Introduction-

Most types of ships require help with cargo operations in port, and the shore labourers that provide this are known variously as ‘dockers’, ‘longshoremen’ or ‘stevedores’.

A brief history

Ships have always been valuable and have always been recycled. They are the greatest assets ever moved in bulk, assets which represent such investment that entire new systems of banking and government have been designed to finance them.

Given their value, it is inevitable that ships do not simply disappear once they are no longer seaworthy. The wood in the earliest dugout canoe would have provided walls and shelters, the fittings on a Viking longship would have benefited the local village where she was laid to rest, and the copper on a ship’s bottom and the long, high-quality timber of her mast and strakes would have been invaluable in future construction projects. Famous examples exist in London alone: the department store Liberty is constructed from the timbers of the fighting ships HMS Impregnable and HMS Hindustan.


As shipbuilding advanced, wood gave way to iron and steel. These ship metals were of the highest quality available. As a result, ship scrapping played a major part in resourcing the industrial revolution.

World War II also left a vast amount of steel locked up in redundant warships and cargo ships (some in the US fleet are still awaiting scrapping). These ships were scrapped at places such as Inverkeithing in Britain and yielded in total approximately 500,000 tonnes of high quality steel.

After the war, ship scrapping continued in places such as La Spezia, Italy, and Japan. However, as the ship building industry shifted eastwards in the 1970s, so did the scrapping industry.

Taiwan was the principal destination, and ships were broken literally in the centre of Kaohsiung port, until, on August 11, 1986, an explosion and fire on board the tanker Canari killed 14 people and injured 47 more. Due to a huge public outcry, what had been an unregulated industry in Taiwan suddenly became subject to a major crackdown. As is typical within the waste sector, the ship scrapping industry moved, overnight.

At exactly this time, Alang, a coastal town in the Indian state of Gujarat, experienced its first major growth spurt in scrapping. Gujarat Maritime Board records the first ship scrapped at Alang as the MV Kota Tenjung, beached on February 13, 1983. Reports indicate that by 1989 the number of employees in Alang had reached 40,000 Bangladesh and Pakistan followed suit.

The shipping industry was slow to notice these developments. This isn’t so surprising. Waste is often ‘out of sight and out of mind’, and when a ship changes hands for scrapping, the original owner is commonly unaware of its destination.

However, there was a growing realisation that working conditions at ship recycling locations were extremely hazardous, and not only in the Indian subcontinent. Will Englund from an American newspaper, The Baltimore Sun, first became aware of the issues surrounding ship recycling in 1995 when the aircraft carrier USS Coral Sea was being scrapped in Brownsville. Problems with the scrapping of this ship had resulted in the company responsible being prosecuted for the first environmental violations within the US ship-breaking industry. The owner, Kerry L. Ellis, was convicted under the Clean Air and Clean Water Acts and died in prison in 2000. Englund dug deeper. He teamed up with the Investigative reporter Gary Cohn and between them they ran a series of articles exposing the worst excesses of ship-breaking around the world. In April 1998, they won a Pulitzer Prize.

The road to regulation

By the late 1990s, pressure was building on the shipping industry. The 1st Global Ship Scrapping Summit was held in Amsterdam in 1999, a year after Englund and Cohn’s prize win. This was just one indication that attitudes were beginning to change and that the industry was realising the need for more responsible ship recycling.

An ‘Industry Working Group on Ship Recycling’ was rapidly formed under the chairmanship of the International Chamber of Shipping (ICS), consisting of the major shipping industry bodies. This Group delivered the first practical guidance on ship recycling – the Industry Code of Practice on Ship Recycling – in August 2001. This document contained guidelines on achieving safer and more environmentally sound ship recycling, and crucially created the concept of the ‘Green Passport’ (or ‘Inventory of Hazardous Materials’ as it is now known). The Code is still in use today.

The International Maritime Organization (IMO) was also spurred on by the shipping industry’s initiative. The subject was formally introduced at IMO’s 43rd Marine Environmental Protection Committee (MEPC) in 1999 when Norway proposed a new work item on ship scrapping. At MEPC 44 a correspondence group was set up under the chairmanship of Bangladesh and at MEPC 46 in April 2001 a Working Group was established.

The Basel Convention published Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships in 2003, and the International Labour Organisation (ILO) published Safety and Health in Shipbreaking: Guidelines for Asian Countries and Turkey in 2004

In December 2003,the IMO published Guidelines on Ship Recycling which relied heavily on the Industry Code of Practice and introduced the Green Passport concept. The world’s first ‘Green Passport’ was issued for the Shell LNG Tanker Granatina in 2004.

Despite the IMO Guidelines, there was still potential for confusion for owners wishing to recycle their ships, especially given the other recycling-related legislation which existed – legislation such as the Basel Convention. The only way forward was to create statutory requirements by developing a legally binding international convention.

The text was developed over three and a half years with input from IMO member states and relevant non-governmental organisations, and in co-operation with the International Labour Organization and the Parties to the Basel Convention. Such was the impetus at the IMO that the deadline was achieved and the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships was adopted in May 2009.

Like all IMO Conventions, it will only enter into force when the requisite number of member states has ratified it. At the time of writing the blog, this would be 2014 at the earliest.   Recycling methods

Beaching

It has become common practice to employ riding gangs to assist with onboard maintenance and other tasks – and, more recently, armed guards for the protection of the ship and its crew against piracy attacks. But, there do not appear to be any internationally accepted guidelines on the employment conditions for these gangs nor for the tasks on which they can be employed aboard ship, such that there is a risk that riding gangs can be used to bypass the regulations that apply to a ship’s crew.

The International Transport Federation (ITF) advises that riding gangs must be covered by agreements giving at least comparable rates of pay to the crew, and minimum conditions and protections.

The US Coast Guard, through their Maritime Transportation Act of 2006, defines a riding gang member as: someone who is not a registered seafarer and who does not perform watchstanding, automated engine room duty watch, or personnel safety functions; or cargo handling functions, including any activity relating to the loading or unloading of cargo, the operation of cargo-related equipment (whether or not integral to the vessel),
and the handling of mooring lines on the dock when the vessel is made fast or let go; does not serve as part of the crew complement; and is not a member of the steward’s department.

Ocean dumping is a topic that has been the subject of a good deal of public scrutiny over the last several years. Traditionally, when considering restrictions on ocean dumping in the United States the vessel operator may have customarily looked to the widely adopted provisions set forth in MARPOL 73/78. These guidelines, as drafted by the International Maritime Organization, were adopted and implemented in the United States in 1980 as part of the Act to Prevent Pollution from Ships (APPS).
However, it may not be widely known that these guidelines are superseded by a more stringent regulatory scheme known as the Ocean Dumping Act (ODA) that became law in the United States in 1972 and for which the Environmental Protection Agency (EPA) has been an absentee enforcer.
 
The Ocean Dumping Act, which “prohibits the transporting of any material from the United States for the purpose of dumping it into ocean waters”, was enacted to establish a “no tolerance” policy prohibiting all ocean dumping of waste from the US and was crafted in such a way as to allow the EPA substantial latitude should it decide to police the regulation. Moreover, and perhaps most importantly, the language “for the purpose of” essentially gives the EPA the right to initiate legal action even if it is found that the vessel simply acted with an intention to dump waste material from the US, which itself constitutes a violation.

 In such cases the EPA has the discretion to commence civil or criminal litigation against violators and, at the extreme, punishment can result in the forfeiture of the vessel.

The ODA regulation is straightforward. Material prohibited from being dumped is classified as “waste”. Material becomes waste when it no longer has a specific purpose in the transportation of goods. An illustrative example is the function of dunnage in the bracing of steel cargo. Wood used for this purpose is “dunnage” when being used to secure the steel in transit. If the steel is discharged in the US, then the dunnage no longer serves a useful purpose and becomes “waste” from the US. “Material” is defined as matter of any kind, including but not limited to solid waste, garbage and other waste.

The US Coast Guard Captain of the Ports offices have traditionally been tasked with enforcement of ocean dumping regulations; however, historically personnel in these offices have themselves seldom been aware of ODA regulations or their supervisory role in enforcing them. In fact, on at least one occasion a vessel requested clarification from the US Coast Guard concerning dumping of material permitted by Marpol 73/78 and received permission to do so, only to discover that such action would violate the Ocean Dumping Act. The EPA have investigated and later initiated proceedings against the vessel and its crew.

Nevertheless, the EPA retains the right to become involved in an investigation at any time and in a supervisory capacity.

It should be noted that the EPA has typically abstained from an active involvement in maritime matters, and that Marpol 73/78, Annex V, while permitting the overboard discharge of certain ship-generated waste, strongly recommends that disposal be undertaken at port reception facilities.

Moreover, the EPA advises that a vessel forced to discharge waste as the result of an emergency situation endangering the vessel or the lives of the crew could become the subject of an investigation but will generally be absolved of liability. Because the US government has wide discretion in deciding whether or not to investigate, much less prosecute (“prosecutorial discretion”) possible statutory violations and because the EPA only recently has shown interest in ODA in the context of blue water merchant shipping, it is difficult to categorically say to what situations and how vigorously the US
Coast Guard or EPA may decide to apply the Ocean Dumping Act.

 It is hoped that the Coast Guard’s expected publication of a new regulation and public comment thereafter will result in clarifying the intentions of the Coast Guard (and of the EPA).

Make the decision to get into sailing and chances are the first thing you’ll discover is the sheer volume of sailing courses being offered across the UK – there are quite literally thousands of them.

Not that this is a negative thing in its own right, but it does mean that those behind the courses are forced to justify themselves as key industry players and standout examples.

An explanation of the processes of dangers -

Solid bulk cargoes can shift by sliding or liquefying, and whilst the factors involved in each of these processes are different, the potentially disastrous consequences are the same – listing or capsizing and/or structural damage.

Dense cargoes, e.g. ore concentrates, have by definition a relatively high mass to volume ratio, so even a small amount of shifted cargo can have a large mass. Coupled with the momentum generated by a moving vessel considerable forces can act upon the ship’s structure.
This force will be even greater when the cargo level within the hold is above the sea level outside the hold, so that the counter-acting force of buoyancy is absent

Add to this the frequent occurrence of multiple or repetitive shifts and the result can be excessive plate flexing increasing the risk of cracking and failure.

In terms of stability, shifting cargo can have numerous consequences. The shift in cargo will cause a list if the cargo does not return to its original position with subsequent vessel movement.

Apart from increased draft concerns, the angle at which the vessel is listed will, if uncorrected, become that about which the vessel rolls. This will usually mean that the righting lever for angles of heel towards the side the vessel is listed will be less than that when the vessel is heeled from her upright position, which in turn means that the force returning the vessel from angles of heel beyond the angle of list, back to the same angle, will be less than the force returning the vessel to the upright had she not been listed.
The angle of deck edge immersion will also be closer than that for an upright vessel and if this is reached stability will also be reduced. A list will also tend to subject the vessel to greater angles of heel and this may give rise to a domino effect causing other cargo and objects to break securings and/or to shift.
Solid bulk cargoes that shift from one side of the vessel to the other with the rolling of the vessel, that is to say, cargoes behaving like a liquid in a part-filled tank, will also give rise to a Free Surface Effect, and this again will reduce the vessel’s stability in a similar way to that described above.

The gravest consequence of shifting is capsizing of the vessel, and this can happen when multiple shifts occur with little return of cargo to original positions. This process can be very quick and obviously disastrous.

Sliding occurs when the cohesive strength, or “stickiness” of the cargo, is insufficient to withstand the effects of rolling. Cohesive strength varies according to moisture content and the height of the stockpile.

A good illustration of this is provided by sand. Wet or dry there is a limit on the height of a pile of sand, but damp sand tends to permit a higher sand pile. A common example of a cargo prone to sliding is grain (The term grain includes wheat, maize, oats, rye, barley, rice, pulses and seeds.), which is particularly free flowing.

The International Maritime Organisation (IMO) Code of Safe Practice for Solid Bulk Cargoes 1991 states (at Para 5.2.4.2) that “non-cohesive bulk cargoes having an angle of repose.( The angle which the cargo naturally, and of its own accord, makes with the horizontal.) less than or equal to 30 degrees flow freely like grain and should be carried according to the provisions applicable to the stowage of grain cargoes”.

The stowage and carriage of grain is governed by the IMO Grain Rules 1982 which set out a number of requirements including specific stability criteria.

There is also some industry authority to support a theory that sliding can also occur when, due to downward moisture migration, a saturated base layer (which need not be liquefied) is formed allowing the upper, relatively drier layer, to move against it.

Liquefaction of solid bulk cargoes depends on particle size and distribution as well as moisture content. The former determines whether moisture can drain freely through the cargo, and will obviously change during a vessel’s voyage due to vibration, rolling, pitching and twisting. The effect of this movement is to break down lumps of cargo and reduce the space between particles – effectively compacting the cargo.
Moisture can then become trapped between cargo particles and if there is sufficient saturation a flow state can develop. The point at which this occurs is called the Flow Moisture Point (FMP) and is usually expressed as a percentage of the moisture content.
The IMO Bulk Cargo Code referred to above adopts what is known as the Transportable Moisture Limit (TML), and this is the maximum moisture content of a cargo deemed safe for carriage by sea in ships other than “specially designed ships”. It is defined as 90 per cent of the FMP.
Cargoes prone to liquefaction are those with a small particle size and those which contain moisture as a result of the way they are processed before loading, e.g. iron ore concentrates and coal slurry or duff (The IMO Code of Safe Practice for Solid Bulk Cargoes 1991 (as amended) lists some commodities which may liquefy).

It is perhaps worth mentioning here that solid bulk cargoes are increasingly being carried in Intermediate Bulk Containers (IBC)( An IBC may be described as a disposable or re-usable receptacle designed for the carriage of bulk commodities in parcels of 0.5 to 3.0 tonnes. They can be of rigid (e.g. fibre board) or flexible (e.g. bags) construction).The general experience with this type of carriage suggests that the dangers of shifting cargo can be just as real. Solid bulk cargoes which are prone to sliding have been known to force the sides of even rigid IBC’s to move and if there are gaps within the stow, or the sides of the stow are insufficiently shored, a general collapse of the stow can occur.

A case example – Liquefaction of scale dust

An increasingly common solid bulk cargo is dust, commonly originating from industrial chimneys. Industry has for some time been required to limit the pollutants discharged into the environment and to this end chimneys can be installed with filters.
The material collected by these filters is generally termed filter dust; material which builds up on the inner chimney surfaces also gives rise to another type of dust – scale dust. The contents of these substances vary enormously and chemical hazards are often associated with them.
This is one of the reasons why many societies in our greener world no longer allow them to be left stored and forgotten on open slag heaps or in land-fill sites.

The option to be considered in many of today’s societies is re-cycling and it is this which has, to some extent, led to the water transport of dust.

The experience with problems and dangers of watery filter dust, suggests to us that these problems and dangers are not fully understood and that essential precautions are not being adhered to.

The vessel in question loaded at Algeciras, Spain, and the scale dust in bulk was to take up most of her centre hold. The majority of the scale dust was noted by the master to be in open storage on land, unprotected from the elements, and on closer examination, was found to have a high moisture content in parts.
Whilst the master was concerned as to the state of the cargo, loading commenced, and since this took place during periods of rainfall, moisture levels increased.

No documents were produced by the shippers to record the properties of the scale dust, and when the master did raise concerns with the various cargo interests, including their surveyors, he was told that the loading of the cargo during rain, and the wetting of the cargo, was normal and of no importance with regard to the quality of the cargo.

The loading of the cargo seemed to be completed without further event or protest and clean bills of lading were issued. On the loaded passage the vessel encountered moderately heavy weather, causing heavy rolling and pitching at times. Four days into the passage a series of splashing and banging noises were heard which seemed to come from the hold containing the scale dust.

Inspection of this hold revealed that the scale dust had become fluid and was splashing violently against the hold sides. The inspection itself was not without danger as a 5 – 6 meter geyser erupted from the booby hatch opened for inspection. The resultant mess on the ship’s superstructure was the least of the worries facing the master as shortly afterwards the vessel took on a list.
Fortunately the vessel was able to compensate for this by careful and strategic ballasting and was able to reach the discharge port without further serious incident.

Further inspection at the discharge port revealed that the forces involved with the shifting of the liquefied scale dust had resulted in the penetration of the cargo into an adjacent hold under and above a moveable transverse grain bulkhead.

Problems ensued with the consignees who held the vessel liable for loss and damage to the cargo and the extra costs of discharging and storing the fluid cargo. The surveyors appointed by the owners learnt that the surveyors appointed on behalf of shippers, had issued a “certificate” of the moisture content at the loading port and given this to the consignees, but not to the master.
The certified moisture content was said to be in the region of 11 per cent but tests at the discharge port determined a moisture content of nearly double this figure.

Collision avoidance can be said to be a bit like riding a bicycle. After a (frequently) wobbly start, once people get the hang of it, the ability never leaves them. However,knowledge, understanding and the correct application of the Rules do take a little time to accomplish. 

The Rules are not intended to be an intellectual challenge.They are a logical protocol designed to keep vessels apart and to provide a complete and sufficient framework, within which to defend yourself, your vessel and the lives of others.

Here then, are a few ‘tricks of the trade’: