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Ships roll in on the dock of the bay

Recycling in the maritime shipping sector is already centuries old. The fabric of a ship, whether constructed of wood a century ago or of steel today, has always had considerable value and the good news is that the shipping industry is well ahead of other industries in re-using up to 98% of a ship build material by weight.

The bad news is that even if ship recycling has been efficient in providing a ready supply of steel and other metals for re-use, there has been a cost in terms of lives lost and local environmental impact. Global conventions and EU laws are waiting to be adopted, meaning a huge disparity between nations on what is and is not allowed, no more so than that highlighted by the permit recently granted to Wales’ first authorised ship dismantling facility in Swansea.

Swansea Drydocks has been a ship repair yard dating back to the early twentieth century, when Swansea was one of the UK’s major ports for the trade of coal, iron, copper and tinplate. There have been multiple owners, but the drydocks are now in the safe hands of the Dunn family who, up until 2011, ran Dunn Brothers, one of the largest metal recyclers in the UK. The company owned seven recycling centres in the Midlands, South Wales, South East and South West England and was renowned for investment in new technology and practices, twice winning the Queen’s Award for Enterprise. The family, however, already had their eyes set on a greater challenge ahead, so in May 2011 they sold the business and immediately acquired Swansea Drydocks with a view to using their knowledge of scrap metal recycling by moving into ship dismantling.

Swansea Drydocks has a long history of the docks being used for dismantling and scrapping of marine vessels, so the aim was to re-establish these operations by creating the first current ship breaking facility in Wales.

The aim was to upgrade the site and target UK and European commercial shipping, by offering a facility that would accept up to 150,000 tonnes per annum of end of life hazardous, and non-hazardous waste vessels, through an investment of over £4million. Since this plan fell within the scope of the Environmental Permitting (England & Wales) Regulations 2010 an Environmental Permit was required from the Environment Agency Wales (EAW), now Natural Resource Wales (NRW), in order to begin operations.

Cutting apart big steel structures is a complex business. And even though a high proportion by weight of the ship’s structure is re-usable, there can be large amounts of plastics and other materials that should be handled carefully and appropriately. Added to this, Swansea Drydocks was faced with multiple site sensitivities which required addressing within the rigorous permitting application process laid down by the EAW. Obtaining the Permit required specialist help, so environmental consultancy Enzygo was brought on board to manage the application and then carry out the required environmental surveys.

There were a number of ecological concerns including a neighbouring Shellfish Designation Area, a nearby mussel farm and the Crymlyn Bog nature reserve, which is a designated Site of Special Scientific Interest. Consideration also had to be given to potential contamination risks from anti-fouling paint on the ships’ hulls and the possible danger of asbestos on board. And since the location of the site was directly in Swansea Bay, and close to the newly developed Marina area, there were concerns that this new development would impact the residential harbour developments and the Marina itself. Added to this was mounting public opposition.

As well as undertaking ground assessments, water quality, noise assessments and ecological surveys, Enzygo also prepared a Fugitive Emissions and Odour Management Plan to accompany the application. Throughout the process, close working with the client and EAW’s national permitting team ensured that all the concerns from a number of local organisations as well as local residents, were satisfactorily addressed.

The result was that not only did Swansea Drydocks secure its Environmental Permit for ship dismantling, but the operational procedures that Enzygo employed to obtain the permit are now being used by both the EA and NRW as an example of best practice for all future ship dismantling licences in England and Wales.

This was an extremely challenging application and although many more surveys and assessments were required when compared to other countries, this has now become a landmark case for all future ship breaking permits that marks the start of more stringent rules being applied to other parts of the world in order to safeguard lives and environmental impact.

But while the EA and NRW in England and Wales both strive towards applying stricter permitting conditions for ship dismantling, there is considerable inconsistency in the regulatory approach within the other parts of the UK where, for example, SEPA in Scotland still allows some form of ship breaking on open waters.  More alarmingly, in many parts of the world, particularly in South East Asia, few rules apply at all. It is estimated that an average of 600 end of life ships per annum are dismantled on the beaches and open waters of Indonesia, India, Pakistan and Bangladesh where low labour costs and less stringent environmental regulations apply.

Action is being taken but it is a slow process. The  International Maritime Organisation (IMO) adopted the ‘Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships’ in May 2009 but, like all IMO Conventions, it will only enter into force when the requisite number of member states has ratified it which would be 2014 at the very earliest.

And while hazardous materials such as asbestos are already prohibited by previous conventions, the Hong Kong Convention will now require that all new ships include onboard an Inventory of Hazardous Materials to assist with their handling during decommissioning. However, there is still no requirement to design a ship so that lifecycle safety and environmental costs are considered.

While we wait for a global solution, the EU wants to take action now to ensure that shipping companies take on more responsibility for disposal of their vessels. Existing rules say any ship from the EU should be dismantled within the OECD but these rules are routinely ignored with more than 90% of European shipping currently being dismantled outside of the OECD, mostly in South Asia, using the controversial beaching method. To encourage ship owners to comply with the rules, the European Commission has proposed setting up a list of approved recycling facilities that meet EU standards, such as those already employed at Swansea Drydocks, and to create financial incentives that would make approved recycling facilities more competitive. Ship owners would also be fined for having their vessels dismantled at a non-approved facility. The proposal could yet get wrecked as it still requires EU parliament approval but urgent action needs to safeguard the environment and to ensure that approved facilities, like those in Swansea, can compete commercially with the rest of the world.

Lucinda Hall, principal consultant at Enzygo

Inconsistent regulations

While England and Wales strive towards applying strict permitting conditions for ship dismantling, there is considerable inconsistency in the regulatory approach within the other parts of the UK. For example, the Scottish Environment Protection Agency still allows some ship-breaking on open waters.

More alarmingly, in many parts of the world, particularly in south-east Asia, few rules apply at all.

It is estimated that an average of 600 end-of-life ships a year are dismantled on the beaches and open waters of Indonesia, India, Pakistan and Bangladesh (pictured below), where low labour costs and less stringent environmental regulations apply.

Action is being taken but it is a slow process. The International Maritime Organisation (IMO) adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships in May 2009 but, like all IMO conventions, it will only enter into force when the requisite number of member states has ratified it, which would be 2014 at the earliest.

And while hazardous materials such as asbestos are already prohibited by previous conventions, the Hong Kong Convention will now require that all new ships include an onboard inventory of hazardous materials to assist with their handling during decommissioning. But there is still no requirement to design a ship so that lifecycle safety and environmental costs are considered.

The EU wants to take action to ensure that shipping companies take on more responsibility for disposal of their vessels. To encourage owners to comply, the European Commission has proposed a list of approved recycling facilities that meet EU standards, such as those already employed at Swansea Drydocks, and to create financial incentives that would make approved recycling facilities more competitive.

Ship owners would also be fined for having their vessels dismantled at a non-approved facility. The proposal still requires European Parliament approval, but urgent action is needed to safeguard the environment and to ensure that approved facilities can compete commercially with the rest of the world.

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