- With reference to the International Convention for the Safe and Environmentally Sound Recycling of Ships:
(a) state the operational requirements for compliance;(4)
(b) list FOUR prohibited hazardous materials;(4)
(c) list TWO hazardous materials whose use should be restricted.(2)
What is the International Convention for the Safe and Environmentally Sound Recycling of Ship?
The International Convention for the Safe and Environmentally Sound Recycling of Ships, commonly known as the Hong Kong Convention, is an international treaty adopted by the International Maritime Organization (IMO) in 2009. Its primary purpose is to ensure that ships, when being recycled, do not pose unnecessary risks to human health, safety, and the environment. The convention establishes mandatory standards for the design, construction, operation, and recycling of ships, as well as requirements for shipyards and recycling facilities.
Key Objectives of the Hong Kong Convention:
- Safety of Workers: Protect the health and safety of workers involved in ship recycling by reducing exposure to hazardous materials and ensuring safe working conditions.
- Environmental Protection: Minimize environmental damage from ship recycling activities by controlling the release of hazardous substances and ensuring proper waste management.
- Safe Ship Recycling: Ensure that ships are designed and constructed in a way that facilitates safe recycling and the minimization of hazardous materials used on board.
- Inventory of Hazardous Materials: Ships must maintain an inventory of hazardous materials onboard throughout their operational life, so that these materials are identified and properly managed during recycling.
- Recycling Facility Requirements: Ship recycling yards must meet specific requirements and be certified to carry out environmentally sound and safe recycling practices.
Main Components of the Hong Kong Convention:
1. Scope of Application:
- The convention applies to ships flying the flag of a state that has ratified the convention and are over 500 gross tons (GT), as well as to ship recycling facilities under the jurisdiction of those states.
- It does not apply to warships, naval auxiliary vessels, or ships owned and operated by governments for non-commercial service.
2. Inventory of Hazardous Materials (IHM):
- Every ship covered by the convention must maintain an Inventory of Hazardous Materials (IHM), which lists all the hazardous materials present onboard. This inventory must be kept up to date throughout the ship’s life.
- The inventory is essential for identifying, managing, and safely removing hazardous materials during the recycling process.
- Typical hazardous materials found on ships include asbestos, heavy metals, hydrocarbons, and ozone-depleting substances.
3. Ship Recycling Plan (SRP):
- Before a ship is sent for recycling, a Ship Recycling Plan (SRP) must be developed by the recycling facility. This plan outlines how the ship will be recycled safely and in an environmentally sound manner.
- The plan includes details on how hazardous materials will be removed and managed, how the ship’s structure will be dismantled, and the steps taken to ensure the safety of workers and the protection of the environment.
4. Certification and Authorization:
- Ships that comply with the convention must be issued with an International Certificate on Inventory of Hazardous Materials by their flag state or an authorized body.
- Ship recycling facilities must be authorized and certified by the competent authority of the state where they are located, ensuring that they meet the standards set out in the convention for safe and environmentally sound recycling.
5. Monitoring and Enforcement:
- States that are party to the convention are required to enforce its provisions through inspections, certifications, and penalties for non-compliance.
- Ship recycling facilities must be subject to regular inspections to ensure they are meeting the required safety and environmental standards.
Why the Hong Kong Convention was Needed:
- Human Health and Safety: Ship recycling is traditionally carried out in developing countries where workers may face hazardous conditions, such as exposure to toxic materials, inadequate safety gear, and poor working environments. The convention aims to protect workers by enforcing safety measures.
- Environmental Impact: Shipbreaking can result in the release of hazardous materials into the environment, including the contamination of soil and water with substances like heavy metals, asbestos, and oil residues. The convention ensures proper handling and disposal of these materials to minimize environmental harm.
- Sustainable Recycling: The convention promotes sustainable ship recycling practices by encouraging ship design and construction that facilitates recycling, as well as establishing requirements for recycling facilities to manage hazardous waste in an environmentally responsible way.
Status of the Hong Kong Convention:
As of today, the Hong Kong Convention has not yet entered into force. For the convention to become legally binding, it must be ratified by at least:
- 15 states representing 40% of the world’s merchant shipping by gross tonnage, and
- These ratifying states must account for at least 3% of the recycling capacity of their ship recycling facilities.
Several countries with significant ship recycling industries, including India, Bangladesh, China, and Pakistan, are encouraged to adopt the convention to help achieve these criteria.
Conclusion:
The Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships is a critical international agreement aimed at improving safety and environmental practices in the ship recycling industry. By establishing a framework for the design, operation, and recycling of ships, the convention seeks to protect both human health and the environment while promoting sustainable shipbreaking practices. While it is not yet in force, ongoing efforts are being made to encourage more countries to ratify the convention and implement its provisions.
What are the operational requirements for compliance?
To comply with the International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention), ships and ship recycling facilities must meet specific operational requirements. These requirements ensure that ships are recycled in a manner that protects both human health and the environment. The operational requirements are divided into obligations for ships and ship recycling facilities.
Operational Requirements for Ships:
- Inventory of Hazardous Materials (IHM)
- Requirement: All ships covered by the convention must maintain an Inventory of Hazardous Materials (IHM) throughout their operational life. This inventory lists all hazardous materials present on the ship in its structure, systems, equipment, and components.
- Details:
- The IHM must be kept updated and should be available for inspection by authorities.
- It must identify the location, quantity, and type of hazardous materials, such as asbestos, lead, mercury, polychlorinated biphenyls (PCBs), and ozone-depleting substances.
- Verification: The IHM must be verified by the flag state or an authorized organization, and ships must carry an International Certificate on Inventory of Hazardous Materials.
- Minimization of Hazardous Materials in Design and Construction
- Requirement: Ships must be designed and constructed to minimize the use of hazardous materials, making it easier to recycle them safely at the end of their operational life.
- Details:
- New ships should comply with the convention’s guidelines to reduce the environmental impact of ship recycling.
- Minimization includes selecting materials and components that reduce the risk of releasing harmful substances during recycling.
- Ship-Specific Recycling Plan (SRP)
- Requirement: Before a ship is sent for recycling, it must have a Ship-Specific Recycling Plan (SRP) developed in cooperation with the recycling facility.
- Details:
- The SRP is prepared by the recycling facility, outlining how the ship will be dismantled and how hazardous materials will be managed and disposed of.
- The plan must include details of the ship’s structure, hazardous materials on board, and the specific procedures for ensuring the safety of workers and environmental protection during recycling.
- Ship Recycling Facility Authorization
- Requirement: Ships must only be recycled at authorized recycling facilities that meet the standards set by the Hong Kong Convention.
- Details:
- Shipowners must ensure that the recycling yard is certified by its respective national authority and complies with the required safety and environmental standards.
- Ships can only be sent to facilities that have demonstrated the ability to handle hazardous materials in a safe and environmentally sound manner.
- Issuance of Ready for Recycling Certificate
- Requirement: When a ship reaches the end of its operational life and is about to be recycled, it must be issued a Ready for Recycling Certificate by its flag state or an authorized organization.
- Details:
- This certificate confirms that the ship complies with the Hong Kong Convention’s requirements, that its IHM is up to date, and that a recycling plan is in place.
- The certificate is issued following a final survey conducted to verify the condition of the ship and its readiness for recycling.
Operational Requirements for Ship Recycling Facilities:
- Ship Recycling Plan (SRP)
- Requirement: Each ship sent for recycling must have a Ship-Specific Recycling Plan prepared by the recycling facility.
- Details:
- The SRP outlines how the ship will be dismantled, with special attention given to the removal and handling of hazardous materials identified in the IHM.
- The plan must include procedures to ensure that the recycling process will be carried out safely and without adverse effects on the environment.
- The SRP must be approved by the competent authority before recycling begins.
- Environmental Protection Standards
- Requirement: Ship recycling facilities must implement measures to ensure the safe handling and disposal of hazardous materials, preventing the release of pollutants into the environment.
- Details:
- Waste generated during the recycling process must be managed in accordance with national and international regulations.
- Facilities must have systems in place for the collection, storage, and proper disposal of hazardous materials such as asbestos, heavy metals, hydrocarbons, and other toxic substances.
- Recycling facilities must have suitable infrastructure to prevent contamination of soil, water, and air during the recycling process.
- Worker Safety and Health Protection
- Requirement: Recycling facilities must ensure that all workers involved in the dismantling and recycling process are provided with appropriate safety measures to protect their health.
- Details:
- This includes the use of personal protective equipment (PPE), proper training, and procedures to prevent accidents and exposure to hazardous materials.
- Facilities must have first aid and emergency response measures in place, along with regular safety inspections and drills.
- Workers should be trained in hazardous material handling, fire safety, and safe dismantling procedures.
- Facility Authorization and Certification
- Requirement: Ship recycling facilities must be authorized by their national competent authority to carry out ship recycling in compliance with the convention.
- Details:
- The facility must be certified to meet the requirements of the Hong Kong Convention, including safety standards, environmental regulations, and waste management practices.
- The authorization ensures that the facility has the appropriate infrastructure, equipment, and procedures in place to recycle ships safely and responsibly.
- Waste Management and Reporting
- Requirement: Recycling facilities must have procedures for handling, processing, and reporting on the disposal of hazardous materials.
- Details:
- They must document the removal and disposal of hazardous materials and ensure they are disposed of in accordance with national and international waste regulations.
- Facilities are also required to submit regular reports to authorities on the recycling operations, including waste management practices, safety records, and environmental performance.
- Monitoring and Inspections
- Requirement: Recycling facilities are subject to regular inspections by national authorities to ensure compliance with the Hong Kong Convention.
- Details:
- These inspections verify that the facilities are following safety protocols, environmental protection measures, and proper waste management practices.
- Facilities must keep records of all recycling activities, including the handling of hazardous materials and the implementation of worker safety measures, which must be made available for review during inspections.
Summary of Operational Requirements for Compliance:
To comply with the Hong Kong Convention, both ships and recycling facilities must adhere to several key operational requirements, including:
- Ships: Maintaining an Inventory of Hazardous Materials (IHM), having a Ship Recycling Plan (SRP), ensuring recycling is done at an authorized facility, and obtaining a Ready for Recycling Certificate before recycling.
- Recycling Facilities: Developing a ship-specific SRP, adhering to environmental protection standards, ensuring worker safety, being certified by national authorities, and managing hazardous materials properly.
These operational requirements ensure that the process of recycling ships is safe, environmentally sound, and compliant with international standards designed to protect human health and the environment.
Prohibited hazardous materials
Under the International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention) and other international regulations such as the International Maritime Organization’s (IMO) guidelines and the European Union Ship Recycling Regulation (EU SRR), specific hazardous materials are either prohibited or strictly regulated in shipbuilding and operation. These materials are banned due to their potential health hazards and harmful environmental effects during a ship’s operational life and recycling process.
Prohibited Hazardous Materials:
- Asbestos
- Description: Asbestos is a fibrous material that was once widely used in ships for insulation, fireproofing, and other applications. However, it poses severe health risks, particularly asbestosis and lung cancer, when inhaled.
- Regulation: The use of asbestos in new ships is prohibited. Ships built before the ban must have an Inventory of Hazardous Materials (IHM) identifying any asbestos-containing materials, and these must be safely removed during recycling.
- Polychlorinated Biphenyls (PCBs)
- Description: PCBs are synthetic organic chemicals that were commonly used as coolants, insulating fluids in electrical equipment (such as transformers and capacitors), and hydraulic fluids. They are highly toxic, persistent in the environment, and can cause cancer and other serious health effects.
- Regulation: PCBs are prohibited in ships built after certain dates (typically post-1980) under international agreements such as the Stockholm Convention. Any ship that contains PCBs must identify them in the IHM and ensure they are removed and disposed of safely.
- Ozone-Depleting Substances (ODS)
- Description: Ozone-depleting substances include chemicals like chlorofluorocarbons (CFCs), halons, methyl chloroform, and carbon tetrachloride, which were historically used in refrigeration, fire suppression systems, and air-conditioning systems. These substances deplete the ozone layer, increasing the risk of harmful ultraviolet radiation reaching the Earth’s surface.
- Regulation: The use of ODS is banned under the Montreal Protocol and the Hong Kong Convention. Ships containing ODS must have these materials listed in the IHM and phased out or removed in a controlled manner before recycling.
- Perfluorooctane Sulfonic Acid (PFOS)
- Description: PFOS is a synthetic chemical used in fire-fighting foams and other industrial applications. It is resistant to environmental degradation and can accumulate in living organisms, potentially causing health and environmental damage.
- Regulation: PFOS is prohibited under the Stockholm Convention on Persistent Organic Pollutants (POPs). Ships equipped with fire-fighting systems that use PFOS must transition to safer alternatives, and any residual PFOS must be documented and safely managed.
- Organotin Compounds (Including Tributyltin (TBT))
- Description: Organotin compounds, particularly tributyltin (TBT), were widely used in antifouling paints to prevent the growth of marine organisms on the hull. However, TBT is highly toxic to marine life and has long-lasting environmental impacts.
- Regulation: The use of TBT and other harmful organotin compounds in antifouling systems is banned under the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention). Ships must remove or encapsulate existing organotin-based coatings before recycling.
- Mercury and Mercury Compounds
- Description: Mercury is a heavy metal that has been used in various marine applications, including batteries, thermometers, and switches. It is highly toxic and can accumulate in the environment, leading to serious health effects such as damage to the nervous system.
- Regulation: Mercury is prohibited in many applications under the Minamata Convention on Mercury. Any mercury-containing components must be identified and safely managed during recycling to prevent contamination.
Other Hazardous Materials of Concern (Strictly Controlled but Not Completely Prohibited):
In addition to the fully prohibited hazardous materials, there are other materials that are tightly regulated, but not fully prohibited. These materials are subject to strict controls due to their environmental and health risks.
- Lead and Lead Compounds
- Description: Lead is a toxic metal used in batteries, paints, ballast, and electrical components. It poses significant health risks, particularly affecting the nervous system and causing developmental issues in children.
- Regulation: While lead is not fully banned, its use is restricted, and ships containing lead components must manage them safely, with these materials documented in the IHM.
- Cadmium
- Description: Cadmium is a toxic heavy metal found in certain paints, batteries, and electronics. It can cause kidney damage and bone degradation in humans and is harmful to aquatic life.
- Regulation: Cadmium is regulated and must be listed in the IHM. Recycling facilities must have procedures to handle and dispose of cadmium-containing materials safely.
- Hexavalent Chromium
- Description: Hexavalent chromium is used in anti-corrosion coatings, stainless steel production, and some paints. It is a known carcinogen and poses serious risks to workers and the environment.
- Regulation: Its use is restricted, and any components containing hexavalent chromium must be documented in the IHM and safely handled during recycling.
- Radioactive Substances
- Description: Some ships, particularly older vessels, may contain materials that have become contaminated with low-level radioactivity, or components such as luminous dials or gauges that use radioactive materials.
- Regulation: Any radioactive materials must be carefully managed and safely removed during the ship recycling process, with compliance to national and international regulations.
Requirements for Safe Management:
- Inventory of Hazardous Materials (IHM): For all ships subject to the Hong Kong Convention, an IHM must be maintained to track the presence of any hazardous materials onboard. This ensures these materials are identified and managed safely when the ship is recycled.
- Removal and Disposal: Ships that contain any prohibited or hazardous materials must ensure their safe removal before or during recycling, according to international environmental and safety regulations.
- Recycling Plans: Ship Recycling Facilities (SRFs) are required to follow strict guidelines for the removal, handling, and disposal of hazardous materials to ensure that no environmental harm occurs during shipbreaking activities.
Conclusion:
The Hong Kong Convention and related international regulations prohibit the use of hazardous materials such as asbestos, PCBs, ozone-depleting substances, PFOS, organotin compounds, and mercury in ships. These materials are banned due to their serious health risks and environmental impacts. Ships that contain any of these substances must document them in an Inventory of Hazardous Materials (IHM) and follow stringent requirements for their safe removal and disposal when the vessel is recycled. The goal is to ensure that ships are recycled in a manner that protects workers, the environment, and public health.
Hazardous materials whose use should be restricted
Several hazardous materials are not entirely banned but are restricted in their use due to their potential environmental and health risks. These materials can be found in various ship components and systems, and while they are still permitted in certain applications, their use is regulated to minimize harmful impacts. The International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention), alongside other international regulations such as the Stockholm Convention and the European Union Ship Recycling Regulation (EU SRR), defines the limitations for these materials.
Hazardous Materials Whose Use Should Be Restricted:
1. Lead and Lead Compounds
- Description: Lead is a toxic heavy metal used in various ship applications, including batteries, paints, ballast, piping, and electrical components.
- Health and Environmental Impact:
- Lead exposure can cause neurological damage, particularly affecting brain development in children, and can result in kidney damage and reproductive issues in adults.
- In the environment, lead is toxic to aquatic organisms and can persist in soils and sediments, leading to long-term contamination.
- Regulation:
- The use of lead and its compounds is heavily restricted, especially in paints and coatings.
- Ships must document the presence of lead in the Inventory of Hazardous Materials (IHM), and special care must be taken during recycling to ensure lead-containing materials are safely removed and disposed of.
- Lead-acid batteries, common on ships, should be managed according to safe disposal practices to prevent leakage of lead and sulfuric acid.
2. Cadmium
- Description: Cadmium is a toxic heavy metal used in ship applications such as batteries, coatings, and plating for corrosion resistance, as well as in certain electrical components.
- Health and Environmental Impact:
- Cadmium exposure can lead to kidney damage, lung disease, and bone degradation (osteoporosis).
- In the environment, cadmium is highly toxic to plants, animals, and marine life, and can accumulate in food chains.
- Regulation:
- The use of cadmium is restricted due to its toxicity, especially in paints and coatings.
- Ships must include any cadmium-containing components in their IHM and manage them carefully during recycling.
- Cadmium-containing products, such as batteries, should be handled and disposed of properly to prevent environmental contamination.
3. Hexavalent Chromium (Chromium VI)
- Description: Hexavalent chromium is used in anti-corrosion coatings, plating, and stainless steel production. It is often found in ship hulls, piping, and fittings to prevent rust and corrosion.
- Health and Environmental Impact:
- Hexavalent chromium is a known carcinogen that can cause lung cancer, skin ulcers, and respiratory problems when inhaled or absorbed through the skin.
- It is toxic to aquatic life and can contaminate water sources if not properly managed, leading to long-term environmental damage.
- Regulation:
- The use of hexavalent chromium is restricted, especially in paints and coatings.
- Ships must document its presence in the IHM, and any components containing hexavalent chromium must be removed carefully during recycling.
- Alternatives to hexavalent chromium, such as trivalent chromium, are increasingly being used to reduce health and environmental risks.
4. Polyvinyl Chloride (PVC)
- Description: PVC is a plastic material commonly used in shipbuilding for cable insulation, piping, and flooring due to its durability and resistance to corrosion.
- Health and Environmental Impact:
- PVC itself is not highly toxic, but when burned or heated, it releases toxic gases, including dioxins and furans, which are harmful to human health and the environment.
- Dioxins are persistent environmental pollutants that can accumulate in the food chain and cause serious health issues, including cancer.
- Regulation:
- The use of PVC is restricted in certain applications where there is a risk of fire or heat exposure.
- Ships must manage PVC-containing components carefully, particularly during recycling or repair, to prevent the release of hazardous gases.
- Proper ventilation and protective equipment are required when handling PVC in high-heat environments.
5. Brominated Flame Retardants (BFRs)
- Description: Brominated flame retardants are chemicals used to reduce the flammability of materials such as plastics, textiles, and electronics found on ships.
- Health and Environmental Impact:
- BFRs can accumulate in human tissues and are linked to health issues such as endocrine disruption, neurological damage, and reproductive toxicity.
- They are persistent in the environment and can bioaccumulate in wildlife, leading to long-term ecological impacts.
- Regulation:
- The use of certain BFRs, such as polybrominated diphenyl ethers (PBDEs), is restricted under international agreements like the Stockholm Convention on Persistent Organic Pollutants (POPs).
- Ships must document the presence of BFRs in the IHM, and special precautions must be taken during ship recycling to prevent their release into the environment.
6. Perfluorinated Compounds (PFCs)
- Description: PFCs, including perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), are used in firefighting foams, non-stick coatings, and water-repellent materials on ships.
- Health and Environmental Impact:
- PFCs are linked to health issues such as liver damage, kidney disease, and cancer. They are persistent in the environment and can accumulate in human and animal tissues.
- PFCs can contaminate water sources and have been found to persist in groundwater near areas where firefighting foams were used.
- Regulation:
- The use of certain PFCs, particularly PFOS, is restricted under the Stockholm Convention.
- Ships must document and properly manage any firefighting systems or materials containing PFCs, ensuring they are safely removed or replaced during recycling or retrofitting.
7. Phthalates
- Description: Phthalates are plasticizers used to make PVC and other plastics more flexible. They are commonly found in ship components such as cable insulation, flooring, and seals.
- Health and Environmental Impact:
- Phthalates are endocrine disruptors, which can interfere with hormone function and lead to reproductive and developmental issues.
- They can leach out of plastics into the environment, contributing to long-term pollution in marine and terrestrial ecosystems.
- Regulation:
- The use of phthalates is restricted, particularly in materials that may come into contact with food, water, or the human body.
- Ships must manage phthalate-containing components to prevent leaching during use or disposal and document them in the IHM.
Summary of Restricted Hazardous Materials:
These restricted hazardous materials—lead, cadmium, hexavalent chromium, PVC, brominated flame retardants, PFCs, and phthalates—are still in use in shipbuilding and operations but are subject to strict controls. They must be carefully managed to prevent harm to human health and the environment, particularly during recycling or disposal. Shipowners and operators must ensure compliance with international regulations by maintaining an Inventory of Hazardous Materials (IHM) and implementing safe handling, removal, and disposal practices to minimize the risks associated with these materials.
By managing these hazardous materials effectively, the shipping industry can reduce its environmental footprint and protect the health and safety of workers and communities involved in ship operations and recycling.