as well as a final survey are required before the ship is ready for recycling. The surveys are carried out by the flag state, but the certificates may also be subject to checks by other countries’ authorities through the port State control regime.

The Convention requires that ship recycling can only take place at scrapping yards in countries that are parties to the Convention and that are approved to handle all the substances that are found in the ship.

Prior to this, a ship recycling plan shall be prepared. This shall be prepared by the scrapping yard, but the Convention requires that the ship assists by providing the yard with all necessary information.

The scrapping yards must be approved for the purpose by their authorities, and one of the requirements is that plans be prepared to safeguard the environment and safety for the employees.

In addition to the Convention itself, a total of six sets of guidelines have been developed which deal with details in the scrapping process, details related to shipyard approval, details of surveys and issuance of certificates and guidelines on port State control.

The Convention will enter into force 24 months after it has been ratified by 15 Member States or 40% of the IMO’s member tonnage. In addition, the Convention has a requirement that aims to ensure sufficient scrapping capacity for the parties to the Convention when it enters into force.

The Convention will take effect for all ships of more than 500 gross tonnage registered in flag States which are parties to the Convention.

Providing increased safety for all

The international focus during the work on the Convention quickly led to afew improvements in the scrapping industry. The fact that working conditions have been under intense assessment and that accidents have been registered has led to change. In Alang, India, which is the world’s largest ship recycling centre, there has practically been a security revolution. Workers are no longer permitted to work without protective equipment and some training.

The Hong Kong Convention aims to take better care of nature, and the requirements for an overview of hazardous materials on board will make the working environment better both for the seafarers who are on board during the ship’s lifetime and for those who are recycling it.

 

Source: sdir


A detailed document outlaying all potentially hazardous material onboard a vessel

  • Hazardous material is any substance that can pose a risk to the health and safety of people or to the environment as identified and listed by the Hong Kong Convention (2009) & EU Regulation 1257/2013
  • Inventory of Hazardous Material (IHM) is a document in which all potentially hazardous materials onboard a vessel are identified, located and quantified and follows IMO Resolution MEPC.269(68) guidelines.

Hazardous Material Inventory (Inventory of Hazardous Materials-IHM)

As you know, as of December 31, 2020, an Inventory of Hazardous Materials (IHM) has been approved for all ships above 500 GT that will visit the EU ports and iron fields. IHM Part I and its certification will be checked frequently and meticulously whether it has been properly prepared in the EU port state controls and whether necessary updates have been made.

There are many classes of hazardous substances to be checked for IHM Part I. The IHM Part I hazardous materials analyzes specified in the regulation, including asbestos analyzes, are carried out by our Accredited Laboratory.

In general, more than 35,000 ships in total will need IHM under these rules. Given the current situation with the Covid-19 and pandemic process experienced worldwide, it does not seem possible for HazMat Experts and analysts to meet this capacity and provide certification. We recommend you to plan according to this information.

Scope & Definitions

The Regulation applies to ships on international voyages, of 500 GT and above flying the flag of a Member State or the flag of a third country under the conditions of Article 12 of the Regulation.

The Regulation applies to all vessels of any type whatsoever operating or having operated in the marine environment including submersibles, floating craft, floating platforms, self-elevating platforms, FSUs and FPSOs, as well as ships stripped of equipment or being towed.

It does not apply to any warships, naval auxiliary or other ships owned or operated by a state and used, for the time being, only on government non-commercial service. ‘New’ and ‘existing’ ships, ‘ships going for recycling’ as well as ‘ships flying the flag of a third country’ shall have on board an IHM in accordance with the relevant provisions of Article 5 or Article 12 of the Regulation.

Definitions

The terms used in this guidance document have the same meaning as those defined in the Regulation and in the IMO guidelines with the following additional definitions which apply for the purposes of this guidance document only

IHM process is the whole process of development and maintenance of an IHM throughout the operational life-cycle of the ship. It involves all the steps of developing an IHM including issuing/checking of any relevant documentation (e.g. Material Declarations), sampling and analysis, verification and life-cycle management

Individual IHM expert is a person who has the appropriate training, qualifications and knowledge to conduct HM surveys for the development and maintenance of an IHM. He or she should have experience on ship structure and on handling of HM and sufficient knowledge of how to compile an IHM and of all the relevant international and EU legislation14

IHM expert company is an entity employing or contracting individual IHM experts to conduct any relevant work or task in relation to the IHM process for the purpose of compiling or updating Inventories of Hazardous Materials. The IHM expert company should use a documented management system and should work on suitable standards, covering the relevant activities of the company

HM survey is an investigation to trace and identify the presence or absence of Hazardous Materials contained in the equipment, systems, and/or areas on board a ship and may include review of any relevant documents, visual inspections and sampling

Sampling check is the taking of samples to identify the presence or absence of HM contained in the equipment, systems, and/or areas on board a ship, by suitable and generally accepted methods such as laboratory analysis

Representative sampling is a method to sample materials of the same kind in a representative manner. Such materials should be checked to ensure that they are of the same kind

Blank Sample is a clean sample or sample of matrix processed so as to measure artifacts in the measurement (sampling and analysis) process

Blind Sample is a sample submitted to evaluate performance with concentration and identity unknown to the analyst

Bulk Sample is a sample taken from a larger quantity (lot) for analysis or recording purposes

Specific testing is a repeatable and reliable method of testing samples, which can demonstrate definitively whether a Hazardous Material exists or not and provide a known type of the Hazardous Material

Accredited laboratory is a laboratory accredited in accordance with ISO 17025 or an equivalent standard for the purpose of conducting specific tests for HMs included in the SRR and capable of providing a written report that can be relied upon by all parties.

 

Source: ihmexpert


Applicability: shipowners, ship operators, ship managers and ship masters. ​​​Advice for owners of ships going for recycling and recycling facilities wishing to be included in the UK and EU maintained lists of recycling facilities.

As of 1 January 2021, the United Kingdom (UK) has finished its transition period to leave the European Union (EU). The UK Ship Recycling Regulation (UK SRR) now retains the requirements of the EU Ship Recycling Regulation 1257/2013 (EU SRR) in UK domestic legislation. Note that the EU SRR applies in the European Economic Area (EEA) (EU countries plus Iceland and Norway).i

This Class News summarises the information contained in MGN 633 (M+F) Amendment 1 regarding requirements for final surveys and ship recycling facilities under the UK SRR, as well as further direct correspondence with the UK Administration.

The UK SRR does not apply to:

  • Ships of less than 500 GT;
  • UK ships operating throughout their life only in UK waters; and
  • Any warships, naval auxiliary, or other ships owned or operated by a state and used, for the time being, only on government non-commercial service.

Note that the EU SRR still applies to UK ships operating throughout their life only in UK waters when they go to a recycling facility in an EEA member statei.

A. Final survey requirements

These are required for compliance with the UK SRR (from 1 January 2021) as an owner of:

1. a UK flagged ship going for recycling at an EEArecycling facility; or
2. a UK flagged ship going for recycling at a recycling facility in Great Britain (GBii); or
3. an EEA flagged ship going for recycling in a GBii recycling facility; or
4. a third country flagged ship (to both the EEA and UK) going for recycling in a GBii recycling facility.

 

Source: info


Recent reports from Brussels indicate that the EC is considering reviewing and revising the EU Ship Recycling Regulations (EUSRR), with a view to strengthening its controls. This Update covers the recent development of following issues:

  • Revisions to the EU Ship Recycling Regulations
  • Interpretation to assess the equivalence between the Hong Kong Convention and the Basel Ban (& action requested)
  • IHM Approval Processes – Feedback from IHM services providers

Source: intercargo


Introduction

With 50 units lying idle, and Brent crude languishing at around 20 dollars per barrel, there is currently a strong incentive for recycling of older floating production units. However, significant recent changes to the regulations may complicate an owner’s decision making. Hence, I hope the following article will be of interest to those planning end-of life solutions, and facilitate safe navigation through these potentially choppy waters.

What can go wrong?

Firstly, some words of caution regarding the risks that poorly planned recycling attempts may encounter. These can include:

  • Risk of prosecution and/or reputational damage;
  • Tow risk;
  • Emergent scope.

Due to concerns over environmental protection and health and safety, the regulations have been significantly strengthened in recent years. Hence for poorly planned recycling projects there is an increased risk of non-compliance. Although a number of owners have chosen to sell end-of-life vessels to cash buyers, experience has shown that in the event of legal transgressions by the buyer, this may not absolve the original owner from the ensuing legal investigation, and will do little to alleviate the reputational damage.

Peculiarities of wet towing of end-of-life semis and FPSOs that can lead to enhanced risk, include:

  • Higher windage and drag (as compared to trading vessels);
  • Directional instability;
  • Possibly poor physical condition following prolonged lay-up.

A recent case of a semi-submersible exemplifies the risk. The unit was under tow from the North Sea to a Turkish recycling facility when heavy weather was encountered and the tow line broke. The unit subsequently grounded off Scotland. There have been other cases of difficulties during tows to recycling facilities, including several involving merchant vessels.

Finally, an unclear understanding of the condition of the vessel may lead to emergent scope. For example, a North Sea unit recently underwent deep cleaning prior to recycling. Part way through the cleaning process, it became apparent that not all waste materials could be removed without dismantling parts of the vessel. Hence to complete the deep-clean, it became necessary to amend the execution plan and employ a different contractor.

There are circumstances where the deep clean can be a significant project in its own right, and its cost may exceed the scrap value of the vessel. For example, where the recycling facility cannot handle Naturally Occurring Radioactive Materials (NORMs), it is necessary to fully remove these prior to the delivery voyage.

The Regulations

At international level, the following are of relevance:

The HKC was developed by the IMO in response to concerns regarding health, safety and environmental standards within the ship recycling industry. The convention places obligations on each facility to prepare a Ship Recycling Facility Plan (SRFP) and obliges the owner to have the vessel inspected, an Inventory of Hazardous Materials (IHM) prepared and an International Ready for Recycling Certificate (IRRC) secured. The owner provides the IHM and IRRC to the chosen facility and in exchange, the facility prepares a ship Recycling Plan (SRP). Upon completion of the recycling, the facility issues a statement of completion. The flag state and the ship recycling state approve the documentation at each stage. Otsubo’s 2014 Seminar explains this process in more detail.

The HKC has not yet achieved the necessary conditions to become international law. However, several ratifying countries have embodied the convention within their national regulations.

The BC entered into force in 1992 and regulates the transboundary movement of hazardous and other wastes by using the ‘Prior Informed Consent’ procedure. This means that shipments of waste cannot be transported unless the exporting country, the receiving country and any transit countries have provided consent for the transport to take place.

The BBA came into force in December 2019 and is an amendment to the BC. In a scenario where either the export country or the importing country is a ratifying party, it prohibits the movement of hazardous waste from an OECD country to a non-OECD country. It takes precedence over the existing convention.

To varying degrees, these international regulations have been embodied within national and regional legislation. For example, within the European Union (EU):

The EU SRR implements the HKC for vessels flagged within the EU, and came into force in January 2019. In some respects, it is more onerous than the HKC, e.g. with regard to the number of prohibited hazardous materials. It also has a specific requirement for recycling to be conducted on built structures. The EU audits facilities against the EU SRR requirements and maintains an approved list, currently containing 34 ship recycling facilities in the EU, 6 in Turkey and 1 in the USA.

The EU Waste Shipment Regulation (EU WSR) was adopted in 2006 and most importantly enforces the BBA by prohibiting the movement of hazardous waste from the EU to non-OECD countries. This regulation applies to EU flagged vessels and non-EU flagged vessels departing from EU waters. Hence in the absence of any Asian based facilities approved under the EU SRR, it effectively prevents European based floating production facilities from recycling within the Indian sub-continent.

Other national regulations may influence the choice of recycling location or impact the scope of work.

Relevant Standards

The ISO30000 family of standards relate to ship recycling and may be specified within recycling contracts.

The Recycling Market

The market breaks down into principally two sectors, these being the recycling facilities and cash buyers. Traditionally the recycling facilities have focused on their core business and have been unwilling to take ownership of a vessel and then transport it for recycling. They have also preferred the use of bank letters of credit rather than cash. Hence to enable a turn-key solution for owners, cash buyers have emerged within the market. The cash buyers typically pay cash for the vessel as-is where-is and then arrange delivery to the preferred recycling facility. Nevertheless, Crondall’s recent experience has been that some recycling facilities are now offering more of a turn-key solution by offering cash payments and taking on the responsibility for the delivery voyage, hence blurring the distinction between the two sectors. An advantage of contracting directly with the facility is that the owner has greater certainty over where the unit will be recycled. As previously mentioned, this is important for ensuring compliance with the BBA and the EU WSR.

The characteristics of the principal ship recycling regions are summarised as follows:

India/Pakistan/Bangladesh

Facilities within the Indian sub-continent have been recycling the majority of world tonnage and generally pay the highest rates per long ton of lightweight. Many Indian facilities are compliant with the HKC, but none have yet been included on the list of EU SRR compliant facilities. None are within the OECD and hence under the BBA and/or the EU WSR, legal export of a vessel from an OECD country that has ratified the BBA to the sub-continent, is very difficult.

Turkey

Turkish facilities generally pay higher rates than Europe or USA, but less than those within the Indian sub-continent. Turkey is part of the OECD and 6 Turkish facilities are currently included on the list of EU SRR compliant facilities. Hence it is relatively straightforward to move a floating production facility from Europe or other OECD countries to a Turkish recycling facility.

It is noted that, under Turkish law, import of radioactive waste is banned. Hence prior to the vessel’s delivery voyage, any Naturally Occurring Radio Active Materials (NORMs) must be removed to the satisfaction of the Turkish authorities.

EU & USA

Facilities within the EU and USA generally pay lower rates than either the Indian sub-continent or Turkey. Indeed, it may be necessary for the owner to pay the facility to carry out the recycling.

34 EU facilities and 1 USA facility are included on the list of EU SRR compliant facilities.

China

Since January 2019, China has banned the import of all foreign flagged ships for purposes of recycling and has only recycled Chinese flagged vessels.

On the Horizon

The HKC is now close to meeting the IMO’s criteria for coming into force, although it will be a further 24 months after the criteria are met, before it becomes international law. Implementation will be a driver for improved health, safety and environmental protection, particularly in Bangladesh and Pakistan, which are not yet signatories but are currently recycling significant percentages of world tonnage. Even after becoming international law, it is questionable whether it will take precedence over the BBA, and hence the HKC is unlikely to facilitate the movement of vessels from OECD countries that have ratified the BBA, to the Indian sub-continent.

Recycling Strategy

To minimise risk whilst maximising value, it is recommended from an early stage to develop a recycling strategy. Key elements of this can include:

  • Independent advice.
  •  Due diligence leading to a clear understanding of both the international regulations and the relevant national regulations.
  • An early decision on the preferred contracting methodology, i.e. either segmented or turn-key.
  • Evaluation of the recycling options by:
  1. Carrying out initial screening and long-listing of the options for recycling;
  2. Short-listing and pre-qualification of the potential bidders based on their questionnaire responses;
  3. Defining the scope of work and issuing to the short-listed parties within an Invitation to Tender (ITT);
  4. Evaluating the bids (this is best done as a formal scoring, hence giving a transparent and defendable process).
  • Maximisation of financial return by maintaining the competition as long as possible.
  • Ensuring strong contracts by giving consideration to:
  1. Tow risks;
  2. Pre-contract auditing of the recycling facility;
  3. Financial incentives for completion of the recycling work as specified;
  4. On-site supervision of the recycling process by the owner’s representative.
  • When planning deep cleaning, ensure that the limitations of the recycling facility are well understood, particularly with respect to any legal restrictions on import of hazardous materials (e.g. NORMs).

Closing Remarks

The net financial return for recycling a floating production unit is likely to be small, just a few million US dollars at best. However, with the recent strengthening of regulations, the financial and reputational risks for poorly managed recycling activities can be significant. Hence, a diligent approach to an owner’s planning, and the early development of a clear recycling strategy are recommended. Such forward planning should be time well spent during the current COVID-19 lock-downs.


Inventory of Hazardous Materials (IHM)

While much of the shipping world’s attention is focused on IMO’s sulphur cap entering into force on 1 January 2020, there is another important date for shipping coming up in the diary in 2020!

December 2020 will be a key month for the EU’s Ship Recycling Regulation (SRR). Adopted in 2013 and aimed at reducing negative environmental impacts associated with recycling ships flying the flags of EU member states, the regulation sets out requirements that ships and recycling facilities must fulfil.

A key element of this is the Inventory of Hazardous Materials (IHM), which since 31 December 2018 has been required for newly contracted vessels with a gross tonnage of 500 or more flying the flags of EU member states. From 31 December 2020, this requirement will be expanded to the existing EU fleet. But owners of non-EU flagged vessels also need to have an understanding of the SRR and IHM process as, from 31 December 2020, equivalent non-EU flagged vessels calling at EU ports or anchorages will also be required to carry and maintain an IHM.

The elements of the SRR relating to vessels coming to the end of their working life, applying to ships flying the flag of EU being sent for recycling, have been in force since 31 December 2016. Before delivery to a recycling facility, vessels should have parts 1, 2 and 3 of the IHM completed in order to receive an International Ready for Recycling Certificate from their class society.

The IHM covers fifteen substances and is aimed at controlling and documenting hazardous materials on board ships. It requires expert knowledge to compile and will be produced by a third-party inspection specialist and validated by class.

Inventory of Hazardous Materials (IHM)

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