4.1 The Environmental Compliance Plan (ECP) should serve as the primary basis for evaluating the degree towhich the ship recycling facility:
.1 understands the environmental risksassociated with ship recycling;
.2 understandsandimplementstheenvironmentalrequirementsimposedbynational and international laws and regulations;
.3 canmanageanddisposeofallthematerialsusedinthestructureoftheship,its equipment and/or on board the ship in an environmentally sound manner; and
.4 implements controls to protect the environment, which include handling and disposing ofthe hazardous materials.
4.2 TheECPshouldincludeinformationontherecycler'sabilitytorecycleshipsanddispose
oftheresultingmaterialsinamannerthatiscompliantwithapplicablenationalandinternational laws, regulations, and guidelines. Further, the ECP should reflect the applicable national legislation and, where appropriate, the Basel Convention “Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships”.
4.3 Elements ofthe ECP
4.3.1 The ECP should provide a clear and concise explanation of procedures for managing potentially hazardous materials, including, but not limited to:
.1 fuel, lubricants, and coolants; chemicals in drums, buckets, pressurized bottles, stored solvents, and other chemicals stocks, etc.;
.2 cargo residue;
.3 floatablematerials(e.g.plastics, Styrofoaminsulation wood);
.4 materialspossiblycontainingPCBs,suchaswiringinsulation(electricalcabling installed before 1975) (plastic covering may contain PCBs)1;
.5 waste water/sludges (generated aboard the vessel during the scrapping process fromrainwaterintrusion,firefighting,asbestoscontrolactivity,etc.,aswellas water that may be in compartments of the vessel at the time of arrival); human waste in the formof sewage or graywater;residues of ballast water;
.6 harmfulaquaticorganisms,non-indigenousspeciesandmarinegrowthinballast water and on the hull, and sediments in ballast tanks;
1 PolychlorinatedBiphenyls(PCBs)(includestransformers,capacitors,electricalcableinsulation,feltandrubber gaskets,thermalandacousticinsulationmaterials,adhesives,paint,caulking,grouting,variousrubberandplastic products). Address procedures for each potential application noted. The recycler must have a thoroughly
documentedsamplingplanandmethodologyfortestingmaterialsthatpotentiallycontain(orarecontaminated
with) PCBs. Painted metal surfaces must also be tested in accordance with a sampling plan. A storage and disposalplan should also beinplace andprovidedaspart of thePlan.
.7 asbestos used in older ships as insulation material and in accommodation
panelling(includesbulkheadandpipeinsulation;bulkheadfireshields;electrical cablematerials;brakelinings;floortilesanddeckunderlay;steam,waterandvent flange gaskets; flexitalic gaskets; garlock seals; packing material; pipe hanger inserts; and weld shop protectors and turn covers);
.8 chromium(ballast watertreatment, paint coatings, gaskets, etc.);
.9 TBT paints;and
.10 environmental monitoring.
4.3.2 Itemsonshipsthatmaypotentiallycontainsubstancesofconcernincludethoseidentified
in section 4.2 of the IMO Guidelines.
4.3.3 In identifying potentially hazardous materials on board ships the list of “Potentially hazardous materials which may be on board ships delivered to recycling facilities” (appendix 2 of
the IMO Guidelines) should be considered for guidance.
4.3.4 The ECP should identify all permits, certificates, approvals, and licences required by international, national and local environmental agencies and issued to the recycling facility to carry out the work, including those required for the management of potentially hazardous material.
4.3.5 The ECP should identify all entities to be involved with the process. This includes sub-contractorsinvolvedwithrecyclingoperationsatthesite,andthosewhotest,transportand provide the disposal site/method. Copies of licences, approvals, permits, and insurance, etc. should be included.
4.3.6 TheECPshouldincludeacopyofthesite'sspillpreventionand/orspillresponseplan. Information related to on-site water discharge requirements should be included.
4.3.7 The ECP should describe whether the recycling facility, any parent companies, subsidiariesoraffiliatesoranyproposedsubcontractors,disposalfacilities,withinthepastfive yearshasreceivedanyfines,notices,deficiencies,etc.fromanyregulatoryentitiesorthird party environmental auditors.