When dismantling a ship, few materials or equipment go to waste. Generators and batteries find use ashore, hydrocarbons become fuel in brick mills, and steel is recycled into the construction industry. Ship recycling could be seen as positively contributing to conserving energy and resources were it not for the fact that:
- Ships may contain hazardous materials such as asbestos and heavy metals
- The workforce handling scrapping is often largely unskilled and unprotected
- Hazardous waste disposal may not be regulated in the country where recycling sites are located, resulting in heavy pollution of both land and ocean
Bangladesh, China, India, Pakistan, and Turkey are responsible for 90% of shipbreaking, an activity ILO qualifies as a major occupational and environmental health problem in the world.
To address these issues, a diplomatic conference held in China in 2009 adopted The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention) aiming to ensure that recycling ships doesn’t pose unnecessary risks to health, safety, and the environment. As a result, the requirements for an International Certificate of Inventory of Hazardous Materials were introduced, commonly known as the Green Passport.
How Does The Green Passport Work?
The Green Passport must accompany ships operating in the maritime environment weighing equal or above 500 Gross Tonnage (GT) throughout their working life, 20 to 25 years on average. This document contains an inventory of hazardous materials used in construction and must be updated upon modifications, maintenance, and changes of equipment.
Shipbuilders apply for the initial certificate which is passed on to successive owners of the ship and finally to the ship recycler who may not proceed to dismantle the vessel without it.
In essence, the Hong Kong Convention addresses the issue of hazardous materials disclosure throughout the operating life of a ship and the authorization for a recycling facility to scrap the ship and dispose of its content.
Ship Recycling: The Case Of Europe
The Hong Kong Convention has been signed by over 60 nations; and while not yet legally binding internationally, many countries have adopted the treaty’s requirements.
In 2013, the EU Ship Recycling Regulation (EU SRR) entered into force, addressing two key issues for vessels equal or above 500 GWT (excluding navy ships and domestic ships such as ferries):
- A mandatory Inventory of Hazardous Materials (IHM)
- A list of approved ship recycling facilities
Per the EU SRR:
- New ships flying a member state flag shall carry a certified IHM.
- Ships reaching end-of-life shall carry a certified IHM and be sent to an EU-approved recycling site.
- Existing ships flying a European flag and ships calling to European ports and anchorage shall carry a certified IHM.
Ship Recycling Compliance: Starting At The (Data) Source
While the IHM is crucial for ship recyclers to responsibly and safely proceed, it is equally important to builders and owners to own the accuracy and completeness of information throughout the entire life of the vessels.
The compliance process should be data-driven and the IHM should at the very least contain:
- A list of hazardous materials on board
- A list of areas “Potentially Containing Hazardous Materials” (PCHM)
- A history of structural conversions, additions, and repairs subsequently updating the lists
Where To Find The Data
Working with Tier 1 suppliers and going through your purchase orders, you start by sending out requests for Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC). They in turn may ask their suppliers to provide information not readily available.
The next step is to proceed to an analysis of the documents and update the IHM accordingly.
Inventory Of Hazardous Materials Accuracy
The goal of the inventory is to minimize the adverse impact of toxic materials to human health and the environment via data that allows operators and recyclers to be aware of risks posed by substances like asbestos, PCBs, hydrocarbons, etc. and take appropriate protection measures.
To that effect, accuracy is paramount through the relevance of the inventory from the shipyard to the recycling yard. Simply put, the document should ensure ship recycling happens in the most effective, efficient, and sustainable way. It should also ensure that ship recyclers are in possession of all the information necessary to safely handle and dispose of materials during the scrapping process.
As the leader in supply chain compliance data solutions, Source Intelligence has developed a platform that bridges the gaps in supply chains and allows suppliers to easily provide all the data you need. Thanks to automation, you eliminate unnecessary manual time spent following up and avoid redundant tasks.
Whether you’re a shipbuilder or owner, remember recyclers cannot do their job if the inventory of hazardous materials is not completely accurate.
To learn more about ship recycling regulations through the Inventory of Hazardous Materials, download our white paper "Navigating The International Marine Organization's Green Passport" by clicking the button below.
