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.

 

FATALITIES AND MEDICINAL HELP:

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 POWER OF MISDIRECTION AND IMPORTANCE OF FACTS:

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.

 

THE POSITIVE REALITY OF RECYCLING IN INDIA

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.

 

ABOUT HARIYANA RECYCLING YARD AND THE RECYCLING OF “LANCE”

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.

 

CONCLUSION

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:

Sr. No. Date Designated Facility Waste Description Total Quantity
(in MT)
1. 13/02/2019 GEPIL Bilge Water 0.240
2. 13/02/2019 GEPIL Garbage 0.140
3. 13/02/2019 GEPIL Oily Rags 0.040
4. 13/02/2019 GEPIL Contaminated Sand 0.150
5. 18/05/2019 GEPIL Glasswool 0.720
6. 30/05/2019 GEPIL Glasswool 0.820
7. 10/06/2019 GEPIL Glasswool 0.780
8. 22/06/2019 GEPIL Glasswool 0.930
9. 25/06/2019 GEPIL Glasswool 1.280
10. 27/06/2019 GEPIL Glasswool 0.880
11. 28/06/2019 GEPIL Asbestos 0.095
12. 16/07/2019 GEPIL Glasswool 0.790
13. 04/10/2019 GEPIL Glasswool 1.200
14. 18/10/2019 GEPIL Glasswool 1.200
15. 22/10/2019 GEPIL Glasswool 1.200
16. 24/10/2019 GEPIL Glasswool 0.880
17. 01/11/2019 GEPIL Glasswool 1.020
18. 18/11/2019 GEPIL Glasswool 0.970
19. 22/11/2019 GEPIL Glasswool 0.990
20. 23/11/2019 GEPIL Glasswool 1.110
21. 04/12/2019 GEPIL Glasswool 1.110
22. 14/12/2019 GEPIL Booch 0.210
23. 14/12/2019 GEPIL Booch 0.240
24. 26/12/2019 GEPIL Rubber 0.060

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.

 

 

– END OF TEXT –
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)

Regulation Implementation:
  • • 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.

Preparation of IHM Part I (Work Process):
  • • 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 31st December 2020
  • New ships, by 31st 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.

Green Recycling Services by an Expert

EPE has a record with hundreds of IHM surveys onboard vessels since 2006, and is an active company in marine business worldwide for more than 30 years dedicated to the protection of marine environment and human life.

EPE has established –on a constant basis- cooperation with accredited laboratories according to EN ISO/IEC 17025:2005, and testing methods which are in line with the requirement of Appendix 9 of the MEPC.269(68) Guideline and Annex C of EMSA IHM Guidance for analysis of asbestos and other hazardous materials.

Classification Approvals

EPE has been approved by major classes for services onboard ships as Hazmat Expert Company and for Quality Assurance for identification, sampling, reporting and
preparation of Inventory of Hazardous Materials – namely DNV GL, Lloyd’s Register, ABS and Bureau Veritas. All EPE’s HazMat engineers have been trained and certified as Hazardous Materials Experts from DNV GL.

Approved I.H.M Services Provider by:

Member of:

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.

IHM Preparation

A short description of our methodology for Compilation of the Inventory of Hazardous Materials on an existing ship according to the guidelines of MEPC.269(68), the EU SRR regulation 1257/2013 on ship recycling and EMSA Guidelines in IHM Preparation, has the following steps:

Source: epe


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


Every year, around 1,000 ships reach the end of their operating life. The European Ship Recycling Regulation (EU SRR) was introduced to ensure proper vessel dismantling methods are used to achieve safe disposal or recycling of all ship components, including hazardous materials. To assist shipyards and owners with this process, Bureau Veritas Solutions Marine & Offshore supports preparation of an Inventory of Hazardous Materials (IHM) and development of a Ship Recycling Plan (SRP) that complies with EU SRR.

Shipyards must comply with numerous regulations governing hazardous materials, including EU SSR requirements concerning the ship dismantling process. To ensure compliance, vessel owners and operators need to draft, certify and maintain an Inventory of Hazardous Materials (IHM) to accompany the ship throughout its life. In addition, they must develop an approved Ship Recycling Plan (SRP) for dismantling a decommissioned vessel safely and without emitting harmful pollutants.

  • Bureau Veritas Solutions Marine & Offshore helps you gain a comprehensive understanding of all mandatory regulations concerning hazardous materials and vessel dismantling

  • Our GreenPassport EU notation supports you to maintain compliance with EU SRR

  • Complying with EU SRR enables you to minimize reputational risk by ensuring people safety and environmental protection when dismantling vessels

  • We offer advanced digital tools that give you fast access to data

EU Ship Recycling Regulation & IMO Hong Kong Convention

OUR OFFER

A GLOBAL IHM SOLUTION

Bureau Veritas Solutions Marine & Offshore can establish and certify an Inventory of Hazardous Materials (IHM) to help shipyards prepare for safe dismantling operations and enhance QHSE management.

GREENPASSPORT EU NOTATION

Prior to vessel construction, Bureau Veritas Solutions Marine & Offshore supports owners in obtaining GreenPassport EU notation by ensuring the compliance of all materials. This notation accompanies the ship throughout its life, guaranteeing safe and eco-responsible ship recycling upon dismantling.

CUSTOMIZED SHIP RECYCLING PLANS (SRPS)

Bureau Veritas Solutions Marine & Offshore helps shipyards develop Ship Recycling Plans (SRPs) tailored to the specific needs of vessels reaching the end of their operating life. These plans minimize risks during the dismantling process and prepare the ship for scrapping.

MANAGEMENT AND MONITORING OF DISMANTLING OPERATIONS

Bureau Veritas Solutions Marine & Offshore helps limit potential risk to people and the environment throughout the dismantling process with rigorous monitoring of all phases. We provide onboard survey, hazardous materials sampling, and laboratory tests. Our advanced digital tools provide clients and surveyors alike with fast access to data.

source: marine-offshore


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


In view of an increased concern about various environmental issues, the focus on the use of non-hazardous materials in ship design, building and operation is also increasing. Two regulations are presently governing these issues:

  • Regulation (EU) No. 1257/2013 of the European Parliament and of the Council of 20 November 2013 on Ship Recycling (EU SRR)
  • Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC)
IHM and EU Ship Recycling - DNV GL Maritime
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EU SRR vs IMO HKC

The EU SRR and the HKC, both statutory requirements, place responsibility on ship owners, ship builders, suppliers, recycling facilities and national authorities to ensure the safe and environmentally viable management of hazardous materials (hazmats) as well as the sustainable recycling of ships. A fundamental requirement of these regulations is the documentation of hazardous materials on board ships, the so-called Inventory of Hazardous Materials (IHM), and the authorization of ship recycling facilities.

The table below provides an overview of the requirements from the two regulations in terms of their scope and certification:

EU SRR vs IMO HKC

COMPARISON
EU SRR
IMO HKC

Entry into Force

31 Dec 2018

  • for EU/EEA flagged new* ships; and
  • for EU/EEA flagged ships going for recycling

31 Dec 2020 for all EU/EEA flagged ships and third part ships visiting EU/EEA ports and anchorages

Not yet ratified

Applicability

EU/EEA flagged ships ≥ 500 gross tonnage (GT)Ships ≥ 500 gross tonnage (GT) calling any EU/EEA ports/anchorages

Ship Recycling Facilities (SRFs) (European List)

Ships ≥ 500 gross tonnage (GT)Ship Recycling Facilities

Excluded

any warships, naval auxiliary, or other ships owned or operated by a Party and used, for the time being, only on government non-commercial service;ships of less than 500 GT; or

ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly.

any warships, naval auxiliary, or other ships owned or operated by a Party and used, for the time being, only on government non-commercial service; ships of less than 500 GT; or

ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly.

IHM

IHM Part I investigates 15 hazardous materials listed in Annex I & II

IHM Part I investigates 13 hazardous materials listed in Appendix I & II
IHM Certification done by

Flag states or ROs

  • IC (IHM Certificate) for EU/EEA flagged ships
  • SoC (Statement of compliance) for third party flagged ships

Flag states or ROs

  • ICIHM – International Certificate on IHM
SRF authorization
European Commission through site inspections accept SRFs to «European List»
Competent authority of each party authorizes its SRFs

According to EU SRR, “new ship” means ships; building contract is signed on or after 2018-12-31, or in the absence of building contract, if keel is laid on or after 2019-06-01, or delivery date is after 2021-06-01.

“Ship” means a vessel of any type whatsoever operating or having operated in the marine environment and includes submersibles, floating craft, floating platforms, self elevating platforms, Floating Storage Units (FSUs), and Floating Production Storage and Offloading Units (FPSOs), including a vessel stripped of equipment or being towed.

Source: dnvgl


Ship Recycling Convention

The “Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009” (Ship Recycling Convention) was adopted in May 2009 at IMO.
This convention sets forth requirements for ship recycling facilities and procedures for recycling aimed at minimizing environmental pollution and promoting occupational safety and health of workers.
Once the Convention enters into force, development and maintenance of IHM as well as related periodical surveys will be required for all ships over 500GT engaged in international voyages, and will also be required for existing ships not later than 5 years after the Convention enters into force.

Inventory of Hazardous Materials

IHM is a list of hazardous materials, waste, and stores present in a ship and identifies the locations and approximate quantities of these materials and items onboard ship. This detailed information is intended to help to realize the following aims:

  • To protect occupational safety and health of workers at Ship Recycling Facilities
  • To prevent of environmental pollution.
  • To promote development of substitution of hazardous materials and efficient use of resources.

As of March 2017, it is not expected explicitly when the Ship Recycling Convention entre into force. However, the deliberation of guideline concerning the Ship Recycling Convention was completed at IMO and development of IHM is required for both EU flagged ships and non-EU flagged ships by EU regulation on Ship Recycling that has been entered into force on December 30, 2013. By these movements, it is expected that ratification of the Ship Recycling Convention will be promoted around EU Member States. Therefore, early development of IHM for each existing ship is highly recommended.

Development of IHM for existing ships

Development of IHM for existing ship basically consists of the following steps. Steps 1 to 5 require the assistance of “Experts” who can help shipowner develop IHM more effectively. We stands ready to provide Expert consulting and related services.

Although development of IHM for existing ship generally requires complex and highly involved work, we can help to make IHM development process proceed much more smoothly and precisely by drawing on its extensive wealth of know-how.
Our staff of highly-trained and experienced experts can help to make obtaining the “International Certificate of Inventory of Hazardous Materials” required by Ship Recycling Convention in smooth process.

Once shipowner submits his or her request, we can provide services for development of IHM for existing ship, including arranging expert to assist in development of IHM.

Source: classnkcs


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.

CTI Marine Services is a Singapore-headquartered organisation that has already been involved in production of thousands of IHM projects. CTI Marine Services is the maritime specialist arm of Centre Testing International (CTI), a China-headquartered international conglomerate that provides a range of testing, environmental safety and material reliability services spanning industrial products, consumer goods and maritime hazardous materials management. We spoke with CTI Marine Services business manager Andreas Lougridis to understand more about what exactly is involved in producing the IHM, and what owners need to know before they go about commissioning a report.

“Many owners don’t know how time-consuming the IHM is, and how much effort has to be put in for a successful completion,” says Mr Lougridis.

As the IHM is a ship-specific project, inspectors will collect drawings and prepare a visual sampling check plan (VSCP) identifying from which locations samples must be taken.. This process is carried out at the inspector’s office and takes one or two work days.

Once the VSCP has been drawn up, the inspector can go on board a vessel to collect samples. Mr Lougridis notes that based on CTI Marine Services’ experience, two days or 20 man hours is sufficient for the sampling process to be completed.

With the samples taken, the next step is for them to be sent to a laboratory for testing. The length of time this takes depends on the inspector and which facilities they are using. For CTI, which has in-house labs, this process takes around 10 days, following which the final report can be compiled.

“From zero to final reporting takes an average of 20-30 days, and once we’re finished, class will take over to review our reports,” Mr Lougridis explains.

This can take as little as 2-3 weeks or up to three months, depending on where the review takes place. And once this review is completed, a class society inspector will go on board the vessel to perform a verification survey, which will take about half a day, following which, assuming all is as it should be, a Statement of Compliance (SoC) validating the IHM can be issued by class on behalf of the vessel’s flag state.

“So from the very start to issuing the SoC, we’re talking a minimum of two months and – from our experience – as much as five months per vessel.”

The IHM is reviewed on each special survey, so about every five years, and if properly maintained the SoC will be re-endorsed in a process that will be repeated throughout the vessel’s working life.


This article is the first in a series of three looking at issues surrounding the IHM process and what shipowners need to be aware of. In the next article in this series, we will look at what shipowners need to be aware of when planning IHMs and how to avoid associated pitfalls.

 

CTI Marine Services and Riviera Maritime Media are jointly hosting a webinar on the Inventory of Hazardous Materials, detailing what every vessel operator needs to know and do by 2020, on Tuesday, 10 December 2019 at 9:30am GMT. Book here to register for the webinar.
Source: rivieramm


Leading Classification Society ClassNK has released its “Guidelines for the Inventory of Hazardous Materials (Ver.4.00).

The “Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009” (HKC) was adopted in 2009. After the entry into force of the HKC, the development and maintenance of an Inventory of Hazardous Materials (IHM), which identifies the location and approximate quantities of hazardous materials onboard a ship, will be required for all ships over 500GT.

Hopes are high for entry into force, as currently, 13 countries making up 30% of the merchant fleet have acceded to the HKC(*1). Ahead of the HKC’s entry into force, EU ship recycling regulations will require all existing ships sailing under the flag of EU Member States as well as ships flying the flag of a third country and calling at an EU port or anchorage to have an IHM from 31 December 2020.

In light of the situation, ClassNK has revised its guidelines to include comprehensive content on the development and maintenance of IHM in line with not only the HKC, but also EU regulations, including the validity of an existing statement of compliance. The Guidelines for the Inventory of Hazardous Materials (Ver.4.00) are available to download free of charge via ClassNK’s website www.classnk.com for those who have registered for the ClassNK “My Page” service. To register for the “My Page” service free of charge, go to the ClassNK website www.classnk.com and click on the “My Page Login” button.

(*1): The HKC will enter into force 24 months after the date on which 15 States, representing 40 percent of world merchant shipping by gross tonnage, have either signed it without reservation as to ratification, acceptance or approval or have deposited instruments of ratification, acceptance, approval or accession with the Secretary-General. Furthermore, the combined maximum annual ship recycling volume of those States must, during the preceding 10 years, constitute not less than 3 per cent of their combined merchant shipping tonnage.
Source: ClassNK


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