The absence of one international and uniformly applicable convention for ship recycling can make this a difficult field to navigate for operators, causing even reputational and financial damage because of how their ships have been recycled at the end of the ship’s life.
As such, Eddy Morland, Head of Division at the Standard P&I Club, looked at practical considerations on ship recycling and made some recommendations as to what members should consider when it comes to recycling their ships, including their obligations regarding the club.
In the absence of a universally applicable convention for ship recycling and uniform standards for safety and environmental standards at ship recycling locations, the Club recommends that operators:
a) select recycling yards that have a Statement of Compliance with the Hong Kong Convention or the EU Ship Recycling Regulation (ESRR) 2013;
b) when selling a ship to a third party, ensure that the third party’s compliance with the Hong Kong Convention or ESRR, the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (the Basel Convention), the Basel Ban Amendment or the European Waste Shipment Regulation (EWSR) and all other applicable regulations and licences;
c) refer to additional industry guidance (e.g. Shipping Industry Guidelines on Transitional Measures for Shipowners Selling Ships for Recycling by International Chamber of Shipping).
It is also reminded that operators must disclose when they intend to recycle a vessel, so that insurers can determine the appropriate point at which cover should terminate.
When a company informs the managers, it will be asked to:
- provide details of the final voyage, the ship’s flag, the location of the recycling and at what point in the process title will transfer to the ‘buyer’
- confirm that all relevant regulations, conventions and local licences/permissions for export and recycling have been complied with/obtained.
- A special loss prevention article on ship recycling will follow this one to assist members intending to recycle ships.