A Closer Look at the European Owners' Visit to Alang

At the end of April, European shipowners, government officials from France, Germany and Belgium, and the European Commission visited shipbreaking yards in Alang, India. Despite several indications that NGOs, including the NGO Shipbreaking Platform, would be part of the delegation, no NGO was invited to join. MarEx took a closer look.

The Complaint

“We were clearly not welcome to join this visit. Critical civil society voices are not wanted in Alang – neither by shipowners, nor by the yards,” said Patrizia Heidegger, Executive Director of the NGO Shipbreaking Platform. “This confirms the lack of transparency under which the yards in Alang operate.” 

The visit is organized by the European Community Shipowners’ Association (ECSA). It is an attempt by both shipowners and certain yards in India to convince European policy makers that yards in Alang should be approved for the upcoming E.U. list of accepted ship recycling facilities, says Heidegger. “However, under the European Ship Recycling Regulation and the recently published technical guidelines on the requirements for ship recycling facilities, it is clear that beaching facilities do not qualify for the E.U. list.”

In regard to the visit, local environmental groups raised concerns related to working conditions, poor downstream waste management and continued pollution of the coastal waters in Alang.

On Site in Alang

MarEx spoke to Dr Anand M. Hiremath, a specialist on Indian ship recycling based in Bhavnagar, India, who accompanied the owners on their visit to Alang. Hiremath works closely with selected yards to ensure compliance of the guidelines established by the Hong Kong Convention (HKC) for Safe and Responsible Recycling of Ships. In this regard he liaises closely with the Ship Recycling Association of India, the Gujarat Maritime Board, the Ministry of Shipping and other local organizations and governmental institutions. Additionally, he is responsible for the development and implementation of cash buyer GMS’ responsible ship recycling program. 

Can you tell us about the yards that ECSA visited? 

The ECSA fact-finding delegation started its day in Alang by visiting the Labor Training and Welfare Institute followed by a labour colony.  The delegation then visited eight yards:

Kalthiya Ship Breaking Yard (HKC certified)
Panchavati Ship Breakers (Normal yard)
Hariyana Ship Breakers (Normal yard)
Shubh Arya Steel (HKC certified)
Leela Ship Recycling (HKC certified)
J R D Industries (Certification in process)
Priya Blue Industries (HKC certified)
Hoogly Ship Breaking Yard (Normal yard)

They closed the day at the Gujarat Enviro Protection and Infrastructure Limited’s Treatment Storage and Disposal Facility, part of their Integrated Common Hazardous Waste Management Facility. 

There are currently 80 working yards in Alang out 130 registered yards, the eight yards visited by the delegation therefore represent 10 percent of the number of yards and contribute around 15 percent of the total recycling activity in Alang. 

How were the yards chosen?

After discussions between the Ship Recycling Association of India and ECSA it was decided that the delegation would chose the yards that they wished to visit. 

Half of the yards visited were HKC compliant as one of the key goals of the trip was to demonstrate that the HKC does deliver the high standards of worker welfare and environmental stewardship that the European Commission expects from yards on its approved European List of ship recycling facilities. One yard was in the process of improving its infrastructure and systems to achieve HKC compliance and the remaining three were normal yards. 

The visit to one of these normal yards was specifically requested at the time of the visit by one of the officials as they had heard negative reports about that particular yard and wanted to see it for themselves. At that yard they toured the facility and met with the owner who explained his ambition to upgrade the facilities. 

This manner of yard selection ensured that the delegation had confidence that they were experiencing full transparency and openness. 

What levels of environmental protection and worker health and safety were covered across the range of yards chosen given that the industry in general has been criticized for beaching in a way that is polluting and unsafe for workers, for lack of protective wear for workers, for lack of medical support in case of accidents and for using child labor?

Let me first state that in my six years of experience in Alang I have not seen child labor in any yard. 

In terms of the yards visited on this trip. The HKC compliant yards work and manage each project according to a bespoke ship-specific recycling plan, using the design of the vessel and Inventory of Hazardous Materials (IHM) provided by the ship owner to plan a safe and environmentally-friendly dismantling sequence. They have developed safe waste removal procedures, and installed advanced waste handling facilities at their yards (for example, negative pressure asbestos handling units) and specialist employees have been trained and equipped for handling specific wastes. 

All workers are provided with an Employer State Insurance Corporation (ESIC) card which entitles the worker and his family to free medical treatment in any ESIC approved hospital in the state. They are also provided an identity card and have a dress code based on tasks and personal protective equipment where necessary. Periodic training is also mandatory for workers including training for working at height, or in a confined space, oil spill control, fire prevention, control and evacuation and for safe welding, cutting and grinding.
 
These are the standards one of the other yards is working towards, and they already have the majority of the necessary safety processes and procedures in place.

The ECSA delegation witnessed lower standards at the non-compliant yards in Alang, but GMS is not arguing that the E.U. Ship Recycling Regulation permit these yards for use by European shipowners or that there be no legislation for change. Indeed GMS has long been a supporter of the entry into force of the HKC so that compliance with its rigorous safety and environmental standards becomes mandatory.
 
The trip was intended to demonstrate the considerable progress that is being made in sustainable ship recycling within the region. It further aimed to demonstrate that the HKC can deliver safe and environmentally sound ship recycling regardless of its location, if it is supported the world over. 

If interpreted as a ban on beaching, the E.U. legislation threatens to split the industry into “good recycling” and “bad recycling” along geographic lines with no way to bridge the gap between the two. By allowing recycling at HKC-compliant yards the E.C. could help to raise standards for all of the world’s recycling yards and all those that work within the sector, no matter where in the world they happen to be.

How much time did the yards have to prepare for the visit? 

The yards visited underwent no special preparation for the ECSA visit. They have been maintained as per routine housekeeping procedure and most of the yards were working when ECSA delegation visited. Yards were transparent in providing information to the delegation and the attendees were free to inspect every inch of the yards without any restriction other than those posed by ensuring the health and safety of the workers and the attendees themselves. 

How can you reassure the industry that the visit wasn’t skewed to ensure that the shipowners went home with a positive impression?

The organizers worked very hard to ensure that the visit was transparent and open and that the delegation saw the real Alang. The input of the delegation into the yards that were visited, including that they chose and visited unrestricted a yard that they had received negative reports about, is evidence of that transparency. 

The trip worked on the principle of seeing is believing. Most of the people who talk about the situation in Alang have not visited the yards, seen what HKC compliance means in practice or had a chance to witness the change taking place. The trip has gone some way to changing that.

What Indian regulations govern the yards?

The Government of India has implemented the Ship Breaking Code-2013 which has firmed up safety provisions for workers and delegated more powers to industrial safety personnel. It is very similar to requirements outlined in the HKC. The yards are implementing the code effectively and with the intended spirit in tact. 

What proportion of yards do you consider need to make substantial change in order to reach levels acceptable by the Hong Kong Convention and what are the key things that need to change?

Irrespective of the ratification status of the HKC, yards will continue to adopt compliance voluntarily and seek certification of that compliance from leading class societies. Last week, the fifth yard in Alang received HKC compliance certification from RINA and seven further yards are currently going through HKC Statements of Compliance process to be certified. Once there are 12 compliant yards that would represent 15 percent of the total yards in Alang.

The view has been expressed that although the standards of worker safety, amenities and medical care in the region’s shipbreaking yards might seem low by the standards of some nations, they are actually relatively good compared to the villages from which many workers come. Do you think that is true in the case of Alang? How much change, therefore, do you think is realistic to expect?

I agree with that assessment. However, that does not mean that improvement has not occurred, that those improvements cannot be taken further and that we should not expect high safety standards for workers wherever they are in the world. 

The demand for green recycling is currently filling the HKC compliant yards in India. It is driving improvement throughout the region by creating competition and we have seen this developing into a virtuous cycle.

By banning beaching, including at HKC compliant yards that have made significant investments in infrastructure and training to deliver high standards of worker welfare and environmental stewardship, the European Commission will negate that improvement and catalyze a reduction in standards. All this regulation will achieve is to abandon the majority of the world’s ship recycling infrastructure and workers to the realms of the non-compliant, not at all in line with the goal of raising standards at all yards across the world.