ISRA Network

News item no. 9, December 2020 Unofficial translation Source: Website of the Human Environment and Transport Inspectorate (ILT), Netherlands   Quote: “The Human Environment and Transport Inspectorate (ILT) intervenes in the illegal transport of drilling platforms and the demolition of ships News release | 10-12-2020 | 09:05 Two drilling platforms that were transported to the port of Vlissingen earlier this year have to be returned to their country of origin, the United Kingdom. This is stated by the Human Environment and Transport Inspectorate (ILT) because the transport has been in conflict with the rules of the EU regulation for the shipment of waste (WSR). The platforms contain hazardous (waste) materials and have been moved without a WSR permit. The platforms have already been partially demolished in Vlissingen at a company that does not have the appropriate permits. The intention was to then move the platforms to Turkey for further demolition there. The WSR prescribes that waste materials that have been illegally shipped must be returned to the country of export. The first platform has now been returned to England with the permission of the English environmental authorities. Enforcement action is taken against all parties involved (transport and dismantling).  End of life ships Earlier this year (October), the ILT also took action and made an official report against the illegal export of two container ships to India. This export is presumably in violation of the ban on sending dangerous substances from Europe to non-OECD countries. The ships belonged to an Icelandic shipping company and are believed to have been decommissioned against the rules as scrap ships in India.  Criminal law At the end of 2019, the Icelandic shipowner sold both container ships, with the agreement that the buyer would charter the ships until the Icelandic shipowner could renew its fleet with new ships. One of the obsolete ships was subsequently brought to India via the port of Rotterdam. Because the ships were transported via the Netherlands, it was possible for the Netherlands to ask Iceland to perform. The Functional Public Prosecutor's Office has asked the Icelandic Public Prosecution Service to prosecute the Icelandic company. Damage to people and the environment The ILT wants to prevent seagoing vessels and offshore installations from being scrapped on the beaches of, for example, India, Pakistan, Bangladesh and / or Turkey. This results in unacceptable damage to people and the environment, because hazardous substances that are released during demolition must be properly processed. The ILT wants to prevent waste from being dumped in (non-OECD) countries with a vulnerable processing and supervision culture.” Unquote

The European Commission (EC) arranged a meeting on 26 November 2020 between the EC, the Member States and representatives of three NGO’s: ECSA, NGO Ship Breaking and ISRA. This was the fourth time the EC arranged such a possibility to exchange views. NGO Ship breaking (NGO SB) had two extensive interventions: clear and unambiguous figures about the amount of end of life vessels being illegal exported and for a major part beached. The other presentation of NGO SB concerned the export of  EU-flagged end of life vessels to EU-listed facilities. NGO SB pointed out that this conflicts with the Basel Ban, where exports of waste to Non-OECD countries is prohibited. Since end of life ships are defined of waste, exports are not allowed. ECSA referred to the possibilities for Indian recycling yards to get a place on EU-list of ship recycling facilities. ECSA emphasized the need for these facilities and repeatedly underlined the fact that the applicants concerned had found a way to deal with the intertidal zones. ECSA stated that downstream waste management and hospitals are elements that are not controlled directly by the applicants, but the applicants have to experience the negative impact in the process of application. ISRA, Board Member, illustrated with convincing figures that the present EU SRR is in practice not working properly. He made clear that a number of Member States do not act in conformity with the EU SRR. He referred letter of ISRA sent to Commissioner Sinkevicius, calling up to take action and to address a number of Member States to commence with a serious enforcement policy and to letters to some Member States which obviously ignore (partial) the EU SRR. The Head of the Waste department of the EC, Mr. M. Pelligrini welcomed the way the convincing figures were presented. He was very clear that these data and the open communication about these figures, can lead to targeted policy actions, either to be taken by the EC or the Member States involved. In this context, it was made clear that some Member States had received information from the EC concerning the enforcement of the existing EU SRR. The EC called upon and exchange of views between the ISRA and ECSA and also advised to talk with producers of steel (through electro furnaces) in the EC.    

Letters to the European Commissioner and some Member States ISRA repeatedly expressed its support to the policies of the European Commission on sound and safe ship recycling. This policy has led to an adequate regulatory frame work: together with the European Waste Shipment Regulation (EU WSR 1013/2006), the EU Ship Recycling Regulation (EU SRR 1257/2013); including the adjoining Technical Requirements (TR) and the Basel Convention, a clear judicial base is offered directing companies and Member States how to act when ships  are destined for dismantling. The majority of EU owned end of life ships –notwithstanding this framework– find their final destination on the beaches of South East Asia which is strictly forbidden. The shipping sector, like others, is significantly affected by the decreasing worldwide economic activities. In the case of COVID-19, a sudden and unprecedented disruption of shipping activities has caused some ship-owners to prematurely decide to end the economic life of their vessel(s), leading to a substantial increase of ships to be recycled. Although some shipowners take their responsibility now and send their EU-flagged vessels to EU approved ship recycling facilities, a far bigger number of shipowners find a way to evade the restrictive laws and end up with their ships on a beach. In numerous occasions ISRA emphasized the importance of enforcement as an essential component of the legal framework (EU-SRR and EU- WSR) and the important role Member States have to fulfill in this respect. The current situation, amplified by the specific economic circumstances at this moment, requires a firm answer preventing workers and environment paying the bill on the beaches of South East Asia. ISRA has called in various letters upon the Commissioner and a number of Member States to see that the important issue of enforcement is carried out properly.

Statement of the Chairman of the International Ship Recycling Association, Dr. Konstantinos Galanis All the members of the International Ship Recycling Association (ISRA) are pleased to learn that the European Commission has adopted the latest edition of the EU List of ship recycling facilities. The inclusion of additional facilities is another major milestone for safe and environmentally sound ship recycling according to the highest standards. The continuous increase of capacity that the EU listed facilities are offering is a proof that the implementation of investments, efforts and resources can be successful. Nevertheless, this can only be achieved if a ship recycling facility is concerned, committed and dedicated to the needful and strict technical requirements, rules and regulations that lead to the proper recycling for end-of-life ships.

News item no. 6,  October 2020   Ship Recycling Webinar Week organized by Riviera Maritime Limited Riviera organized three webinars in September on various aspects of ship recycling. The first session was strongly related with the (results) of the Ship Recycling Transparency Initiative (SRTI), primarily aimed at collecting and disseminating date on ship recycling. (SRTI organized three seminars over the past months, which were attended by board member ISRA, Dimitri Ayvatoglu and Director Reinoud Pijpers). During the second session of the Riviera Webinar, reconciling the Hong Kong Convention and the European push for regulation. Mr. Nikolas Panagakis (owner of Nick Environmental Services) held a strong argument against beaching practices. Dr Peter Glover (partner), with a strong judicial approach, gave a broad overview of the various aspects and steps of the IMO and the EU SRR. Although he emphasized the steps that were taken in the right direction, he concluded that beaching was still the major ship recycling method. He questioned the disappearance of this method. Reinoud Pijpers (ISRA)  concluded that the HKC is undeniable a good step in the right direction, but that the clear and unambiguous, independent of the country concerned,  EU regulation gives a better regime. He argued that shipowners promoting their business as sustainable should also apply this to the end of life situation of their fleet. Director ISRA also attended a webinar organized by Metalogic PMS, Steel Scrap Recycling Processes. During this webinar a lot of attention was given to the various aspects of scrap in general, with the common denominator that India has a shortage of scrap of around 6 mln-7 mln ton per year. ISRA made clear that the EU list for ship recycling facilities represented high global standards enabling individual yards to compete on an equal level of competition. European Commission ISRA will participate in a meeting in November, to be organized by the EU, in the presence of the Member States. Enforcement of the EU regulation will be one of the topics, in any case to be addressed by ISRA.

We would like to inform you about the upcoming ship recycling webinar week, starting on 15 September 2020. Follow the link for more information and to register. https://www.rivieramm.com/events/events/ship-recycling-webinar-week  

In memory of Tom Peter Blankestijn 25 October 1960 - 12 August 2019

Your presence we miss Your memory we treasure Gone but not forgotten

News item no. 5, July 2020 Press release ISRA COVID-19 / EU List capacity ISRA issued a press release on 24 July 2020 regarding the consequences of COVID-19: “The outbreak of COVID-19 has a tremendous global impact including the maritime industry. Nevertheless, the capacity of the European List of ship recycling facilities is still sufficient to satisfy the rising supply of end-of-life ships that will be recycled. Want to read more? www.isranetwork.com BREXIT Ship recycling Great Britain and Northern Ireland The European Commission published in June 2020 a notice to the stakeholders concerning the consequences of the Brexit for the sector in the UK and Northern Ireland. You are advised to open link below “WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF SHIP RECYCLING” https://ec.europa.eu/environment/waste/ships/pdf/Notice%20to%20stakeholders_brexit_ship%20recycling_REV1_FINAL.pdf EU-India summit 15th July 2020 On 13 March 2020 a summit was foreseen between the European Commission (EC) and India. Ship recycling was one of the items at the agenda. A number of Indian ship recycling facilities have applied to be included in the European list of ship recycling facilities. ISRA supports and welcomes these developments, since a place on the list means compliance with strict European Ship Recycling Regulation (EU-SRR) and its additional Technical Requirements (TR). Prior to this summit, ISRA wrote a letter (5 March 2020) to the Commissioner responsible for Environment and the Commissioner responsible for Trade. In this letter ISRA explicitly supports the EC: “We are very pleased to see that in the recent past, the Commission successfully adhered this basic rule (…) i.e. decisions for inclusion in the European List of ship recycling facilities should be made without any political interference or considerations”. The summit took place on 15 July 2020 under COVID-19 screen- conditions. It is not clear whether ship recycling was discussed explicitly. A joint declaration* on resources, efficiency and circular economy was adopted: ”(….) strategic exchanges on best practices and available technologies (…) and cooperation on ship recycling”. ISRA will actively observe the EU-listing procedure. *EU-INDIA JOINT DECLARATION ON RESOURCE EFFICIENCY AND CIRCULAR ECONOMY, 15 July 2020 SRTI The Ship Recycling Transparency Initiative organized three seminars over the past months, which were attended by ISRA board member Dimitri Davutoglu and Director Reinoud Pijpers. For ISRA this gremium provides a possibility to exchange views openly on various subjects. The Chatham House Rule is applicable leaving the possibility for participants to speak freely. 25 signatories had joined these webinar meetings amongst them: shipowners, financial institutions and NGO’s. With the three seminars, (three more foreseen) a broad inventory was made on three subjects: Data and Transparency, Circular economy and the Role of financial stakeholders. A final conclusion cannot be drawn perhaps other than that this kind of meetings present an overview of relevant data and enables a free discussion on various aspects of ship recycling. ISRA will also attend the coming meetings.

PRESS RELEASE International Ship Recycling Association (ISRA) concerning the impact of COVID-19 on the capacity of the European List of ship recycling facilities: July 24, 2020 – The International Ship Recycling Association (ISRA) concludes that  the present capacity of the European List of ship recycling facilities is sufficient to deal with the increased supply of (EU-flagged)- ships to be recycled. Shipowners will find ample capacity to the EU List, which will be extended in due time. A resurgence of COVID-19 could lead to a further reduction of economic activity, which possibly will affect the number of ships to be recycled. “The outbreak of COVID-19 has a tremendous global impact including the maritime industry. Nevertheless, the capacity of the European List of ship recycling facilities is still sufficient to satisfy the rising supply of end-of-life ships that will be recycled”.

1. It is well known that COVID-19 has an enormous impact on the economies worldwide. IMF’s recent publications and other reports show a steep fall in the world economic activity. Predictions regarding the short-term economic developments are very uncertain and pessimistic: an immediate recovery in foreseeable time is not likely to happen.  It is therefore important to keep in mind that this is a one-in-a-lifetime event and that systems that are in place to regulate day-to-day human activities may not be (and rightfully so) designed to address such a black swan event (e.g. the health/hospital system around the world).

 

2. Shipping contributes substantially to economic growth. Also a sector, amongst others, that is significantly affected by the decreasing worldwide economic activities. In the case of COVID-19, a sudden and unprecedented disruption of shipping activities has caused some ship-owners to prematurely decide to end the economic life of their vessel(s).

 

3. International Ship Recycling Association (ISRA) promotes the sound and safe recycling of ships. It is an association acting on a global level. Ship recycling facilities which are members of ISRA operate in alignment with its high standards preventing the adverse impact of ship recycling on the environment and safety of the workers.

 

4. EU List of ship recycling facilities. ISRA welcomed the entry into force of the EU Ship Recycling Regulation (EU-SRR) in 2019, recognizing that with this Regulation high standards are ensured. Besides this, EU-SRR also enables the European Commission (EC) to approve ship recycling facilities, that are outside the European Union (EU). Ship-owners with vessels that fly an EU flag are required to recycle their ships only at an EU List approved ship recycling facility.

 

5. Capacity of facilities in the EU List: no shortage with the present supply of EU-flagged ships to be recycled, the capacity of the EU List is at this moment capable to handle the current flow, though there are regional differences. Turkey’s EU-listed facilities are using their full capacity to accommodate the increased ship-owner’s supply. Other EU-listed facilities have sufficient unused capacity (also for larger vessels). The general picture still shows overcapacity on ship recycling facilities on the EU List.

It cannot however be excluded that this capacity may be utilized at a certain moment if the current abnormal level of the supply of end of life ships to be recycled continues until the end of the year due to a possible second wave /resurgence of COVID19, leading to further global economic stain. However, such a scenario should not be considered as a failure of the EU-SRR but rather as one of many logical side effects of such a unique global situation that is negatively affecting so many aspects of everyone’s private and business life.    

Covid-19 An inventory amongst the ISRA-members shows that our members find themselves in a more or less status quo-situation compared to the previous Covid-19 update from ISRA. Some of the restrictions imposed by governmental authorities, could perhaps in theory allow -on the site- a type of ”business as usual” model, the practice, however, shows that continuation is cumbersome because of restrictions on flights (applicable to the crew) and sailing. So, until now the ship recycling activities are still considered at a low level for the ISRA-members. Market predictions The views on the market outlook are similar among the members. From the supply side of vessels, there is an increase, but not yet on a concrete level, meaning that suppliers (ship-owners) are making their rounds without further tangible results. The supply of cruise ships is an exemption at this point, where it appears that those are likely to come to more specific negotiations in due time. Ship Recycling Transparency Initiative (SRTI) SRTI aims to accelerate a voluntary market-driven approach to responsible ship recycling practices through transparency and subsequently to influence and improve decision-making about ship recycling, creating an industry-wide level playing field. Following the postponement of the SRTI in-person foreseen at the roundtable event (initially scheduled for March 2020), the SRTI community organized a series of themed webinars between April and June 2020. Each webinar covers a theme of relevance to the SRTI's vision and responsible ship recycling: data and transparency, circular economy, and the role of financial stakeholders. The main purpose of the SRTI is to reflect on what kind of data could be disclosed and from which source(s), exploring how such data points could contribute to the SRTI’s mission to accelerate a voluntary market-driven approach to ship recycling through transparency. Like in the physical meeting, the Chatham House Rules are applied. ISRA has always participated. The first webinar, held on the 30th of April 2020 Feedback on the current SRTI disclosure criteria: participants were invited to provide feedback on the current SRTI disclosure criteria, consisting of six overarching sections: (1) Overall approach, (2) Ship recycling policy and standards, (3) Policy for selling owned vessels for further trading, (4) Ship recycling contract, (5) Inventory of Hazardous Materials (IHM) and Ship Recycling Documentation, and (6) Implementation of ship recycling policy and standard. Along the lines of a previously sent inquiry various subjects were treated. The outcome could be summarized as follows: it was obvious that international regulations play an important role in the field of ship recycling. Not only a prominent role for the EU-SRR and HKC but also reference was made to other international agreements, like ILO-instruments. On the question of the SRTI expanding to include data from ship recycling facilities, some stakeholders believe that developing a separate section for SRFS – and possibly also for cash buyers – with their own separate set of disclosure criteria is a logical next step for the SRTI. It was commented that the SRTI must exercise caution to avoid conferring a level of undue credibility to SRFs which could be potentially used by unscrupulous SRFS (and shipowners). For an adequate implementation of ship recycling policy and standard, the addition of the following information was proposed: Disclosure of actions taken to address any issues reported in environmental monitoring reports, disclosure of data on safety-related issues including near misses and actions taken to address any issues to avoid recurrence and injuries in the future. The next webinar to be held on the 28th of May will be concentrated on the “Circular Economy”.