ISRA Network

News item no.12 April 2019 On the 22th of April Tradewinds published an interview with Mr. Kamil Onal, President of the Ship Recyclers Association of Turkey and the General-Director of the Executive Board of Avsar Yard. Avsar is a senior member of ISRA. In this interview Kamil illustrates the high level of ship recycling and refers to the high standards of the EU-list. ISRA is proud to present to you this interview in Tradewinds. Kamil Onal is president of the Ship Recyclers’ Association of Turkey Photo: Ship Recyclers’ Association of Turkey Compliance with game-changing EU regulation gives the nation’s facilities an opportunity to show what they can do on the world stage April 22nd, 2019 13:13 GMT by Kamil Onal The entry into force of the European Union Ship Recycling Regulation (EU SRR) on 31 December 2018 was a game changer, not so much for its increased technical requirements with regards to yard compliance, but for its provisions requiring facilities outside the EU to undergo a rigorous assessment and onsite audit by the European Commission. It also became the first international regulation to ensure a level playing field among ship­ recycling yards anywhere in the world. Turkish yards seized the opportunity to demonstrate that their operations go beyond the requirements of the IMO’s Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention) - whose remit stops at the gate of the yard. They are also showcasing that waste management in Turkey is in compliance with EU environmental rules all the way to the final downstream waste processing and disposal. This was one of the most critical elements verified by EC auditors last year when they gave the green light for the first two Turkish facilities of the Leyal Ship Recycling Group to go on the EU's approved list of yards under the EU SRR. Ship recycling at Aliaga, Turkey Photo: Ship Recyclers’ Association of Turkey At least six more yards have gone through or are now undergoing inspection. These eight companies form the backbone of Turkish ship recycling, with a proven annual capacity in excess of 500,000 ldt, in effect doubling the EU list’s capacity when their inclusion is completed this year. More facilities are now asking the Ship Recyclers’ Association of Turkey about the process and requirements for applying to be included on the list. Turkey, with a proven ship recycling capacity in excess of one million ldt per year, offers a big part of the solution to the capacity issue of the EU list. It is a matter not only of ldt, but also of the size and type of ships that yards can handle. Our members have recycled all types of ships, from typical bulkers, tankers and containerships to larger floating storage and offloading units, floating production, storage and offloading vessels, drill ships, drill rigs and even aircraft carriers, up to 50,000 ldt in the case of an FPSO converted from a VLCC. "Turkey, with a proven ship recycling capacity in excess of one million ldt per year, offers a big part of the solution to the capacity issue of the EU list" It is, therefore, no coincidence that in recent years, Turkey’s role as a leading green ship recycling destination has been recognized by oil and gas and offshore service companies such as Shell, Chevron, ENI, Transocean, SBM, Saipem, Technip, Subsea 7 and Schlumberger, as well as shipping giants AP Moller-Maersk, CMA CGM, Hapag-Lloyd, CSL, MOL, NYK, K Line, Royal Boskalis and many others that no longer accept the unsafe, environmentally damaging disposal of vessels. And with Turkey having been an EU accession country since the early 2000s, our authorities have already almost completed compliance with EU environmental rules, having transposed more than 200 pieces of EU environmental legislation into national law, including Europe’s main waste management legislation, the Waste Framework Directive. The Turkish regulation on waste management entered into force in April 2015. This regulation has been based on European legal texts, aiming for synchronisation of Turkish law with the EU acquis.

Best of both worlds

In January this year, Turkey also became the first major ship recycling nation to ratify the Hong Kong Convention, demonstrating that its focus is not only Europe but a global regime of safe and environmentally sound ship recycling. This can be achieved only by taking the best of both worlds, namely the elevated requirements and uniform auditing mechanism of the EU SRR, coupled with the global reach of the Hong Kong Convention. In this modern world of green ship recycling, Turkey is already the leader on the ground and with respect to regulations, building on a paradigm shift in our attitude to health, safety and the environment. Kamil Onal is president of the Ship Recyclers’ Association of Turkey              

News item no. 10 April 2019 ISIKSAN on the EU-list   ISRA congratulates its member ISIKSAN with a place on the EU-list for sound and safe ship recycling. It is the third yard from Turkey that gets a place on the list. It is important to know that a place on the EU-list means that the yard complies with strict safety and environmental criteria which are stricter than those of the Hong Kong Convention. With their place on the EU-list, ISIKSAN rigs (under the EU-flag) can be recycled at this yard in Turkey. There are 25 pending applications for the EU-list: (6 from Turkey, 14 from India, 4 from China and 1 from USA.)

News item 9 April 2019 Global Maritime Summit 2-5 April 2019 Turkey Together with Soner Sari from ISIKSAN Ship Recycling in Turkey, the Director of ISRA Reinoud Pijpers, held a presentation at this summit. Soner Sari giving his presentation Mr Sari showed the audience what sound and safe recycling means in the daily practice on his ship recycling yard. He elaborated in depth on the process of ship recycling. ISIKSAN has one of the largest dismantling areas of 35.000 square yards and double partial long beach in the Aliaga Breaking District. They have a high breaking capacity of 120.000 tons of steel annually. He elaborated a number of policy goals, amongst them:

• Preventing pollution and incidents in all their activities.
• Maintaining a Ship Recycling Management System which is environment-friendly, following Safety Standards, supported by top management, which is adopted and carried out, supervised, reviewed by all employees, constantly improved and is open to public.
• Minimising non-sustainable energy and sources consumption by efficient input controls.
• Implying methods and systems to ensure an efficient Waste Management and minimising contamination by separating waste on their source.
• Monitoring the performance of our activities constantly, to reduce the harm given to the environment to a minimum, to provide safe working environment, to protect the welfare of employees and to prevent accidents.
• Taking precautions to prevent work accidents and occupational diseases, to support workers with trainings.

Reinoud Pijpers giving his presentation                                                                     Reinoud Pijpers (Director ISRA) explained to the audience that Turkey is an important ship recycling state. He congratulated Turkey with the ratification of the Hong Kong Convention. He stipulated the active role of Turkey in the past by preparing international regulation. He referred to the fact that various Turkeys yards were involved in the founding of ISRA and that the chairmanship of this organization is yet in the hands of Adem Simsek. Mr Pijpers referred to the place of Turkeys yards on the EU-list. (ISIKSAN is now the third). There are 6 applications from Turkey pending for the EU-list.          

News item no 8, March 2019 TradeWinds event Hong Kong On the 5^thand 6^thof March 2019, TradeWinds organized the Ship Recycling Forum in Hong Kong. Instead of numerous presentations, this conference gave much attention to panel discussions. Compared with conferences in the past, this meeting was noticeably less outspoken and the traditional separation between the representatives of the Indian subcontinent and responsible ship recyclers was absent. The application for the EU-list might be causing this effect. Peter Koller from the European Commission stated that there were 25 applications pending; 6 from Turkey, 14 from India, 4 from China and 1 from the USA. He indicated that Turkey and India will very soon make additional applications.             Peter Koller EC A very interesting contribution was made by Chris Calvert. He showed the pathway of the recycling of (warship) HMNZS Endeavour under the Basel Convention. This warship was recycled at an Indian yard. During lunch break Director ISRA was approached by parties who had accompanied this unusual practice. They argued that from the side of ISRA not one recycling yard had reacted on the tender. ISRA will contact Mr. Calvert to see what has happened. (Do not hesitate to email to me if you have information on this subject: Reinoud.pijpers@isranetwork.com).                 Dimitri Ayvatoglu Dimitri Ayvatoglu from Leyal Recycling facilities in Turkey proudly announced that his yard was the first to recycle a vessel under the new EU legislation. He further showed some developments in the recent past: Norwegian pension funds drop investments due to poor recycling practices, an increasing number of banks starting to embrace RSRS and the convictions based on penal law in the Netherlands. Tom Peter Blankestijn (R) as moderator Tom Peter Blankestijn (Sea2Cradle) pointed out the situation in China. Though the ban on end of life ships not flying the Chinese flag remained, China should consider the fact that a great number of ships are being produced in China. That should have implications for the responsibility of the Chinese government. The developments in China will be closely followed by ISRA.  

News item no 7, March 2019 ECSA published strategy document for 2019-2024 The ECSA published the “Strategic priorities for EU-shipping policy 2019-2024” In this document ECSA refers to a changing world driven by challenges such as climate change, social questions, barriers to free trade and security concerns. ECSA elaborates in this document on the need for free and open international shipping markets, maintaining competitiveness through existing guidelines on state aid, calling for global rules to avoid reducing competiveness, innovation and digitalization, the completion of the internal market for (shortsea) shipping and building and maintaining the successes of the Shipping Social Sector Dialogue. ISRA regrets that the ECSA does not address sound and safe ship recycling as one of the key elements in the sustainable shipping industry. No reference whatsoever is made in this field. ISRA is of the opinion that sound and safe recycling should be an integral part of the sustainability policies of ECSA and the individual ship-owners.  

News item no. 6 February 2019 ACI congress ACI conference on Ship Recycling 30– 31 January 2019, Amsterdam ISRA was well represented at this conference in Amsterdam. Tom Peter Blankestijn (Sea2Cradle, associated ISRA member) held a very clear and instructive presentation regarding the similarities and differences between HKC and the EU SRR: HKC aiming at the structure, EU-SRR not only the structure but also the operation. He elaborated further more the process of getting EU verified and listed. Tom Peter got further into detail concerning the relationship with China since their ban on imports of end of life ships. He showed the new political reality of the just renamed ministry of Ecology and Environment. Tom Peter mentioned that there are signals indicating a possible rethinking of this matter in China. Peter Wyntin (Galloo Ghent) answered the question of an alleged shortage of capacity. Based on IHS-figures he easily could demonstrate that in the past the amount of surplus recycling capacity was enormous, considering the little amount of supply of end of life ships. Peter also stressed that the EU and NGO came with the same figures. Peter underlined the fact, that also with the new EU-regulation, capacity is no problem. He mentioned furthermore that health, safety and environmental standards must not be seen as fixed, but could and should be subject of new legislation. He gave as example the lost time injury frequency rate considering accidents at work, carbon footprint reducing oil and fuels and maximization of using renewable industry. Of course, Peter mentioned the necessity of enforcement of the rules, by national governments and the EC. ISRA members invest heavily in safe and sound recycling. By enforcement of the regulations the authorities have to play their active role. Dimitri Ayvatoglu (Leyal Ship Recycling group Turkey) had a presentation on changing the mode of contracts. In his presentation, he pointed out the various relationships with templates of contracts and “layers” to complete the contract commercially. Reinoud Pijpers (director ISRA) introduced himself as the new director of ISRA. In his presentation, he treated the role of ISRA in the past, the present and the future. ISRA started mainly as a policy formulating organization, delivering bricks for the HKC and the EU-SRR. Nowadays emphasis is put on the enforcement. Reinoud mentioned the actions of ISRA which were and are taken in this field. He also referred to the excellent contacts with the EC. Through these contacts ISRA can carry out influence, for instance in the China case. Reinoud called up to become an ISRA (associate) member illustrating that this membership is a clear signal that the company concerned is taken sound and save ship recycling seriously.

News item no. 5, February 2019 The Netherlands ratifies Hong Kong Convention   The ratification of the Netherlands by the Hong Kong Convention is scheduled next Wednesday, 20 February 2019. Then, on behalf of the Kingdom of the Netherlands, the Netherlands will hand over the official deed of acceptance of the Hong Kong Convention to the Secretary-General of the IMO.The Netherlands is then the 8^th* country that ratifies the Hong Kong Convention. *Countries that have ratified the HKC: Belgium, Congo, Denmark, France, Norway, Turkey and Panama.

News item no. 4, February 2019 Director ISRA visits Turkish yards  A vessel landing Reinoud Pijpers visited (the first week of February 2019) the yards of a number of (new) ISRA members. Reinoud had the excellent opportunity not only to visit the various yards but also to have an exchange of views with several yard owners. The yards concerned: Avsar, Isiksan, Leyal, Leyal Demtas, Simsekler, SOK and Temurtaslar are all on the same spot. The method of recycling is landing. After the main parts of the ship are removed, the ship is pulled ashore for further demolition. Of course, the ships are in that phase demolished at a concrete floor and a drainage system prevents (oil) spills running into water. The downstream waste is carried out jointly, by all the yards concerned. The Ship Recycling Association Turkey, SRAT, situated close to the premises of the yards plays an active role in the waste management of the downstream of waste. ISRA had also the possibility to exchange views with the SRAT. Membership of ISRA is highly appreciated by the newly appointed chairman of the SRAT. During my visit the good news was received that Turkey had ratified the Hong Kong Convention (HKC). Though the government had one condition: a ship recycling plan should be presented for approval to the Turkeys authority. With this condition, the Turkeys authorities will stay to play an important role on the enforcement of the HKC. It was not clear whether this role will also be applicable for the EU-listed yards. During the various talks it was clear that being on the EU-list is very important.  Membership of ISRA lies in the same line. The Turkish yards concerned see ISRA as an organization that represents the (Turkish)-ship recycling yards very well on a global scale.  

News item 3, February 2019 Secretary General ISRA, Bernard Veldhoven, was invited by the European Commission (EC) on 1 February to attend an expert meeting with the EC and the member states. ECSA and NGO-platform were also invited. One of the reasons for the EC to organize this meeting was to facilitate member states to a direct exchange of views concerning the entry of force of the new EU Ship Recycling Regulation. One of the main issues related to his new regulation, is the capacity needed and the capacity available. ECSA published figures concerning this field. The EC, NGO and ISRA thoroughly scrutinized the capacity issue and shared the conclusion that the needed capacity for ship recycling at EU-(listed) yards was more than sufficient. ISRA emphasized during the meeting that the EU ship recycling yards are keen to receive (EU-flagged) ships in order to fill the under capacity. ISRA also pointed out that requests for quotations are up till now minimal and sometimes fake which makes it difficult for the EU-yards to treat them seriously. ISRA made its position very clear to the member states that only high standard yards should be listed as its members are. ECSA repeatedly maintained that HKC is the only (global) solution, implicitly stating that without this global instrument, ship owners are confronted with a non-level playing field forcing them to choose for the beaches. Some member states were very surprised ECSA did not openly support during the meeting the efforts done by the EC and the MS. ECSA also had difficulty denying that India, as soon as the HKC gets into force, will make all Indian yards “HKC-compliant” in order to protect its own substandard industry. NGO shipbreaking made it very clear that the supposed positive effects of the ship recycling industry for Bangladesh are very disputable since only 18000 workers on a total population of 140 million people might have any advantage, if any, given the regular and on-going casualties. Furthermore, only a small part of steel is used, since the quality is so bad that it is not fit to be used for important structures.          

News item No. 2  January 2019 Visit European Commissioner Vella, Galloo Ghent On January the 8^th, an EU delegation led by EU Commissioner Karmenu Vella, responsible for Environment, Maritime Affairs and Fisheries, visited the Galloo yard in Ghent. Mr Vella was guided through the yard by Director of the yard Peter Wyntin. Peter Wyntin showed him the various measures that have been taken to enable sound and safe recycling. He explained him that only through huge and costly investments these facilities can operate in a responsible way. He referred to the illegal exports of end of life ships from the EU(flag) and stated that those exports harm the competition position of responsible yards severely. After the visit, Mr. Vella was informed about the figures of the Galloo yard. Secretary General lSRA Bernard Veldhoven and Director Reinoud Pijpers used this opportunity to thank him personally for the progress made on the EU- list. They emphasized that the EU Regulation and its Technical Requirements are good instruments for the accession on the list. They underlined a correct application of the requirements. Mr Vella stressed the need for ISRA to expand their members, so that ISRA represents a broad basis for sound and safe ship recycling. In his press statement afterwards, Mr Vella was very clear: “For too long, EU vessels have been dismantled in poor environmental and social conditions. This is not acceptable any longer. The full entry into force of the EU Regulation on ship recycling is a milestone for this sector, as it provides for the first time clear and specific rules on how EU-flagged vessels should be recycled. Like other recycling activities, ship recycling can be carried out sustainably, in a way which is good for workers, the environment and the economy. This is what is happening at the Ghent ship recycling yard and this is what the EU aims at. We count on all actors in the sector to work constructively with us to make it happen”.