In preparation for the entry into force of the IMO Hong Kong Convention
ICS released guidelines on transitional measures for selling ships for recycling five years ago, to prepare ship owners for the entry into force of the IMO Hong Kong Convention. The intention is that thisguidance will be updated periodically as the new IMO standards areimplemented by governments and more experience is gained.These measures are also supported by the national shipowners’associations in Australia, Austria, Belgium, Bulgaria, Canada, Chile,Croatia, Cyprus, Denmark, Finland, France, Germany, Greece, HongKong, India, Ireland, Italy, Japan, Korea, Kuwait, Liberia, Mexico,Netherlands, Norway, Singapore, Spain, Sweden, Switzerland, Turkey,United Kingdom and United States.
The Convention requires each recyclingfacility to possess an approved FacilityManagement Plan which should providea holistic system to ensure that ships arerecycled in a safe and environmentallysound manner. It is unknown how manyfacilities possess such a plan at presentand, if they do, the extent to which theycomply fully with the IMO Convention.
During the transitional period, obtainingconfirmation that a Facility ManagementPlan exists is perhaps less important thanshipowners obtaining firm guarantees inthe contract of sale with respect to theShip Recycling Plan and ‘gas freeing’ (seeabove). However, where shipowners areable to do so, confirmation of the existenceof a Facility Management Plan, and itsconstituent subsidiary plans as describedbelow, will serve as an indicator of thecompetence of the facility and help developa picture of available global capacitythroughout the transitional period.
A Facility Management Plan should containsubsidiary plans and sections specificallyaddressing the areas highlighted below.The degree of detail provided should serveas an indication of the suitability of thefacility to receive a ship and recycle it in asafe and environmentally sound manner:
Facility Management
- A programme for appropriate training ofworkers for the safe and environmentallysound operation of the ship recyclingfacilities;
- The implementation of an emergencypreparedness and response plan; A system for regular monitoring ofthe performance of the ship recyclingoperations, and;
- A system for record keeping on howthe ship recycling operation is performed,including reporting discharges, emissionsand accidents causing damage or with thepotential of causing damage to workers’safety, health and the environment.
Worker Health and Safety
- The provision and availability of personalprotective equipment and clothing neededfor all ship recycling operations, and;
- Appropriate training of workers toundertake safely all operations they aretasked to do.
Waste Treatment
Capacity and treatment ability withrespect to the following waste streams:
- substances or objects containing heavymetals such as lead, mercury, cadmiumand hexavalent chromium
- paints and coatings that are highlyflammable and/or may lead to toxicreleases during cutting
- asbestos and asbestos containingmaterials (ACMs)
- PCBs and materials containing PCBs
- CFCs and halons.
Materials to be listed in inventories of hazardous materials for all ships
Credit: ICS Guidelines on Selling Ships for Recycling
Further information may be found at the ICS Guide