5 Inspection at two OECD yards, Danish Environmental Protection Agency

Shipbreaking in OECD

5 Inspection at two OECD yards

5.1	Spain
5.2	Italy

The HSE relevant conditions at the two companies offering have been assessed by inspection of the facilities, documentation available on site and interviews with the owners and employees.

The Basel Convention Draft Guideline, Technical Guidelines on Environmentally Sound Management for Full and Partial Dismantling of Ships (draft May 2002), have been prepared with the intention of providing guidance to countries which have or wish to establish facilities for ship dismantling. Recognising that OECD countries were not the prime target the facilities in OECD must nevertheless comply with the same demands for ESM. Table 11 of the Draft Guideline (Generic checklist for closing the gaps – achieving ESM-compliance) addresses the issues to be dealt with within one year, one to five years and five to ten years, and the two facilities in Spain and Italy has been evaluated relative to this table. In the case of the OECD yards the time scale mentioned in the column heads should only be taken as indication of urgency, not the actual time span allowed for complying with the ESM demands.

Although, no guideline for ship dismantling has been available in the past it was expected that no "violations" of column one would be found, very few in column two, while the issues of column three could be less stringent complied to. The use of "compliance" refers only to the issues of table 11 in the draft guideline.

5.1 Spain

A. Implementation of actions immediately - at the latest within one year	B. Within one to five years	C. Within 5 to 10 years at the latest	Spanish demolition company, Asturias
Physical identification and labelling of hazardous materials on board	Adequate transfer operations facilities	Impermeable floors wherever hazardous materials and wastes are handled	A. Compliance B. Non-compliance C. Non-compliance
Cleaning of oil tanks/compartments before hot work commences	Spill containment boom	Adequate draining and pumping equipment	A. Compliance B. Non-compliance C. Non-compliance
Use solvents to dissolve heavyweight sludge so that most oil and sludge can be pumped out	Minimise use of manual labour inside the tanks for removal operations (use of pumps)	Provide adequate treatment/ disposal facilities for the different hazardous materials	A. Compliance B. Compliance C. Hazardous materials removed by licenced company
Ventilate compartments/tanks continuously	Provide adequate storm water discharge facilities, to avoid contamination of storm water runoff	Spill cleanup equipment	A. Compliance B. Non-compliance C. Non-compliance
Introduce a hot work certification system	Create an enclosed chamber in the ship where asbestos has been identified. Limit access. Filter air emissions	Create a separate area for paint removal operations, with impermeable floor. Cover and install air filtration	A. Compliance B. Compliance C. Non-compliance
Test compartments for presence of flammable vapours before hot work	Create dedicated area for asbestos removal. Limit access	Create a dedicated area for segregation of hazardous materials (e.g. PCBs)	A. Compliance B. Compliance C. Compliance
Provide adequate storage facilities for hazardous wastes	Collect and contain all wastes resulting from asbestos removal processes. Pack asbestos in approved packaging system	Complete containment/ impermeable floors	A. Non-compliance B. Compliance. Packaging not inspected. C. Non-compliance
Test compartments for presence of toxins, corrosives, irritants before entrance (manual cleaning)	Decontaminate workers when leaving the asbestos removal area		A. Compliance B. Non-compliance
Identify and remove toxic or flammable paint prior to metal cutting			A. Non-compliance
Collect and contain all wastes resulting from paint removal processes			A. Non-compliance
Spill cleanup and notification procedures			A. Non-compliance
Always wear rigid helmets, hard-toed shoes and gloves, as well as personal protective equipment for eyes, face and skin			A. Compliance. Equipment available, but use must be enforced
Use appropriate protective equipment against respiratory hazards			A. Compliance
Keep fire extinguishing equipment immediately available			A. Compliance
Implement appropriate asbestos management procedures in accordance with ILO code of practice			A. Compliance
Work with asbestos should be carried out by trained personnel only			A. Compliance
Determine pollutant concentrations prior to removal of bilge and ballast water			A. Non-compliance
Remove and dispose of PCB-containing material in a controlled manner			A. Non-compliance.

The overall impression is that most required safety and protective gear was in place, although not fully used in accordance with regulations. The facility was so small that no safety organisation was in place. The different waste fractions were separated, although only cables and certain types of metals were kept in bottom-closed containers. All other waste fractions were disposed directly on the ground. The facility operates presumably in accordance with Spanish regulations, but the overall impression is that the facility is under close-down due to constant stronger competition from non-OECD facilities on the commercial and much more profitable market for ship dismantling.

5.2 Italy

A. Implementation of actions immediately - at the latest within one year	B. Within one to five years	C. Within 5 to 10 years at the latest	Italian demolition company, Napoli
Physical identification and labelling of hazardous materials on board	Adequate transfer operations facilities	Impermeable floors wherever hazardous materials and wastes are handled	A. Compliance B. Compliance C. Compliance
Cleaning of oil tanks/compartments before hot work commences	Spill containment boom	Adequate draining and pumping equipment	A. Compliance B. Compliance C. Compliance
Use solvents to dissolve heavyweight sludge so that most oil and sludge can be pumped out	Minimise use of manual labour inside the tanks for removal operations (use of pumps)	Provide adequate treatment/ disposal facilities for the different hazardous materials	A. Compliance B. Compliance C. Hazardous materials removed by licenced company
Ventilate compartments/tanks continuously	Provide adequate storm water discharge facilities, to avoid contamination of storm water runoff	Spill cleanup equipment	A. Compliance B. Storm water facilities not inspected C. Compliance
Introduce a hot work certification system	Create an enclosed chamber in the ship where asbestos has been identified. Limit access. Filter air emissions	Create a separate area for paint removal operations, with impermeable floor. Cover and install air filtration.	A. Compliance B. Compliance C. Cover and air filtration not used. Personnel protective equipment available
Test compartments for presence of flammable vapours before hot work	Create dedicated area for asbestos removal. Limit access	Create a dedicated area for segregation of hazardous materials (e.g. PCBs)	A. Compliance B. Compliance C. Compliance
Provide adequate storage facilities for hazardous wastes	Collect and contain all wastes resulting from asbestos removal processes. Pack asbestos in approved packaging system	Complete containment/ impermeable floors	A. Compliance B. Compliance C. Compliance
Test compartments for presence of toxins, corrosives, irritants before entrance (manual cleaning)	Decontaminate workers when leaving the asbestos removal area		A. Compliance B. Compliance
Identify and remove toxic or flammable paint prior to metal cutting			A. Compliance
Collect and contain all wastes resulting from paint removal processes			A. Compliance
Spill cleanup and notification procedures			A. Compliance
Always wear rigid helmets, hard-toed shoes and gloves, as well as personal protective equipment for eyes, face and skin			A. Compliance
Use appropriate protective equipment against respiratory hazards			A. Compliance
Keep fire extinguishing equipment immediately available			A. Compliance
Implement appropriate asbestos management procedures in accordance with ILO code of practice			A. Compliance
Work with asbestos should be carried out by trained personnel only			A. Compliance
Determine pollutant concentrations prior to removal of bilge and ballast water			A. Not assessed. Procedures of Porto di Napoli applies. Bilge water removed by licenced company.
Remove and dispose of PCB-containing material in a controlled manner			A. Compliance. Procedures available, no PCB identified yet.

The inspection did not take place during an actual demolition, and a case cannot be made regarding the organisation of the actual work. However, the manuals and procedures available apparently address all relevant issues regarding workers health and safety. The developed procedures have been driven by considerations for workers environment. Improvements in terms of environmental issues have not yet been addressed by local authorities and the screening carried out suggests that management of Halons, CFCs, HCFCs, PVC and PCB should be improved. However, the general impression is that the company has a good organisational structure, a competent back-up facility in the Port of Naples, that is complies with national regulations and that the improvements needed in terms of compliance with Basel Convention issues are minor.