The dismantling of end-of-life ships to recover materials such as ferrous scrap, non-ferrous scrap, machines, fuel oil and other reusable materials is the core activity in the management of ships that have reached the end of their economic lives. In principle, this activity supports sustainability because metal recycling not only conserves resources and energy but also reduces greenhouse gases emissions, air pollution and water pollution due to a reduced need for mining metals and other raw materials required for steel making and other similar processes. Despite these positives, the ship recycling industry has been under constant scrutiny by environmental activists and watchdogs alleging unsafe working practices at the recycling facilities in South Asia.
The concern shown by environmental groups started in the form of a public campaign to increase awareness towards workers’ safety and environmental management, however, now it seems to have derailed and turned into a propagandist approach which fails to applaud the improvements carried out by several yards in major ship recycling countries in South Asia. In terms of total figures of ships recycled annually, India and Bangladesh top the list of the global ship recycling countries. Recently, both countries made a fair amount of progress in improving the health, safety and environmental standards of the ship recycling sector. In India, yards have taken voluntary steps to obtain certification from reputed classification societies for compliance with the Hong Kong Convention (HKC). Moreover, the government of India is in process of acceding to the HKC. In Bangladesh, one yard has recently obtained a Statement of Compliance (SOC) with the HKC while the government has begun the process of overhauling its national regulatory regime concerning ship recycling.
The developments in India have been going on at a rapid pace within the last few years which has led to the award of the Statements of Compliance with the HKC to 50% of the active yards in Alang. On the regulatory front, in Dec 2017 the government of India initiated pre-legislative consultations with stakeholders for one month to introduce the provisions of the HKC through the Safe and Environmentally Sound Recycling of Ships Bill 2017. In addition to the HKC provisions, the bill intends to impose fine and imprisonment of up to 1 year to any person contravening its provisions. This clearly shows the intentions of the Indian government to accede to the HKC soon in order to regulate the entire industry by introducing even stricter policies than international regulations. At present, the industry in India is regulated by the Ship Breaking Code 2013, which doesn’t include the provisions for fine and imprisonment.
In Bangladesh, although the progress isn’t as rapid as in India, meaningful activities towards a more sustainable ship recycling industry are clearly visible. First and foremost, in Oct 2017 PHP Family Ship Breaking yard obtained a Statement of Compliance (SOC) with HKC by RINA, which has provided impetus to other yards to upgrade their facilities as well. Several instances of yards seeking experts’ advice to comply with the provisions of the HKC have come to light. This clearly highlights the current mood prevailing in the annals of the ship breaking industry in Bangladesh. On the regulatory front, the Bangladesh Ship Recycling Act 2018 came into existence which resembles the India’s bill in terms of penalizing contraventions by fine and imprisonment. In addition, it also promises to setup a Ship Recycling Board and a Waste Treatment, Storage and Disposal Facility (TSDF) replicating the Indian setup of Gujarat Maritime Board and the TSDF in Alang.
The aforementioned developments in India and Bangladesh are certainly commendable steps towards the improvement of the global ship recycling industry. The steps undertaken will ensure better management of waste generated from ship recycling facilities and will deter yard owners from malpractices because of the strenuous penalty provisions. The provisions of the bills in both countries will also ensure the safe and environmentally sound recycling of ships and offshore assets by means of improved infrastructure and trained workforce. In addition, the intentions of the government of India to accede to the HKC also augur well for the global ship recycling industry. A similar step from Bangladesh will be a big boost for the HKC’s entry into force. However, it may take a few more years to materialize given the fact that there is no TSDF in Bangladesh yet and only one yard has received the Statement of Compliance (SOC) with HKC (so far).
In addition to the steps taken by India and Bangladesh, Turkey is likely to submit its ratification documents to the IMO soon. Turkey’s ratification and India’s accession to HKC would help impart pressure on other major recycling countries such as China, to ratify the Convention and therefore, accelerate HKC’s journey towards enforcement. China (including Hong Kong) has a relatively large percentage of fleet registration which is an important detail for the HKC’s enforcement due to its entry into force criteria set by the IMO. Unfortunately, regulatory developments in China are not widely known despite the fact that several HKC-compliant yards exist there. At the same time, there is no information on any sort of regulatory or infrastructure upgrade in the yards of Pakistan.
In conclusion, all major recycling nations need to work in tandem to achieve sustainability in the ship recycling industry, globally. The steps taken by India, Turkey and Bangladesh on the regulatory front need to be complemented by China and Pakistan whereas the infrastructural development seen in India, China and Turkey needs to make in-roads into the yards located in Bangladesh and Pakistan. Any discussion on comparing methods of docking ships (beaching, alongside, landing) for dismantling in light of health, safety and environmental (HSE) standards’ disparity is futile because HSE standards are independent of the way ships are docked. Rather, the industry improvements must be appreciated, acknowledged and yards in all major recycling countries must be supported by all stakeholders so that they continue investing in yard improvements.
By Dr. Kanu Priya Jain, Coordinator, Responsible Ship Recycling, GMS (Dubai)