ACI-conference Ship Recycling Amsterdam 29/30 January 2020
Tradewinds Ship Recycling Conference 3/4 March London

Like in 2019 ACI had organized  a ship recycling conference in Amsterdam , this time followed by a conference in London four weeks later.
ISRA was well represented, by various speakers. IHM, was in the light of the actuality an item that was getting much attention from a number of speakers.

Dimitri Ayvatoglu

Dimitri Ayvatoglu, board member ISRA,  gave an overview of the existing international regulatory frame work relevant to ship recycling.  He presented a matrix of applicability of regulations.(see attachment). He clearly  made a distinction between the regulations concerning the recycling proces as such and the relevant issues concerning the export of waste. He gave an extensive overview including the situation where the HKC comes into force. 


Antonio Barredo, member of the European Ship Recyclers, referred to the regimes concerning the exports of waste. He also emphasized the short comings of the present regulation, illustrating with pictures (abandoned) vessels in EU-waters not flying a EU-flag. 

Dr. Ishtiaque Ahmed

Dr. Ishtiaque Ahmed is the Chairman, Department of Law, North South University, Bangladesh (ACI)

He had made a very convincing gap analyses of the Bangladesh regulatory and practical frame work and the HKC. He showed a very detailed and elaborated worked out overview of the shortcomings which Bangladesh are facing Bangladesh to enter the HKC (Let alone a place on the EU-list).  

Director ISRA , Reinoud Pijpers

Reinoud Pijpers explained the difference between the concept of level playing field as ISRA is using this item and some shipowners. He explained that all members of ISRA had been substantially invested in various fields to enable sound and safe ship recycling.
These ISRA-members are confronted with a unequal level playing field.

Since there is no global regime for ship recycling, some  shipowners claim that this lack of globality , means an unequal level field: they have to choose- as far as applicable-  between EU-SRR, HKC certified ship recycling yards and the beaches. Shipowners choose by far  for the most profit, the beaches. Pijpers pointed out that those two concepts of level playing field are not comparable.

Peter Koller , European Commission

Peter Koller from the European Commission gave an update on the EU-list:

  • Several pending applications from yards located outside the EU;
  • 30 open applications (5 Turkey, 20 India, 4 China, 1 USA)  Assessment process at different stages many facilities already inspected
  • Specific situation for applicant yards located in China;
  • EU-specific requirements applying to ship recycling facilities;

Important criteria:

  • “The facility operates from built structures” (article 13.1.c);
  •  “The facility prevents adverse effects on human health and the environment, including the demonstration of the control of any leakage, in particular in intertidal zones” (article 13.1.f);
  • “Handling of hazardous materials, and of waste generated during the ship recycling process, only on impermeable floors with effective drainage systems” (article 13.1.g.i);
  •  “The facility ensures rapid access for emergency response equipment, such as fire-fighting equipment and vehicles, ambulances and cranes, to the ship and all areas of the ship recycling facility” (article 13.1.h)
  •  Standards for downstream waste management: “broadly equivalent to EU and international standards” (article 15.5)