In an attempt to highlight key issues of ship dismantling, Mr. Stefanos Magoulas, Environmental Protection Consultant, Solix Engineering, refers to the Costa Concordia project which serves as an exquisite example of dismantling and recycling a vessel dockside, outside an approved facility. Mr. Magoulas further questions what needs to be considered in ship dismantling process in accordance with existing legislation. Finally, he suggests that a wider public acceptance of IHM is needed, considering that until the end of 2020, all ships over 500GT calling at EU ports must be equipped with a valid IHM.
Costa Concordia sets as a perfect raw example that ship recycling is, in fact, a process that can take place even out of a facility, if circumstances require, rather than a certain capability for specific facilities. To remind: Costa Concordia was dismantled in Genoa Port, by two leading companies, Eni and San Giorgio del Porto. Genoa is not one of currently EU approved ship recycling facilities. However, Costa Concordia was dismantled properly, giving a very important hint, that can be utilized in other circumstances.
For example, let’s say you have a ship wreck that its status won’t allow its use as a ship, following its refloating. And, moreover, in order to refloat it, certain parts of its structure have to be removed by means of cutting. Does not this suffice to define itself as a partial dismantling work?
In 2014, following its sinking at Mykonos Island, MV YUSUF CEPNIOGLU was refloated and removed in three parts (superstructure, fore, stern), requiring cutting works. In 2015, after heavy grounding, MV GOODFAITH was removed from Andros Island, after extensive cutting of superstructure. In both cases, principals required that, prior to any cutting, asbestos presence onboard should be verified, prior to any cutting. But this is like making a partial Inventory of Hazardous Materials. Asbestos is a Hazardous Material contained in Table 1 of IHM.
At present, there is the grounded and sank MV LITTLE SEYMA, at Isle Tragonissi, near Mykonos Island. Vessel was hard aground in December 2017 and, due to severe weather on site, at present, is significantly deteriorated and will have to be removed in parts. Moreover, in the vicinity of Piraeus port and Elefsis Bay, there is a number of old, abandoned ship wrecks that will have to be removed, in order to clean waters, pertaining to the port privatization actions taken by Greek State.
All aforementioned vessels, at the point that were or will be removed, their status will not allow not even their refloating, in some cases. Additionally, their deterioration may prove crucial to the point that transportation to the nearest approved recycling facility will not feasible at all. All these will lead to the fact that these ships will require to be cut, partially or in whole, at the place they currently lie.
So, here comes the crucial question: Does all this qualifies as an adequate reason to define these actions as “Ship Dismantling” and, thus, demand all preventive measures that need to be taken when every vessel is cut, under the scope EU 2013/1257 Regulation?
The answer is “probably yes”. There seems to be no viable reason no to consider these works as such that hold same level of risks to health, safety and environment as a ship dismantling process. The main danger of ship recycling lies within the risks posed by the improper handling and management of all hazardous materials on-board, while cutting and dismantling takes place. The same cutting and dismantling might be required to refloat and remove these vessels.
So, we have spotted the problem. What is the solution? Well, it is simple. As in every other similar process, stakeholders and authorities must be convinced that all steps should be taken, according to competent legislation. Despite the fact that circumstances may indicate that cutting might be required, this should be done properly. HazMat identification, Health & Safety coverage, Waste Management, Risk Assessment and proper management of overall procedure, with involvement of efficient equipment and personnel, is a prerequisite.
To the extent this will be related to Ship Recycling regulations, it can lead to a wider public acceptance of the requirement of adequate Inventories of Hazardous Materials, that will be created by competent experts, better understanding of Ship Dismantling needs and, hopefully, increase of business opportunities.
A good result would be the increase of awareness of involved parties in order to take this first step towards providing ships with the well-discussed Inventory of Hazardous Materials (IHM). After all, let’s not forget that, until the end of 2020, all ships over 500GT calling at EU ports must be equipped with a valid IHM. And these ships are quite a lot.
By Stefanos I. Magoulas, Chemical Engineer M.Sc.Eng, Environmental Protection Consultant, Solix Engineering
The views expressed in this article are solely those of the author and do not necessarily represent those of SAFETY4SEA and are for information sharing and discussion purposes only.
Stefanos I. Magoulas is an active and experienced Environmental Protection Consulting Engineer, focused on Environmental Protection issues, in matters of Legislation Compliance and Project Operations Consultancy.
Actively involved in Maritime Environment, Health & Safety (EHS) sector, he has worked at different stakeholders of the shipping industry, serving as a Consulting Engineer for shipyards, equipment manufacturers, salvors and waste management companies.
In 2016, he started Solix Engineering™, a firm of Environmental Protection Consulting Engineers, focused on Environmental Compliance, Protection & Awareness.
