Recycling - BIMCO Bulletin


REGULATION March 2020 Crunch time for ship recycling regulation By Craig Eason, Journalist and event host Many shipowners are still unaware of quite how much detail the mandatory European inventory requires Photo (top): Adobe Stock / pryc1969 If Bangladesh and China follow India’s lead and ratify the Hong Kong International Convention for the safe and environmentally sound recycling of ships, the countdown to it coming into force will begin. Regardless of what happens, the industry must first deal with regional regulations from the EU and the challenge of producing compliant inventories for hazardous materials. India has now acceded to the International Maritime Organization’s (IMO’s) ship recycling convention, and Bangladesh is set to follow suit within the next two to four years, according to its government officials. It is also rumoured that China could ratify the convention later this year. Bringing the Hong Kong Convention into force in the coming years, pushes a number of requirements onto shipowners dealing with end-of-life tonnage, as well as the global ship recycling community that has to make sure it is up to scratch. The convention controls how a ship can be recycled and at what type of approved facility. It also requires owners to have a full inventory of hazardous material onboard. But before the convention comes into force, the shipping industry will first have to deal with the regional regulations of the EU’s own Ship Recycling Regulation. Inventories ready by next year, no easy task In a similar way to the Hong Kong Convention, the EU Ship Recycling Regulation also has a key requirement for shipowners and operators to ensure their vessels have a valid inventory of hazardous materials onboard; it must be kept updated right until when the vessel is sold for recycling. Importantly, all ships under European flags, and any entering European ports, must have this inventory up-to-date and confirmed by the end of 2020. The list of substances and materials that need to be recorded is similar, but not identical, to that of the Hong Kong Convention. That is a tough requirement, according to Inventory of Hazardous Materials (IHM) expert Henning Gramann of GSR Services, a Germany-based company specialising in such inventories and compliance with both recycling regulations. Gramann is concerned many shipowners are still unaware of quite how much detail the mandatory European inventory requires. For any certification to be valid, he says, it takes time and effort to get right. He sees many owners going to companies that offer IHM inventory certification at prices that he believes are impossible to deliver. He points, for example, to the detailed testing for asbestos and other harmful materials that is needed, and the requirement to know how much material is in every onboard component, from fire doors and engine parts, to insulation and paint finishes. For some clients, Gramann has had to contact suppliers asking for component material inventories to check for hazards. He believes some suppliers may even have to go to second and third-tier suppliers to track down the exact composition of various products. Not all suppliers are helpful, while others just don’t have the means, says Gramann, and this could be problematic for owners seeking to be compliant. Once the EU IHM certificate requirements come into force on 1 January 2021, it is unlikely to be long before the Paris Memorandum of Understanding pushes member states to launch a detailed inspection campaign to check for compliance, as has happened in the past once new rules have been introduced. India and China In 2019, India acceded to the Hong Kong Convention, following years of effort to improve the condition of the country’s ship recycling facilities. Nikos Mikelis is an environmental consultant who has been working with the IMO for many years and has detailed knowledge of the convention. He is also one of the experts critical of the European regulations, which he thinks have helped delay the development of Asian facilities and the coming into force of the Hong Kong Convention. The Hong Kong Convention will only come into force two years after at least 15 IMO member states have ratified or acceded to it, and those that have done so have a combined 40% of the world fleet by gross tonnage. The maximum annual recycling volume of those countries is also not to be less than 3% of the combined tonnage of the ratifying states. India was the 15th state to sign up to the convention, which means only the second and third requirements now need to be met. India, Bangladesh, Pakistan and China have been the four largest recyclers in recent years, followed by Turkey. While China’s ship recycling industry has virtually stopped, because of a self-imposed ban on import of waste three years ago, should the country ratify or accede to the convention, it would ensure the final two requirements are met and bring the convention into force two years later. This is because the size of its flagged fleet is large enough to reach the 40% target, and because the convention requirements on recycling capacity is a rolling average over the past 10 years. With China’s historically high recycling volumes, it would ensure this requirement is also met. Bangladesh When it comes to Bangladesh, its government has brought in regulations to improve the country’s ship recycling industry and a mandate to ratify the convention within two to four years, according to government sources. The IMO, backed by funds from Norway – the first nation to ratify the Hong Kong Convention – has a work programme in Bangladesh helping with health and safety training, building up recycling yards and helping create ship recycling facility plans, a requirement under the convention. It is also helping with another key obstacle in Bangladesh: the safe disposal of hazardous waste in the yards. The country currently has no adequate waste disposal infrastructure. Once Bangladesh or China ratify the Hong Kong Convention, bringing it into force, it will put pressure on owners to ensure they have their inventories for hazardous materials and other required documentation up to scratch, and force them to use yards that have also done likewise in improving their services. Mikelis says all this could pose a huge problem for Pakistan, the last of the four recycling countries yet to respond to a changing market. Connect with BIMCO Facebook Twitter Linkedin YouTube Bringing the Hong Kong Convention into force in the coming years, pushes a number of requirements onto shipowners Craig Eason is a business journalist, editor, photographer, event moderator and public speaker. He reports on the transformation of the shipping industry and has been covering the regulatory framework, technological developments and social and environmental impact of shipping for 15 years. Craig is editorial director of Fathom World, a provider of news and information relating to the changes in the maritime sector, and former Deputy Editor of Lloyd’s List. Photo (top): Adobe Stock / pryc1969