Memorandum submitted by the Chamber of
Shipping
DISMANTLING DEFUNCT SHIPS
1. The Chamber is the trade Association
for shipowner and shipmanager companies based in the United Kingdom.
Its 125 members and associate members represent over 730 merchant
ships of about 18 million gross tonnes.
2. This memorandum confines its comments
to the UK shipping industry's basic approach to the "scrapping"
or "recycling" of merchant ships and to those bulleted
questions which are most relevant to the industry—on overall
demand for facilities in England and Wales and on how UK vessels
are dealt with.
GENERAL
3. Ships have a long operational life (which
can be over 30 years). Most ships from developed maritime countries
are sold on for further trading long before they reach the end
of their commercial working lives or become "defunct".
However, many are not and ships built for specialised or particular
uses or routes may well be traded by a company right through to
the end of their lives.
4. It is quite possible that, when ships
are recycled, materials may have to be disposed of which were
considered anodyne when the ships were constructed. Equally by
virtue of their need to operate totally independently and safely
away from land, ships include components and substances that are
harmful if not disposed of correctly. Substances such as asbestos
come in the former category, fuel and lubricating oils come into
the latter.
5. Within the Chamber, we encourage members
to work to high standards when having their ships dismantled,
with a view to recovering as much valuable recyclable material
as possible (eg aluminium, copper and steels, as well as oils
and fuels).
6. In March 2000, the International Maritime
Organisation (IMO) started to discuss the issue of ship recycling/scrapping.
The International Chamber of Shipping (ICS), which represents
the shipping industries of some 35 countries world-wide, took
the initiative with other international shipping associations
of producing an "Industry Code of Practice on Ship Recycling"[1]
Chamber members such as BP Shipping and P&O Nedlloyd were
very active in the Code's development.
7. The ICS Code was widely disseminated
and has been accepted as a benchmark standard for good practice.
The IMO adopted a series of guidelines on ship recycling in December
2003, which rely heavily on the Code. It sets out general good
practice and includes a very useful "Inventory of Potentially
Hazardous Materials which may be on Board"[2]
This check-list is intended to be kept up to date and presented
to the recycling yard to enable them to plan safe removal and
disposal of the materials.
(Some Non Governmental Organisations contend
that the Basel Convention on the Transboundary Movement of Hazardous
Wastes and their Disposal is applicable to ships, although general
opinion is that it was never intended to do so and is inappropriate
for application to the shipping industry where ships are built,
operated, and eventually recycled, in different parts of a global
industry.)
THE DEMAND
FOR RECYCLING
FACILITIES IN
THE UK
8. While the Chamber is not able to estimate
the real demand for ship recycling facilities in the UK or globally,
it is clear that there will be a continued flow of ships, large
and small, to be recycled—whether as a result of old age
or from technological or regulatory obsolescence. With the Government's
positive shipping policies encouraging both investment in younger
vessels and overall growth in the UK-owned fleet, it can be expected
that vessels will continue to come into the market for recycling,
as well as being sold for further trading elsewhere.
9. Shipping however is fundamentally a global
business and we believe that ship recycling should be seen on
that basis. Thus demand for ship recycling facilities cannot,
subject to the standards considered above, be viewed from a national
or regional perspective.
10. Shipping companies will always seek
to realise the highest price for their ship/asset within an acceptable
environmental and reputation management framework, and the demand
for suitable recycling facilities fluctuates considerably. Any
UK facility would need to provide a competitive and environmentally
acceptable offer to the international shipping industry.
HOW UK VESSELS
ARE DISPOSED
OF
11. Almost all ships scrapped by UK-based
companies are sold for recycling at facilities outside Europe.
The main centres for scrapping and recycling in the world are
in the Indian sub-continent and China, where there is a massive
demand for recycled steel to feed their expanding economies.
12. Chamber members have gone a stage further
than the ICS and IMO recommendations by developing their own "Standard
Operating Procedures" manual. This lays down all the procedures
to be followed as a ship is scrapped, it provides for the removal
of all hazardous materials not required for safe operation of
the ship before demolition, with the waste being processed in
strict compliance with the IMO and ICS guidance. As an example,
P&O Nedlloyd has successfully recycled 19 ships through yards
in China using this procedure.
13. It is possible that, in processing a
ship in this way, companies will not realise as high a price for
the vessel as if it were scrapped in its entirety in Bangladesh
or India (although the differential, if any, will vary depending
on market demand). However, they consider that they taking a responsible
business and environmental approach to the disposal of ships at
the end of their lives outweighs any commercial disadvantage.
Chamber of Shipping
May 2004
1 http://www.marisec.org/resources/shiprecylingcode.pdf. Back
2
http://www.marisec.org/resources/shiprecylcing-inv-hazardous.pdf. Back
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