Guidance

Guidance on completing ship recycling facility plans

Published 16 February 2016

Applies to England, Scotland and Wales

• Publication for Northern Ireland

1. Facility management: environment

1.1 Operator Information

You must:

• set out your organisational structure, showing how you control your operations
• give a detailed summary of your experience relevant to ship recycling, including, for example, qualifications, previous roles and length of time in the industry
• provide the roles, responsibilities and qualifications of management and all important personnel to demonstrate their ability to perform their relevant roles
• provide any policy statements or other relevant documentation to support how you’ve prevented, reduced, minimised, and where practical, eliminated adverse affects on the environment

1.2 Training

You must:

• provide appropriate worker training
• detail the information on (or suitable links to) training procedures

Training programmes should cover all workers and members of the facility (including contractor personnel and employees) and identify the type and frequency of training.

You should also show how you regularly check that training and qualifications are up to date.

1.3 Records management

You must show how you keep appropriate documentation of all waste generated from your ship recycling activities, including the waste:

• types
• quantities
• storage techniques
• next destinations (note: the next destination must be a facility authorised to accept the specific waste types)

You must detail your procedures for recording incidents and accidents, relating to human health and / or the environment.

You must also detail, or refer to, any policies and procedures for retaining any other records associated with facility operations and, specifically, the recycling of each ship.

2. Facility operation: environment

2.1 Facility information

You must provide:

• a clear, concise description of the physical location of the facility, including total area and access routes as well as proximity to sensitive receptors and any sensitive environmental designated areas
• annotated drawings or maps clarifying where recycling operations will occur, type of dock(s) used, their capacity and other pertinent details
• details of operational equipment, including the quantity, capacity and type of such equipment and other relevant information such as test certificates, safe working load and operator qualifications

You should:

• describe the workshop area used to strip down recycled equipment, make general repairs or conduct maintenance on the site’s equipment
• provide details of access control systems to demonstrate you have sufficient security measures in place
• set out any additional controls for staff involved in dismantling ships

2.2 Acceptance of ships at the facility

You need to work out the facility’s total estimated ship recycling capacity, including the production throughput or capacity of waste materials. This should:

• take into account the logistics of waste segregation and processing
• include annual tonnage capacity as well as number of vessels that can be held or recycled concurrently

2.3 Vessel arrival and management

You should:

• be able to demonstrate how you ensure the vessel is stabilized on arrival
• show how you’ll ensure it remains so throughout the whole dismantling process
• include provisions for mooring, stability during recycling and sinking prevention methods
• consider severe weather disruptions

2.4 Decommissioning structure

You must operate from built structures. You should demonstrate this by describing the structure(s) on which the decommissioning will be carried out. You should detail all docking and berthing facilities used for both storage and dismantling of vessels.

Acceptable structures are:

• dry dock: this method generally allows for greatest control of accidental spillage and provides land access around the whole ship
• floating dry dock (or flat top barge): submersible structures where the ship is positioned over the submerged dry dock and water pumped out until the ship is clear of water - the structure may be susceptible to damage during dismantling operations, so you would need to manage constantly
• slipway: this is a sloping concrete hard standing where the ship will be hauled up above the high water mark for dismantling - procedures must be in place to ensure the ship remains in a stable condition during disassembly and that any contamination is contained
• wet berth: within a wet berth the ship is moored on the quayside whilst being dismantled - you can use this option to remove the internal components of the hull, but you must take care with the ship’s stability and remove the vessel from the water to strip the hull

Grounding a vessel on a beach or river bank is not an environmentally suitable option. You must not dismantle a vessel using this option – you will not gain authorisation for this in the UK.

2.5 Reporting upon completion

You must send a statement of completion to the competent authority within 14 days of completing the recycling operation. Include a report on incidents and accidents damaging human health and / or the environment.

3. Environmental compliance

3.1 All waste management

You must ensure all wastes generated from ship recycling activities are managed in a safe and environmentally sound way. You must describe your processes, control procedures and capabilities in relation to this, detailing any short and long term storage procedures. You must indicate how you will avoid waste being mixed or contaminated in a way that interferes with subsequent handling, storage, treatment, recycling or disposal.

3.2 Environmental monitoring

You should:

• detail your procedures to prevent, reduce, minimise or eliminate adverse impacts on the environment
• have detailed environmental management systems - include any formally recognised international standards for environmental management systems you’ve applied for and any other relevant certification you’ve been awarded

4. Facility management: health and safety

You must ensure safe and environmentally sound management and storage of hazardous materials. This includes the:

• containment of all hazardous materials present on board during the entire ship recycling process
• handling of hazardous materials during the recycling process

You should fully describe your processes, control procedures and abatement methods for dealing with hazardous materials. See the Environment Agency’s hazardous waste guidance for more information:

4.1 Transportation and disposal

You must ensure all wastes generated are documented and only transferred to waste management facilities authorised to deal with their treatment. You must detail your procedures for documenting and transferring waste, including tracking procedures and record keeping.

4.2 Paints and coatings

When detailing hazardous waste management procedures, you should show the Environment Agency how you manage any paints or coatings which are highly flammable or have potential to release toxins during cutting. This could include anti-fouling compounds and systems, toxic and highly flammable paints, hazardous liquids, residues and sediments, heavy metals and any other hazardous wastes.

4.3 Debris prevention and control

Operators may be asked to detail what measures will be implemented to minimise potential for debris deposition to water. You should include maintenance of any areas affected by wind, storm drains, tides or run-off.

4.4 Spill prevention, control and countermeasures

You must demonstrate control of any leakages, particularly in inter-tidal zones. You must detail your procedures for prevention, response and countermeasures to spills and storm water contamination, including procedures implemented in the event of such incidents.

4.5 Incident and spills reporting procedures

Competent authorities may ask operators to describe their procedures for reporting incidents and spills. Operators should give details of relevant roles, responsibilities and reporting methods, as well as how the community is informed. You may also be asked for details of how post-incident surveys and reports are carried out.

5. Facility operation: health and safety

Any facility undertaking ship recycling activities will need to manage and control risks to health and safety. In particular you must include information on:

5.1 Company information

You should include:

• your policy statement on your commitment to health and safety, including an explanation of the objectives you’ve set to control the risks to workers and those living near the facility
• your system for achieving the objectives and goals and the continuous improvement of facility performance

5.2 Training

You should include detailed information on (or suitable links to) training procedures undertaken by staff to ensure the appropriate level of health and safety protection.

You must provide:

• appropriate worker training
• information on (or suitable links to) training procedures

Training programmes should cover all workers and members of the facility (including contractor personnel and employees) and identify the type and frequency of training.

You should also show how you regularly check that training and qualifications are up to date.

5.3 Records management

You should detail or refer to the policies and procedures you use for retaining vital records associated with incidents or accidents impacting health and safety.

5.4 Confined spaces

You should detail procedures for identifying and assessing areas in the ship that might be confined spaces, including management of any confined space work. See guidance on confined spaces.

5.5 Hot work

You should describe the procedures for assessing and managing hot work.

5.6 Drums, containers and pressure vessels

You should summarise procedures for safe and secure handling, transport and storage of pressure vessels containing flammable gases, ozone-depleting substances and hazardous liquids.

5.7 Maintenance and decontamination of tools and equipment

You should detail procedures for the inspection and maintenance of equipment, regulatory requirements for third-party inspections and decontamination procedures, including details of how these inspections are recorded.

5.8 Personal protective equipment (PPE)

You should detail what PPE is provided for carrying out ship recycling activities. Include details of storage and how provision is monitored to ensure staff have all the equipment they need.

5.9 Emergency preparedness and response plan (EPRP)

You should provide a copy of the facility’s EPRP. Operators should confirm how staff are made aware of the EPRP, and where copies of it are available.

6. Further information

European Regulations

UK Ship Recycling Facility Regulations 2015

UK ship recycling strategy

International Maritime Organisation (IMO) guidelines

Marine Consents and Environment Unit