Pandey what difference can hong kong convention make to ship recycling in india

What Difference Can Hong-Kong Convention Make to Ship Recycling in India?

Sachin K. Pandey, Anand M. Hiremath, Anand B. Salve, and Shyam R. Asolekar Centre for Environmental Science and Engineering Indian Institute of Technology Bombay Mumbai 400 076, INDIA Phone: +91-22-2576 7867 Fax: +91-22-2572 3480 asolekar@iitb.ac.in

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Contents • Introduction • International Maritime Organization • Gujarat Maritime Board • Methodology • Comparison of Hong Kong Convention and GMB Regulations • Conclusions • References 2

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Introduction • Ship recycling is the most environmentally friendly way for disposing of the ships those have reached to end of life • Around 1000 ships are recycled every year world-wide • In the last decade around 97% of the world’s recycled tonnage has been recycled by the five recycling countries i.e. India, China, Bangladesh, Pakistan and Turkey Source: (IMO, 2012) 4

Introduction

Contd…

• India is the world’s biggest ship recycling country • Since the past decade, safety, health, environment and welfare matters in ship recycling industry have been matters of concern

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Hong Kong Convention (HKC), 2009

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Hong Kong Convention, 2009 • IMO has developed guidelines for safe and environmentally sound ship recycling in Hong Kong convention, 2009 • The guidelines consist of 21 Articles, establishing the main legal mechanisms, 25 regulations divided into four chapters and 7 appendices 7

Hong Kong Convention

Contd…

• Separately, 6 non-mandatory guidelines are currently being developed providing clarifications, interpretations and uniform procedures for technical issues

• Article 6 and regulations 9 and 17 to 25 of the annex of the Hong Kong convention provide requirements for ship recycling facilities and require these guidelines to be taken into account 8

Hong Kong Convention

Contd…

The four chapters of IMO regulations are: 1. General Provisions: Definitions, applicability and relationship of the guidelines with other standards, recommendations and guidance 2. Requirements for Ships: Design, operation and maintenance of ships, preparation for ship recycling and survey certification 9

Hong Kong Convention

Contd…

3. Requirements for the Ship Recycling Facilities: a. Controls, authorization and requirements of ship recycling facilities, ship recycling facilities plan (SRFP), human health and environment management, hazardous waste management, b. Emergency preparedness, worker safety and training and reporting of Incidents and accidents 4. Reporting Requirements: Initial notification and reporting upon completion

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Alang Ship Recycling Industry and Gujarat Maritime Board (GMB)

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Gujarat Maritime Board (GMB) and Alang Ship Recycling Industry

• Alang is the ship recycling yard situated 50 Km away from the Bhavnagar district of Gujarat, India • Almost 180 plots are in the operation at Alang ship recycling yard

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Gujarat Maritime

Contd…

• GMB is the regulatory body of Gujarat government to guide and regulate maritime activity as well as ship recycling activity • There are two landmark regulations made by GMB to make ship recycling activity environment friendly 1) “The GMB (Prevention of Fire and Accidents for Safety of Workers and Protection of Environment During Ship-breaking Activities) Regulation, 2003” and 2) “The GMB (Conditions and Procedures for Granting Permission for Utilizing Ship 13 Recycling Plots) Regulation, 2006”

Objectives

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Objectives • “What are the prevailing Rules and Regulations set by Gujarat Maritime Board (GMB) for safe and Environmentally Sound Ship Recycling • To articulate the existing Rules of GMB and how they are different from Hong-Kong Convention • If Hong-Kong convention guidelines are implemented then what difference we can expect in ship recycling in India?

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Methodology

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Methodology (1/2) • The first step was to understand the entire system of ship recycling activity at Alang-Sosiya through rigorous scientific literature as well as existing Acts, Rules, Regulations and Notifications related to ship recycling in India • The field study was carried out by the research team of IIT Bombay (IITB) by selecting two ships beached at two different ship recycling yards in Alang-Sosiya to understand the implementation of rules and regulations which are being followed and certifications to be taken by the yard owner from the respective authority during the process of recycling • The team visited the yards every day after the beaching of ship 17

Methodology (2/2) • During the study period, the research team visited the yards and conducted several brain-storming sessions with the yard owners, production-managers, safetysupervisors and safety officers • The team keenly observed the recycling method and safety measures were being followed at the yards • During the field visit the workers were interviewed related to safety and environment • In order to validate findings, the team visited twenty more plots to validate the results • Finally, the validated results from the field study were compared with the regulations of the Hong-Kong 18 Convention, 2009

Procedure of ship recycling at Alang-Sosiya ship recycling yard

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Procedure of ship recycling at Alang-Sosiya ship recycling yard Sr. No

Work Activity

Authority involved

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Ship recycling yard inspection for Gujarat Maritime Board getting permission for ship beaching (GMB)

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Anchoring permission at Bhavnagar Port

GMB, Gujarat pollution control board (GPCB) & Custom officer

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On-board visit to the ship before beaching in the yard

Custom officer and ship recycler

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Deck review

Custom officer, GPCB and Atomic Energy Regulatory Board (AERB) officers

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No Objection Certificate for Beaching GMB, GPCB, and Custom department

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Procedure of ship recycling at Alang-Sosiya ship recycling yard Sr. No

Work Activity

Authority involved

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Removal and destroying of marked radio room

Custom officer

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Oil removal and bilge water removal

Ship recycler and GMB

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Submission of ship dismantling plan

Ship recycler, GMB, and GPCB

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Decontamination certificate

GPCB

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Cutting permission

Cutting permission 21

Hong Kong Convention Vs GMB Regulations

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Inventory of Hazardous Materials 1. Hong Kong Convention Each ship shall have an on-board inventory of hazardous materials listed in appendices 1 and 2 of the convention The inventory shall be properly maintained and updated throughout the operational life of the ship 2. GMB Regulations A hazardous wastes inventory is made by the safety officers and locations are marked Well trained workers do the work of HWs removal and wastes like asbestos is handled by specially trained workers GMB has provided “transport storage and disposal facility 23 (TSDF)”

Ship Recycling Facility Plan 1.  Hong Kong Convention Ship recycling facilities authorized by a party shall prepare a ship recycling facility plan The plan shall be adopted by the board or the appropriate governing body of the recycling company

2.  GMB Regulations The Supreme Court of India has clearly stated in its verdict of 2007 that before granting authorization to the recycling facilities, the SPCB should ensure that the SRFP has been adopted by the Board, or the appropriate governing body of the company 24

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Ship Recycling Plan 1.  Hong Kong Convention Should be recycled only at ship recycling facilities authorized in accordance with the convention A ship-specific ship recycling plan shall be developed by the ship recycling facility(ies) prior to any recycling of a ship, taking into account the guidelines developed by the organization 2.  GMB Regulations The Supreme Court of India order of 6th September, 2007-Before starting the recycling process, the recycler should submit a dismantling (SRP) plan to the authorities, which should include: details about the ship, assessment of hazardous wastes, Ship breaking schedules, Operational work procedures, PPEs, Hazardous waste handling and 27 disposal plan etc.

Oil Removal by Authorized Agency

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General Requirements, Controls on and Authorization of Ship Recycling Facilities 1.  Hong Kong Convention SRFP shall establish management systems, procedures and techniques which do not pose health risks to the workers concerned or to the population in the vicinity of the ship recycling facility and which will prevent, reduce, minimize and to the extent practicable eliminate adverse effects on the environment caused by ship recycling

2.  GMB Regulations In Alang-Sosiya, the authorization for ship recycling facility is given by GMB GMB inspects yards, verify documents and check ship recycling facility plan- If the companies fail to fulfil the required terms and conditions, GMB cancels their authorization

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Prevention of adverse effects to human health and the environment 1.  Hong Kong Convention SRF, authorized by a party taking regulation 19 of the Convention into account shall establish and utilize procedures to prevent explosions, fires, and other unsafe conditions by ensuring that Safe-for-hot and Safe-for-entry work conditions and procedures are established, maintained, and monitored in ship spaces, including confined spaces and enclosed spaces

2.  GMB Regulations Chapter II and IV of the GMB regulation, 2003 deal with the ship recycling activities and permission for cutting respectively 30

Prevention of adverse effects‌

Contd ‌

Chapter II (ship recycling activities) regulation no.5 states that ship recycler must complied withstorage licenses for storage of LPG/Oxygen cylinders, maintain safety distance from storage of petroleum products, provided facilities of water storage and fire-fighting devices, installed portable fire extinguishers, installed fire-fighting equipment such as fire extinguishers, firefighting suits, foam sprayer, sand box etc.

Chapter IV (permission for cutting) regulation no. 12 states that application for permission for cutting should contain : Gas free certificate for man entry (safe-for-entry) into confined spaces likely to contain dangerous fumes issued by competent person, naked light certificate (hot work permit) and copy of evidence of custom clearance of the ship etc.

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Safety Officer Showing the Water Pumping Machine Temporarily Installed Inside Ship

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Safe and environmentally sound management of Hazardous Materials 1.  Hong Kong Convention SRFP shall ensure, safe and environmentally sound removal of any hazardous material contained in a ship certified in accordance with regulation 11 or 12 of the convention that all hazardous materials detailed in the inventory are identified, labelled, packaged and removed to the maximum extent

2.  GMB Regulations Supreme Court of India directs to GMB that a complete inventory of hazardous waste on board of ship should be made mandatory for the ship-owner And no breaking permission should be granted without 33 such an inventory

Negative Pressure Room of Asbestos Removal

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Waste Water Treatment System at Alang Ship Recycling

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Waste Water Treatment System at Alang Ship Recycling

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Emergency preparedness, response, worker safety and training 1.  Hong Kong Convention According to regulation 21 and 22 of the Convention, SRF shall establish and maintain an emergency preparedness and response plan ensure workers safety and provide training

2.  GMB Regulations Many emergency measures are being taken at the ship recycling plots like making availability of fireextinguisher, water-pump, installation of emergency alarm etc.

Fire-fighting department and hospitals are also available for any emergency, A training and welfare centre has been established 38

by GMB to conduct training program

Training and Welfare Institute Alang

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Training Programme Details

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Reporting on incidents, accidents, occupational diseases and chronic effects 1.  Hong Kong Convention Regulation 23 of the Convention states that SRF shall report to the competent authorities any incident, accident, occupational diseases, or chronic effects causing, or with the potential of causing, risks to workers safety, human health and the environment

2.  GMB Regulations Chapter VII regulation 24 and 25 state that the ship recycler shall report in writing to the port authority, the factory inspector as well as the police authority about any accident/fire/explosion occurred on the plot and/or ship, immediate on its occurrence 41

Notification and reporting 1.  Hong Kong Convention When the partial or complete recycling of a ship is completed in accordance with the requirements of this Convention, a statement of completion shall be issued by the ship recycling facility and reported to its competent authorities

2.  GMB Regulations Ship recycling companies give details in writing of the ship which they want to buy for recycling The details contain name of the state of the flag of the ship, IMO number of the ship, name and type of the ship, inventory of hazardous materials and draft ship recycling plan etc. Ship recycling companies inform in written to GMB after the completion of 42 recycling of each ship

Conclusions

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Conclusions (1/2) After the comparative study of the Hong Kong Convention and GMB regulations it has been found that 1.  GMB has taken many demarcated approaches to combat with the human health and environmental problems of the ship recycling activity 2.  Guidelines of Hong Kong Convention and GMB regulations both gives directives to improve the conditions of the industry

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Conclusions (2/2) 4.  Both the Hong Kong Convention and GMB regulation suggests the preparation of ship specific ship recycling plan (SRP) and its approval by competent authority 5.  The implementation of Hong Kong Convention in India can hardly make any difference in its present form because the most of guidelines are already being exercised in India

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References •

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Asolekar, S. R., Greening of ship recycling in India: Upgrading facilities in Alang in the proceedings of “7th Annual Ship Recycling Conference” organized by Informa Maritime Events and Lloyd’s List, UK and held in London during 19th & 20th June, 2012.

Deshpande, P.C., Tilwankar, A.K., and Asolekar, S.R. A Novel Approach to Estimating Potential Maximum Heavy Metal Exposure to Ship Recycling Yard Workers in Alang, India. Science of The Total Environment 2012; 438: 304-311.

Dimakopoulos, S., The IMO’s work on ship recycling. International Maritime Organization, 2005. http://www.imo.org/blast/blastDataHelper.asp? data_id=17986&filename=TheIMO.pdf GMB, 2012, “Hazardous Waste Management at Alang Sosiya Ship breaking Yard”, GMB (GMB) (URL:http://www.gmbports.org browsed on Sept, 2012).

Mikelis, N., Introduction to the Hong Kong Convention and its requirments. Ship recycling technology and knowledge transfer workshop. Izamir, Turkey, July 14-16, 2010.

Supreme Court of India, Order of 6 September 2007 International Conference on the Safe and Environmentally Sound Recycling of Ships 46 http://www.basel.int/Portals/4/Basel%20Convention/docs/ships/

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