8 steps for Sustainable Ship Recycling

The legal requirements for sustainable ship recycling have become a pressing issue for all ships, no matter if they are brand new or very old.

Namely, the regulatory scheme with respect to safe and sound recycling of ships consists of:

1. The EU Ship Recycling Regulation according to which a key requirement all for EU-registered and all EU-visiting ships above 500GT is to have a certified Inventory of Hazardous Materials (IHM) onboard until end of 2020.
2. The Hong Kong Convention which will not enter into force until at least 15 countries ratify it. So far, Norway, Congo, France, Belgium, Panama, Denmark and Turkey have ratified the Convention.

Both the EU SRR and the HKC impose responsibilities on ship owners, ship recycling facilities (SRF) and authorities with respect to safe and sound recycling of ships.  DNV GL recommends eight important steps to ensure that ships would be recycled in a sustainable manner posing less risk to the environment, health and safety at the end of their life cycle.

Step 1 – Contract for ship recycling

In addition to the clause to meet the requirements as per the HKC and/or the EU SRR and its guidelines, the IHM, ship recycling facility plan (SRFP), SRP, SoC and IRRC should be listed above all. Moreover, a SRF monitoring programme should be mentioned.

Step 2 – Inventory of hazardous materials (IHM) preparation

The IHM needs to be ship-specific, should be prepared by a qualified expert and cover all 13 or 15 substances listed in the regulations.

Step 3 – Ship recycling plan (SRP) development

The SRP should be developed accordingly  to MEPC.196(62), refer to a specific SRF, reflect the specific IHM and provide licensed dis­posal and recycling solutions for all materials listed in the IHM.

Step 4 – SRP approval process

The SRP requires Competent Authority (CA) of the recycling State’s approval. Explicit approval shall be with written notice of result and tacit approval shall specify the end date of a 14-day review period. An expert assessment of the SRP is recommend­ed until the regulations are fully applicable.

Step 5 – Approved SRP

The SRF forwards the approved SRP to the ship owner. The SRP should contain the final version of the IHM.

Step 6 – Final survey by class

The final survey shall be conducted before the recycling ac­tivity starts. The survey guidelines (MEPC. 222[64]) should be followed. After the successful survey, an IRRC can be issued. The documents to be submitted for the survey include: the IHM (Parts I, II and III), the approved SRP and a copy of a valid SRF document of authorization of ship recycling (DASR).

Step 7 – Report and start of ship recycling

The SRF launches the start of the ship recycling with the submis­sion of the IRRC to the CA.

Step 8 – Statement of Completion (SoC)

After completion, the SRF issues a SoC together with a report on accidents damaging human health and the envi­ronment and reports this to its client and CA. All involved stakeholders receive a copy of the SoC.