Ship Breaking & Recycling Industry (SBRI) in Bangladesh

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Ship Breaking & Recycling Industry (SBRI) in Bangladesh

1.1 Background

Sea going vessels or ships has a normal lifespan of about 30/40 years after which any repair or renovation becomes uneconomical. These ships are then retired and sold for scrap to commercial ship breakers. Until well into the 20th century, ship breaking used to be carried out in industrialized ports including those in USA and UK. Thereafter, the major centers of the ship breaking and recycling industry (SBRI) first moved from Europe and North America to East Asia and, since the 1980s, to South Asia. Since ship breaking involves highly labor intensive work, the SBRI has gravitated to countries with availability of low wage labor. In addition, weak occupational health and environment regulations, and little or no enforcement may also have been a contributory factor for the emergence of a large SBRI sector in South Asia.

At present, the global center of the ship breaking and recycling industry is in South Asia, specifically Bangladesh, India, and Pakistan. These three countries account for 70–80 percent of the international recycling market for ocean-going vessels, with China and Turkey covering most of the remaining market. Only about 5 percent of global volume is scrapped outside these five countries. This study focuses on the SBRI in Bangladesh to get a better understanding of the economics of the industry and the environmental impacts arising out of such activity and to explore possible ways in which such environmental effects may be mitigated.

In some ways ship breaking can be considered a “green industry”. Almost everything on the ship and the ship itself is recycled and reused, thus adding to the sustainability of our natural resources and the environment. However, the process of recycling itself can also lead to environmental problems. This is because ships contain many hazards that, if not handled and disposed off in a safe manner, can have significant detrimental effects on both human health and the environment. In designing, constructing, and operating ships, a wide range of materials are selected for their technical characteristics, often to provide fire protection or meet other maritime safety requirements. When exposed in the process of ship demolition and recycling, such materials may pose a hazard to the demolition workers’ health or the environment.

The volume of hazardous materials handled in the SBRI is expected to increase significantly with the implementation of International Maritime Organization (IMO) regulations for the phase-out of single hull tankers from 2010 to 2015. In addition, the overcapacity built in the maritime transport sector during the 2002–08 “boom” years is now fueling a wave of ship retirements, providing for an increased flow of hazardous material to the South Asian SBRI yards over the next 10–15 years.

Over the years, the SBRI in Bangladesh has accumulated a long record of work-related injuries and fatalities and has only recently begun to adopt practices for safe management and disposal of hazardous materials. The problem is symptomatic of the overall lack of proper disposal facilities for such materials in Bangladesh and Bangladesh; to date. The limited basic infrastructure in ship breaking yards is often highlighted by the industry as a major constraint to the development of a “green” SBRI, as is the lack of appropriate disposal facilities for hazardous materials in Bangladesh and Bangladesh. In December 2005, in recognition of the need for international action to address SBRI pollution and safety issues.

The IMO Assembly agreed that a new legally binding instrument on ship recycling should be developed under IMO auspices. The International Convention for the Safe and Environmentally Sound Recycling of Ships was adopted by a diplomatic conference in Hong Kong, China, in May 2009.

The Hong Kong Convention (HKC) is expected to enter into force in 2015. The HKC will require that signatories ensure that ships flying their flags are only recycled in another state that is party to the convention and under conditions that comply with its work safety and hazardous waste handling requirements. The SBRI in Bangladesh and Bangladesh may require significant investments in procedures, equipment, and facilities to achieve compliance. If Bangladesh and Bangladesh are to join the Convention, they may further need to fill additional regulatory, institutional capacity, and infrastructure gaps. The costs of upgrading an entire sector should be seen relative to the revenues and profits it generates. However, only limited information is currently available to develop an accurate estimate of any future investments.

This study seeks to strengthen the knowledge base with respect to competitiveness and profitability of the SBRI and to investigate the feasibility of ship breaking countries in this region, specifically Bangladesh and Bangladesh, achieving compliance with the HKC without jeopardizing the future of the industry there.

1.2 Objectives and scope of study

The objective of the study is to inform key stakeholders associated with policy making and ship breaking including the government of Bangladesh about the current problems encountered in the SBRI and suggests a road map to help strengthen institutional and regulatory systems that can improve work practices in the ship breaking and recycling industry. The study addresses the following:

• It assessed the productivity, competitiveness and growth potential of the industry in Bangladesh.

• It undertook environmental audits of hazardous waste materials present in ships scheduled for dismantling and established a pollution inventory as well as projections of hazardous materials till 2030.

• It provides a way to scrape ship breaking process.

1.3 Study methodology

In this study, ship breaking and recycling is defined as an industry that, through the use of land, infrastructure, machinery, and labor and through the consumption of utilities, converts ships that have outlived their economic life into steel and other recyclable items, which are then sold in local markets. The study was cover a period of 4 months in 2011-2012. It consisted of an economic and market assessment of the SBRI in Bangladesh; environmental audits of ships and ship recycling facilities to establish a pollution inventory and a gap analysis and needs assessment for compliance with the HKC.

The study had three interrelated activities:

• Economic and market assessment of the ship breaking and recycling industry (SBRI) in Bangladesh.

• Environmental audits of ships and ship recycling facilities to establish a pollution inventory and a gaps-and-needs assessment for compliance with the Hong Kong Convention (HKC); and

• Consultations with key industry, government, and nongovernmental organization (NGO) stakeholders in the countries and at the global level.

Economic assessment methodology

The economic assessment of the ship breaking industry was carried out in Bangladesh under he prevailing environmental and occupational health regulatory regimes. The estimates used in this analysis are based on reviews, updates, and assessments of previous economic, econometric, and financial studies, as well as field interviews with a large number of stakeholders. The estimates generated in this assessment, however, are subject to some degree of uncertainty. To facilitate cross-country comparison, all profitability calculations are based on the same type of “model” ship—a Panamax oil tanker. The economic and market assessment consisted of:

• Review, update, and assessment of previous economic, econometric, and financial analyses of the global trends and demand for ship breaking capacity over the next two decades;

• SBRI market assessment for Bangladesh including the economic, social, and political economy aspects as well as “downstream” demand and industry linkages;

• Country-specific and comparative assessments of the profitability and sustainability of the SBRI in Bangladesh; and

• Assessment of the financial impacts of different possible levels of implementation of the international regulations in Bangladesh.

Environmental baseline methodology

The environmental baseline was generated through a comprehensive literature review and on-site/on-ship assessments and interviews with ship breakers, shop and yard managers, and other stakeholders. The data on hazardous waste and materials were then measured against other information sources for verification.

Capacity and facility gap analyses were conducted by comparing the likely standards that will be finalized under the new HKC and other relevant guidelines (for example, the guidelines of the Basel Convention and the ILO). The study included:

• Reviews and updates of previous assessments of the quantities and types of hazardous materials present in ships scheduled for scrapping and recycling

• Institutional gap analysis for Bangladesh looking at existing SBRI regulatory structures and environment, institutional capacities, enforcement issues and regulatory and compliance gaps vis-à-vis the HKC

• audits of the hazardous materials present in a structured sample of different ships scheduled for breaking and recycling in SAR—the audits were based on the proposed International IMO inventory lists of the potentially hazardous materials present in ships designated for recycling

• Compilation of a structured sample of environmental audits at the ship breaking and recycling sites in Chittagong (Bangladesh); the sample had to be sufficient to establish a baseline and to estimate the costs of remediation and avoidance of future contamination in line with the HKC

•Establishment of a pollution inventory and baseline data on current handling practices, based on the above audits and other relevant data

• Identification and assessment of options (including costing) for hazardous waste handling and disposal to close the gap between existing SBRI practices and what is needed in order to comply with the objectives and targets of international treaties and conventions (particularly the HKC).

Study preparation and stakeholder methodology:

Stakeholder engagement and knowledge transfer were undertaken to ensure that the results and proposals of the study were disseminated widely, that stakeholder perspectives were considered appropriately, and that strong support was received from stakeholder groups. This activity commenced in March 2009 and involved the development and population of a stakeholder matrix detailing the key stakeholders in the three countries.

The first phase of consultations with stakeholders took place in April 2009 through targeted meetings in Bangladesh (Dhaka and Chittagong). Contact points were identified and used during the field work, where informal consultations also took place (June–September 2009). A second set of formal consultations was held in November 2009. These consisted of a milestone consultation meeting in Dhaka, Bangladesh, and industry cluster meetings in or near the centers of the SBRI in each country: Chittagong, Bangladesh;

2. Ship breaking Process

2.1 Steps in Ship breaking Process

After removal from the fleet site, the vessel is towed or self-propelled to the site where scrapping will occur. The vessel is then scrapped while being moored to a pier, anchored, beached, or dry-docked (including graving docks). Most scrapping is per-formed pier-side in slips, which are typically dredged openings that are adjacent to a shipping channel. Slips are approximately 400 to 1,000 feet long and 100 to 140 feet wide at the entrance. Ship-breaking is generally performed by cutting away large sections, which are then moved to shore for further dismantling. A large winch at the head of the slip is used to drag the hull farther out of the water as work progresses. Throughout the scrapping process, it is important for the appropriate safety precautions to be determined and followed to effectively protect personnel. The scrapping process4 usually occurs in a series of steps:

• Conduct a vessel survey.

Diagrams of all compartments, tanks and storage areas are used (or prepared, if not available) to identify areas that may contain hazardous materials such as fuels, oils, asbestos, PCBs, lead and other hazardous wastes. Sampling is conducted using a systematic approach, usually starting in the compartment that will be cut first. In many cases, a facility will presume that certain items contain hazardous materials and dispose of them as such, in lieu of sampling. In such cases, the employer must use proper engineering controls and work practices to ensure that workers, involved with and in the vicinity of the removal, are properly protected from exposure (e.g., through the use of wet methods, or wetting agents, and vacuums with HEPA filters).

• Remove fuels, oils, other liquids and combustible materials.

The removal of fuels, oils and other liquids (e.g., bilge and ballast water) from the ship generally occurs throughout the ship breaking process. Bilge water is sampled and disposed of appropriately. In addition, during the vessel scrapping process, water may accumulate due to rain, firefighting activity, or use of hot work cooling water, and will have to be properly removed. The U.S. Coast Guard requires booms to be placed around the vessel to help contain any spills. Following removal activities, a marine chemist6 certifies that the vessel is safe for entry and safe for hot work. A competent person must continually monitor these areas to ensure that they are still in compliance with the marine chemist’s certificate.

• Remove equipment.

Fixtures, anchors, chains and small equipment are removed first. Large reusable components (e.g., engine parts) are removed as they become accessible. Propellers also may have to be removed so that the hull can be pulled into shallow water.

• Remove and dispose of asbestos and PCBs.

Both asbestos-containing materials (ACMs) and PCBs are usually removed in two stages. Prior to cutting away a section of the vessel, ACM is removed from areas that are to be cut and PCBs are removed from areas that are readily accessible. After the vessel section has been moved to shore, the remaining ACMs and PCBs are removed as they become accessible during the dismantling of the vessel section. The engine rooms usually contain the most asbestos and, therefore, take the longest for asbestos removal to be conducted.

• Prepare surfaces for cutting.

Following the removal of combustible materials, asbestos and PCBs, paint or preservative coatings must be stripped from surfaces to be cut (29 CFR 1915.53). Hard-to-remove materials on surfaces may require specific cut-line preparation, such as grit blasting or flame removal of paint, which can expose workers to toxic metals and volatile components of paint. Appropriate precautions must be taken (e.g., the use of airline respirators) to effectively protect personnel performing the removal, as well as those workers in the immediate area (see 29 CFR 1910.134).

• Cut metal.

During the cutting phase, the upper decks, superstructure and systems are cut first, followed by the main deck and lower decks. Metal cutting is usually done manually using oxygen-fuel cutting torches, but may be done with shears or saws for nonferrous metals. Typically, as large parts of the vessel are cut away, they are lifted by crane to the ground where they are then cut into specific shapes and sizes required by the foundry or smelter to which the scrap is shipped. As cutting continues and the weight of the structure is reduced, the remaining hull floats higher, exposing lower regions of the hull. Ultimately, the remaining portion of the hulls pulled ashore and cut.

• Recycle or dispose of materials.

Scrap metals, including steel, aluminum, copper, copper nickel alloy and lesser amounts of other metals are sorted by grade and composition, and sold tore melting firms or to scrap metal-brokers. Valuable metals such as copper in electric cable that are mixed with nonmetal materials may be re-covered using shredders and separators. The shredders produce a gravel-like mixture of recyclable metal particles and nonmetal “fluff, “which is not recyclable and needs to be sampled for hazardous materials and disposed of accord-ing to state and federal regulations. The metals are then separated from the fluff using magnetic separators, air flotation separator columns, or shaker tables.

2.2 Initial Visit to Vessel to Determine Suitability for Scrapping

Before any work is conducted, an initial visit to the vessel is required to determine its condition. During this visit, the following must be identified: the hazardous materials (e.g., lead, asbestos, PCBs) that must be removed from the ship, the hazards that workers could be exposed to during the scrapping operations, and the condition of the ship, including its suitability for towing and seaworthiness. From the information obtained, a sampling plan8 must be developed to address environmental remediation and the health hazards9 identified, including the special tools and equipment that will be required to en-sure worker safety. When workers are aboard the ship for this assessment, those who are required to work alone must be checked on frequently, as re-quirked by 29 CFR 1915.94. To comply with this requirement, employers should make arrangements with the ship’s custodian for worker escorts during this visit. The custodian should be consulted with to identify unknown hazards such as missing decking, open holes, or areas that may need to be gas-free.

Figure 2.1 Navy vessel pier-sides for ship breaking

The Hazard Communication standard, 29 CFR1915.1200, requires that employers communicate in-formation about health hazards to workers and that they have material safety data sheets (MSDSs) avail-able for all hazardous materials handled or used in the ship breaking process. OSHA standards for specific substances are generally performance based and require the protection of personnel from hazards through compliance with permissible exposure limits; exposure monitoring, medical surveillance, use of respirators and protective clothing, and other requirements (see 29 CFR 1915, subpart Z). Some specific hazards of ship breaking include:

• Freon commonly found in refrigeration systems that, if released, could evaporate rapidly to create atmospheres immediately dangerous to life or health (IDLH).

• Holon and carbon dioxide12 in fire suppression systems that can create IDLH atmospheres if they are released into spaces. Manual and free-flood automatic fire-suppression systems must be physically isolated or employ other positive means to prevent discharge before any hot works permitted in spaces protected by such systems(29 CFR 1915.506).

• Hydrogen sulfide, a colorless, toxic and flammable gas that can result from the decomposition of microscopic marine life killed by Aqueous Film Forming Foam (AFFF) mixed with seawater in AFFF wet firefighting systems.

Carbon monoxide (CO), a colorless and odor-less gas that is produced by the combustion process such as welding, spontaneous combustion, and internal combustion engines. Prolonged exposure may result in headaches, nausea, dizziness and ataxia.

• Metals of concern may include:

1. Lead15 in paints and some greases, or possibly as tetraethyl lead16 for use as an additive in fuels;

2. Mercury17 in gauges, tank-level indicators, or fluorescent light tubes;

3. Tributyltin oxide18 on underwater hull plates;

4. Chromates19 in paints and varnishes;

5. Cadmium in electrical and electronic equipment; and

6. Arsenic paints.

• Oxygen deficiency due to rusting in tanks that have been sealed for long periods of time.

• Toxic contamination due to hazardous cargoes that may have been carried in tanks.

• Asbestos exposure for workers removing asbestos-containing thermal insulation; handling circuit breakers, cables, and cable penetrations; and removing floor tiles (from asbestos in thematic and in tile). Additional concerns can arise from handling and removing gaskets from piping systems and from electrical systems. Asbestos may also be found in some molded plastic parts All asbestos must be identified, removed and handled in accordance with 29 CFR 1915.1001.Asbestos removal is also regulated by the Expounder the asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP),40 CFR 61 Subpart M. Many states require, and recommends, that an AHERA-qualified (Asbestos Hazard Emergency Response Act of1986) asbestos inspector identify all asbestos-containing materials prior to beginning ship breaking operations. Some states also require that employers notify their environmental regulatory agencies prior to conducting asbestos removal operations.

• Polychlorinated biphenyls (PCBs) in rubber products such as hoses, plastic foam insulation, cables, silver paint, habitability paint, felt under septum plates, plates on top of the hull bottom, and primary paint on hull steel.

2.3 Towing the Vessel

Dead-vessel tows are regulated by the U.S. Coastguard at 33 CFR 165 et seq. Administrative procedures for towing vessels are established by local Coast Guard Sectors, so employers should contact their respective Captain of the Port (COTP) to deter-mine local policy; see Port Directory. Usually, a re-quest for a dead-ship tow is required to be submitted at least 48 hours in advance, if the tow is within the port, and seven days in advance, if the tow is out-side the port. Typically, this task is handled by the contracted towing company. Generally, the request must contain the following information about the towed vessel: name, call sign, flag, length, draft, sail height, and the type, amount, and locations of oil and other hazardous materials onboard. However, the required information may vary depending on the port. Tank diagrams are recommended to detail the location of oil and other hazardous materials. The request must also contain the total number of tugs and their horsepower, place of departure and destination, the date and time of departure, the duration of the tow, and the name and 24-hour telephone number of the responsible party. Indicate if an unusual tow configuration will be used or if the request is for more than one towed vessel.

Figure 2.2 The Roger Stahl towing the Saginaw from Duluth on 10/24/99.

Depending on the particulars of the vessel being towed (e.g., age, extended lay-up status, vessel condition, etc.), the COTP may require that additional safety precautions be established before the tow is authorized. This may include requirements such as obtaining a marine surveyor’s report, verifying the vessel’s seaworthiness, or allowing a representative from the Coast Guard to examine the vessel to verify seaworthiness, pollution potential, and the adequacy of the towing arrangement. Such a report will include the recommended towing configuration, condition inspection to evaluate seaworthiness, determination of which personnel will be allowed onboard during the tow, and any other special instructions to allow for a safe tow. In certain circumstances an International Load Line Exemption Certificate or a Coastwise Single Voyage Load Line Certificate may be required in ac-accordance with 46 CFR 42 Subchapter E (Load Lines).To make this determination and schedule an examination, requests for tows offshore (e.g., beyond the boundary line) must be submitted seven days in advance.

2.4 Mooring the Vessel

Vessels that are intended for pier-side scrapping need to be properly secured using approved mooring lines and a mooring plan reviewed by a qualified professional, such as a naval architect or marine engineer. The facility should have a Heavy Weather Plan, which includes additional mooring requirements for high and low tides, hurricanes, and other adverse weather conditions. Mooring bits should be engineered to have sufficient strength to withstand forces imparted by all weather conditions. It is recommended that ships not be moved during winds exceeding 25 knots.

Figure 2.3 Vessel in dry dock for scrapping.

Personnel assigned to assist in line handling should be experienced in line handling and must wear personal flotation devices22 (PFDs) when there is a potential for falling into the water, as required by29 CFR 1915.152(a). Personnel must be kept clear of the lines and never stand in the bight of a line. Nylon lines, primarily used on older ships, are subject to atmospheric damage (e.g., sunlight, weathering, etc.) and may break without warning, releasing large amounts of energy capable of killing or maiming workers. Spill-containment booms must be placed around all vessels, and personnel should be trained in the procedures for opening and closing the booms. Care should be taken to keep small boats, located between booms, from being crushed due to unanticipated vessel movement. Fenders or other breasting devices should be used to prevent such an incident. Operators of small boats must wear U.S. Coastguard-approved PFDs and have on board a life ring with 90 feet of line. Workers must be denied access to the vessel until a gangway, ladder, or ramp meeting the requirements of 29 CFR 1915.74(a) and (b) and 29 CFR1915.75 (a) thru (d) is provided. Particular attention should be paid to the trim of the gangway, ladder, or ramp, where the fall or rise of tides may cause the angle to become unsafe, or pull away from its sup-port. Means should be provided to deny access to the vessel by unauthorized personnel during non-work hours.

If work is conducted at night, adequate lighting23must be provided and maintained at all times as required by 29 CFR 1915.92(a). In ship breaking operations, the ship’s lighting may be difficult to maintain and, therefore, should be considered unreliable. If ship’s lighting is used, a secondary means of lighting (e.g., temporary lighting or personal flashlights) must be provided as required by 29 CFR 1915.92(e).Personal flashlights must be intrinsically safe or explosion-proof as required by 29 CFR 1915.13(b)(9).Light-emitting diode (LED) flashlights are recommended for use in gas-free spaces due to their small size, durability and dependability.

2.5 Hauling the Vessel

It is important, before hauling a vessel24 out of the water that an evaluation of the stability of the vessel be conducted. Forces can develop that could make the vessel unstable and cause it to tip over. Personnel must not be aboard a vessel while it is being pulled ashore, since it is possible for the vessel to topple over or for sections to break, creating severe hazards for workers onboard. A naval architect or marine engineer who has extensive experience docking ships should evaluate the ship for stability prior to hauling the vessel to ensure a safe operation.

Hauling machines and chains or wire ropes aroused in the hauling process to move vessels in the water and on shore. This equipment is affected by the weight of the vessel, the incline of the slope, the friction between the hull and the slope, and any change in the rate at which the vessel is hauled. When more than one chain or wire rope is used, the loading must be equalized among the chains or wire ropes to ensure that no single leg is overstressed. It’s imperative that the equipment operators are aware of the hazards associated with the hauling process and have the ability to quickly compensate for torque or variation in pitch. Hauling machines usually consist of a train of gears, operated by electric motors turning one or more toothed chain wheels driving the hauling chain. The moving parts of hauling equipment must be guarded as required by 29 CFR 1915.115(b).Steel hauling chains with appropriate pitch and uniform link dimensions should be used for hauling the ship. Because of their high tensile strength and the ease with which they can be connected with special hauling shackles, which are as strong as or stronger than the chain itself, most scrappers find chains more durable and economical than the best wire rope. The ability to measure the strength of chains is a major advantage that chains have overtire ropes. These chains, fitted over alloy steel wheels, have a small pitch diameter that permits hauling heavy loads with relatively small hauling machines. A chain swivel is recommended to prevent excessive twist, which could cause an overload of one section of chain.

2.6 Planning

It is important for employers to have a safety and health management system (SHMS) in place that encompasses all aspects of the facility’s ship breaking procedures and processes. The SHMS should consist of a technical plan, safety and health plan, and an environmental technical plan, which can be altered for each specific job. A written technical plan should outline the scrapping process, schedule, cut lines, and other engineering factors specific to each project, to ensure that the vessel is scrapped in a systematic manner to protect property and personnel.

Drawings of the vessel should be obtained and broken down by work areas to allow a naval architect or marine engineer to develop a cut plan so that the weight and stability of each vessel section can be assessed at each stage to ensure a safe operation. A safety and health plan or manual should cover all aspects of the ship breaking process and specify actions to be taken in the event that an emergency occurs. An environmental technical plan should address remediation of all hazardous materials. Each plan must be developed in accordance with federal, state and local laws. Daily production meetings should take place to discuss the day’s events, upcoming critical processes and procedures, and any safety considerations or special instructions needed to complete the day’s tasks safely. A morning safety talk should be scheduled to discuss safety and health issues that will be faced on that day, or other topics for educational and special emphasis purposes.

2.7 Breaking the Vessel

One of the first steps in breaking the vessel is the removal of hazardous and flammable materials, which is often called the drilling and draining phase (or pumping phase). Drilling refers to the act of drilling holes in systems to allow the release and capture of fluids in the systems. It may also involve opening drain ports already installed in the system. Holes are drilled at the lowest possible points in the sys-tem to ensure that the system is completely drained of fluids. Draining involves removing all hazardous fluids and materials from the ship’s systems including hydraulic, cooling, high-pressure air, steam condensate, preservatives in rudders and skews, and fire-suppressant materials such as AFFF (aqueous film-forming foam), halon and carbon dioxide. It is important to consider the hazards that this process creates, and they should be treated accordingly. Personal protective equipment (PPE) must be provided to personnel to prevent them from coming into contact with liquids, oils, greases and materials that could cause skin and eye irritation (29 CFR 1915.152(a)). All PPE should be selected by appropriately trained personnel and examined for proper fit. Further, atmospheric testing by a competent person is required while these systems are being drained (29 CFR 1915.12(a)).

Testing must be performed in each space or area that workers are required to enter or conduct work. This testing must occur in the following sequence: oxygen content, flammability and toxicity. No hot work is allowed in spaces that contain active fixed fire-extinguishing systems that have not been isolated to prevent discharge. If this precautionary step is not followed, the system could release its contents into the space, producing a dangerous atmosphere.

As hazardous materials are drained from systems, the materials should be segregated by substance and kept separate. Mixing hazardous materials may cause uncontrolled chemical reactions between materials, resulting in exothermic reactions (excessive heat or fire), release of toxic gases, or other reactions that could injure personnel or cause an environmental spill. Several procedures/processes may occur simultaneously during the drilling and draining phase, including hazardous materials remediation, removing recyclable items, and extracting easily removed interior components. This process helps remove as many components as possible from the interior of the vessel, creating a tunnel effect, to allow cutting to begin from the top down. Cutting then proceeds from each end of the vessel, working towards the center of the vessel (see the diagram below – Module Cut Plan).

Figure 2.4 a sample Module Cut Plan.

Source: OSHA (Occupational Safety and Health Administration)

This multifaceted approach requires excellent planning and constant safety oversight so that workers are aware of what operations are ongoing and where they are occurring aboard the vessel. The daily safety talk can be a valuable tool for informing workers of planned operations for the day. As the work progresses, good housekeeping must be maintained to reduce hazards and provide safe work surfaces and areas for workers. Solid wastes should be promptly removed and properly disposed of to aid in maintaining a safe work area.

2.8 Burning Equipment

Burning equipment used in cutting metals must be provided with regulators and flashback arrestors should be installed. Lighter-than-air gases (e.g. acetylene, natural gas) are recommended because they do not pool in low areas as heavier-than-air gases (e.g., argon, propane, and carbon dioxide) tend to do. Lines should be inspected frequently for damage and should be routed to avoid damage and to avoid tripping hazards for workers. Lines must not be left in enclosed spaces while unattended for longer than 15 minutes (29 CFR 1915.503(b)(2)(ii)). Pressure-drop tests or other positive measures should be conducted on the lines each time that they are connected to a manifold to ensure their integrity, so that there are no leaks within the burning system (29 CFR 1915.503(b)(2)(iv)).

At the end of each shift the torch lines should be rolled back to the manifold. Fittings for gas lines must be incompatible with respiratory equipment to avoid mixing toxic gases with breathing air. Compressed-gas cylinders must not be taken into confined spaces. During storage, oxygen cylinders must be separated from fuel-gas cylinders by a minimum of 20 feet or by a 5-foot high barrier with a minimum half-hour fire resistance rating. When cylinders are not in use, they must be disconnected and have valve protection caps in place. Cylinders should be stored in an upright and secured position away from high traffic areas.

Cold Cutting

Cold cutting of vessels presents numerous hazards to workers. Therefore, it is imperative that reciprocating saw blades are kept sharp to prevent malfunctions that can lead to possible injuries. This practice will speed production as well. Since saws create noise sufficient to cause hearing loss, hearing protection must be provided to and be used by workers operating or working in close proximity to the saws (see 29 CFR 1910.95). Additionally, ergonomically-designed gloves should be used to minimize vibration exposure to workers. The employer must ensure that the power supply to reciprocating saws is provided with ground-fault circuit interrupters. Electrical cords must be maintained in sound condition and routed or protected so as to prevent damage to the cords and avoid creating a tripping hazard for workers.

Mobile Hydraulic Shear Cutters

Mobile shear cutting is prevalent in ship breaking and presents several hazards to personnel. Workers must not place any part of their bodies in the danger zone of the equipment (e.g., the shear area). When this type of machine is mounted as an attachment on a backhoe or excavator-type machinery, the swing radius should be barricaded to prevent workers from coming into the pinch-point area between the rotating structure of the machine and its drive carriage or other fixed objects, such as the part of the ship being scrapped. Care should be taken to cut materials to prevent recoil and to keep large pieces from striking or falling on workers.

Shore side processing of Metals

Scrap metals, including steel, aluminum, copper, copper nickel alloy, and lesser amounts of other metals, are sorted by grade and composition and sold to remitting firms or to scrap metal brokers. Valuable metals, such as copper in electric cable, that are mixed with nonmetal material may be recovered using shredders and separators. The shredders produce a gravel-like mixture of recyclable metal particles and non-metal “fluff” that is not recyclable and needs to be sampled for hazardous materials and disposed of according to state and federal regulations. The metals are then separated from the fluff using magnetic separators, air-flotation separator columns, or shaker tables. Machine guarding must be provided in accordance with 29 CFR 1910.212 and 29 CFR 1910.219. Guards should be interlocked to shut down the equipment in the event that the guard is opened. Noise exposure must be controlled in accordance with 29 CFR 1910.95.

An industrial hygiene assessment of metals exposure must be conducted and controls implemented to maintain worker exposures within acceptable limits. Asbestos must be removed in accordance with 29 CFR 1915.1001 before processing scrap metal. Measures must be taken to prevent skin contact with polychlorinated biphenyls (PCBs). Additionally, PCBs must be cleaned from cut lines of materials that are to be cut by burning (see 29 CFR 1915.53(d)(1)). Care must be taken to ensure that workers do not position themselves beside or below a section being cut, where falling pieces of scrap or the section might strike them. Pieces being cut often become unstable, shift, fall or slide. Therefore, workers must be positioned so that they are not subject to being struck by shifting materials (see 29 CFR 1915.116(j) and (k)). Several fatalities have been recorded where scrap metal pieces or sections crushed workers walking through cutting areas.

2.9 Fall Protection

Falls are a major hazard in ship breaking due to the ever-changing work environment. Continuous cutting of the vessel weakens the structures or sections and creates new openings and deck edges, making fall protection a necessity. Workers need to wear safety harnesses and be tied off when near open holes and deck edges. Anchorage points for each positioning device system must be capable of supporting at least double the potential impact load of a worker’s fall (29 CFR 1915.160(a)(3)). In addition, life lines must be kept clear from sharp edges to avoid the lines from being cut or damaged. Although the requirement in 29 CFR 1915.73 (“Guarding of deck openings and edges”) does not apply to ship breaking, it is recommended that barriers be placed around or near deck edges and openings whenever feasible.

2.10 Fire Prevention and Protection

Subpart P – Fire Protection in Shipyard Employment, 29 CFR 1915, requires employers to have an overall fire suppression program that establishes the location, type and capacity of firefighting equipment such as extinguishers, fire hoses and standpipes, smoke detectors, automatic sprinklers and other fixed firefighting systems in accordance with applicable fire codes. Employers must have a written plan in place that provides for the routine inspection, maintenance and replacement of this equipment and must require training for new workers and refresher training for all shipyard workers. The writ-ten plan must include procedures for the control of fire hazards, such as flammable and non-flammable compressed gases, ignition sources, combustible materials, welding and hot work operations and must include procedures for evacuation. The employer’s evacuation plan must include the following: emergency escape procedures; procedures to be followed by workers who may remain longer in the worksite to perform critical shipyard operations be-fore they evacuate; procedures to account for all workers after an emergency evacuation is completed; preferred means for reporting fires and other emergencies; and the names or job titles of the workers or departments who may be contacted for further information or explanation of duties.

Employers must have a written fire watch policy that specifies the necessary training of workers, their duties and personal protective equipment (PPE) to be used. This policy may be part of the overall fire safety plan or separate, but must be effective in protecting workers from injury. A fire watch must be posted while hot work is being performed when any of the following conditions are present: slag, weld splatter, or sparks; unprotected combustible materials or insulation; and heat radiation or conduction on insulated pipes, bulkheads, decks, overheads and partitions (see 29 CFR 1915.504). It is important that workers assigned to fire watch duty are not tasked with any additional duties while hot work is in progress. In addition, the fire watch must be able to communicate with the workers performing the hot work, as well as any personnel that may be affected.

2.11 Emergency Response

In addition to compliance with 29 CFR 1915.502, which includes a fire safety plan, OSHA requires compliance with 29 CFR 1910.38 and 29 CFR 1910.39 for emergency response and fire prevention planning. Employers do not need to have separate emergency response plans as long as the plan covers the applicable general industry worker emergency plan and fire prevention plan provisions, as well as the shipyard employment fire safety plan. A mustering plan for each jobsite should be incorporated in the emergency response plan to account for all workers in the event of an emergency where evacuation is required. Each plan or combination of emergency response plans must be in writing, kept in the work place and be available to workers for review.


A fire response organization, as defined in 29 CFR 1915.509, may include (1) fire brigades, (2) shipyard fire departments, (3) private or contractual fire departments, or (4) municipal fire departments. While larger shipyards may have their own fire responders, smaller shipyards often use an outside source, typically the local fire department. These municipal or other fire departments may have little experience in fighting fires in shipyards, especially on vessels. Fighting vessel fires can be more complicated than traditional firefighting because outside firefighters seldom have the opportunity to learn the layout of the vessels. Additionally, vessels being scrapped have constantly changing structures. Therefore, proper coordination, familiarization, training and drills are necessary to ensure the safety of outside firefighters who respond to ship yard fires.

In coordinating drills and other communications with an outside fire department, employers must discuss the types of fire suppression incidents to which the fire response organization is expected to respond to and procedures for obtaining help from other fire response organizations. Additionally, methods of familiarizing the external fire response organization with the layout of the facility or worksite, including access routes to controlled areas and site-specific operations, occupancies, vessels or vessel sections and hazards should be discussed. The employer must ensure the standardization of all fire hose couplings and connection threads throughout the shipyard and on vessels or vessel sections by providing the same type of hose coupling and consecution threads for hoses of the same or similar diameter.

Responders to shipyard fires encounter a complex set of hazards involving buildings, as well as vessels in dry docks, wet slips, or pier-side. Fire responders need to be prepared to safely and successfully handle a wide range of fires from flammable liquids in a storage room of a shipyard building, to oil-soaked rags in the engine room of a ship. The fires could include: combustible materials (such as wood, paper, or cloth); flammable or combustible liquids (such as oil, fuels, paints, or chemicals); insulation and other materials that may give off toxic gases and smoke during a fire; electrical components (such as energized motors, circuit controls, transformers, or wiring); or even combustible metals (such as magnesium or titanium).


A rescue team must be established to respond promptly to rescues required in confined and enclosed spaces or other areas where dangerous atmospheres may be present. The rescue team can be composed of workers, or it can be an outside team that meets all the applicable requirements of 29 CFR 1915.12(e)(1). When an outside rescue team is used, they should be given a tour of the employer’s facility to ensure familiarity with the operations and to identify any special concerns for rescue. They must be given an opportunity to conduct drills on board a vessel being scrapped.

Lifesaving Materials

At least one ladder25 meeting the requirements of 29 CFR 1915.158(b)(5) must be available near each floating vessel on which scrapping work is being conducted. Depending upon vessel length, one or more liferings26 meeting the requirements of 29 CFR 1915.158(b)(1) thru (4) must also be provided. Although they are not required for ship breaking operations, OSHA recommends that at least one lifesaving skiff be immediately available at locations where workers are working over or adjacent to water.

Hazardous Material Spills

Spill kits should be provided that contain an adequate quantity of suitable materials for spill containment and cleanup. The contents of these kits should be restored after each use to ensure that adequate materials are available to allow workers to respond safely to future spills. All applicable environmental regulations should be consulted to ensure that response and reporting requirements are met. Only fully qualified and properly equipped personnel are allowed to respond to hazardous material spills.

Energy Control

Every effort should be made to take all mechanical and electrical systems to a zero energy state during the drill and drain phase of breaking the vessel. However, to provide adequate lighting for workers, the ship’s lighting system28 is often maintained. It may also be desirable to maintain the electrical distribution system, which can be more dependable, rather than using shore-based temporary services to provide power to electrical equipment and tools. When this is done, the employer must ensure that the integrity of electrical systems is maintained in a safe manner, including guarding of live parts and grounding by implementing electrical energy control procedures.

Before hot work is permitted in areas where free-flooding, automatically activated fire-suppression systems are installed, the system must be physically isolated or other positive means used to prevent an accidental discharge.

2.12 Shipboard Rigging

Personnel assigned to perform rigging should be trained in good rigging practices. Rigging gear must be of adequate capacity to safely handle the largest anticipated load with a safety factor of no less than. While the use of tag lines is not required in ship breaking, care must be taken to ensure that loads are not carried over the heads of workers and that workers do not place themselves between a suspended load and a fixed object where they could be crushed. When slings attached to eye-bolts are used, the pull must be within 20 degrees of the axis of the bolt as required by 29 CFR 1915.116(e). Only shouldered eye-bolts should be used. Wood, canvas, or other suitable materials must be used as chafing gear or softeners to pre-vent damage to wire rope slings where they run over the edges of materials being handled.

Materials Handling

During the ship breaking process, workers handle large sections of steel and other heavy or awkward materials, resulting in unique materials handling issues that may cause injury. To the extent feasible, manual materials handling should be avoided when weights are unknown or excessive, or because of other conditions such as uneven walking surfaces, falling hazards and irregular or sharp edges of a cut plate. Mechanical materials handling methods should be used whenever possible (e.g., cranes); however, when manual materials handling is performed, gloves should be provided to protect against cuts. Walking paths31 should be kept free from obstructions and tripping hazards. Shoes should be maintained in a dry, oil-free condition, with soles and heels evenly worn.

Crane Services

One of the more hazardous operations in ship breaking is handling materials with cranes.33 Crane operations involve a complex relationship between the machine, the operator, the material being handled, the rigging and rigging gear that secures the material to the crane hook, the workers and obstructions in the area, and the ground surface or foundation of the crane. Failure, inadequate planning, or improper operation can have disastrous consequences. In 2005 alone, crane accidents.com34 reported 127 fatalities related to crane accidents.

Only workers who are properly trained and qualified may be assigned to operate cranes in support of ship breaking operations. Crane operators must know and understand signals used to control the crane and must be familiar with the operation of the specific machine to which they are assigned. Riggers should also be trained to safely carry out their assigned tasks.

The swing radius of the counterweight and superstructure must be established and guarded to prevent workers from being struck. Special attention should be given when cranes are operating near buildings or other structures. Loads must not be swung over the heads of workers. Both swing and travel alarms should be used to warn workers of machine movement. When lifting “in the blind,” a signalman who is visible to the operator must be placed to assist the operator in safely moving the load. Cranes used for removing materials from the ship must be certified. A crane of sufficient capacity to safely handle the largest expected load must be used.

Figure 2.5 Crane being used to lift cut section from vessel undergoing scrapping.

It is particularly important in selecting cut lines to consider the weight of the total load to be handled. A qualified naval architect or marine engineer should be consulted to ensure that sections cut are within the safe lifting capacity of the machine to be used. Industry practice often involves attaching the load to the crane before the final cut frees the load to avoid shock loading of crane. The use of electric load-indicating devices recommended ensuring that the crane or rigging is not overloaded beyond the structural safe load rating.

If any recognized over-load or shock load o curs, then the crane should be removed from service until the crane and rigging are inspected in accord with the crane manufacturer’s or certified agent’s instructions. The crane must be maintained in accord with the manufacturer’s recommendations and must be inspected in accord with applied standards for the type of crane used.

Fork Trucks

If fork trucks are used to move materials, only rough terrain fork trucks are recommended. Operators must be trained and must not have any condition that could cause them to become incapacitated (e.g. uncontrolled diabetes, epilepsy or heart disease) (29 CFR 1915.117(c)). Fork trucks should be of sufficient capacity for the intended load. Loads should not extend beyond the forks in a manner that could cause the fork truck to tip over. If frontend attachments are used, other than factory installed attachments, the employer must have the truck marked to identify the attachments and the appropriate weight of the truck and attachment combination (29 CFR 1910.178(a) (2) (5).

Fork trucks should be properly maintained with consideration given to the effects of the marine environment on the truck. Gasoline or diesel fork trucks should not be placed in vessel holds due to the potential for buildup of toxic gases (e.g., exhaust fumes). Fork trucks should not be driven up to workers where they might be crushed by the truck or load. Where the operator’s view could be obstructed by a load, the truck should be operated with the load trailing. In situations when loads must be carried uphill they should only be driven in a forward motion and with a designated spotter. The truck path should be twice the width of the load being carried to avoid inadvertent contact with objects. An inspection must be performed on all trucks in service before each shift and at necessary intervals during its use, in accordance with 29 CFR 1915.111(a). If any item that affects the safe operation of the truck is found to be defective, the truck should be removed from service until it is repaired.


Trucks may be used to haul scrap both over the road and in the yard. Trucks used over the road should be maintained in a road-worthy condition and inspected in accordance with federal and state safety regulations. The truck should be inspected daily by the driver and any condition that affects the safe use of the truck should be corrected before it is used.

Trucks used in the yard should never be backed or driven up to workers standing between the truck and a fixed object. Additionally, backup alarms should be provided on these trucks when they are used in the yard to haul scrap. A spotter should be used to assist the driver when the view to the rear is obstructed. Over-the-road drivers must have a proper Commercial Driver’s License. Scrap should be loaded within the safe capacity of the truck and evenly distributed over all axles, ensuring compliance with state and federal axle weight requirements. It should be loaded so as to prevent materials from shifting in or falling from the truck. While on the road, the load should be covered to prevent loose pieces from falling out.

2.13 Training

All workers engaged in ship breaking operations must be trained in the hazards of the work to which they are exposed (e.g., persons assigned to burn materials should be trained in burning safety; riggers in rigging safety). General hazard recognition and safety precautions should be included in worker orientations, as well as training provided on the personal protective equipment (PPE) to be used at the worksite. PPE training must include use of hardhats, eye protection, footwear, hearing protection, work gloves, and other PPE as appropriate. Workers should be instructed to avoid the use of synthetic clothing that melts or burns rapidly such as nylon, rayon, or Coram, in areas where burning operations are conducted. A daily “tool-box safety talk” to review work progress, planned work for the day and anticipated hazards associated with that work is recommended.

2.14 Communication

Increasingly, non-English-speaking workers are being employed in the ship breaking industry. As a result, it has become difficult for employers and workers to communicate effectively. Despite the language barrier, signage and instructions must be understood by all workers (29 CFR 1915.16(a)). Therefore, employers may need to provide required postings and warnings in more than one language (e.g., English, Spanish, and Vietnamese) at the worksite.

It is important for workers to understand the hazards to which they might be exposed and the precautions necessary to avoid injury from those hazards. If workers are unable to read MSDSs or other hazard communication information themselves, then the employer should provide an interpreter to pass the information on to them.

2.15 Maintenance Shops

Maintenance shops at ship breaking facilities have similar safety and health hazards normally encountered in other maintenance shops. As in other shops, particular attention should be paid to housekeeping, electrical safety, machine guarding and storage, and the use and disposal of hazardous materials.

3. The Economics of the Ship Breaking and Recycling Industry

This chapter presents an assessment of the economics of SBRI in Bangladesh by examining the industry’s growth, profitability, and productivity. Specifically, the discussion focuses on:

• The SBRI’s historical development and current trajectory within its global industrial context

• The structure and performance of the industry relative to market demand for its outputs

• The policy and business environment in which it operates

• Localized social and economic impacts and their management.

Historically, there has been limited analysis of the overall economics of the SBRI and of its competitiveness. Most studies have mainly focused on the process of ship breaking and its environmental and social consequences. As a result, information on the economics of the industry is typically either glossed over or examined in a very general and superficial way. Profitability is only assumed in consequence of supply side factors, and economic significance is usually viewed as a result of the apparently high employment in the industry and its multiplier effect. Until now, there has been little analysis of the downstream demand for SBRI outputs and how it contributes to the industry profitability.

At present the SBRI in Bangladesh and Bangladesh is mainly concentrated at two ports/ship breaking areas:

• Chittagong in Bangladesh

Such geographic concentration of ship breaking and recycling activity is no accident. The formation of these clusters have been driven by location advantages as well as the presence of upstream suppliers and downstream re-rolling mills and the easy access to reworking or processing, wholesaling, and retailing of other recyclable items. Over time, the SBRI concentration in the two locations in these countries have become a part of wider metropolitan complexes—spanning the wider urbanized areas of Chittagong and Karachi. This has further helped in attaining the economies of scale needed for the SBRI to grow and prosper.

The SBRI’s ongoing growth, development, and performance in each place benefit from external economies of scale or agglomeration economies in two forms:

• Localization economies: productivity-enhancing economies of scale that are internal to the industry and arise from “within-industry” interactions that accrues to firms on account of the size of the industry in a specific location

• Urbanization economies: productivity-enhancing economies of scale arising from the size and diversity of the urban setting that is external to a particular sector or industry but available to all firms.

3.1 Global SBRI supply and demand dynamics

At any particular time, broad globa