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Are you concerned about how to comply with your ESG goals when it comes to recycling your end-of-life assets? Sust… https://t.co/zAYHbDmXG8


#ShipRecycling Market - Week 43 - BITING BACK! After the recent brief lull, levels have spiked in the sub-continen… https://t.co/T5eSE3hR9k


Our Non-Executive Director, Dr. Nikos Mikelis, will be attending @tradewindsnews Ship Recycling Forum 2021. The pan… https://t.co/Jpe9CXsTA1


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Demystifying Ship Recycling - Issue 15

Standard Operating Procedures (SOPs) against COVID-19 at HKC Compliant recycling facilities

Amid the surge in COVID-19 cases in India, the HKC compliant recycling facilities are taking absolute precautions against the spread of COVID-19. The recycling facilities and the local regulatory authorities have developed standard operating procedures to curb the spread. 

The entry and exit points in each yard are sanitized regularly. The recycling facilities are sanitized every morning before commencing activities and after completing activities in the evening. At entry and exit points, hand wash facilities along with soap are arranged. Washing of hands before entering the recycling yard is imperative. The safety officer and HSE team monitor every worker's body temperature and ensure that workers use proper PPE & masks. In work locations, social distancing is assured with strict compliance. 



During the regular breaks as well, social distancing is strictly followed. Workers are provided with masks, gloves, and adequate PPE. Safety officers supervise the social distancing norms. The number of workers present in the yard at any given time is restricted to ensure adequate social distancing. If a worker is observed with any of the COVID-19 symptoms, he is transferred to the quarantine facility allotted by Gujarat Maritime Board (GMB).

The medical attention is provided by the Alang multi-specialty hospital. Primary Health Centre (PHC) arranges regular COVID-19 tests for the yard workers to identify any asymptomatic patient. 

Similar SOPs are developed for the crews who deliver the vessels to the recycling facilities. The COVID-19 test is done for the crews onboard the vessel at anchorage. Once all the crews are tested negative, they are allowed to disembark. A crew member with symptoms is given prompt medication and treated as per the COVID-19 guidelines onshore. Crews are provided with masks and disposable protective clothing. Once the crew disembarks from the vessel, they are immediately transported to the accommodation, and they are not allowed to visit other than designated areas in the recycling facilities. A trained person sanitizes vessels' access points and common areas before yard workers or regulatory authority representatives board the vessel. 

Strict adherence to the above SOPs helps curb the spread of COVID-19 and ensures continuity in the ship recycling process without any loss of time.

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Demystifying Ship Recycling - Issue 14

Drills at HKC Compliant recycling facilities – Part 2 


In Drills at HKC compliant recycling facilities - Part 1, we discussed the drills, including fire and explosion on the plot & ship, confined space rescue, and evacuation from ship and Plot. In addition to those drills, few more drills are conducted at recycling facilities:

Falling from Height:

When the ship is recycled, she is sitting on the ground. The ship's structures are quite high from the ground. During the recycling, process workers need to board the vessel regularly. Although workers use PPE and the NO GO areas are marked & barricaded on the vessels, there is a hazard of falling from the height.  Therefore, yard workers need to understand the actions which should be taken if a person falls from a height. Falling from height drill is conducted by simulating the fall of a human dummy. Workers are trained to rescue the person who fell down and give him first aid and medical attention.



Medical Emergency on Plot and Ship:

At any ship recycling yard, around 80 to 100 workers are present on a typical working day. It is important for workers to understand how to react if any of their colleagues face medical emergencies such as heart attack, fainting, etc. In this drill, workers are explained about the significance of first aid and the use of medical equipment. 

Oil spillage on Sea Water and Plot: 

When a vessel is delivered to the recycling facilities, it usually contains small quantities of fuel oil, lube oil, bilge water, and oily sludge. These oils are transferred from the vessel to the oil collection tanks using oil transfer pumps with the help of flexible hoses. Transfer of oil possesses the risk of oil spill either on sea water or on the Plot. Yard workers must understand how to respond in case of oil spillage as it is a major environmental hazard. Recycling facilities have oil spill kits to contain and collect the spilled oil. The kit has all the necessary material to clean the oil, such as oil absorbent pads, booms, shovels, drums, etc.  


Monsoon and Storm:

More than 90 % of ship recycling is done at southeast Asian facilities. India, Bangladesh, and Pakistan face the monsoon season from June to September every year. During monsoon, it is obvious to face heavy rainfalls, rough seas, and occasional storms. Therefore, it is significant for yard owners and workers to understand the actions to be taken during the monsoon. 

Every week emergency sirens are function tested to ensure the workers' awareness of different patterns of the emergencies. All drills are recorded, and post drill debriefings are done and discussed in the toolbox meetings. Drills are recorded until expected performance is achieved. 

HKC compliant recycling facilities strictly comply with the annual schedule of various drills to ensure safety at yards.

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Demystifying Ship Recycling - Issue 13

Drills at HKC Compliant recycling facilities – Part 1 

Any person related to shipping is aware of the various mock drills. Whenever any movie is filmed on ships, it’s apparent to see bells ringing, hooter sounding, and drills held on the ships. Have we ever wondered what types of drills are conducted on the Hong Kong Convention compliant yards while recycling the vessels? The entire ship recycling process is related to gas cutting, heavy plates lifting and their movements, confined space entries, working at a height, etc.

Although the workers employed in the yards receive regular training, it is vital for them to participate in mock drills and understand the procedures followed during actual emergencies. The motto behind carrying out any drill at recycling facilities is to make the workers acquainted with various procedures to be followed during emergencies. Participation in mock drills is the way to make the workers familiar with the methods and equipment which can be used in a crisis. It helps workers to understand the SOPs to be followed. 



Fire and explosion on plot and Fire and Explosion on Ship:

While conducting a fire drill on the ship, a small fire is simulated and workers are asked to extinguish the fire as the SOP. Actions taken during the drills by each worker are observed, and their timing is recorded. In the drill, different types of fire extinguishers are function tested. Post drill review meetings are conducted under the guidance of the safety officer for effective learning.

Confined Space Rescue:

Ships are built of steel and have multiple compartments. Double bottom tanks, fuels oil tanks and smaller auxiliary tanks are all confined spaces. It’s foremost for yard workers to understand the significance of confined space rescue. Keeping this in mind, yards conduct the drills to rescue a person from confined spaces. It helps workers to respond promptly during an actual emergency. 

Evacuation from ship and plot: 

Once the ship recycling commences, its structure changes every day due to the slicing of the hull and the access to the vessel is altered as per the structure. Workers need to understand the evacuation from the ship and plot in case of emergency. Therefore, yards regularly conduct the evacuation from ship and plot drills. 

The drills are also conducted during the audit by the SOC issuing classification society. 

Each type of drill has its own significance. HKC compliant recycling facilities strictly comply with the annual schedule of various mock drills.

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British Broadcasting Corporation (BBC) recently published a news article about the UK cruise ships scrapped in India's graveyard. In this article, the BBC attempts to propagate biased opinions about the ship recycling industry in India. After reviewing the misleading information and erroneous views of the ship recycling industry in India by the BBC, we are required to address some falsified items stated in the report. 

World's largest ship graveyard

BBC has described Alang, a coastal village in Gujarat, as "The world's largest ship graveyard". However, Alang is the largest green ship recycling destination preferred by global ship owners for recycling of their end-of-life vessels for the following reasons:

  • Major blue-chip ship owners from Japan, Norway, Denmark, Italy, and other developed nations have visited, inspected, audited, and vetted the recycling facilities at Alang. Based on the facts observed at Alang, they have been sustainably recycling their vessels in India. Japanese shipowners' association and the Danish shipowners' association representatives have visited and vetted the recycling facilities to their satisfaction. 
  • More than 1000 foreign nationals have visited the Alang to diagnose the difference between facts and opinions spread about the ship recycling at Alang. These visitors are none other than the ship owners, classification society representatives, auditors, safety inspectors, diplomats, capital providers, delegates from international banks and pension funds, etc. 
  • The infrastructure consists of impermeable floors, fire-fighting arrangements, application of heavy-duty cranes, training to workers, effective hazardous waste management, etc. 
  • At present there are 92 out of 120 (77%) yards are Hong Kong Convention compliant and received Statement of Compliance (SOC) from leading classification societies. The classification societies include ClassNk, Lloyd's Register, RINA, and Indian Register of Shipping. They all are members of the International Association of Classification Societies (IACS) who are the Recognized Organizations (ROs) for implementing various international conventions on behalf of flag states. 
  • The Government of India has appointed the Directorate General of Shipping as an apex body to oversee India's ship recycling activities. The Government of India ratified the Hong Kong Convention in Nov 2019 to promote ship recycling at Alang. India is the only country in South East Asia to ratify the Hong Kong Convention. In addition, as Alang is in Gujarat province, the activities at Alang are further supervised by the Gujarat Maritime Board (GMB). 

Alang is a stretch of muddy beach

The remark made in the article about Alang being 'a stretch of muddy beach' is merely incorrect and out of context. 

  1. Alang is blessed with the natural sea front of a hard-rocky bottom with a slope of 15 degrees. This makes it convenient to deliver the vessel to the recycling yards along the side of the sea front. 
  2. Alang is not a muddy beach, but it's a complete ecosphere of the recycling yards, backyards, neighboring villages, steel mills, spare parts warehouses, and yard workers. 
  3. It is a notable example of how recycling of end-of-life vessels becomes a green circular economy. More than 700 shops sell materials recovered from the recycled vessels. These materials include unused spare parts, old machinery & equipment, cutlery, furniture, special tools, etc.  
  4. The steel plates extracted from the vessels are used in the adjacent steel re-rolling mills. Alang is the place where the end-of-life of vessels is given reincarnation. Studies done on the CO2 emissions in the recycling process show that the emissions can be reduced by at least by four times than extracting a similar amount of steel from raw iron ore. Recycling helps to reduce CO2 emissions which is the primary concern of global warming
  5. With the impact of Covid-19 and the global recession, the recycling industry is generating employment opportunities. 

Asbestos Bomb:

The BBC article mentions that any vessels recycled at Alang are asbestos bombs. It is critical to understand how the asbestos, asbestos containing material (ACM), and other hazardous wastes generated during the ship recycling process are removed and disposed of at Alang. 

  1. Alang has developed the infrastructure to dispose of asbestos in an environmentally friendly way. 
  2. The workers use adequate PPE, which comprises helmets, safety glasses, masks, hand gloves, safety shoes, boiler suits, and disposable overalls while removing and packaging asbestos. 
  3. The asbestos is solidified and stabilized with cement and water, converting it into solid cubes and disposed of into engineered landfill at GEPIL (with HDPE geo liner and multiple layers of solids).  
  4. Trained workers with adequate PPE also handle other hazardous materials like lead. They are disposed of to only authorized recycling vendors.

Pumping of waste into the sea and burning the materials on the shore

Furthermore, the BBC article mentioned the worker's statement that the oil and other wastes thrown to sea are completely baseless and merely opinion-based. 

  1. It is essential to know that oil is used as resalable material. There is no cost-benefit of the oil being thrown into the sea. There are a solid infrastructure and SOPs to collect the oil, bilge water, and various types of wastes generated during recycling facilities. 
  2. Each type of waste is collected, quantified, and disposed of as per the environmental standards. Recycling facilities have developed segregated storage facilities within the yard to store segregated wastes for a temporary period 
  3. The law prohibits the burning of oil along with other waste in the recycling facilities. The license issued to yards for recycling vessels is suspended if any yard is observed violating the rule. 

Medical Facilities at Alang:

The BBC article criticizes the Alang for having inadequate medical facilities. However, it is crucial to note that Alang has 3 hospitals within the cluster of recycling yards. 

  1. Alang Hospital, located at South Side Road, Alang, Gujarat 364150, India.
  2. GMB multispeciality hospital Alang, located at South Side Road-Alang, Alang, Gujarat 364150, India.
  3. Redcross Hospital of Alang, located: Near Mahadev Temple, South Side Road-Alang, Alang, Gujarat, 364150, India.
  4. Recently, GMB has granted USD 1.3 Million (INR 9,00,00,000) for upgradation of medical facilities, including a trauma center.

Recycling vessels pollute the beaches:

As a specialized body established under the Government of India's National Green Tribunal (NGT) Act, NGT is equipped with the necessary expertise to handle environmental issues. NGT has also ordered the development of recycling facilities along the coast of the Alang. It approved the 'Beaching' method of ship recycling. It observed that the recycling at Alang would not affect the environment much as claimed by different international NGOs with biased opinions.


Ship recycling in India is a convincing example of the Green Circular Economy. The Government of India has determined to double the capacity of ship recycling at Alang by developing infrastructure and enforcing regulatory measures. Therefore, comments in BBC's article about Alang being 'India's ship graveyard' are entirely unverified. 

We hope that this release has helped to foster a better understanding of the present status of ship recycling in Alang and that readers recognize the importance of taking the time to understand recycling industry facts vs. biased opinions.

BBC should do responsible journalism and not just publish scripts without fact-checking.  The prejudiced opinions do not affect the sustainable growth that is taking place in Alang. In addition, the Government of India is planning to double ship recycling capacity by the year 2024.

At GMS, we pride ourselves as being responsible leaders in an industry vital to the shipping supply chain. Over the years, we have made it our mission to improve the safety and quality of working and living standards across the industry. The advancements that have been made in the environmental standards and long-term sustainability throughout the ship recycling industry and in the geographic areas that house it has been immense, and GMS considers it an honor to be at the forefront of these developments.

Please feel free to contact GMS at info@gmsinc.net with any comments or questions that you might have.

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March 17, 2020
5 things to know about Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, 2009
The International Maritime Organization's Marine Environment Protection Committee (MEPC) developed the Convention with the participation of the Secretariats of the Basel Convention and the International Labour Organization from 2006 to 2009. The diplomatic conference that adopted the Convention took place in Hong Kong, and thus, it's commonly known as the "Hong Kong Convention" (HKC). In this article, I am answering the top 5 frequently asked questions on the Hong Kong Convention. 
1) Why was the Hong Kong International Convention required for end-of-life ships?
The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal,1989 considers end-of-life ships as Wastes. The Basel Convention was successful in controlling illegal transport of hazardous wastes from many industrial sectors to countries with minimum or no capacity for waste disposal in an environmentally sound manner. However, when it comes to the ship recycling sector, it was not suitable for end-of-life ships. It does not define a minimum standard for ship recycling other than prior-informed consent to export and import, nor does it make any provisions for workers' safety issues. Basel Convention is not cognizant of the concept of flag State for ship recycling sector, and the State from which the ship departs for its last voyage is regarded as exporting State, both of which create a problem of enforcement.  Therefore, a standalone international regulation on ship recycling was required, which can address ship recycling issues in a safe and environmentally sound manner. 
2) To whom does HKC will apply? 
The Convention, after its entry into force, will apply to all ships, except ships below 500 GT, government-owned non-commercial service ships, and ships operated throughout their life exclusively in waters of the State whose flag the ship is flying.
3) What HKC include?
1. the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling, without compromising the safety and operational efficiency of ships;
2. the operation of ship recycling facilities in a safe and environmentally sound manner; and
3. the establishment of an appropriate enforcement mechanism for ship recycling (certification/reporting requirements).
The central part of the Convention contains 21 Articles and 25 regulations. The Convention has
seven appendices, with lists of hazardous materials, standard formats for certificates, etc. It has six guidelines that were developed by IMO's MEPC, namely:
• Resolution MEPC.196(62) - 2011 Guidelines for the Development of the Ship Recycling Plan
• Resolution MEPC.210(63) - 2012 Guidelines for Safe and Environmentally Sound Ship Recycling
• Resolution MEPC.211(63) - 2012 Guidelines for the Authorization of Ship Recycling Facilities
• Resolution MEPC.222(64) - 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention
• Resolution MEPC.223(64) - 2012 Guidelines for the inspection of ships under the Hong Kong Convention
• Resolution MEPC.269(68) - 2015 Guidelines for the development of the Inventory of the Hazardous Materials
4)  When will HKC come into force?
HKC will come into force 24 months after the date on which it meets the following three conditions: 
1. not less than 15 States have either acceded to it or have ratified it;
2. the combined merchant fleets of the States that have acceded to it or have ratified it represent not less than 40 percent of world merchant shipping by gross tonnage;
3. the combined maximum annual ship recycling volume of the States that have acceded to it or have ratified it must constitute not less than three percent (3%) of their combined merchant shipping tonnage.
5) Which all conditions of HKC are fulfilled to date? And how many ship recycling yards in South Asia voluntarily complied with the same?  
1. As of 20 January 2020, 15 countries have acceded/ratified the HKC. Namely, Norway, Congo, France, Belgium, Panama, Denmark, Turkey, Netherland, Serbia, Japan, Estonia, Malta, Germany, Ghana, and India;
2. 30.1% is the combined merchant fleets of the above 15 States that have acceded/ratified to HKC. 9.9% less than the mandatory 40 percent of world merchant shipping by gross tonnage to meet the second condition (estimation is as per 2018 fleet data which is subjected to change once 2019 fleet data is available);
3. 2.6% is the combined maximum annual ship recycling volume of the States that have acceded which is still 0.4% less than the required three percent (3%) of their combined merchant shipping tonnage to mee the third condition (estimation is as per 2018 recycling data which is subjected to change once 2019 recycling data is available);
This means, though the first condition is met, we still need to fulfill the second and third conditions for HKC to enter into force. 
To fully satisfy the 2nd condition is quite straightforward, as ratification by either Liberia or Marshall Islands is enough to meet the 40 percent requirement. Whereas both these open registers appear keen to see the Convention enter into force, they, as well as other registers, have been reluctant to ratify, in case too much tonnage is accumulated, making it difficult, or even impossible, for the third condition to be met. This is because the third condition on recycling capacity is expressed in terms of a percentage of the second condition on the tonnage in operation.
An additional recycling capacity of 2.1 million GT is presently needed to satisfy the third condition. This can only be provided by Bangladesh (present capacity 9.9 million GT), or Pakistan (5.7 million GT), or by China (8.2 million GT). The rest of the world (excepting Turkey and India who have already ratified) can only contribute 0.6 million GT altogether.  
For a few more years, China will be able to contribute significant "notional" ship recycling capacity arising from the tonnages it recycled before banning the import of end-of-life ships. This legacy capacity will stand at 8.2 million GT until May 2023 (which was the volume recycled in 2012) and will then progressively decline until a decade has passed from the time China banned the import of ships for recycling. Therefore, noting that the fleets of China and Hong Kong together currently represent 13.4% of the world's fleet, it follows that if China with Hong Kong were to ratify the Convention today, then the three conditions will have been met today and the Convention would enter into force in just 24 months. 
However, considering above all conditions into consideration, we can expect HKC to come into force before 2025.
Seventy-seven ship recycling yards received over 105 Statement of Compliance (SOC) from IACS, mainly ClassNK, RINA, IRClass, and Lloyd's Register in India.  Whereas, In Bangladesh, one recycling yard (PHP) achieved SOC with HKC from ClassNK. 
About the Author
Dr. Anand Hiremath is the Head of Research and Development Division of GMS. A Civil Engineer and a Master's degree holder in Environmental Engineering from the Indian Institute of Technology Guwahati (IIT-G). He has been awarded Doctorate Degree for his research work on Ship Recycling by the Indian Institute of Technology Bombay (IIT-B). Also, he is a qualified OHSAS 18001:2007 Lead Auditor from Bureau Veritas and an "Approved HazMat Expert" from DNV GL.
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