Click to View January 2016 (Policies)

UK Ship Recycling Strategy

Strategy objectives :

  • To develop a strategic approach to the recycling of UK-flagged vessels consistent with the UK’s national and international sustainable development commitments.

  • To encourage through the provision of guidance, the development of UK capacity for recycling of end-of-life vessels in an environmentally sound manner.

Policy on Government-owned vessels:

Vessels destined for further use:

  • When a vessel is sold for further use, either to foreign Governments or commercial entities, the Government seller will undertake a market assessment of the vessel prior to its sale. If this indicates that the age, condition and value of the vessel make it likely that it is close to the end of its working life, the vessel will then be sent for recycling instead. In marginal cases, the vessel will be sent for recycling.

  • Government will negotiate for inclusion of the following provisions relating to the new owner’s responsibilities when the vessel reaches its end-of-life. These are based on the policy provisions, Government will adopt for recycling its own vessels.

The new owner has the responsibility:

  • To ensure that the vessel’s Green Passport is updated throughout the remainder of its service and passed to the recycling facility.

  • Not to dispose of the vessel without prior consent in writing of the UK Government

  • To demonstrate that the vessel will be recycled in accordance with all applicable legislation, and with reference to the International Maritime Organization Guidelines on Ship Recycling and the Basel Convention Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships

  • To take appropriate steps to ensure the facility where the recycling is to take place abides by acceptable environmental, health and safety standards.

  • Where the new owner breaches its contractual obligations, Government will review the options it has available for recourse on a case-by-case basis.

Vessels destined for recycling:

  • In the case where a Government-owned vessel is to be recycled, Government will tender the contract for recycling only to facilities in OECD countries.

  • Government will specify minimum environmental, health and safety standards that must be demonstrated and adhered to by the recycling facility during the recycling operation. Clear specifications of standards are to be provided in tender documentation and in the criteria for evaluating tender bids

  • Government will specify minimum environmental, health and safety standards that must be demonstrated and adhered to by the recycling facility during the recycling operation. Clear specifications of standards are to be provided in tender documentation and in the criteria for evaluating tender bids

  • Government commits to obtaining the best possible value when selling its assets within the parameters of the policy on the recycling of Government-owned vessels.

Application of the waste shipments regulation and recommendatory guidance for ship owners:

  • The strategy sets out the relevant waste controls applicable to the export of UK-flagged end-of-life vessels for recycling from UK ports, and provides recommendatory guidance for ship owners.

  • The EC Waste Shipments Regulation (WSR) implements the Basel Convention in the EU and covers the supervision and control of shipments of waste within, into and out of the EU. The WSR provides detailed rules for the control of transboundary movements of waste, the central aspect of these being a notification procedure involving the competent authorities of dispatch, transit and destination.

  • The WSR defines waste in accordance with article 1(a) of the Waste Framework Directive11 which states: ‘waste’ shall mean any substance or object…which the holder discards or intends or is required to discard. Where a UK-flagged vessel is being exported from a UK port for recycling, it is likely to fall within the definition of waste and thus be subject to the EC WSR12. Recital 35 of the revised Waste Shipments Regulation (EC) No 1013/2006, notes that a ship may become waste as defined in Article 2 of the Basel Convention and that at the same time it may be defined as a ship under other international rules.

Thus, in the absence of any internationally recognized mandatory regime for end-of-life vessels, Government expects:

  • Where an end-of-life vessel falls within the definition of waste, as set out in the Waste Framework Directive, controls under the EC Waste Shipments Regulation will apply.

  • Any imports of vessels for the purposes of recycling to be notified in accordance with the provisions of the Waste Shipments Regulation or existing international rules (under the Basel Convention and/or OECD Decision13) as appropriate.

  • Any exports of UK-flagged vessels from a UK port for the purposes of recycling to be notified in accordance with the provisions of the Waste Shipments Regulation.

  • The WSR implements the Basel Convention’s Decisions II/12 and III/1, known as the ‘Basel ban’, whereby exports of all hazardous wastes to non-OECD countries are prohibited. Given the range of hazardous materials found in end-of-life vessels, it is likely that an end-of-life vessel would be classified as hazardous. In practice, this means that they may only be exported to OECD countries.

  • Government recommends that ship owners make reference to the IMO Guidelines at all stages when a ship is sold for recycling, paying particular attention to the following elements:

    1. Design of ships and ships’ equipment to facilitate recycling

    2. Inventory of hazardous materials onboard and preparation of a Green Passport (for new builds and existing ships)

    3. Selection of an acceptable recycling facility

    4. Preparation of a Ship Recycling Plan

    5. Pre-decontamination

    6. Gas freeing

  • Ship owners are encouraged to review their current ship recycling practices in line with this strategy in preparation for the introduction of the new International Convention on the Safe and Environmentally Sound Recycling of Ships

Recommendations for recycling facilities :

Expansion of capacity:

  • It is recommended that site operators wishing to undertake ship recycling activities in the UK consult the Defra guidance - ‘An Overview of the Ship Recycling Process in the UK’.

  • Given the complexities of the applicable regulatory regimes, this guidance does not negate the need for operators to take their own legal advice. It is strongly advised that those wishing to recycle vessels in the UK engage with the relevant regulators at the earliest stage possible

  • Government encourages other OECD countries to consider undertaking studies to improve information on current and potential ship recycling capacity.

Upgrading facilities:

  • Joint technical cooperation programmes between the International Labour Organization, IMO and Basel Convention are welcomed and Government commits to participation in these activities through the relevant bodies.

  • Government will work to develop suitable projects to promote responsible ship recycling, especially through the implementation of the IMO, ILO and Basel Convention Guidelines on ship recycling

  • Government will also support development of a technical co-operation project, based on the Basel Convention Guidelines, to assist in the upgrade of standards at facilities in developing countries and to expand the provision of Environmentally Sound Management compliant ship recycling capacity.

The international agenda:

  • Government encourages other countries to consider development of their own ship recycling strategies, examining national fleets, where relevant, and looking at domestic ship recycling capacity.

Annex I- Minimum Standards

Recycling facility:

(IMO) indicates standards or criteria recommended in ‘Guidelines for the Development of the Ship Recycling Plan’ issued by the International Maritime Organization

The facility:

  • will be a registered business entity within the applicable national framework.

  • will be auditable by the organization selling the vessel and provisions should be made for site visits (if required).

  • will be in possession of all relevant permits, approvals and licences required by international, national and local agencies, and will provide a list and evidence of these on request (IMO).

  • will have adequate insurance to cover health and safety liabilities and environmental remediation in compliance with local legislation.

  • will identify all entities to be involved in the ship recycling process, including sub-contractors, waste management companies, asbestos removal companies, and provide evidence of their licences, approvals, permits, etc (IMO).

  • will provide a list of hazardous materials the facility is capable of handling including related details of the final disposal facility.

  • will have prior experience in recycling ships and other marine structures and will have professional references readily available (not applicable for new facilities).

  • will declare whether it, its parent company(ies), subsidiaries or affiliates, or any proposed sub-contractors or other entities involved in the recycling process, has received any fines, notices, etc. from regulatory entities in the last five years (IMO).

  • will be in receipt of the following documents prior to the commencement of recycling to assist in the development of a Ship Recycling Plan .

    1. A 'Ready for Recycling' certificate (or its equivalent)

    2. The vessel’s Green Passport including a list of hazardous materials (and their location) onboard (IMO)

    3. Any ship plans or drawings

    4. will issue a ‘Recycle’ certificate upon completion which confirms the remainders of the ship have been processed and removed;

  • is recommended to make reference to the following sets of Guidelines throughout the recycling process:

    1. Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships developed by the Secretariat of the Basel Convention

    2. IMO Guidelines on Ship Recycling developed by the International Maritime Organization

    3. Safety and Health in Shipbreaking: Guidelines for Asian countries and Turkey developed by the International Labour Organization

    4. The facility, in conjunction with the ship owner, will be responsible for the development of a ship recycling plan for the vessel and should have procedures in place to develop such a plan (IMO). The plan should include provisions for: worker health and safety; environment including waste management

  • It should be noted that both existing and new facilities should be acceptable, provided that they have or obtain all the necessary regulatory consents and satisfy all other requirements, including those of the competent authorities for transboundary waste controls.

Worker health and safety:

The facility is required to implement methods and procedures to protect, monitor and enforce worker health and safety. These should reflect applicable requirements of national legislation and, where appropriate, the ILO Guidelines on Safety and Health in Shipbreaking. The facility is required to have procedures in place to cover the following operations in respect of worker health and safety:

  • Confined and enclosed spaces (procedures for identifying and working in dangerous atmospheres) (IMO) .

  • Welding, cutting, grinding and heating (procedures for ventilation, personnel monitoring for lead/cadmium/mercury/beryllium exposure, protection of personnel, training, respiratory protection, torch cutting, permits and inspections (including hotwork certification)) (IMO) .

  • Fire prevention/protection (procedures for fire watch, raising alarm, hazards, fire extinguishers, hose lines, water supply, fire fighting equipment, training, proper handling and storage procedures and identification of potential ignition sources) (IMO).

  • Compressed gas cylinders (procedures for transporting, moving, securing and storing, and the use of hoses and torches in the vicinity of or on the bottles) (IMO) .

  • Scaffolds, ladders and workman aloft, other working surfaces (procedures for use of personnel flotation devices, guarding of deck openings and deck edges, platforms, personnel fall arrest systems, guardrails and access to ships) (IMO) .

  • Housekeeping and temporary lighting (procedures for work areas, including aisles, passageways and temporary floor openings) (IMO) .

  • Health and sanitation (availability of toilet and washing facilities, changing rooms and eating and recreational areas) (IMO) .

  • Communication of hazards (procedures for providing information to employees on potential hazards associated with the job) (IMO) .

  • Asbestos Abatement Programme or similar (exposure assessment processes, use of regulated areas, in-process monitoring procedures, engineering controls and work practices, qualified personnel, measures to prevent exposure of workers and the environment to asbestos) – see ILO Code of Practice (Appendix C of Basel Guidelines) (IMO) .

  • Gear and equipment for rigging and material handling (procedures for testing and inspection of ropes, chains, slings and hooks, chain-falls and hoisting and hauling equipment) (IMO).

  • Personal Protective Equipment (procedures and equipment for protection of employees from risks associated with ship recycling) (IMO) .

  • Employee emergency plans (emergency escape routes, procedures to account for employees during evacuations, alarm systems, weather plans, rescue and medical duties, treatment of injured personnel and training procedures) (IMO) .

  • Lead Abatement Programme or similar (procedures to provide ventilation, hygiene facilities and practices, shower/change rooms, warning signs, medical surveillance, exposure monitoring, testing and training) (IMO) .

  • Spill containment and emergency response plans (procedures for clean-up activities, emergency equipment, site security, etc.) (IMO) .

  • Diving operations (a full diving programme, if required) (IMO).

    1. The facility is required to have a system which reports, records and notifies work-related injuries, diseases and death

    2. The facility is required to ensure the competence of its employees through safety and skills (use of tools, machines and other equipment) training

    3. The facility is required to monitor its workers’ health and work environment and provide occupational health services as required.

Environment :

  • The facility will implement methods and procedures to protect the environment. These should reflect applicable requirements of national legislation and, where appropriate, the Basel Convention Technical Guidelines for the Environmentally Sound Management of Dismantling of Ships. The facility is required to demonstrate the following in respect of the environment:

    1. That it engages in safe and effective waste management and has operational waste reception facilities (for storage of waste on site prior to remediation, recycling and/or disposal either on or off site) (IMO)

    2. Has procedures in place for managing (including identification (sampling/analysis), abatement, removal, treatment, storage, transportation and disposal) potentially hazardous materials, including (IMO)

    3. Fuel, lubricants and coolants; chemicals in drums, buckets, pressurized bottles, stored solvents and other chemical stocks

    4. Cargo residue

    5. Floatable materials (e.g. plastics, styrofoam, etc)

    6. Materials possibly containing PCBs, such as wiring insulation, paints, transformers, lighting ballasts, capacitors and other electrical items if installed before 1986)

    7. Waste water/sludges, sewer or grey water, residues of bilge and ballast water

    8. Harmful aquatic organisms, non-indigenous species and marine growth in ballast water and on the hull, and sediments in ballast tanks

    9. Asbestos used in older ships as insulation material

    10. Chromium (ballast water treatment, paint coatings, gaskets, etc.)

    11. TBT paints (collection and containment of all wastes resulting from paint removal process)

    12. That work will be carried out in a controlled environment so that any loss of pollutants can be monitored and managed (e.g. bunds and booms for wet dock work, work planning to minimize pollutant loss, etc.).

    13. Best practice suggests that full recycling should be undertaken in a dry dock, or within an area that allows full capture of all liquid/solid waste (e.g. oil/water/bilge/ballast/etc.)

    14. That the local environment is monitored at regular intervals to mitigate the effects of pollution.

  • A monitoring programme is required for:

    1. Ground/groundwater

    2. Seawater/sediments

    3. Air, noise, vibrations

Operations :

  • The facility will provide details of the methods and procedures involved, and sequencing of, the ship recycling process, including work that will be accomplished prior to and after the ship arrives at the facility. These should reflect practices recommended in the ILO, IMO and Basel Convention Guidelines on ship recycling.This facility is required to detail the following elements in a ship recycling plan or similar document: -- A schedule showing the progressive order in which the work will be carried out (IMO)

    1. Details of the arrangement of the facility to accommodate the flow of regulated material and completion of recycling, including the production flow of hazardous/regulated material and the layout/arrangement of the facility (IMO)

    2. Details of the arrangements with other facilities for the safe handling, transport and ultimate recycling/disposal of all wastes

    3. Provide step-by-step procedures to be followed when performing ship recycling, including (IMO)

    4. Plans for using dry dock, slipway, floating dry dock or other method -- Procedures for identification and labelling of hazardous materials

    5. Measures to be taken to ensure stability and strength during hull recycling

    6. Procedures for final recycling of underwater hulls

    7. Measures to be taken to prevent flooding/sinking of the hull

    8. Measure to be taken to prevent slag or other contaminants from entering the water

    9. Cleaning tanks and bilges prior to recycling

    10. Dealing with piping and fittings (not burning but cutting)

    11. Procedures to be used for securing the vessel in the event of severe weather (IMO)

    12. Procedures for spill cleanup and notification (IMO)

    13. The facility is required to have procedures in place for hot work, cutting and entry into enclosed spaces onboard ships including (IMO)

    14. 'Gas free for hot work' certification carried out by a relevant and appropriate body

    15. Continuous ventilation of tanks and compartments

    16. Cleaning of oil tanks and compartments before hot work commences

    17. Has management controls and procedures in place.

Design and construction of vessels

    The ship owner will abide by criteria required by the IMO Guidelines or other relevant standards, including:

  • Minimization of hazardous materials used in construction of new vessels

  • Minimization of potentially hazardous materials used in construction of new vessels

  • Design ship/equipment to facilitate recycling and removal of hazardous waste

  • Preparation of a Green Passport

  • Minimization of waste generation.


  • Ship owner should ensure transparency in all phases of the recycling process:

    1. Announce intention to sell a ship

    2. Tender/bid process (including confirmation that facility meets minimum environmental, health and safety standards)

    3. Negotiation and main terms

    4. Preparation of documentation (contracts, sales agreement, and memorandums of understanding between the owner and facility)

    5. Pre-cleaning (ready to recycle certificate)

    6. Delivery/decommissioning of vessel.

  • Ship owner should select a facility that is in compliance with the minimum environmental, health and safety standards required of recycling facilities. Best practice suggests adherence to the IMO/ILO/Basel Convention Guidelines at all stages of recycling

  • Ship owner should make provisions for facility audits to verify standards and site visits (if required);

  • Where required, the shipowner should be in possession of a ‘Ready for Recycling’ certificate, signalling that all hazardous materials onboard the vessel have either been removed or notified to the recycling facility;

  • Ship owner should present an updated version of the vessel’s Green Passport to the recycling facility

  • Ship owner should be in receipt of a contract, sales agreement and a ship recycling plan (issued by the recycling facility) prior to dispatch of the vessel to the facility.