Memorandum submitted by Able UK Ltd
DISMANTLING OF DEFUNCT SHIPS
On 25 March 2004 the Environment, Food &
Rural Affairs Committee issued Press Notice No 41 giving notification
on the decision to set up a sub-committee to undertake an inquiry
into the environmental impacts of the dismantling of defunct ships
in the United Kingdom.
As an interested party, we (Able UK Ltd—"ABLE")
were invited to submit written evidence addressing the terms of
reference of the inquiry.
1. EFRAC INTRODUCTION
"In light of the issues surrounding
the dismantling of US Navy vessels on Teesside, the phasing out
of single-hulled tankers, and the need to dispose of defunct UK
naval vessels, the Committee is undertaking an inquiry into the
environmental impacts of dismantling defunct ships in the United
Kingdom, and the methods of disposal to be used".
The Committee are considering the points numbered
below and ABLE's written evidence is noted below each point raised.
2. WHAT FACILITIES
AND EXPERTISE
ARE ALREADY
IN PLACE
IN ENGLAND
AND WALES
TO DISMANTLE
DEFUNCT SHIPS
SAFELY?
ABLE response:
The only facilities and expertise that are in
place in England and Wales to dismantle defunct ships in a manner
that will provide the Best Practicable Environmental Option ("BPEO")
and meet the European Environmental legislative requirements is
Teesside Environmental Reclamation and Recycling Centre ("TERRC")
based on the River Tees, Hartlepool, England, UK.
The only Company that has the experience and
proven track record in England and Wales for decommissioning marine
structures in a manner that provides the BPEO and meets the European
Environmental legislative requirements is Able UK Ltd based at
Able House, Billingham Reach Industrial Estate, Billingham, Teesside,
England, UK.
3. WHAT IS
THE LIKELY
DEMAND FOR
SUCH FACILITIES
AND WHAT
WOULD BE
THE LIKELY
ECONOMIC AND
ENVIRONMENTAL IMPACTS
OF MEETING
SUCH A
DEMAND?
ABLE response:
There is large demand for ship recycling in
the world. The majority of ships are demolished in Asia because
it is more economic for the ship-owners to do so for the following
reasons:
Demand
3.1 TERRC is the only facility in Europe
than can receive the larger ships for recycling.
3.2 There is no facility, other than the
TERRC facility in Hartlepool within in the UK that can recycle
ships in the correct manner with regards to health and safety
and protection of the environment.
3.3 The ship recycling market is a certain
growth market. At the end of the decade (2010) some 4,000 ships
with an aggregate gross tonnage of 24 million should be recycled
every year.
3.4 In 1999, 93% of ship breaking tonnage
was carried out in non-OECD countries. An increase in the number
and tonnage of vessels requiring scrapping is predicted over a
15-year timescale from 2001-15 (CEC 2001). The predicted average
annual scrap volumes for the European merchant ship fleet are:
— 0.86-1.48 million tonnes steel.
Economic impacts UK
3.5 ABLE could have produced circa £35
million per year to the Teesside economy if the works had not
been stopped.
3.6 ABLE could have produced circa £70
million per year to the UK economy if the works had not been stopped.
3.7 Potential of around 1,000 direct new
permanent jobs for at least the next 10 years.
3.8 Potential for a large number of other
indirect new permanent jobs for at least the next 20 years.
3.9 Major source of raw materials—ABLE
would have provided around 300,000 tonnes of recycled raw material
(scrap) if the works had not been stopped.
3.10 It is forecast that by 2010 the value
of ship recycling will be in the region of £3.5 billion per
year.
Environmental impacts
3.11 One ship breaking company in Asia advertised
the benefits of the tide cleaning their facility on a daily basis
(by washing all wastes to sea).
Asian Competition
3.12 In Asia there are taxes that assist
the industry.
3.13 Asian Local Regional Government Departments
encourage the ship disposal operations.
3.14 The majority of the worlds ship breaking
is undertaken by ramming the ships up beaches (no costs for facility
development).
3.15 The Asian ship breaking companies sell
the Asbestos on the street markets or strip it and dispose of
it whilst the ship is in transit to the beach, Asbestos and other
wastes therefore a credit to the works. We dispose of such hazardous
materials under UK Legislation at a significant cost to a licensed
facility. Greenpeace have monitored the Asbestos contamination
of ship breaking workers, workers houses, ship breaking local
community markets and mosques and found extremely high levels
of blue, brown and white Asbestos present and presents risks.
3.16 The Asian requirements for health and
safety of the public and the workforce together with their requirements
for environmental protection are of a very poor standard.
3.17 The Asian ship breaking companies sell
the materials contaminated with PCBs for reuse. We dispose of
such hazardous materials at a significant cost to a licensed facility.
3.18 The works are undertaken with virtually
no protection to the workers (no costs for personnel protection
equipment).
3.19 We understand that processed scrap
imported into Asia is taxed but ships for breaking are not.
4. WHAT IS
THE LEGAL
STATUS OF
IMPORTING SUCH
VESSELS FOR
DISMANTLING (THE
COMMITTEE WILL
PARTICULARLY SEEK
TO CLARIFY
WHAT ARE
THE IMPLICATIONS
FOR THE
INDUSTRY OF
THE STOCKHOLM
CONVENTION ON
PERSISTENT ORGANIC
POLLUTANTS?
ABLE response:
4.1 The Stockholm Convention states in Article
3 para 1(a)(ii) that "each party shall prohibit and/or take
the legal and administrative measures necessary to eliminate its
import and export of the chemicals listed in Annex A in accordance
with the provisions of paragraph 2".
4.2 Para 2(a)(i) states that "each
party shall take measures to ensure for the purpose of environmentally
sound disposal as set forth in paragraph 1(d) of Article 6".
4.3 The Stockholm Convention states in Article
6 para 1(d)(iv) that we must "take appropriate measures so
that such wastes, including products and articles upon becoming
waste are: Not transported across international boundaries without
taking into account relevant international rules, standards and
guideline".
4.4 The UK Government needs to clarify how
they intend to transpose the articles within the convention, after
taking fully into account the implications for future business.
4.5 It would be assistance to ABLE if the
Government would confirm what the measures (referred to above)
will be and that under the Convention the import of the vessels
and marine structures will meet para 2(a)(i) of Article 3 and
therefore be permitted for importation into the UK. The Government
should also clarify to what degree the importing company needs
to take into account the relevant rules, standards and guidelines
and what impact, if any, do these standards have on the importation
of vessels and marine structures for recovery.
4.6 A problem which we would appreciate
if the Committee could consider is that when such new EC legislation
has to be transposed to UK Legislation, there does not appear
to be sufficient research in the relevant industries to understand
the potential consequences. As an example, it is quite possible
that when Legislation comes into force for the POPs, that the
personnel concerned in considering it will have meetings and discussions
with companies that may be involved in the manufacturing and use
of this product, however, these persons are not aware of the consequences
it may have on, say for instance, importing marine structures
and ships for decommissioning.
4.7 We therefore suggest that there should
be improvement in the consultation period at this stage.
4.8 An example of this is on the ban of
the importation of Asbestos. This was obviously decided with the
objective of Asbestos materials being brought into the country
either to be used to produce new construction materials or to
be part of construction materials imported (ie Asbestos cement
sheets etc). However, at the time it is our opinion that nobody
considered the potential of, for instance, importing marine structures
or ships for decommissioning. The current situation, as in the
case with the MARAD Contract, is that we have had to apply to
the Government to obtain an Exemption Certificate to import the
Asbestos on these ships.
4.9 However, other ships can come into the
UK, go into Port, have repairs carried out and the Asbestos can
be removed and disposed of into licensed facilities in the UK
but outwith these Regulations.
5. HOW DEFUNCT
UNITED KINGDOM
VESSELS ARE
CURRENTLY DEALT
WITH AND
WHAT PLANS
HAVE BEEN
MADE TO
COPE WITH
THEIR DISPOSAL?
ABLE response:
Occasionally small defunct UK vessels are demolished
in the UK at facilities, which, we understand, do not have Waste
Management Licences or planning permission to carry out the works.
The work is undertaken in ways that do not provide the BPEO. In
particular, existing practices appear to be mainly using river
banks or slipways with protective barriers.
To our knowledge there have been no plans made
by the authorities to cope with the disposal of any redundant
vessels.
6. OTHER RELEVANT
INFORMATION
6.1 The methods used by ABLE for recycling
ships at TERRC provide a positive benefit to the environment.
6.2 The only other method of ship disposal
is to sink them, however, this provides a negative balance to
the environment.
6.3 The BPEO is achieved if the remediation
and decommissioning are completed at the same location.
6.4 It is not possible to remove all hazardous
waste materials from the ships and then deliver them to a different
recycling facility.
6.5 It is safer to undertake the remediation
and decommissioning works at the same location.
6.6 Attached is a document with extracts
from web sites with information[10]
6.7 Attached is a copy of a study carried
out in Asia by Greenpeace[11]
6.8 Please note that I am willing to appear
at the inquiry if required.
Able UK Ltd
May 2004
10 Not printed. Back
11
http://www.greenpeaceweb.org/shipbreak/shipsforscrap3.pdf.= Back
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