Section 4 - Environmental Compliance Plan
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Statutory Documents - IMO Publications and Documents - Circulars - Marine Environment Protection Committee - MEPC/Circular.419 – Guidelines for the Development of the Ship Recycling Plan – (12 November 2004) - Annex - Guidelines for the Development of the Ship Recycling Plan - Section 4 - Environmental Compliance Plan

Section 4 - Environmental Compliance Plan

  4.1 The Environmental Compliance Plan (ECP) should serve as the primary basis for evaluating the degree to which the ship recycling facility:

  • .1 understands the environmental risks associated with ship recycling;

  • .2 understands and implements the environmental requirements imposed by national and international laws and regulations;

  • .3 can manage and dispose of all the materials used in the structure of the ship, its equipment and/or on board the ship in an environmentally sound manner; and

  • .4 implements controls to protect the environment, which include handling and disposing of the hazardous materials.

  4.2 The ECP should include information on the recycler's ability to recycle ships and dispose of the resulting materials in a manner that is compliant with applicable national and international laws, regulations, and guidelines. Further, the ECP should reflect the applicable national legislation and, where appropriate, the Basel Convention "Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships".

  4.3 Elements of the ECP

  • 4.3.1 The ECP should provide a clear and concise explanation of procedures for managing potentially hazardous materials, including, but not limited to:

    • .1 fuel, lubricants, and coolants; chemicals in drums, buckets, pressurized bottles, stored solvents, and other chemicals stocks, etc.;

    • .2 cargo residue;

    • .3 floatable materials (e.g. plastics, Styrofoam insulation wood);

    • .4 materials possibly containing PCBs, such as wiring insulation (electrical cabling installed before 1975) (plastic covering may contain PCBs)footnote;

    • .5 waste water/sludges (generated aboard the vessel during the scrapping process from rain water intrusion, fire fighting, asbestos control activity, etc., as well as water that may be in compartments of the vessel at the time of arrival); human waste in the form of sewage or gray water; residues of ballast water;

    • .6 harmful aquatic organisms, non-indigenous species and marine growth in ballast water and on the hull, and sediments in ballast tanks;

    • .7 asbestos used in older ships as insulation material and in accommodation panelling (includes bulkhead and pipe insulation; bulkhead fire shields; electrical cable materials; brake linings; floor tiles and deck underlay; steam, water and vent flange gaskets; flexitalic gaskets; garlock seals; packing material; pipe hanger inserts; and weld shop protectors and turn covers);

    • .8 chromium (ballast water treatment, paint coatings, gaskets, etc.);

    • .9 TBT paints; and

    • .10 environmental monitoring.

  • 4.3.2 Items on ships that may potentially contain substances of concern include those identified in section 4.2 of the IMO Guidelines.

  • 4.3.3 In identifying potentially hazardous materials on board ships the list of "Potentially hazardous materials which may be on board ships delivered to recycling facilities" (appendix 2 of the IMO Guidelines) should be considered for guidance.

  • 4.3.4 The ECP should identify all permits, certificates, approvals, and licences required by international, national and local environmental agencies and issued to the recycling facility to carry out the work, including those required for the management of potentially hazardous material.

  • 4.3.5 The ECP should identify all entities to be involved with the process. This includes sub-contractors involved with recycling operations at the site, and those who test, transport and provide the disposal site/method. Copies of licences, approvals, permits, and insurance, etc. should be included.

  • 4.3.6 The ECP should include a copy of the site's spill prevention and/or spill response plan. Information related to on-site water discharge requirements should be included.

  • 4.3.7 The ECP should describe whether the recycling facility, any parent companies, subsidiaries or affiliates or any proposed subcontractors, disposal facilities, within the past five years has received any fines, notices, deficiencies, etc. from any regulatory entities or third party environmental auditors.

Parent topic: Annex - Guidelines for the Development of the Ship Recycling Plan
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