ISRA Network

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.

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”.    

Meeting in Brussels with European Commission, member states and stakeholders on 13 February 2020 ISRA was invited to join this meeting which was organized by the EC, to evaluate the EU Ship Recycling Regulation, a year after its entry into force.  Other stakeholders: ECSA and NGO ship-breaking. ECSA referred to the lack of a global regulatory regime and was frustrated about the sluggish developments in this field. The Norwegian Shipowners, represented ECSA, gave an extensive overview of developments for responsible ship recycling activities and pointed out that the Hong Kong Convention is the only solution for a level playing on ship recycling. Director ISRA, Reinoud Pijpers ISRA was represented by Director Reinoud Pijpers and board member Peter Wyntin. Reinoud emphasized the need for a proper enforcement and a technical non-political accession policy for the EU-list. The regulation is clear, it is now up to the member states to enforce it. He distributed the letter concerning the responsibility of the member state that was sent by ISRA to all the member states in 2019. Board member ISRA, Peter Wyntin Board member Peter Wyntin gave a very impressive overview of the number of (EU) flag ships that were recycled on the beaches and had to conclude that the EU-SRR had no effect whatsoever.  He called up to the EC to come in action to the members states who fail to enforce and called upon the EC to think about a central point of contact for matters concerning enforcement. The EC will also publish figures from EMSA. Until now 17 march these figures are not published. As soon as these figures are published, ISRA will distribute them. Peter Wyntin also referred to the fact that numerous ships within the borders of the EU, but not flying an EU-flag can be recycled on a non-EU-facility in the EU. He showed a slide with a number of ships who fall under this definition. Ingvild Jenssen NGO Ship breaking platform Ingvild Jenssen showed that from 2009-2019 almost 400 workers lost their lives and 250 were severely injured. With some impressive slides she showed the convincing figures from the world of beaching. Furthermore, she illustrated that the polluters pay principle should be applied for ship recycling. Ingvild Jenssen referred to the several reports concerning a financial incentive. She argued that various financial driven possibilities were extensively scrutinized and that it takes political willingness to introduce them.     European Commission The EC, Mr. Pellegrini head of the waste department and successor of ms. Lenen, concluded that technical requirements are the basis for accession to the EU-list. This goes for every country outside the EU. He concluded that EMSA-figures (not yet disclosed) gave more or less the same picture as Peter Wyntin had shown: the fast amount of end of life ships is still going to the beaches. A central point for enforcement, as suggested by ISRA, could in theory be supported by the EC, but in practice, such an entity is not feasible in due time: member states have to take their responsibility. (Concerning the scope of the EU-SRR, the impression was that the EC would be willing to evaluate the EU-SRR, but not in due time). The EC related the EU-SRR to the HKC, and stated that the HKC will not come into force in due time and that Bangladesh remains a country of beach practices. This should be taken in account when evaluating the EU-SRR. (A formal evaluation of the EU-SRR is 18 months before the entry into force of the HKC). A financial incentive was not rejected and the EC seem to be positive to put this on the agenda as a means to prevent circumvention. The EC was interested in the way steel, as a commodity, relates to the ship recycling business. He was questioning whether the steel market was, in the EU, was interested to use the scrap, in that way making better process for the EU based recyclers and a reduction of CO2.  He suggested that ISRA should contact Eurofer, the association for steel producers, in the EU.   Summit EU-India 13 March 2020 The EC also referred to the coming summit between the EU and India. The applications to the EU-list from a number of Indian ship recycling facilities will be discussed. ISRA will address this item separately to the EC (this meeting is postponed due to the Corona crisis).