The Hong Kong (HK) International Convention for the Safe and Environmentally Sound Recycling of Ships was adopted in May 2009. Its entry into force will happen 24 months after ratification by at least 15 states, representing 40% of world merchant shipping by gross tonnage, and combined maximum annual ship recycling volume not less than 3% of their combined tonnage. Last year, the 10 th anniversary of the Convention was marked by the ratification by India, the 15 th country, representing a huge step forward for the industry.
As India is home to a large proportion of ship recycling activities, these new regulations will impact the country’s processes and national ship workers on a huge scale. Only once fully ratified and approved will we see the Convention come into force and understand exactly how it impacts the industry, but this is not far away from being implemented.
Keeping an up-to-date Inventory of Hazardous Materials (IHM) on board a ship throughout its life-cycle is a key requirement in both the HK Convention and the EU Ship Recycling Regulation (SRR). The development and maintenance of an IHM should be subject to two values: quality and independence. This will enhance the credibility of the IHM and prevent conflicts of interest between the entity (individual, company or organisation) developing or updating the IHM, and those verifying the IHM on behalf of the flag state. Progressive and professional shipowners, operators and managers are increasingly recognising the potential conflict of interest if the company taking the samples is also testing those samples in its own laboratories.
To date, the EU Commission has been dictating the terms of ship recycling yards and auditing them. But the IMO needs to utilise representatives from various stakeholders, such as laboratories, flag states, and IHM companies, to ensure independent oversight of ship recycling activities. Regular and unexpected audits will ensure that the EU’s list of shipyards that are exceeding standards and demonstrating best practice is accurate and up to date. The main problem is that while some shipyards in India have achieved approval from the class societies, they have still not been able to clear audits by the European Commission, which means there is huge disparity in quality that needs to be addressed.
Verifavia Shipping provides EU SRR and IHM services across the globe, and the majority of our hazmat experts are marine engineers and ex-seafarers from India, Singapore, China, Honk Kong and Turkey. Currently, if an IHM report is shown to a ship worker, for example, and they are asked to take appropriate precautions, there isn’t the education or training in place to support them in making safe decisions. However, we provide extensive mentoring and training which enables us, with a clear conscience, to ensure quality and consistency worldwide, regardless of the regulations in place. Verifavia also prides itself on using independent laboratories through the process to ensure impartial results.
Following ratification of the HK Convention, the industry stakeholders must take action to raise standards, such as providing medical and financial support directly to workers and suitable safety training to reduce accidents. Companies also need to put budget aside from the beginning of owning a vessel to ensure there are funds available for recycling the vessel safely, efficiently and environmentally at the end of its life.