The International Ship Recycling Convention

On 15 May 2009, a Diplomatic Conference held in the Hong Kong Special Administrative Region of the People’s Republic of China adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.

The Ship Recycling Convention is the culmination of a 10-year effort which was initiated by the Norwegian Delegation at MEPC 41 in November 1998.

Concern was raised as to the problems associated with ship dismantling and the need for an internationally acceptable solution which would ensure the protection of the environment and the safety workers in the scrapping of ships.

Entry into force after significant debate and attempts to take into account the capacity of ship recycling facilities versus the estimated demand on these facilities by ships which have reached the end of their operating life, the Conference agreed that the Ship Recycling Convention would enter into force 24 months after all of the following conditions are met:

  1. 15 States have ratified the Ship Recycling Convention;
  2. The combined merchant fleets of the ratifying States is at least 40% of the gross tonnage of the world’s tonnage; and
  3. The combined maximum annual ship recycling volume of the ratifying States during the preceding 10 years is at least 3% of the gross tonnage of the combined merchant shipping of those ratifying States.

The value of 3% was based on information provided to the Conference by Japan which indicated that the maximum annual disposal of ships for the last 10 years was 2.98%.

Scope of Application

The Ship Recycling Convention applies to all (new and, to the extent practicable, existing) ships of 500gt and above as determined by the International Convention on Tonnage Measurement of Ships, 1969.

A “ship” is defined as any vessel of any type whatsoever operating or having operated in the marine environment and includes:

  • submersibles
  • floating craft
  • floating platforms
  • self elevating platforms
  • FSU (Floating Storage Unit)
  • FPSOs (Floating Production Storage and Offloading), including a vessel stripped of equipment or being towed.

A new ship is defined as a ship:

  1. with a building contract date on or after the entry into force date; or
  2. in the absence of a building contract, the keel is laid 6 months after the entry into force date, or
  3. regardless of the contract or building date, the delivery date is 30 months after the entry into force date.

There are two exemptions under which the Ship Recycling Convention does not apply:

  1. warships, naval auxiliary ship or government-owned non-commercial ships;
  2. ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State.

Prerequisites to Certification

Inventory of Hazardous Material (IHM)

The first document that is needed for ship recycling is the Inventory of Hazardous Material – IHM.

The IHM consists of three parts which are developed at two stages.

  • Part I comprises a list of hazardous materials (as listed in Appendices 1 and 2 of the Ship Recycling Convention) contained in ship’s structure or equipment, their location and approximate quantities;
  • Part II lists operationally generated wastes onboard, and
  • Part III contains an inventory of ship’s stores. (ABS’ Green Passport provides compliance with Part I.)

Appendix 1 prohibits systems, equipment, insulation, or other material which contain ozone-depleting substances, plychlorinated biphenyls (PCB) and asbestos from being installed on or after the entry into force date of the Ship Recycling Convention.

Antifouling substances are prohibited consistent with the AFS Convention.

Appendix 2 contains a minimum list of hazardous material to be included in the IHM which include the substances in Appendix 1 as well as other hazardous material including cadmium, mercury and lead.

Part I

New ships are to be provided with Part I at delivery.

Existing ships are to be provided with Part I (to the extent practicable) not later than 5 years after the entry into force of the Ship Recycling Convention.

For existing ships, a visual or sampling check plan is to be prepared by hazardous material experts prior to developing the IHM.

Throughout the operational life of the ship, Part I is to be properly maintained and updated to reflect new installations (i.e., systems, equipment, insulation, or other material installed on or after the the entry into force date of the Ship Recycling Convention) containing hazardous materials listed in Appendix 2 and relevant changes inship structure and equipment.

Parts II and III

The shipowner prepares Parts II and III of the IHM at the time the ship is being prepared for the final survey pursuant to issuance of the International Ready for Recycling Certificate.

Ship Recycling Plan

The shipowner, upon selecting a Ship Recycling Facility that has beed authorized by the recycling State, will need to arrange for the Facility to prepare a Ship Recycling Plan (SRP) which is to be developed based on the particulars of the ship and information on the IHM from the shipowner.

The SRP is to include information concerning the establishment, maintenance, and monitoring of safe-for-entry and safe-for-hot work conditions and how the type and amount of materials including those identified in the IHM will be managed.

Two different levels of approval of the SRP by the Competent Authority of the recycling State are provided for in the Ship Recycling Convention based on the formal communication sent to International Maritime Organization (IMO) by the signatory State:

  1. Explicit approval of the SRP; or
  2. Tacit approval of the SRP, provided written acknowledgment of receipt, without any objections, is provided at the end date of a 14-day review period.

The tacit approval process was introduced to accommodate the practices in the USA.

Survey and Certification

Periodic and Additional Surveys

An initial survey is to be carried out before a new ship is put in service or before the International Certificate on Inventory of Hazardous Materials is issued.

This survey verifies that the IHM (Part I) corresponds to the ship.

A 5-year renewal survey verifies continued compatibility of the IHM (Part I) with the ship.

An additional survey is carried out, at the request of the shipowner, to verify that any change, replacement, or significant repair complies with the Ship Recycling Convention and that IHM (Part I) is updated as necessary.

Final survey prior to issuance of the 3-month International Ready for Recycling Certificate, a final survey is carried out on board prior to the ship being taken out of service and before the recycling of the ship has started.

It is important that the SRP is approved and that the Parts II and III of the IHM are completed so that they can be compared with the approved SRP prior to commencing the survey.

The final survey verifies:

  1. that the IHM (Part I) corresponds to the ship;
  2. that the approved SRP properly reflects the information contained in the IHM (Parts I, II and III);
  3. that the approved SRP contains information concerning the establishment, maintenance and monitoring of safe-for-entry and safefor-hot work conditions; and
  4. that the Ship Recycling Facility where the ship is to be recycled holds a valid Document of Authorization to conduct Ship Recycling (DASR) issued by the Competent Authority.

The Ship Recycling Convention requires oil and chemical tankers to arrive at the Ship Recycling Facility with their cargo tanks and pump room(s) in a condition that is ready for certification as safefor-entry, or safe-for-hot work, or both, according to the provisions of the SRP developed by the Ship Recycling Facility.

Guidelines for Implementation Six sets of guidelines are referenced by the Ship Recycling Convention.

Preliminary drafts of some of these guidelines have been developed and are scheduled to be completed at future sessions of the MEPC.

Development of the Inventory of Hazardous Materials

  • Survey and certification;
  • Inspection of ships;
  • Authorization of Ship Recycling Facilities;
  • Safe and environmentally sound ship recycling; and
  • Development of the Ship Recycling Plan.