7 Site Inspection
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Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee - Resolution MEPC.211(63) – 2012 Guidelines for the Authorization of Ship Recycling Facilities – (Adopted on 2 March 2012) - Annex – 2012 Guidelines for the Authorization of Ship Recycling Facilities - 7 Site Inspection

7 Site Inspection

 Site inspections should be conducted at Ship Recycling Facilities. The Competent Authority(ies) is responsible for planning and undertaking the site inspection. The site inspection may involve, or use the guidance and reports of, local or national labour inspection services.

 The main purpose of the site inspection is to check the consistency of the documentation with the actual arrangements and operations at the Ship Recycling Facility.

 The first site inspection should be announced in advance to the Ship Recycling Facility, in order to ensure that it will be possible to meet all relevant persons.

 In advance of, during and following the site inspection, any necessary information should be provided by the Ship Recycling Facility.

 Safety issues should be considered and sufficient precautions taken throughout the site inspection, including with respect to personal protection.

 The inspection should address the functionality of arrangements established, focusing on safety and environmental protection and the handling of all materials including hazardous wastes and debris. The inspection should cover situations in which the Ship Recycling Facility is operating at maximum capacity with a full body of staff, including subcontractors.

 The site inspection should verify that a SRFP exists and that it is being fully implemented. In particular, the following factors should be verified:

  • .1 availability of the SRFP to all personnel at the Ship Recycling Facility;

  • .2 knowledge of the SRFP, as appropriate, among management, Competent persons and workers according to their designated tasks, roles and responsibilities, including those with special duties such as first-aid personnel and fire fighters, as assessed through interviews with all categories of personnel and supervision of drills if appropriate; and

  • .3 implementation of the objectives of the SRFP, as demonstrated by implementation of operational procedures in:

    • ship preparation processes;
    • monitoring of Safe-for-entry and Safe-for-hot-work conditions;
    • deconstruction processes;
    • hot work processes;
    • management of Hazardous Materials and wastes (protective measures and removal, transport, storage and disposal); and
    • emergency preparedness.

 The site inspection should identify procedures and routines for the following:

  • .1 developing and using the Ship Recycling Plan;

  • .2 accepting ships, taking into account relevant requirements and the required certificates;

  • .3 reporting and following up incidents; and

  • .4 conducting operations in a safe and environmentally sound manner, in accordance with the regulations of the Convention.

 The site inspection should verify the availability, size, restrictions and general set-up of the Ship Recycling Facility as stated in the application. Any arrangements established for the purpose of facilitating the recycling process should be described in the inspection report, as should any limitations related to the operation of the Ship Recycling Facility.

 All sites utilizing established procedures, methods, arrangements and facilities for the removal, storage, processing (incineration, reclamation and specific treatment), transport and disposal of Hazardous Materials and wastes should be inspected. The inspection should verify that the Ship Recycling Facility is designed and constructed to manage any Hazardous Materials and wastes that are included in their application.

 In cases where the Ship Recycling Facility is engaging one or more contractors by means of subcontracting for any activities related to the requirements of the Convention, the contractors should be subject to the same verification as if the Ship Recycling Facility itself was undertaking the activities. The Ship Recycling Facility is responsible for providing the Competent Authority with information required to perform a verification on the aforementioned contractors, as part of the overall assessment of the Facility.

 Furthermore, the site inspection should include a practical test for assessing the implementation of measures relating to emergency preparedness and response. This may involve an unannounced complete evacuation of the Ship Recycling Facility or a similar procedure described in the plans for emergency preparedness and response.

 The Competent Authority(ies) should have procedures in place for providing detailed information and analysis of the authorization process to the Ship Recycling Facility. Such procedures could include a written report by the Competent Authority(ies), to be made available to the Ship Recycling Facility, containing inspection data and an evaluation of findings.

 The supplement to the DASR (appendix 5 of the annex to the Convention) may be used as guidance in planning site inspections.

 If the Ship Recycling Facility is under construction or not fully operational, the site inspection should be conducted as far as practicable, and the Competent Authority(ies) may issue the DASR subject to certain terms and conditions as appropriate. In such a case, an additional, follow-up site inspection should be conducted after the Ship Recycling Facility becomes fully operational. According to the results of the follow-up site inspection, the Competent Authority(ies) may suspend, amend or withdraw the DASR.

Parent topic: Annex – 2012 Guidelines for the Authorization of Ship Recycling Facilities
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