Ship Dismantling By The Rules

SHIP DISMANTLING PROJECT PROPOSAL by Louis J. Lemos

In the less-developed countries in which many ships are dismantled industrial safety regulations and environmental rules are commonly ignored resulting in a high incidence of industrial accidents and illegal environmental pollution. The following proposal is for the establishment of a Ship Dismantling Program (SDP), to be managed by a private contractor and operated in accordance with the provisions established by the International Maritime Organization (IMO), of the United Nations Organization.

1.0 - Feasibility Study - To facilitate drafting a meaningful Project Proposal a prerequisite study should be made of the current scope and range of Ship Dismantling activity throughout the world, in terms of the following:

* Number of ships dismantled per year, and corresponding tonnage of resultant metal.
* Countries involved, and specific locations of dismantling projects.
* Average price of scrapped metal per ton, per country.
* Productivity, in terms of average man-hours per ton of scrap metal produced.
* Industrial Safety, in terms of "lost-time accidents" per year.
* Environmental safety, in terms of tons or gallons of hazardous materials produced and re-cycled, plus methods of
disposal of non-re-cycled materials.
* Existing rules and regulations, if any, local, national and international, pertaining to industrial safety and
environmental restrictions, applicable to Ship Dismantling.

2.0 - Corporate Title - Given that the finished product will consist of scrap materials including steel plate; electrical wiring; non-ferrous valves and fittings; piping; wire rope; various electric motors and machinery parts, all of which will be sold for disposal by re-cycling same, the corporate title of this entity should reflect its ultimate objective as a "re-cycling center" rather than the term "scrap yard". This should serve as a constant reminder to employees that they are employed in an environmentally-friendly occupation.

3.0 - Site Selection - The ideal location would be a former shipyard, either civilian or naval, wherein the following facilities and factors would be highly desirable or applicable: 1) - Space readily available for commercial and industrial use. 2) - Existing dry-dock, at least one, capable of accommodating large vessels. 3) - Existing dock-side cranes capable of lifting heavy loads. 4) - Existing pier space for mooring barges to load scrapped materials.
5) - Proximity to a MARAD Reserve Fleet, or at least within 100 miles thereof. 6) - Proximity to a large labor force.
7) - Providing potentially new employment opportunities to a depressed area.

Besides the U.S.A., Ship Dismantling activity is quite prevalent within the South East Asia region where there is an abundance of unskilled labor available and a need for new business ventures. Currently there are several hundred commercial vessels of various tonnages and flags laid up at anchorage offshore, in the vicinity of Singapore. Unless the world economy returns to normal within the next two years or so, many of these ships are expected to be disposed of by scrapping, thereby creating new business opportunities in this field at overseas locations.

4.0 - Business License - Prior to procurement of a local Business License from the City of registry, the applicant party, interested in scrapping obsolete U.S. Government vessels, will be required to submit a "Ship Dismantling Proposal" to the U.S. Maritime Administration to determine the availability of a minimum number of ships to be dismantled within a given fiscal year. As part of this proposal, the applicant party will need to develop a formal Industrial Dismantling Operation Procedure conforming to applicable IMO guidelines; and obtain approval of same by the U.S. Environmental Administration and by the Occupational Safety and Health Administration (O.S.H.A.). Since such vessels designated for dismantling will have been stricken from the register and are no longer "in service", they should not fall within the purview of the U.S. Coast Guard, except while under tow from the Reserve Fleet location to the dismantling yard, to ensure that the towing rig and procedures are safe and do not constitute a potential hazard to other vessels. The primary concerns of interest to the U.S. Federal authorities will most likely be the safe handling and approved disposal of hazardous materials, and adoption of a sound industrial safety program, given the hazardous nature of the work involved.

4.1 - Insurance Coverage - Likewise, proposals should be solicited from major insurance companies for the provision of:
1) Employee Health and Accident Insurance; 2) Workman's Compensation Insurance; 3) Corporate Industrial Liability Insurance. This latter provision may be viewed by the authorities as evidence of acting in good faith and may in fact be mandatory. It should also be an important factor conducive to the determination of a contract award and approval of a business license.

5.0 - Legislation, - Following the drafting and formal implementation of a Ship Dismantling Code of Compliance by the IMO a further mandatory protocol will be required to ensure that all Ship Dismantling Firms (SDF) in all countries involved become members of a Ship Dismantling Industry Federation (SDIF) and abide by the SDCC covenant as it applies to industrial safety, environmental safety, allowing free access of SDCC Inspectors, and full compliance with their recommendations, plus consistent compliance by SDF members in the maintenance and periodic reporting to IMO of accurate statistical records covering items listed in para.1.0 above. Failure to comply with said protocol, following the first citation for violation of same, should result in suspension of the SDF Business License by the local government and banning the guilty firm from the IMO Approved List of SDF, for a period of one year.

5.1 - Training of Inspectors - Formal training courses should be established, first to train prospective SDCC Inspectors to be employed by IMO and secondly, to train Industrial Environmental Safety Officers (IESO), to be employed by SDF members yards. This latter -provision should be incorporated into the above-mentioned protocol, so that each SDF member has at least one SDCC-trained in-house ESO inspector on duty during business hours.

6.0 - Funding - Initially, the United Nations should provide a Project Inaugural Grant to fund the establishment of the SOP for at least the first two years. As part of the SOP Protocol, provisions should be made to charge all ship-owners a one-time mandatory fee for every new vessel built such as U.S. $1.00 per displacement ton and a similar fee imposed upon all Ship Breakers for every ship dismantled, such as U.S. $1.00 per ton, based on the reported tonnage at time of sale by the ship-owner. All such fees shall be payable by the ship builders and the ship breakers into the IMO-established SDCC account for this purpose. Currency of fee payments shall be monitored by the IMO in-house SDCC Inspectors.

7.0 - Employment - To spread employment opportunities around on a world-wide basis prospective SDCC Inspectors should be recruited from and stationed within their respective home countries. This should serve to show that (a) There is no discrimination against any particular nationality; (b) There should be no difficulty due to language barrier; (c) Inspectors would be required to spend less time away from home; (d) Long distance travel expenses will be minimized.

8.0 - Training of Employees - A formal Training Program to be established by IMO, translated into various languages spoken by the countries in which Ship Dismantling Firms operate, and published accordingly. Employees working for SDF members shall be required to undertake a specific in-house training course applicable to their specific work assignments and to complete a written test on the subject matter before being allowed to start work. Training subjects shall include a general knowledge of Hazardous Materials Identification (HMI) and Industrial Safety Guidelines (ISG); reporting procedures to be followed when any material encountered 1S suspected of being hazardous, or when potentially dangerous conditions are observed within the immediate vicinity of the workplace; an extensive briefing on environmental preservation and mandatory compliance with applicable environmental rules.

8.1 - Industrial Safety Program - A company-wide Industrial Safety Program shall be implemented as a mandatory requirement to be observed by all persons without exception. This includes an ISP and HMI briefing for visitors to the Yard. A prominent feature of the Industrial Safety Program shall be the establishment of an in-house Emergency Response Team (ERT), trained and equipped to perform fire-fighting; first aid; hazardous material spillage recovery (solid and fluid); plus search and rescue. This ERT group will consist of a dedicated full-time Primary Response Team based at the ERT Station, adjacent to the Safety Training Classroom. They shall also have the collateral duty of conducting Industrial Safety Instruction courses for all SDF employees. A First-Aid Station located within the ERT Station shall be staffed by a full-time trained nurse who shall also be a member of the Primary Response Team. If and when necessary, the Primary Response Team shall be supported by an equally-capable" Secondary Response Team comprised of specially-trained yard workers of various trades, who will be required to attend an Emergency Response Drill one day per month. Secondary Response Team members shall be paid at their respective overtime rate (150%) for all hours spent in supporting the Primary Response Team during an emergency event. Due to the wide usage of oxy-acetylene cutting torches and burners. All yard employees shall be trained in the proper use of fire extinguishers. As part of their safety awareness function, PRT members shall be responsible for checking all fire extinguishers and fire-fighting appliances on a daily basis and in ensuring that all extinguishers are fully charged. All fire extinguishers shall be weighed on a weekly basis to determine their relative condition of charge, and findings shall be recorded on a Fire Extinguisher Log on which the date of re-charge shall also be recorded.

8.2 - Industrial Safety Control - All industrial gas bottles shall be tagged with a control number and date of issue. A Safety supervisor shall be required to verify that all gas bottles are properly closed at the end of each shift. A log shall be maintained on a daily basis by the Section Supervisor, of all gas bottles in use within the area of his jurisdiction, on board and on the pierside, and all tagged bottles accounted for at the end of each work day. Only authorized Gas Shop workers shall be allowed to deliver full bottles to designated work areas and collect empty bottles for return to the Gas Shop. Dockside cranes shall be weight tested every sixty days in the presence of a Safety Supervisor who shall maintain a log of such testing.

8.3 - Industrial Security - A security fence shall be erected around the perimeter of the De-Contamination Pier and strict traffic control of personnel and vehicles shall be maintained. Employees and Official Government Inspectors shall be issued with a color-coded DCP photo identity badge at the Front Yard Office to enable them to enter said area. The assigned Security Guard at the DCP Gate shall be provided with a listing of all DCP ID cards issued on a daily basis. Persons attempting to enter the DCP enclosure whose badge is not listed shall not be allowed in.

8.4 - Industrial Procedures - Delivery - Upon award of a formal Ship Dismantling Contract by MARAD (U.S. Maritime Administration) to a U.S.-based member of the SDF a towing company will be retained by the successful bidder to "break-out" a specified ship from the Reserve Fleet Anchorage and to deliver same to the designated "De-Contamination Pier" (DCP) of the selected Ship Dismantling Firm.

9.0 - De-Contamination - At the DCP the vessel will be encapsulated (where necessary) to contain fugitive air-borne effluent of hazardous materials during the removal of asbestos materials, including steam pipe and boiler insulation and deck tiles within the accommodation; waste oil products; sundry chemicals, paints, solvents, cleaning fluids, etc., until the vessel is officially certified to be "Free of Hazardous Materials"; "Gas-Free" and "Safe for Men" and "Safe for Hot Work" in all tanks and compartments, by a Certified Marine Chemist. This phase shall be carried out by a licensed firm specializing in this line of work, under contract, to the SDF member yard. As part of this decontamination process, a tank barge shall be moored alongside the ship to receive any and all fluids pumped out of the ship's tanks. During this fluid off-loading procedure, strict control shall be maintained to ascertain the nature and quantity of each type of fluid transferred from the ship to the tank barge. This shall be accounted for by a formal sounding of all tanks on the tank barge upon" completion of transfer, and recording of all tank soundings onto a "Fluid Transfer Certificate" showing the volume of each different fluid, properly identified and listed on the Certificate by a Marine Chemist, and the respective tank number holding such fluid. Copies of all Fluid Transfer Certificates shall be recorded in the Hazardous Materials Log on a daily basis and maintained current by the Supervisory Chemist-in-Charge.

9.1 De-contamination Control - The de-contaminated vessel shall not be moved from the DCP until the designated Engineering Superintendent is assured that all hazardous materials and fluids have been safely removed from the ship, properly tagged, quantified and accounted for. Documentation of all hazardous materials shall be completed in accordance with applicable local, state and federal laws and shall be an integral part of the contract. Documentation shall be required for each bag or container, showing the assigned bag or container number, nature of contents, date of removal, name of vessel from which the material originated, net weight of contents, identification of Hazardous Waste Contractor License number, method of disposal, location, date of disposal and signature of Supervisory Marine Chemist on duty during removal and bagging of said hazardous materials. Each and every bag shall be numerically serialized and a signed and dated receipt shall also be required from the ultimate recipient of said hazardous material bags or containers to whom said material is delivered for disposal. All pertinent records shall be preserved for inspection by competent authorities when required.

10.0 - Dry-Docking - The certified de-contaminated vessel will then be towed to a designated dry-dock where the necessary supporting blocks will have been positioned on the dock floor in accordance with the "Docking Plan" for that particular vessel. No dismantling work will begin until the vessel is sitting on the blocks and the dry dock has been pumped out. A hopper barge will be moored at the pier near the dry-dock to receive scrapped steel as it is removed from the ship.

10.1 - Material Sorting - Several flat-bed trailers provided with large open dumpster bins shall be required to receive the non-ferrous materials (other than steel). Each bin shall be clearly marked for its respective cargo, namely, copper wire; electric motors and switchgear; brass and bronze valves and fittings; machinery parts, etc. and color coded accordingly. Fork-lift trucks will deliver the loaded bins from the dock-side to a storage area where they shall be weighed, numbered and recorded, along with their specific location within the storage area warehouse, pending sale.

10.2 - Yard Tugs - At least two small tugboats, of about 45 feet LOA shall be required to move barges around as necessary. Crew members shall be trained in search, rescue, recovery and first-aid techniques, plus safe re-positioning of barges. Likewise, a 25 foot outboard-powered rescue boat shall be maintained for search and rescue in the event of a "Man-Overboard" emergency, and to assist the tugs as required. This small craft will also be required for periodic inspection of the draft of barges being loaded, to ensure that they are not being overloaded beyond their rated load-line capacity. All crew members of the tugboats and small craft shall report to an in-house Marine Supervisor who shall maintain a log of all vessel movements, periodic draft readings of each barge being loaded and the actual draft of each barge at the end of each work day; departure of each barge from the yard for delivery to a designated unloading site, and the light draft of each barge upon return to the Yard.

11.0 - Yard Traffic Control- Given that in addition to the presence of employee vehicles, forklift trucks, etc, there shall be outward bound trucks carrying loads of non-ferrous scrap and hazardous materials, a strict Yard Traffic Plan will be required to ensure safety of all personnel and to minimize potential liability.

12.0 - Emergency Lighting - Prior to employees entering shipboard tanks or other enclosed compartments for dismantling purposes, and subject to completion of daily gas-free certification, temporary lighting shall be strung in all work areas and passageways leading into and out of said areas. In addition, battery powered emergency lights shall be strung at the discretion of the Safety Supervisor, to ensure safe exit of employees in the event of a major power failure. A copy of the a Gas-Free Certificate showing "Safe for Men" and "Safe for Hot Work", for each and every compartment shall be posted in a conspicuous place at the entrance to each compartment or tank, and delivered to each Section Supervisor Before the start of each Day Shift. A Safety Supervisor shall be required to inspect all areas of a vessel being worked, several times per day, to ensure adequacy of illumination and currency of Gas-Free Certification.

13.0 - Work Schedule - To minimize operating costs and to maximize safety of workers, ship dismantling work shall be performed on a Day Shift, 40 hours per week basis only. All holidays shall be observed. Where and when necessary, temporary protection from the elements shall be provided to ensure reasonable comfort of the workers and to maintain continuity of production.

14.0 - Material Control - Inventory verification shall be made of all materials within storage area bins, in terms of weight per bin, and within barge hoppers, in terms of tonnage computed on the basis of draft, at 12 noon on a daily basis, by in-house Material Control attendants and the results forwarded to the Material Control Manager.

15.0 - Administrative and Regulatory Compliance - Management shall be responsible for implementing and monitoring the following:

1) - Industrial Safety Program
2) - Industrial Safety Control
3) - Industrial Security
4) - Overall Environmental Preservation
5) - Oversight of De-Contamination procedures and security of DCP area
6) - Training of Employees
7) - Adherence to the IMO Code of Compliance and maintenance of statistical records
8) - Support of SDCC Inspectors
9) - Payment of SDCC Ship Breakers fees
10) - Periodic testing of employees to ensure compliance with Industrial Safety.
11) - Periodic verification of office staff to ensure compliance with record keeping.

16.0 - Industrial Safety Summary - While there are many skeptics inclined to minimize the importance of a comprehensive Industrial Safety Program and others who complain about the cost of same, the sad truth is evidenced by recently reported statistics. From 1997 to 2009, the industrial accident rate within the ship-breaking industry in the Chittagong area of Bangladesh, alone, accounts for 1,300 worker fatalities plus 6,000 workers seriously injured, resulting in disablement. This equates to an average of 108 deaths, plus 500 serious injuries per year. On this basis, the skeptics would be hard pressed to suggest an industrial accident rate that they could comfortably live with.