The Process of Hong Kong Convention Statement of Compliance issuance

28 Apr 2021
Author: Mr. Kiran Thorat & Dr. Anand Hiremath

Demystifying Ship Recycling - Issue 21

Hong Kong International Convention for Safe and Environmentally Sound Recycling of Ships (HKC) was adopted in 2009. For the Hong Kong Convention on ship recycling to come into force, three criteria were mentioned. Out of the three, only the first has been fulfilled as of today. Shipping industry stakeholders expect the last criterion to be fulfilled by 2023. But during this decade-long journey, recycling facility owners in India, Bangladesh, Turkey, and China came forward to comply with the Hong Kong Convention on ship recycling standards voluntarily. A Classification Society issues a Statement of Compliance (SOC) after technically verifying that a recycling yard is in line with the HKC-2009. Presently, ClassNK, IRS, RINA, LR, and BV are the leading classification societies that have developed the guidelines to issue a SOC to recycling facilities.

Did we ever wonder, what is the procedure to get SOC? How much time does it take to issue SOC?

Any recycling facility that develops the infrastructure and demonstrates the recycling process as per the Hong Kong Convention on ship recycling regulations is eligible for a SOC by a Classification Societies. The verification process by the classification society is stringent and involves multiple stages.

Stage 1 of SoC issuance for the Hong Kong Convention on ship recycling: 

A recycling yard that wishes to get SOC must develop infrastructure within its premises. The infrastructure includes the construction of impermeable floors and drainage systems to wash oily blocks, cutting zones, training facilities, SOPs, segregation, and temporary storage of hazardous wastes recovered from the vessels, etc. 

 

Stage 2 of SoC issuance for the Hong Kong Convention on ship recycling:

The recycling facility should prepare a Ship Recycling Facility Plan (SRFP) and submit an application to the Classification society. 

 

Stage 3 of SoC issuance for the Hong Kong Convention on ship recycling:

The classification society reviews the application and SRFP to verify that operations and procedures followed by the recycling yard comply with IMO Resolution MPEC. 210(63). As per the review, the required amendments are directed to the recycling yards. The time taken to complete this stage is between 2 to 12 months.

 

Stage 4 of SoC issuance for the Hong Kong Convention on ship recycling:

The classification society carries out the site inspection to examine the operations and procedures described in the SRFP that are followed in actual practice. Major Non-Conformities (MNC) and Non-Conformities (NC) are raised during the inspection. Supplementary audits are carried out to check that corrective actions are being taken. It takes 3 to 12 months to conduct site inspections and implement corrective measures.

 

Stage 5 of SoC issuance for the Hong Kong Convention on ship recycling: 

After completing site inspection, document review, and closure of MNCs & NCs, a SOC is issued. Like any other class certificate, SOC has an expiry date and is subject to annual and renewal audits. 

In general, a yard takes around 10 to 12 months to get a SOC after developing an infrastructure; sometimes, it even takes longer.

As of now, 92 yards in India, 1 yard in Bangladesh, 2 yards in China, and 14 yards in Turkey have received SOC.

Getting a SOC for a recycling yard is a rigorous and time-consuming process and requires commitment and considerable investment in infrastructure from recycling facility owners. The efforts and persistence shown by recycling facility owners are simply commendable. The classification societies have come forward to verify technical guidelines to improve the process of ship recycling globally. 

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Ship Recycling Team

About Author

Kiran Thorat is a Sustainable Ship & Offshore Recycling Executive at GMS, where he looks after sustainable ship recycling projects. Kiran believes that Sustainable Recycling is an integral part of Sustainable Shipping and a notable example of a circular economy. He holds a Bachelor's Degree from Marine Engineering and Research Institute (DMET), India, and a Master's Degree in Energy, Trade, and Finance from Cass Business School, London.

Dr. Anand M. Hiremath is a Civil Engineer and holds a Master's Degree in Environmental Engineering from the Indian Institute of Technology Guwahati (IIT Guwahati), India. He was awarded Doctorate Degree in the year 2016 for his research work on Ship Recycling by the Indian Institute of Technology Bombay (IIT Bombay), India. In addition, he has a diploma in Industrial safety, is a qualified lead auditor for ISO 9k, 14k and 18k. Dr. Hiremath published the first practical handbook on ship recycling, entitled: "The Green Handbook: A Practical Checklist to Monitor the Safe and Environmentally Sound Recycling of Ships" which highlights the procedures the GMS RSRP follows to help both Ship and Yard Owners recycle a vessel in an environmentally-friendly manner.

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Ship Recycling Team