Ship recycling, constituting a fundamental pillar of the maritime industry, is pivotal for environmental and safety considerations. The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC), slated to take effect in the next 18 months, stands out as a crucial regulatory framework designed to navigate the complexities inherent in ship disposal. This article critically explores the key arguments supporting the adoption of HKC as the exclusive regulation, taking into account the International Maritime Organization (IMO), the United Arab Emirates Ship Recycling Regulation, the Basel Convention, and the Basel Ban Amendment.
The HKC, established by the IMO, serves as a comprehensive guide for the safe and environmentally sound recycling of ships. Notably, HKC was formulated after recognized authorities such as Basel and the International Labour Organization (ILO) acknowledged the need for a dedicated ship recycling regulation around 2005. Its ratification, spanning nearly 15 years, underscores its meticulous approach in reconciling environmental and safety concerns inherent in ship recycling. The provision for amendments, especially to address social and downstream waste management challenges, positions HKC as a singular IMO regulation, alleviating challenges for ship owners posed by region-specific regulations.
The Basel Convention, originally designed to manage hazardous waste movement, faces limitations in adapting to ships as shipping work on the concept of “flag state” and exporting country and transit countries are fixed unlike other hazardous wastes. The Basel Ban Amendment, restricting the export of hazardous waste from developed to developing nations, introduces complexities in ship movements, creating challenges for ship owners navigating intricate international regulations.
Guided by the Vienna Convention on the Law of Treaties, the global community recognizes the significance of the latest conventions in resolving conflicting obligations. This principle underscores the need for a contemporary regulatory framework, strengthening the case for HKC as a leading international standard in ship recycling.
Despite India, Bangladesh, and Pakistan ratifying the Basel Convention, the absence of endorsement for the Basel Ban Amendment highlights challenges in aligning regional regulations with evolving global standards.
The Basel Ban Amendment's restrictive stance on waste movement, particularly end-of-life ships, poses challenges, risking legal consequences for non-compliance. Ship owners may inadvertently breach the law even when adhering to the latest convention, HKC, meant for safe and environmentally sound ship recycling.
In promoting a streamlined process, the Ready for Recycling certificate under HKC should be regarded as the definitive document confirming adherence to HKC, Basel, and the Basel Ban Amendment. Advocates propose international acceptance of this certificate, fostering a standardized approach to ship recycling globally.
The UAE Ship Recycling Regulation, with restrictions on nearly 95% of recycling destinations, strains global drydock capacity. This underscores the need for a uniform and globally accepted standard to facilitate ship recycling operations worldwide.
Limited drydock capacity and increased retrofitting work, driven by Carbon Intensity Indicator (CII) and Energy Efficiency Existing Ship Index (EEXI) rules, present challenges in the maritime industry. Drydocks, traditionally designed for shipbuilding and repair, lack an ecosystem for efficient ship recycling, leading to suboptimal utilization of scrap materials.
Recognizing HKC as the sole governing rule for ship recycling emerges as a strategic imperative. While allowing for amendments as needed, a uniform regulatory framework ensures clarity, compliance, and successful navigation of environmental and safety considerations in ship recycling.
The transition towards making HKC the exclusive regulation for ship recycling is imperative for fostering sustainability, environmental stewardship, and safety within the maritime industry. By addressing overlapping regulations and embracing a unified approach, the international community can lead ship recycling practices toward a safer and environmentally responsible future.
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Dr. Anand Hiremath is a leading voice in sustainable ship recycling, with a strong foundation in civil and environmental engineering and more than a decade of specialised expertise in safe and environmentally sound ship recycling.
He holds a master’s degree in Environmental Engineering from IIT Guwahati and earned his PhD from IIT Bombay, where his pioneering research on the Integrated Risk Assessment Framework for Best Practices in Ship Recycling contributed to advancing safety, environmental responsibility, and structured risk management within the industry.
As Chief Executive Officer of the Sustainable Ship and Offshore Recycling Program (SSORP), Dr. Hiremath plays a key role in strengthening responsible ship recycling practices across the sector. He works closely with recycling yards to support compliance with the Hong Kong Convention (HKC) for the safe and environmentally sound recycling of ships. Under his leadership, SSORP has overseen more than 100 Inventory of Hazardous Materials (IHM) surveys and successfully supported the recycling of over 130 end-of-life vessels.
His commitment to worker safety and practical capacity-building is reflected in more than 800 free safety awareness sessions conducted at recycling yards across the Indian subcontinent, benefiting over 13,000 workers. These initiatives have helped improve awareness, hazard recognition, and safe work practices at the yard level.
Beyond his operational leadership, Dr. Hiremath contributes to the development of the next generation of ship recycling professionals as Course Director for the Lloyd’s Maritime Academy Ship Recycling course in London. His global influence extends through his involvement in major international research and improvement initiatives, including the EU-funded DIVEST project and the Green Alang Initiative, both focused on improving environmental standards and sustainability in ship recycling.
Dr. Hiremath’s work has been published in leading international scientific journals, reinforcing his position as a thought leader in the field. He is also the author of The Green Handbook: A Practical Checklist to Monitor the Safe and Environmentally Sound Recycling of Ships, a practical industry resource for monitoring responsible ship recycling practices.
His professional credentials include Lead Auditor certifications for ISO 45001 and ISO 9001, certification as a Hazmat expert, Social Auditor, Responsible Steel Auditor, and sustainability practitioner.
With his combination of technical expertise, field experience, academic contribution, and commitment to worker safety and environmental protection, Dr. Anand Hiremath remains at the forefront of the global movement toward safer, greener, and more sustainable ship recycling.
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