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The Process of Hong Kong Convention Statement of Compliance issuance

Demystifying Ship Recycling - Issue 21

Hong Kong International Convention for Safe and Environmentally Sound Recycling of Ships (HKC) was adopted in 2009. For the HKC 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 HKC 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 HKC regulations is eligible for a SOC by a Classification Societies. The verification process by classification society is stringent and involves multiple stages.

Stage 1: 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: The recycling facility should prepare a Ship Recycling Facility Plan (SRFP) and submit an application to the Classification society.


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

Stage 5: 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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Demystifying Ship Recycling - Issue 20

Pulling of ships towards the recycling yards

In major ship recycling destinations such as Turkey, India, Pakistan, and Bangladesh, ships are recycled at the sea-shore interface. Superannuated ships are delivered to the recycling facilities, where the hull is cut into big slices. These gigantic slices are shifted to the secondary cutting zones for the extraction of steel plates. The ship’s hull needs to be gradually pulled towards the ship recycling yard to cut further slices. Have you ever wondered how the massive hull of a ship is pulled towards the recycling facility?

Ship recyclers who recycle ships at sea-shore interfaces have developed unique techniques to pull the hull towards yards. Strategic windows are cut on the ship’s side shell on the port and starboard side. Through these openings, giant chains are passed. These chains are connected to the steel wires with the help of robust shackles and pulleys. Steel wires are connected to the heavy-duty winches. These heavy chains, shackles, and pulleys are shifted and passed through the hull openings with the help of moving cranes.

The wires used for winching operation are typically 32 mm in diameter.

Usually, any ship recycling facility has two or sets of winches. These winches are powered by diesel engines. Winches are periodically load tested. Routine maintenance is carried out on the winches and their prime movers. Protective guards cover winches to guard the operator in case the wire snaps.

The ship’s hull is pulled towards the recycling yard during high tide because the aft part of the hull gets partially lifted due to buoyancy and significantly lessens the load on the winches. Before pulling operation, adjacent recycling facilities are alerted beforehand. Throughout this critical operation, none of the other tasks are allowed in the yard. 

Following the winching operation, the steel wire ropes are coiled and stored in the trays adjacent to the winches. Qualified inspectors regularly inspect the wires for any kinks, broken strands, corrosion, and any other defects. It helps to assess the real condition of the wires and the need for replacement. 

With the use of heavy-lift capacity cranes with more extended booms, larger slices are cut and lifted from the ship’s hull and kept on the secondary cutting zones, minimizing the use of winches to pull the hull.

The process of pulling the hull is periodic and needs to be conducted with absolute care and precautions. Few recycling facilities use the load cells to monitor the load applied on the wires as they have understood the significance of monitoring load. And they have developed the Standard Operating Process to execute these critical tasks seamlessly without any incident and accident. 

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Demystifying Ship Recycling - Issue 19

Used and unused spare parts recovered during ship recycling

Ships run round the clock transporting raw commodities and finished goods across the continents. Even in pandemic times, when the entire world was at a standstill, ships ran and kept global supplies uninterrupted. Did we ever wonder who keeps these ships moving? The answer is simple and straightforward: the machinery installed on ships and the seafarers who operate them.

An oil tanker takes around 18 days to sail from a load port in Arabian Gulf to a Far East discharge port. It simply means the Main Engine and other auxiliary machinery that started operating when the vessel is in Arabian Gulf will continuously run for the remaining 18 days to arrive in the Far East.

Machinery parts are subjected to have wear & tear and breakdowns because of nonstop operation. For the smooth functioning of this machinery, it is critical to carry out regular planned maintenance. Ships are supplied with adequate spare parts throughout her life for conducting planned maintenance and troubleshooting. These spare parts are periodically used to replace old used spares. Used spares are recovered and often reconditioned for reuse.

It is mandatory for ships to maintain an adequate inventory of critical spare parts. When ships complete their useful life, they are sent for recycling. The vessels delivered for recycling often carry used and unused spares. Ship recycling facilities recover these spares and sell them in the secondhand market. There are clusters of at least 700 shops along the road leading to Alang beach, India. These shops buy the recovered spares and stock them at the warehouse. Similar spares clusters are found in Chittagong, Bangladesh. 

spare parts recovered during ship recycling

The secondhand market covers all types of spares for the machinery used onboard vessels. Some vendors stock only specific types of spares. It is usual to find vendors who stock and sell only anchor and anchor chains. Some vendors stock the spare parts for the Main Engine, such as piston crowns, piston rings, liners, etc. 

In fact, some vendors stock critical spares for pneumatic and hydraulic systems. It is common to see a warehouse with only lathe machines and emergency generators storage.

It is easy to discover the spares for machinery at Alang, whose manufacturing is stopped by the original makers. Some of these spares are critical and need to be connected at short notice. 

Recovery, resale, and reuse of the spares from recycled vessels is the true example of the Circular Economy. The spares not only generate value but also serve the ships in critical moments. 

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Demystifying Ship Recycling - Issue 18

Infrastructure for Treatment, Storage and Disposal of Hazardous Waste at Alang

It is widely criticized that recycling facilities do not have adequate procedures and infrastructure to collect and dispose of the hazardous waste recovered from the ships during the recycling process. However, it is critical to know and understand the infrastructure available at Alang. 

Gujarat Maritime Board (GMB) is the regional regulatory body supervising recycling activities in Alang, India. GMB constructed the landfill site and assigned Gujarat Enviro Protection Infrastructure Limited (GEPIL) as an operator for the Treatment, Storage, and Disposal of hazardous waste recovered from the vessels during the recycling process. The first facilities were constructed in 2005-2006. The facilities had the following cells and capacities.

  • Asbestos and glass wool disposal cell: 43,000 M3
  • Industrial hazardous wastes: 10,200 M3  
  • Municipal solid waste: 8,700 M3

When the capacity of the above landfill cells was about to complete, GMB expanded the earlier capacity in 2013 to new landfill cells of a total of 100,000 M3. The facility was further upgraded by installing a separate oily bilge water treatment plant that can treat bilge water recovered from the ships. The separated oil is stored in the designated tanks until enough is accumulated. To burn the oil, an incinerator plant was installed. A key point to note, the separated water is stored in the underground and overground tanks, which can be used as firefighting water for the incinerator. Excess water is used for trees planted on the site. With the addition of an incinerator and bilge water treatment plant, the GEPIL site became a fully integrated waste management facility.

Infrastructure for Treatment, Storage and Disposal of Hazardous Waste

The existing capacity of the GEPIL Treatment Storage Disposal Facility (TSDF) at Alang is as below:

  • Landfill cell for hazardous waste: 70,000 M3
  • Landfill cell for municipal solid waste: 35,000 M3
  • Common hazardous waste incinerator: 5 MT/day
  • Fire Fighting System, Underground reservoir: 200 M3
  • Effluent treatment plant: 30 M3 / day

It is evident that the recycling facilities have sufficient infrastructure to dispose of hazardous wastes. HKC compliant recycling facilities hand over the segregated waste only to GEPIL against the receipts. Waste disposal is appropriately documented. Since its inception, GEPIL has managed 65,000 MT of ship recycling waste.

The commitment shown by the local regulatory bodies and yards for sustainable ship recycling is commendable.  

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Demystifying Ship Recycling - Issue 17

Training imparted to recycling facility workers by Gujarat Maritime Board

In the 16th issue of Demystifying Ship Recycling, we discussed free compulsory training imparted to the yard workers to upgrade their skills and awareness. However, the recycling yards have HSE Officers and Supervisors who monitor the yard workers' day-to-day activities. Gujarat Maritime Board (GMB) has developed workshops and seminars to train the workers who perform managerial jobs and lead smaller teams. 

a. Hazardous Materials Manager's Course: 

The content of the course includes identification, extraction, and storage of hazardous material from the ships


b. Ship Recycling and Toxic Health Hazard:

In this course, the health hazards related to exposure to toxic materials are discussed.


c. Use of multi-gas detectors

The use of multi-gas detectors is crucial before making man-entry to the confined spaces and before commencing the hot work. The participants are trained for the correct application of the multi-gas detectors.


d. Advanced First Aid and Basic Life Support Safety in Plot

It is essential for workers to understand the first aid and the basics of life support to respond appropriately in an emergency onboard vessel and at the shipyard.


e. Environment and Safety Risk Assessment 

Risk assessment is foremost and should be conducted before commencing any physical work onboard vessel. The associated risks with specific jobs should be identified and mitigated as per the Risk Matrix. The participants are trained to carry out not only safety risk assessment but also environmental risk assessment.


f. Operations of Crane and Winches

Ship recycling cannot be imagined without cranes and winches. In this training, participants are trained for the Cranes and Winches' proper operations and hazards associated with the crane and winch wires.


g. Work Stress Management

In this workshop, the participants are educated about managing the stress related to work. Due to a hectic day-to-day lifestyle, it is evident that someone gets stressed, and it's paramount to understand work stress management. 


h. Handling of Asbestos

In this workshop, participants are explicitly trained to handle Asbestos. The workshop covers training for identification, extraction, segregation, and disposal of Asbestos. 


i. Work Permit Systems

Shipyard workers have to perform different tasks like enclosed space entry, hot work, working at height, etc. Filling a permit before the beginning of the work is vital for communicating critical safety information. The workshop explains the significance of the work permits and how to fill them effectively.


j. Fire Safety Awareness onboard vessel and in the plot

Ship recycling is impossible without gas cutting. There is always a hazard associated with fire, and it is crucial to make participants aware of the fire safety onboard vessel and at the plot.

It is worth noting that periodic Refresher courses are conducted to ensure workers are up to date with evolving safety standards and safe working practices. In case of any incident, learnings from the incident training are undertaken to prevent such events in recycling facilities. The effectiveness of training is evaluated by written & oral exams and issuance of a certificate. GMB provides all trainings for free of cost keeping the workers' safety at the forefront. GMB is persistently imparting such training over the last two decades. 

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