Final Site inspection report Application 026 V3...- Issue of draft report - Implement comments to...
Transcript of Final Site inspection report Application 026 V3...- Issue of draft report - Implement comments to...
INSPECTION OF A SHIP RECYCLING FACILITY IN TURKEY
Site Inspection Report
Application 026 European Commission DG Environment
Report No.: 2019-0920, Rev. 0
Document No.: 11EBF7CF-2
Date: 2019-10-21
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page i
Project name: Inspection of a ship recycling facility in Turkey DNV GL AS Maritime
Environment Advisory
Veritasveien 1
1363 Høvik
Norway
Tel:
Report title: Site Inspection Report Application 026
Customer: European Commission DG Environment,
Customer contact:
Date of issue: 2019-10-21
Project No.: 10152882
Organisation unit: Environment Advisory
Report No.: 2019-0920, Rev. 0
Document No.: 11EBF7CF-2
Applicable contract(s) governing the provision of this Report: Framework contract
ENV.A.2/FRA/2015/0013 with specific request number 070201/2017/772222/ENV.B.3
Objective: The objective of the on-site inspection is to verify compliance of the facility with the
requirements set out in the Ship Recycling Regulation.
Prepared by: Verified by: Approved by:
Copyright © DNV GL 2019. All rights reserved. Unless otherwise agreed in writing: (i) This publication or parts thereof may not be copied, reproduced or transmitted in any form, or by any means, whether digitally or otherwise; (ii) The content of this publication shall be kept confidential by the customer; (iii) No third party may rely on its contents; and (iv) DNV GL undertakes no duty of care toward any third party. Reference to part of this publication which may lead to misinterpretation is prohibited. DNV GL and the Horizon Graphic are trademarks of DNV GL AS.
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hazardous waste, waste management,
health, safety, monitoring.
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Rev. No. Date Reason for Issue Prepared by Verified by Approved by
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Table of contents
1 EXECUTIVE SUMMARY ..................................................................................................... 1
2 INTRODUCTION .............................................................................................................. 2
3 OBJECTIVE .................................................................................................................... 2
4 SCOPE OF WORK ............................................................................................................ 2
5 METHODOLOGY AND ACTIVITIES ...................................................................................... 4
6 RESULTS OF THE ASSESSMENT ........................................................................................ 6
7 PHOTOS FROM THE INSPECTION .................................................................................... 52
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 1
1 EXECUTIVE SUMMARY
The objective of this report is to document the results of the site inspection at EGE CELIK SAN. VE TIC.
A.S., located in Aliaga (Izmir region, Turkey), following the facility's application for inclusion in the
European List of ship recycling facilities. The on-site inspection took place on the 27th and 28th of June
2019.
During the site inspection, the facility demonstrated that it is approved by its authorities and has a
suitable organisation with a proven track record. Overall, the evaluators found the operation to be
according to good practice, with well-kept and well-equipped facilities, and with a well implemented
quality management system.
The governing document for the site inspection, defining the baseline of the facility’s performance, is the
Ship Recycling Facility Plan (SRFP). A paramount task of the inspection was to verify that the SRFP is a
living, logic and systematic document accurately reflecting the operational practices on the ground. The
content of the SRFP at the time of the inspection was good, especially because the SRFP had been
developed from scratch by the facility itself and not a “tweaked” standard template from external
provider. However, many good, daily key practices such as cutting procedures and intertidal zone
protection were not described sufficiently in the SRFP. In September 2019, the applicant forwarded an
updated SRFP, which was found to be adequate.
Compliance could not be confirmed for monitoring of soil and sediment during the site inspection, but the
applicant had initiated measures. A new monitoring plan of soil and sediment was forwarded by the
applicant in October 2019 and found acceptable.
Upfront of the inspection the applicant had revised its Emergency Preparedness and Response Plan
(EPRP), but there were still some shortcomings. It was recommended that the facility further
consolidates its EPRP. A revised EPRP was subsequently submitted in September 2019 and found to be
satisfactory.
In conclusion, based on the results of the site inspection and considering the relevant additional
documentation received from the facility in response to the draft report, it is considered that the facility
is capable in practice to recycle ships in accordance with the requirements of Regulation (EU) No
1257/2013 on ship recycling.
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2 INTRODUCTION
The European Commission DG Environment (hereafter referred to as The Commission) has contracted
DNV GL to conduct a site inspection of the recycling facility EGE CELIK SAN. VE TIC. A.S., located in
Aliaga (Izmir region, Turkey) hereafter referred to as the facility. An application for inclusion in the
European List of ship recycling facilities has been registered for this facility under application number 026.
3 OBJECTIVE
The objective of the on-site inspection is to verify compliance of the facility with the requirements set out in the Ship Recycling Regulation Articles 13, 15 and 16 and clarified in the 2016 Technical guidance note1.
Hereunder the objectives of DNV GL’s methodology is to:
• Verify the Facility’s capability to comply with the regulations and requirements listed in the
assessment scope
• Assure that documented recycling processes, work procedures, quality controls and
document handling are managed and implemented as specified in the regulations and
requirements
• Ensure that the Facility has enough knowledge and understanding of the regulations and
requirements for recycling facilities
• Assure consistent evaluation of facilities on equal terms
4 SCOPE OF WORK
The scope of the assessment is, according to contract:
• Ship recycling regulation (EU) No 1257/2013
• Technical guidance note under Regulation (EU) No 1257/2013 on ship recycling
This inspection also considered article 13(1) of the Ship Recycling Regulation: "In order to be included in
the European List, a ship recycling facility shall comply with the following requirements, in accordance
with the relevant Hong Kong Convention provisions and taking into account the relevant guidelines of the
IMO, the ILO, the Basel Convention and of the Stockholm Convention on Persistent Organic Pollutants".
The scope for the assessment methodology is divided into three main elements and several second and
third level sub-elements. These practical steps ensure that all article 13, 15 and 16 SRR requirements for
inclusion of a ship recycling facility in the European List are checked.
1. Management
• Facility business model and quality statement
• Policy
• Management, ownership and organisation
1 C/2016/1900, Communication from the Commission — Requirements and procedure for inclusion of facilities located in third countries in the
European List of ship recycling facilities — Technical guidance note under Regulation (EU) No 1257/2013 on ship recycling.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 3
• Quality assurance systems and certificates
• Human resources (availability, skills and experience, training, stability etc.)
2. Safety, security and the environment
• Safety & health (PPE, hazardous materials, fire safety, medical services etc.)
• Security
• Environment (spills, emissions, etc.)
• Emergency preparedness and response (fire, medical, environmental etc.)
• Regional conditions (acts of nature, political, etc.)
3. Vessel demolition
• Applied rules, regulations and internal standards
• Recycling control, inspection and supervision regime
• Non-conformities and corrective actions
• Document control
• Facilities (methods, capacities, condition of equipment, logistics, etc.))
• Maintenance
• Recycling planning and execution
• Methodology, criteria and performance regarding:
- Project start-up, commercial process etc.
- Ship Recycling Facility Plan (SRFP)
- Contract review, verification and acceptance criteria owner / cash-buyer / facility
- Pre-planning
- Vessel preparation (IHM, Ship Recycling Plan, flag state clearance, pre-cleaning etc.)
- Vessel arrival and securing
- Demolition management (methodology, “safe for entry”, “safe for hot work”, working
at heights, lifting, supervision and reporting)
- Waste disposal (sorting, sub-contractors, end users)
- Completion instruction
- Project close-out with de-briefing, lessons learned, suggestions for improvement
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5 METHODOLOGY AND ACTIVITIES
The inspection methodology followed the framework of DNV GL’s facility assessment protocols and
reporting formats, calibrated with the requirements and criteria of the Ship Recycling Regulation as
clarified in the 2016 Technical guidance note.
Activities:
- Preparations, scheduling, travel arrangements, fact-finding, etc.
- Issue objective, scope and schedule to facility in advance
- Site assessment (2 days; 3 assessors)
- Reporting
- Issue of draft report
- Implement comments to the draft report
- Final report
The on-site assessment was performed according to a schedule advised to the Facility in advance,
incorporating:
• Opening meeting
- Introductions, present objective, scope and methodology, agree on schedule
- Review of facility history, current activities, future ambitions
• Interviews with key responsible personnel in all relevant disciplines, including
- Ownership and management
- Contracts
- Planning, preparations, vessel arrival and securing
- Quality assurance, quality management systems
- Human resources
- Health, safety, security and environment
- Vessel dismantling management
- Quality control, document control
- Project management
• Document review
- Spot checks and evaluation of consistency, content, validation and language. Traceability
• Facility site inspection
- Inspection of Facility, all workstations and worker facilities
- Inspection of vessel, for access and escape-ways
- Spot-checks of worker certificates and permits, crane certificates
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- Lifting equipment, fall barriers, safe for entry, safe for hot-work etc.
- Questioning (brief) of foremen / supervisors on key procedures
• Closing meeting
- Reiterate the objective of the inspection and present preliminary results in way of initial
observations and findings
- Facility may respond to the initial results, and agree to rectify non-conformities including
deadlines and corresponding responsible persons
- Acknowledgements and departure
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6 RESULTS OF THE ASSESSMENT
The assessment of the facility was carried out on the 27th and 28th of June 2019 at EGE CELIK SAN. VE
TIC. A.S., located in Aliaga (Izmir region, Turkey). EGE CELIK SAN. VE TIC. A.S has operated in Aliağa
from 2012, at Parcel 10. The main representatives from the facility during the inspection were
The evaluators from DNV GL were ,
accompanied by from the EU Commission.
The facility had 37 employees at the time of the site inspection. The Facility is in the outskirts of the city
of Aliaga, a city with a population of around 100,000, approximately 6 km from the city centre. Overall
the surrounding area belongs to one of Turkey’s largest industrial provinces with major bulk- and
container ports, power generation plants, an oil terminal, an LNG gas terminal, a refinery and a
petrochemical complex. There are 23 ship recycling facilities, 21 of them active. Adjacent to the facility,
to the east and to the west are recycling facilities. The access road connected to the road transportation
network is to the south of the facility.
The table below summarises the results of the site inspection with respect to article 13, 15 and 16 of the
SRR requirements for inclusion of a ship recycling facility in the European List.
DNV GL wishes to thank the management and key personnel at EGE CELIK SAN. VE TIC. A.S for the
friendly reception and good co-operation during the assessment, ensuring that the inspection could be
carried out in an effective manner. Facilities for the assessment itself were excellent and the fullest
degree of access to all aspects of the facility’s areas and management was offered.
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Site inspection results Compliant? Article 13-1 (a) it is authorised by its competent authorities to conduct ship recycling operation Technical
guidance note
2.2.1,
MEPC 210(63)
Section 3.2.2
Authorisation Ship Dismantling Permit from the Ministry of Environment and Ship Dismantling
Authorization Document from the Ministry of Transport were checked during the
inspection. The permits are valid until February 2020.
Compliance was
confirmed during the
site inspection
Article 13-1 (b) it is designed, constructed and operated in a safe and environmentally sound manner Technical
guidance note
2.2.1
Measures and
infrastructure
The facility uses the slipway landing method, employing a combination of afloat and
landing dismantling. All secondary cutting takes place on concrete flooring with drainage.
Dismantled materials from the vessel to shore are transported by crane without contact
with the intertidal zone.
Only the lower aft section of a seismic survey vessel remained at the facility during the
site inspection, the hull had been pulled completely above the drainage line. The distance
from the shore line to the drain line was quite long, covered in concrete and showing little
wear of the concrete indicating that it was newly renewed. The facility reported it had
been renewed 6 months ago and was regularly kept up. It was assumed by the
evaluators that, due to this length i.e. the corresponding friction between a full-length
double bottom and the concrete would require a hull to be lightened significantly to allow
pulling, probably all cut down to the double bottom. The evaluators could not witness any
craning of cut blocks from the intertidal zone to the secondary cutting area but there was
no reason to believe this was not done according to regular practice as seen in the Aliaga
cluster.
It was perceived during the site visit that the facility recycling methodology worked
according to the same principles as the other applicants.
The facility reported that their philosophy and intention was to improve their economy by
continuous investment and training, aiming to be the best facility in Europe.
Overall, the facility gave a good impression, with the management committed to achieve
this goal. Current further expansion plans involved acquiring more internal human
resources and competence, and new cutting devices such as plasma cutting, doing away
Compliance was
confirmed during the
site inspection
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with LPG.
Article 13-1 (c) it operates from built structures Technical
guidance note
2.2.4
Operates from
built structures
The operation is from built structures, with the use of cranes and trucks on concrete
flooring. The maximum width of a ship to be recycled was limited by the width of the
facility at the waterfront, which was 50 m according to the SRFP.
The facility operates by the landing method, onto the intertidal zone followed by a sandy
zone, to a concrete cutting zone with drain. The SRFP stated that no cutting of double
bottom was performed between the concrete floor drain and the sea, the vessels were
always pulled above the drainage line before cutting the double bottom.
Topside blocks and sections were hooked up by crane before final cutting, then lifted and
transported to the impermeable floor of the secondary cutting zone.
Hence, the facility operates with the principle of using the vessels’ hulls as built structure
during primary cutting, using the impermeable floor with drain in the primary cutting of
the double bottom.
Compliance was
confirmed during the
site inspection
Article 13(1) (d) it establishes management and monitoring systems, procedures and techniques which have the purpose of
preventing, reducing, minimising and to the extent practicable eliminating health risks to the workers concerned and to the population
in the vicinity of the ship recycling facility, and adverse effects on the environment caused by ship recycling Technical
guidance note
2.1.4 (a), (b)
MEPC210(63)
Section 3.4.1 /
BC TG 6.2
General The employees are trained in various subjects related to health hazards, from SRAT.
Procedures for environmental monitoring are contained within section 4.1 SRFP as a one-
page overview.
Compliance was
confirmed during the
site inspection
Soil The applicant had initiated measures since the desk assessment and contracted a
laboratory who had assisted the facility in sampling and analysing the samples. The
samples were however not analysed for all the required parameters.
After the site inspection, the applicant contracted a second laboratory. The laboratory
took the samples and analysed them for materials listed in Annex I and II of the EU SRR
(except ODS and radioactive materials), PAH, copper, zinc and oil.
The samples and analyses were carried out according to well-established standards, and
Compliance was
confirmed in
response to the draft
report.
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by accredited laboratories.
The results have been compared with recognised standards: Turkish Regulation on Soil
Pollution and Point source Contaminated Sites, the soil standard under the Environmental
Protection Act in Canada (https://www.ontario.ca/page/soil-ground-water-and-
sedimentstandards-use-under-part-xv1-environmental-protection-act), Classification of
condition for contaminated sites, TA-2553/2009 (Norwegian environmental agency
(NEA)) and the HBCDD EQS dossier 2011.
Chromium VI was found slightly higher than the standard, but other parameters were
within the limits in the standards.
Sediment The applicant had initiated measures since the desk assessment and contracted a
laboratory who had assisted the facility in sampling and analysing the samples. The
samples were however not analysed for all the required parameters.
After the site inspection, the applicant contracted a second laboratory. The laboratory
took the samples and analysed them for materials listed in Annex I and II of the EU SRR
(except ODS and radioactive materials), PAH, copper, zinc and oil.
The samples and analyses were carried out according to well-established standards, and
by accredited laboratories.
The results have been compared with recognised standards: the sediment standard under
the Environmental Protection Act in Canada (https://www.ontario.ca/page/soil-ground-
water-and-sedimentstandards-use-under-part-xv1-environmental-protection-act) and the
HBCDD EQS dossier 2011.
All results were within the limits in the standards.
Compliance was
confirmed in
response to the draft
report.
Water Sea water samples are taken by the Provincial Department of Environment authorities
every 6 months. An example report was provided. This is the same type of measurement
as for other Turkish facilities and includes suspended solids, heavy metals, ammonia,
dissolved oxygen, pH, turbidity, oil, phenols, organic matter, PAH, PBDE, PFOS, PCB etc.
The sample was tested by an accredited lab (Çevre Laboratuvari) with adequate detection
Compliance was
confirmed during the
site inspection.
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limits.
Runoff from the site is collected in a drainage system and water in the drainage channels
are collected in storage tanks, transported to SRAT for temporary storage prior to
disposal at Izaydaş or cement factories. These facilities separate the oil from the water
and use the oil as fuel additive and dispose of the waste water per national legislation.
Please refer to Article 15(5) below for further details.
Air The air quality monitoring includes dust level in the work place, personnel dust, chemical
levels in the workplace, thermal comfort and vibration. Sampling results were presented
on-site. The measurements and report are compiled by an accredited company.
Compliance was
confirmed during the
site inspection.
Noise The facility monitors noise from the surrounding areas and for worker health. The facility
is in a heavy industry area well away from populated centres, thus noise to domestic
neighbours is of no concern. The noise measurements were presented to the evaluators
on site. The noise measurement and report are compiled by an accredited company.
Noise was measured for two individuals at the yard. The measurements concluded that
ear protection is required for workers in the cutting areas.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.1.4 (b),
Health The facility conducted regular medical monitoring of its employees. When asked for a
specific cutter’s medical monitoring; these were readily available and presented on site to
the evaluators.
Periodical health checks are required by national law for all employees including
management, due to the classification of the work place as “very hazardous”. A health
check is conducted when a new employee starts and followed up annually. The check
includes x-ray of lungs, hemogram, lead in the blood, liver and kidney test. On-site
workers had additional blood tests every 3 months, as required by Turkish law.
The evaluators witnessed the overview of blood tests for all workers from the latest
examination, observing that 4 workers had lead levels in their blood higher than 20
µg/dL. The applicant provided a form F-09 Lead in Blood as an overview document to
check workers lead levels in their blood. They only kept the 2019 records, reportedly due
Compliance was
confirmed during the
site inspection.
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to a high employee turnover rate. It was thus not possible to obtain a complete overview
for all employees. However, the applicant had the data available and SRAT was keeping
the data as well.
2.1.4 Technical
guidance note
2.1.4 (b), MEPC
210(63) 3.1.1 (5)
Management
system
The facility is ISO 9001:2015, ISO 14001:2015, ISO: 30000:2009 and OHSAS
18001:2007 certified by NQA.
The Waste Management Coordinator Ersin ÇEVİKER of SRAT was appointed as ISO
consultant for the facility.
It is not a
requirement to have
ISO certificates.
ILO SHG p21-23,
p138:18.1, 18.3,
p139:18.5
Workers facilities Worker facilities included a canteen with kitchen, wardrobe with individual dirty- and
clean cabinets, benches to sit, showers and toilets. All were found in good to very good
condition, brand new finished only 15 days before the site inspection.
Food was provided pre-fabricated by external catering company and served in the
canteen, the same food for managers and workers.
A signboard was mounted in the canteen, with extensive information afforded to the
workers.
There was also a dormitory on site, newly built including a TV, hosting 4 workers during
the weekdays, as they were weekly commuting.
Fresh water for drinking and showering were from 2 storage tanks, one 5 tons the other
with 6 tons capacity, one feeding the office building the other feeding the worker
facilities. The applicant provided the tank disinfection records done by a service supplier
every 6 months. The evaluators witnessed the latest disinfection record from 4 April
2019.
The evaluators advised that both shower water and drinking water should be of potable
quality to EU standards. As there were no filters in the systems, and the tanks were
sanitized only twice a year, the evaluators warned of stagnant water and bacterial
growth, especially in hot climates. The water was not tested for aerobic plate counts or
legionella.
Compliance was
confirmed in
response to the draft
report.
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Following the evaluators comments, the applicant immediately acted by providing
drinking water from 19L hard plastic bottles instead of the tanks. The bottles were
observed in the canteen during the second day of the inspection.
In response to the draft report the applicant forwarded test results of the water, dated
21.08.2019 and 13.09.2019, by accredited laboratories. The results were within
acceptable limits.
Article 13 (1) (e) it prepares a ship recycling facility plan Technical
guidance note
2.1.2
SRFP The SRFP which was submitted to the evaluators and used during the inspection, was
revision 37 dated 11 February 2019. The applicant reported that they were constantly
updating the SRFP as the core document of the facility, thus the revision in force at the
time of the inspection was version 43. Since this version was not available to the
evaluators, the evaluator’s comments during the site inspection were mainly based on the
revision 37 of the SRFP. The SRFP is mostly clear and well readable and mentions all
aspects of IMO guideline MEPC.210(63).
The applicant’s SRFP was entirely written in-house, from scratch. This made it an
especially good basis for further development, as it was not based on a cut, paste and
tweak “one size fits all” template from external provider. It was written according to the
actual activities at the facility.
The SRFP was as such found good in content and language, clearly a significant effort had
gone into it from the facility management. It was also clear that personnel from the
production, chiefly the Technical Manager, was feeding input to the SRFP by verbal advice
and communication.
The response to the facility was that the SRFP was written mostly as a text-book rather
than an instruction to the workers. Many good procedures were seen drowned in
storytelling, and several key processes such as cutting procedures and intertidal
protection were described in insufficient detail, and not as instructions.
Examples of improvement and philosophy was discussed and advised to the management
during the site inspection, who clearly understood the point and advised they would
Compliance was
confirmed in
response to the draft
report.
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restructure the document and enhance instructions on key procedures; improved by
using more bullet points, less text with some matrixes or tables.
It was advised to write the document numbers (TB-xx, F-XX, P-xx) in the SRFP, under
records management. E.g.: Daily gas check form. What is the Form Code F-xx of the
documents mentioned in the SRFP?
In response to the draft report the applicant forwarded a revised SRFP, revision 57, dated
2019-09-17. Please see under each item in the report for further advice.
MEPC 210(63)
Section 3.1.1 (1) Ownership The facility, operating in Aliaga since 2012, is privately owned by 5 owners within two
families, with following shares:
-
The owners are in the Board of Ege Çelik; the only ship recycling facility the owners own
and operate in Aliağa.
owns non-ferrous metal recycling facilities in the Izmir region; the primary
objective in owning Ege Çelik was to supply non-ferrous metals to their metal recycling
facilities.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.1.1 (3),
(4)
Facility
organisation
The facility Recycling Yard Manager reported to the Members of the Board, in effect in
empowered charge of the facility, the decision-maker, advising the board mostly for
information.
The Recycling Yard manager had 3 reports, the Technical Manager, Sales & Purchasing
Manager and Financial Manager.
Compliance was
confirmed during the
site inspection.
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The evaluator’s contact and host during the entire inspection, answering most of the
questions was the Sales & Purchasing Manager. It was the impression that it was the
Sales and Purchasing Manager who was running the facility on daily basis, with many
responsibilities including medical checks, periodical checks of the machinery, HR, HSE
matters, toolbox trainings, QMS and all documents including the SRFP. A high workload.
The Technical Manager, with over 30 years’ experience, had the supervision of the site
activities, including the ship- and field supervisors and the skilled workers such as the
crane drivers and operators and was as such a hands-on 100% operational leader.
The facility had very recently employed an environmental engineer, and a new employee
handling international affairs under the Financial Manager, having started work only a
week prior to the site visit. These two positions were so recent that they had not been
included in the organization chart in the SRFP. It was clear that the facility was investing
in human resources, in order to strengthen its capabilities and build competencies.
The facility did not have an internally employed HSE responsible, they utilized the
mandatory service supplier subcontractor Aliağa OSGB, but they were planning to employ
an in-house Safety Expert.
Salaries were handled by Financial Manager.
As of the date of the inspection, 37 people were working at Ege Çelik. The employee
turn-over rate seemed on the high side, 10 people had left or joined in 2018.
The facility was found with a fulfilled, competent and ambitious management, eager to
improve and develop.
MEPC 210(63)
Section 3.1.1 (4) Roles and
responsibilities
The prevailing set of roles and responsibilities at the time of the site inspection were
those established in the SRFP revision 37. Although most of the roles were included in the
SRFP with actual responsibilities, considering especially the Sales & Purchase Manager’s
actual and many duties, his responsibilities could be more detailed as it seemed he was in
practice managing the facility operations from day to day.
The responsible for training and welfare of the workers should be included in the
Compliance was
confirmed in
response to the draft
report.
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appropriate role. The evaluators were advised of this during the site inspection, but it was
not established in the Roles and Responsibilities.
The new employees’ roles as environmental engineer and International Affairs must be
included in the roles.
In response to the draft report, the facility submitted a revised SRFP (revision 57), which
includes adequate descriptions of the roles and responsibilities of the environmental
engineer and the international affairs responsible.
MEPC 210(63)
Section 3.1.1 (5),
(7) and (8).
Quality
Management
System
The facility demonstrated a comprehensive and up-to date quality management system
(QMS), according to ISO 9001, certified by NQA. The system was administered by the
Sales & Purchase Manager.
In general, the QMS was found tidy and systematic, with many procedures, instructions
and relevant checklists, with all records well filed both in digital and soft copies, although
sometimes the digital ones were the most up to date. They were discussing to change
their system to paperless regime, only keeping digital copies. The system was only in
Turkish language.
Every department had the ownership of its relevant documents, including developing
checklists.
All records, checklists and procedures asked for were readily found and available.
The QMS upkeep was done based on the management review meetings held 2 times a
year. They also had monthly management meetings, ad-hoc as found necessary. There
were no other scheduled management meetings, or systems for such meetings. An
elected worker representative was included in the management review meetings.
Every month there was a health and safety committee meeting whose members were the
doctor, the external HSE Expert, the Land- and Ship foremen, Technical Manager, the
Sales & Purchase Manager and the worker’s representative.
The facility had a good non-conformity and corrective action regime, with during the time
It is not a
requirement to have
a QMS system, but
considering MEPC
210(63) Section
3.1.1 (5), (7) and
(8), this is
comparable to a
QMS.
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 16
of inspection 19 corrective actions in 2019. They had registered 11 near misses and one
accident in 2019; they had a complaint form, internal and external audits and health
checks, all used as experience to update their quality system documentation.
Subcontractor services, rules and regulations, health records and other necessary
documents to regularly attend to were kept up by update warnings from the providers
and by the Sales & Purchase Manager. Tables over periodic schedules were seen in place.
Records management: The Sales & Purchase Manager kept the QMS documents in his
laptop’s hard drive, backed up minimum once a week to 2 external hard disks, one in the
office and one in the archives. This instruction was found in the procedure for record
management.
Management and senior personnel had access to the QMS external harddisk but did not
have editing rights. All changes to the QMS were administered by the Sales and
Purchasing Manager based on input from the organization, new offical laws and
regulations, information from SRAT, OSGB and from other consultants on new
environmantal or safety issues.
The evaluators witnessed table TB-14 on compliance with legal requirement and
legislations . If there was something to be changed, the Sales & Purchase manager
revised accordingly.
The QMS system included forlders for each vessel, and other important documents such
as the SRP with revision numbers as per ISO standards.
It was observed that it sometimes, during the interviews took time to find the latest
revision of documents, having to search for a while among computers and hard disks. It
appeared that the document control could be somewat improved for efficiency. The
evaluators recommend a cloud based system.
The evaluators also recommend that the QMS and the SRFP procedures are harmonized
to be one on one with regards to content, not variations of the same procedures written
differently, or overlapping procedures and instructions.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 17
MEPC 210(63)
Section 3.1.1 (6) Policy In response to the desk top assessment, the facility issued a new SRFP revision 37 dated
11.02.2019. This included a part on environmental policy and safety policy, from page
12.
Compliance was
confirmed during the
site inspection.
Working hours and
annual leave
The employees work 45 hours a week. Working hours are from 08.30-17.00 Monday-
Saturday with lunchbreak from 12.00-13.00. By Turkish labour law, all employees who
have worked for at least one year, including the probation period, are entitled to paid
annual leave; and leave periods, which is determined according to employee's length of
service:
1 to 5 years (included) 14 working days
5 to 15 years 20 working days
15 years (included) or longer 26 working days
Interviews with employees on-site confirmed a practice per Turkish labour law.
There were some mismatches in the SRFP with working hours which were corrected in
revision 57, received in response to the draft report.
Compliance was
confirmed during the
site inspection.
Contracts and
minimum wage
The latest list of employees, for May 2019, was checked for wages and social security ID
and found in order. White- and blue-collar workers were listed under the same company
code in the social security system.
Interviews with workers on site confirmed that they had contracts and were paid above
minimum wages. Overtime is rarely required, but they are paid. This is in line with the
experience from other Turkish facilities. Due to the refineries, there is a competition for
the workforce, driving wages.
As of the date of the inspection, 37 people were working at Ege Çelik. From the latest
available official social security list of the facility (SGK Hizmet Listesi) from May 2019,
there were 50 people working at the facility. When the applicant was asked why there
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 18
was a so much difference in a month, they explained that half of the workers had left to
their home villages to work in the agricultural fields, a part of them had left on their own
will and a part of the worker’s contracts had been terminated by the facility due to not
having enough jobs ahead, due to the ship they were dismantling would be finished in 1,5
weeks.
The facility reported that they had an annual turnover of 10 people, which is quite high
considering a workforce of 35 – 50 people.
MEPC 210(63)
Section 3.1.1 (7) Instructions and
procedures
The contents of the instructions were good with room for improvement on details,
however they were in large parts in text-book form, more explanatory to third party
stakeholders what the facility does rather than step-by step instructions to workers and
staff. For example, many procedures started with “Ege Celik knows that…”, typically
something you would read on a web-page and not an instruction or plan.
Instructions shall not only tell what to do but how to do, in as few words as possible
using to a large extent bullet points, tables, graphics and matrixes.
Key critical procedures, such as cutting, cleaning, debris control, monitoring of various
activities, emergency response, working at heights, safe for entry, gas-freeing etc. need
to be instructed in detail and clarity.
In response to the draft report, the facility forwarded an updated SRFP (revision 57)
which included updated and detailed procedures. The new procedures were found
adequate.
Compliance was
confirmed in
response to the draft
report.
MEPC 210(63)
Section 3.1.4 Project
management
progress reporting
The facility did not have a project management- or progress reporting regime, however
this is not required according to the regulation. The only reporting was as follows:
The facility must submit a request to the Harbour Master when the double bottom of the
dismantled vessel remains. Upon verification, the Harbour Master grants permission for
completion of dismantling. Upon actual completion, the facility confirms to the Harbour
Master that the final part of the keel has been dismantled. Subsequently, the Port
Authority issues Statement of Completion of Dismantling, and the facility provides the
Compliance was
confirmed during the
site inspection.
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Statement of Completion to Customs.
Article 13 (1) (f): it prevents adverse effects on human health and the environment, including the demonstration of the control of any
leakage, in particular in intertidal zones; Technical
guidance note
2.2, 2.2.1, p8:
footnote (26),
2.2.2 (f), MEPC
210(63) Section
3.4.4.3/BC TG:
p13: Table 1,
p33: Table 5,
p44: 4.1 / ILO
SHG: p65:
7.2.4.4
Intertidal zone All dismantling of equipment and interior, cleaning, and cutting of topsides in order to
reduce weight, is carried out in the intertidal zone, below the drain line.
The beach was seen with very minor debris of all sorts, including plastics.
During the site inspection, the procedures for the above tasks were investigated in detail
by interviewing the Technical Manager. During the sessions, it was apparent that some of
the procedures of protecting the intertidal zone as applied were good but not quite
reflected in the SRFP or instructed in the same detail as reviewed in the site inspection.
Protection of the intertidal zone was based on the following principles:
• Pre-cleaning of tanks and other polluted areas
• Stripping of accommodation areas, down to steel, putting debris and insulation in
bags
• Dismantling of pipes by de-flanging, emptying oil residues in containers
• Cleaning of machinery components with rags etc.
• Blocking of open pipes and machinery components inlet / outlet connections by
rags, wooden plugs or steel flanges
• Daily planning of cutting, considering vessel balance and steel structural balance,
avoiding bouncing, by experience
• Lifting cut blocks directly from the vessel to the impermeable secondary cutting
area, by crane
• The crane lifts and moves the blocks partly above the vessel by using the vessel
as a containment and places the pieces on to the secondary cutting zone.
Compliance was
confirmed in
response to the draft
report.
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• Nothing is dropped on the intertidal zone
• Slag and chips are removed from the intertidal zone by industrial magnet
attached to the excavator, recorded, stored and sold
• A net is erected towards the sea to catch larger flying debris
• The beach is manually cleaned about every second day, with records kept
• There was an instruction on cleaning of bottom of sea, by divers
• Two drain channels were made below the secondary cutting area
The procedure on soil pollution prevention during landing was witnessed, and the
instruction on how the shore is to be cleaned, with graphics.
T-18 was an instruction on how double bottom is cut, however the instruction was more a
cleaning of double bottom instruction.
The Technical Manager explained that Fuel oil tanks are cleaned by pumping the
remaining oil into a portable tank which is sent to SRAT. The tank is subsequently rinsed
with water i.e. flushed down by fire hose, which also is pumped out into the portable tank
and sent to SRAT. Normally sludge is dilluted by the water, remaining residue removed
by shovles into buckets. The last step is to spray the tank with fire fighting foam. Wood
chips are not used, not either rags. Spills on deck of machinery spaces etc. are picked up
by absorbent pads.
The facility had newly aquired a slag collector, which was in use reportedly always, when
cutting outer skin below the drain line. Normally using basket. There was no instruction
on slag collecting in the SRFP.
This narrative from the Technical Manager was not identical to the instructions in the
SRFP, nor in the instruction T18 or scheme SM-6 tank and pipe cleaning. The facility was
advised to revise the instructions accordingly and issue a new SRFP as previously
discussed.
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The tidal range is between 25-45 centimetres in Aliaga. The evaluators could not verify
that the facility efficiently surrounds the vessel with oil booms since the ship under
recycling was completely above the drain line.
Spare oil booms, capable of surrounding the entire ship, were found readily accessible
and could be deployed rapidly if needed.
The facility had procedures, personnel and equipment for emergency response to acute
oil pollution and spills, with additional assistance from SRAT and local port emergency
response units, with boats. During the site inspection at SRAT in June 2018, the
evaluators observed an oil filter curtain boom. The procedures and equipment combined,
demonstrate control of leakage.
It was recommended to the facility to clean up and revise its instructions and SRFP. That
done, the facility’s actual performance was deemed good.
In response to the draft report, the applicant forwarded a revised SRFP (revision 57) with
a step by step procedure on primary cutting, how lifting and transporting are to be
decided and carried out, the detailed measures in place to prevent impact on the
environment in way of leakages from piping, machinery and tanks, slag, paint chips,
debris, double bottom cutting etc. The revised procedures were found adequate.
Article 13 (1) (g) (i); the containment of all hazardous materials present on board during the entire ship recycling process so as to
prevent any release of those materials into the environment; and in addition, the handling of hazardous materials, and of waste
generated during the ship recycling process, only on impermeable floors with effective drainage systems; Technical
guidance note
2.2.2, MEPC
210(63) Section
3.3.4.3 / BC TG:
p78ff: 5.3, p67:
figure 6
Cutting areas The cutting zone, both below and above the drain line, was found tidy and swept for
surface dust and mud. The concrete was seen intact with fresh repairs in several areas.
The cutting area covered the entire plot working area and had a continuous slope from
the upper part of the plot to the end of the concrete next to the waterfront. Primary
cutting of the double bottom was reportedly always done above the drain line, secondary
cutting in the same area where space allowed.
There was no scrap stored at the facility, waiting to be sold. The facility’s policy was to rid
itself of scrap, machinery components and equipment as soon as possible after removal
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 22
from the vessels.
Technical
guidance note
2.2.2,
MEPC210(63)
Section p34:
3.4.4.1
Drainage Ege Celik has 3 drainage channels, channel A, B and C respectively, underground pools
and permanent drain water tanks covered with overflow pools.
The drainage channels A are stretched on the right and left side of the plot, which
surrounds the whole secondary cutting area with a length of 170 m, depth of 20 cm and
width of 60 cm, each.
Drainage channel B is stretched almost the full width of the plot (45 m) and connected to
side channels A, therefore forms a complete semi-round of the entire plot. The depth of
the channel B is 50 cm with a width of 60 cm.
Channels A and B are connected to an underground pool, with a capacity of 20 m3. When
the drain water level reaches to a certain level, a buoy system runs automatically, and
the drain water is pumped to two cylindrical tanks with capacity of 13.4 + 24.48 = 37.88
m3. There are 3 pumps to pump the drain water into collection tanks for emergency
reasons. The channel itself has a capacity of 55 m3, therefore the total capacity of the
first drainage system is 112.88 m3.
The drainage channel C was located a couple of meters below the first drainage system,
closer to the shoreline with a length of 45 m width of 70cm and depth of 90cm. The
drainage channel was connected to an underground pool with a capacity of 20 m3. When
the drain water level reaches a certain level, a buoy system runs automatically, and the
drain water is pumped to a cylindrical tank with a capacity of 25 m3. There were 3 pumps
to pump the drain water into collection tanks for emergency reasons. The channel had
been properly engineered, with a capacity of 28.35 m3. The total capacity of the second
drainage system was 73.35 m3.
Maximum rainfall faced in the past in Aliağa was 0.117 m/d, according to the calculation
for Vrain-max: R max (0.117 m/d)*(13,000 m2 /24h/d) = 63.3 m3 capacity is needed
for one hour, Ege Çelik’s total storage capacity is (112.88 + 73.35) = 186.23 m3,
therefore the facility would have around 3 hours to discharge the drained water.
Compliance was
confirmed during the
site inspection.
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The facility had a procedure for cleaning out the drain channel for residue.
Technical
guidance note
2.1.4, 2.2.2,
2.2.3, 2.2.5, 3.5,
MEPC 210(63)
Section 3.4.2.5 /
BC TG 3.1, 3.3,
3.4.3, 4.1, 5.1,
5.2(Zone D),
5.3(Zone D), p
92: Table 11
Waste storage The facility stored non-ferrous materials on site to be further recycled, separating the
metal from the remains of the products. The material was seen stored on concreted
flooring with drainage. Other waste materials were transported directly to waste
management facilities.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.1.4, 2.2.2,
2.2.3, 2.2.5, 3.6,
MEPC 210(63)
Section 3.4.3/ BC
TG 3.1, 3.3,
3.4.3, 4.1, 5.1,
5.2 (Zone D), 5.3
(Zone D), p92,
Table 11
Hazardous waste
storage
Hazardous waste is temporary stored on site before it is sent to SRAT for temporary
storage prior to transportation and disposal at a waste management facility.
The temporary storage areas on site were observed to be roofed on concrete flooring with
curbs and found tidy and clean.
The hazardous waste storage areas at SRAT were inspected by the evaluators during a
previous site inspection in June 2018. The storage area was observed to be roofed on
concrete flooring with drainage.
Compliance was
confirmed during the
site inspection.
Article 13 (1) (g) (ii): that all waste generated from the ship recycling activity and their quantities are documented and are only
transferred to waste management facilities, including waste recycling facilities, authorised to deal with their treatment without
endangering human health and in an environmentally sound manner; Technical
guidance note
2.1.4, 2.2.2,
2.2.3, 2.2.5, 3.5,
MEPC 210(63)
Section 3.4.2,
3.4.3/ BC TG
p11, p12, p48ff:
41, p50ff: 4.2,
Waste
management
As much as the evaluators could verify and cross-check, waste is only transferred to
waste management facilities authorised to deal with the specific waste type.
Transportation of hazardous waste is by licensed trucks to licensed disposal facilities. All
vehicles are equipped with mobile tracking device by satellite that are available to the
Ministry of Environment (Çevre ve Şehircilik Bakanlığı). The waste transfer form is
completed on the webpages of the Ministry of Environment.
At the time of the site inspection, the applicant did not have a procedure on what they
can re-sell. The evaluators verbally asked the applicant on the routes of following items;
whether they are re-sold to second hand dealers, to licenced waste reception facilities, or
Compliance was
confirmed in
response to the draft
report
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to disposal facilities:
- Main Engine: The applicant can sell but usually they are dismantling it in little
pieces and sending it for scrap.
- Gyro compasses: If it is in a working condition, it is sold to 2nd hand dealers.
- CO2 cylinders: They sell to Habaş. Ege Celik never releases the CO2' into the
atmosphere. Habaş has a licence for that.
- ODS cylinders: give or sometimes pay to Yılmazer. Association coordinates and
gives the waste receipts.
- Cold room insulation: ripped off and sent as hazardous waste.
- Navigation equipment: If it is in a working condition and suitable, sold to 2nd
hand dealers.
- Fire doors: If there is an insulation in the door, SRAT is taking care.
- Gaskets are all regarded as hazardous material and disposed of properly.
- Portable fire extinguishers: They don't sell but use on board during cutting.
- Firefighting foams: The Facility is aware that they shouldn’t use such foams
however if the drum of the foam is not opened, have a proper label on it, by
referring to the MSDS and manufacturers information on PFOS containment, the
facility may use it.
The Sales & Purchase Manager understands and assess the information provided in the
IHM booklets and he takes active role in the decisions for the waste routes, whether the
items can be used or should be sent to waste reception facilities. SRAT is removing the
hazmat, but Sales & Purchase Manager is doing the follow up, and sometimes tell the
SRAT that they forgot to remove one part. During the dismantling works, when the time
comes for hazmat removals, they call the SRAT again, up to now, it was not a problem to
wait for the SRAT. If SRAT was busy the applicant changed their direction and cut
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somewhere else.
The facility can consider random sampling for some items on board the vessel if they are
not covered in the IHM and if they intend to re-sell the equipment.
The applicant was requested to update their waste management procedure. In response
to this, the facility forwarded an updated procedure titled ‘TB-40 Saleable, Unsaleble
materials from the scrap vessel’. The procedure was found adequate.
Technical
guidance note
2.1.4, 2.2.2,
2.2.3, 2.2.5, 3.6,
MEPC 210(63)
Section 3.4.2,
3.4.3/ BC TG
p11, p45ff: 7. /
4.2
Waste disposal SRAT is responsible for waste disposal. The traceability of waste is ensured through
satellite-based tracking system of the waste.
Please refer to Article 15(5) below.
Compliance was
confirmed during the
site inspection.
Article 13 (1) (h); it establishes and maintain an emergency preparedness and response plan; ensures rapid access for emergency
response equipment, such as fire-fighting equipment and vehicles, ambulances and cranes, to the ship and all areas of the ship
recycling facility; Technical
guidance note
2.1.3, MEPC
210(63) Section
3.3.5/ BC TG p3,
p5/6, p47, p56,
p63/64/65/66/6
7, p70, p81, p83,
p87, p89/ ILO
SHG p32: 4.6, p
49: 7.1.8, p
128:16.
Emergency
preparedness and
response plan
The EPRP witnessed during the site inspection was considered inadequate. It was a
template-based document from external provider, which contained a lot of “management
speak”, while important details for specific situations (e.g. falling from heights and rescue
from confined space) were missing from the plan.
The facility was requested to provide an updated EPRP where management and QMS
terminology may be included, but that a separate, efficient document with less text,
concentrating on the actual emergency and response is the useful part of the EPRP.
In response to the draft report, the facility submitted a revised EPRP, which includes a
section on falling from heights and rescue from confined spaces. The revised EPRP is
considered adequate.
Compliance was
confirmed in
response to the draft
report.
Technical Emergency access Evacuation routes and assembly stations were seen in place on site, marked with signage Compliance was
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 26
guidance not
2.2.4, MEPC
210(63) Section
3.2.1
routes and borders, with good access for emergency vehicles. confirmed during the
site inspection.
MEPC 210(63)
Section 3.2.1 Access and
logistics within
facility,
Access and logistics were found good.
Compliance was
confirmed during the
site inspection.
Technical
guidelines
2.1.4 (b), MEPC
210(63) Section
3.2.1, 3.3.5, ILO
SHG, Section 3.6
Medical services
and facilities
The facility utilized SRAT’s medical services and doctor, the latter visiting the facility for
consultancy 11 hours per month. The doctor’s visiting schedule was announced to
workers, and all employees can book an appointment or visit at own convenience.
The facility had access to the well-equipped first aid room at SRAT, with doctor and
nurse. Hospitals and private medical services are available in the city of Aliaga, close by.
The EPRP includes the phone numbers to two hospitals: Aliaga State hospital and
Menemen State Hospital (page 223). Map checks confirm distance of the hospitals to be 8
and 30km respectively. The Aliaga hospital is equipped with a trauma unit.
Izmir has even more advanced hospitals (severe burn unit) and medical
helicopters/flights are available if required.
Compliance was
confirmed during the
site inspection.
Technical
guidelines 2.1.4
(b),
MEPC.210(63),
Section 3.3.4.11
Regulatory
requirements
health
Turkish Occupational Health and Safety Law (No. 6331, published: 30.06.2012 / Official
Gazette No. 28726) requires every company to contract an occupational health and
safety expert and a company doctor based on the company’s hazardous class. Depending
on the number of workers on site, the minimum time that the doctor should spend at a
company is defined in the respective regulations, at least 15 minutes per worker per
month for very hazardous establishments.
Compliance was
confirmed during the
site inspection.
MEPC.210(63),
Section 3.1.1 Regulatory
requirements
safety
Turkish Occupational Health and Safety Law (No. 6331, published: 30.06.2012 / Official
Gazette No. 28726), requires every company to contract an occupational health and
safety expert based on the company’s hazardous class. Depending on the number of
workers on site, the minimum time that the OHS Expert should spend at a company is
defined in the respective regulations, at least 40 minutes per worker per month for very
hazardous establishments. The facility is well experienced with regulatory safety
Compliance was
confirmed during the
site inspection.
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requirements and their documents, and on-site implementations are periodically
inspected by the OHS Expert. OHS Expert attends the monthly health and safety
committee meetings, in which any accidents, incidents or near misses are discussed and
corrective actions determined.
MEPC.210(63),
Section 3.1.1 Regulatory
requirements fire
It was reported that mock fire drills were held once a year, according to national
legislation. The drills were however held with the SRAT fire team, which are not
professional firemen and smoke divers, the fire truck has a water canon but is not a full
fire truck as such. For a full fire, the local fire brigades are nearby.
Compliance was
confirmed during the
site inspection.
Article 13 (1) (i) it provides for worker safety and training, including ensuring the use of personal protective equipment for operations
requiring such use; Technical
guidance note
2.3.1
Safety inspectors
on site
The facility was, as many other applicants, under the safety inspection regime of
subcontractor OSGB. They had no in-house safety inspection team. The supervisors and
emergency teams were trained in safety and first aid by OSGB and SRAT.
The level of safety, and the assurance of training was administered and followed up by
the Sales & Purchase Manager. It is the evaluators’ opinion in general that an SRF should
have an in-house safety inspector or inspection force, although it is not a requirement.
The contracted OSGB did not stay at the site the full working day but visited to train and
to perform spot inspections.
Reportedly the facility had 2 contracted OHS Experts from Aliağa OSGB.
is contracted for 1760 minutes per month since 15 January 2019, and
is contracted for 1480 minutes per month since 25 June 2019. As there are 37
employees on site, and 40 minutes of service per worker is required, the facility needs
1480 minutes of service from an OHS Expert.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.3.2
Condition of safety
equipment
The condition of safety equipment was in general found well kept, serviced and in good
order.
Compliance was
confirmed during the
site inspection.
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Technical
guidance note
2.3.3, MEPC
210(63) Section
3.1.2/3.2.2
Safety induction
and training,
employees
Safety training for employees in general, including safety induction and toolbox-talk
refreshment, was found in good order, with signed training records and training
schedules.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.3.3, MEPC
210(63) Section
3.1.2/3.2.2
Safety induction
and training,
subcontractors
Sub-contractors are not used. N/A
Technical
guidance note
2.3.3, MEPC
210(63) Section
3.1.2/3.2.2
Safety induction,
visitors
The evaluators were given a safety briefing in the security room at the entrance of the
facility, in the form of a short presentation of the facility, escape routes, walking lanes,
muster point in case of an emergency, waste storage areas, safety signage and required
PPE on site. Safety induction for visitors was given by the Sales & Purchase Manager. The
Environmental Engineer provided PPE and visitor ID cards. The evaluators were asked to
fill in a Visitor, Subcontractor and Customer Instructions available both in English and
Turkish.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.3.3, MEPC
210(63) Section
3.1.2/3.2.2
Risk Assessment Risk assessment’s initial template was provided by the Aliağa OSGB. The Sales &
Purchase Manager, Technical Manager and Ship- and Field responsibles revised the Risk
Assessment continously. The evaluators appraised the Risk Assessment Revision 18,
dated 2019-06-07 and made a spot check on falling from heights. In total 4 items were
identified in the risk assessment with respect to falling from heights. However the risks
identified were more in the form of general risks without a real mitigation plan, no
responsible and no due date.
The applicant explained that they were considering the risks not only through the risk
assessment but also through the near miss reports, corrective / preventive actions and
trainings.
The method of the Risk Assessment is quite a cumbersome and complex, probability x
frequency x severity.
Compliance was
confirmed during the
site inspection.
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The facility also keeps a ship based risk assessment, which appeared simplified with
probability x severity. The risk assessment was only related to safety and environment,
not covering commercial and financial risks.
MEPC 210(63)
Section 3.1.2 Hazardous waste
handling training
Only trained SRAT personnel handle hazardous waste. Examples of various certificates
were forwarded to the evaluators as part of the SRAT reply upfront of the site inspection.
The desk assessment
showed compliance
with this point. This
was confirmed during
the site inspection.
MEPC 210(63)
Section 3.3.5 Ship access control The facility had a Persons on Board system, where the ship worker’s names were written
on a formatted pre-prepared table by the ship foreman. The table showed the working
days in a week and for each day there were two columns, one for before noon and one
for afternoon. The ship foreman marked the workers who were present with a permanent
marker, noting if they were back from lunch and had resumed work in the afternoon
again.
The board also showed which workers were doing hot work or were working at heights.
The board was placed somewhat close to the vessel and not well protected against
damage due to fire. It could be moved further away.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.5 Prevention of
falling from heights
During the site inspection, cutting was in progress on top of the remaining aft double
bottom, around 2 metres height. All the cutters were wearing spool harnesses fixed to
the vessel, and the open end of the deck was closed with a warning-tape type zig-zag
barrier.
The facility was subject to the same training regime by OSGB as the other yards, the
instructions were in place.
Compliance was
confirmed during the
site inspection.
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MEPC 210(63)
Section 3.3.4.1.8 Safety signage on
site
Safety signage on site was abundant. Many signs were apparently quite new.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.1.8 Safety signage on
vessel
There was only a small remaining aft section at the facility during the site inspection.
Safety signage in way of no entry and no hot-work was seen posted on board, in front of
the entrance to the remaining enclosed hull spaces.
In front of the vessel, safe for hot work and non-smoking signage was observed. Safe for
hot work permission colour was green.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.6 Lifting equipment
and instructions
Lifting equipment including shackles and slings were all found marked and part of a
maintenance and inspection scheme, repeated every three months, carried out by
Perkon. Records were checked and found in good order.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.6 Crane operators’
certification
Checked during the desk assessment. The desk assessment
showed compliance
with this point.
MEPC 210(63)
Section 3.1.2 Training of forklift
operator
N/A N/A
MEPC 210(63)
Section 3.1.2 Certification/
training of cutters
Cutters were trained and certified as per requirements. A spot check on a random worker
was carried out and found in order.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
3.4.3 Cutting procedures Cutting procedures were found in good order and implemented, however it was observed
that the procedures should be tidied up and made clearer, according to reality.
The applicant advised that the vessels were cut in a cascading stair fashion, above the
double bottom, gradually lightening the vessel in order to pull it as far above the drain
Compliance was
confirmed in
response to the draft
report.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 31
line as possible. By experience, long straight cuts could cause build-up of tension,
causing bouncing. Each cut is selected daily, based on experience. Before the last cut,
the piece is strung by the crane in a 3-point hen’s foot and put under tension, to control
the reaction when the piece is released. A typical piece weighs at 12–13 tons but no
calculations were made, it was all done by experience.
The Technical Manager stated that after 30 years in the business he had never
experienced bouncing.
The Technical Manager decided, every morning at 08:30 in meeting with the ship
supervisor, where to cut, subsequently marking the cut on a General Arrangement plan of
the vessel. The Vice ship foreman and all 8 ship cutters were experienced, and could also
decide on the next cutting lines, substituting the Technical Manager.
The Technical Manger had a certificate on gas measurement. 4 other workers had been
trained in conducting gas measurements.
The ship foreman’s primary job is to check working at height and otherwise observe and
advise the Technical Manager on any issues. He does not do any cutting.
The evaluators recommended that the cutting procedures and instructions are written in
the SRFP in a clear and simple way, the way it is done and according to the Technical
Manager’s explanations as above.
In response to the draft report the facility submitted a revised SRFP, which includes
sufficiently detailed cutting procedures.
MEPC 210(63)
Section 3.3.4.3 /
ILO SHG:
p108ff:13.
Steel cutting
machines
The facility used gas torches for steel cutting and plasma cutters for stainless steels. The
surface must be very clean in order for the plasma cutter to work.
Compliance was
confirmed during the
site inspection.
ILO SHG:
p108ff:13. Other machinery N/A N/A
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 32
ILO SHG:
p67:7.2.4.4,
p108ff:13.
Winches, mooring
gear.
The winches were inspected periodically, as the rest of the equipment. The winch wires
however, were not present at the facility. The applicant reported that they had sent the
old wires (steel ropes) to scrap and they purchased new ones for the winches. Steel wires
in general is not part of the maintenance scheme and had no ID attached. The evaluators
asked the yard to elaborate and revert accordingly.
In response to the draft report the applicant forwarded additional descriptions and the
winch ropes are included in the ‘Machines, tool and devices periodically control list’ in the
revised SRFP.
Compliance was
confirmed in
response to the draft
report.
MEPC 210(63)
Section 3.3.4.6. Ropes/chains/
slings
The slings and shackles were marked with ID, with test records and certificates kept. Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.8 Maintenance and
decontamination of
tools and
equipment
Maintenance records of cranes and excavator were witnessed and found in order.
Maintenance records of the cranes were kept, and the applicant provided a form F05-
which included the main crane’s maintenance records.
A Table TB-01 showed the overview of all items that needed to be tested, controlled and
periodically checked. There were 56 items in the list. There was also an overview
available on when the slings were checked for the next time.
There was a daily checklist TB-17 on vehicle maintenance control plan, which was filled
by responsible operators.
The applicants observed a form F-14 - vehicles report follow up, in the computer as
digital copy where the last periodic check date was shown as 01 May 2019. The form was
not updated in the computer but updated in the hard copy.
For the winches there was a monthly checklist to be filled by the winch responsible.
Every morning critical equipment was inspected by the ship- and yard supervisors,
following a checklist. This procedure was seen in the SRFP rev.11 and confirmed by
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 33
witnessing actual used checklists, with dates, signed and duly filed.
ILO SHG 16.1.6
Eye-wash Eyewash bottles, all seemingly new, were located at 3 different locations.
It is recommended that the facility checks the MDSD of the various paints and chemicals
they handle on site. In many MDSD the first aid required is 15 min of continuous eye
flushing. Eyewash bottles typically hold less than a litre of water, which would supply the
user with flushing fluid for less than 1 minute. Hence eyewash bottles do not provide an
adequate amount of flushing fluid and cannot be considered a primary means of
protection.
The evaluators recommended that an eyewash station with flushing water is provided.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.8 Condition of
electrical
equipment
The electrical equipment was observed to be in mostly good condition, including the
generator, the switchboard and starter boxes.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.7 Housekeeping and
illumination
Housekeeping and illumination were found good to very good. Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.1.3, MEPC
210(63) Section
3.3.5/3.3.6 / BC
TG: p63: 4.5
Fire station Izmir fire department has a station in Aliaga
(http://itfaiye.izmir.bel.tr/en/cars/1059/1206 and reportedly they have 117 fire trucks in
various tonnages, 48 laddered fire trucks, 17 laddered vehicles, 56 meters hydraulic foam
towers, 104 meters laddered vehicles with baskets, 2 fire trucks for industrial fires etc. At
the Aliaga station they have, among others, an unmanned robotic fire engine for chemical
fire response.
No drills are held with the participation of the local fire brigades.
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 34
ILO SHG: p49:
7.1.7 Instructions and
signage
Basic firefighting instructions and warning signage were seen to be in place. Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.3.3, MEPC
210(63) Section
3.1.2 ILO SHG:
8.8
Fire station
manning, fire-
fighters
There was no fire station on site.
All workers are trained in basic fire-fighting by licenced fire brigade.
There were 2 emergency teams for fire-fighting, one for the vessel and one for the field.
Each team consists of 4 workers, a total of 8, trained in advanced fire-fighting including
the use of breathing apparatus and fire clothes. Drills were held according to training
plan.
The fire-fighting equipment was stored in the emergency response room and found in
order.
Compliance was
confirmed during the
site inspection.
ILO SHG: p83:
8.8.8 Fire station
equipment
N/A N/A
MEPC 210(63)
Section 3.3.6,
ILO SHG: 8.8.11
Fire alarm system
on shore
Several alarm buttons were located along the east perimeter, connected to sirens and
well-marked with signage. One was tested and found in order.
Compliance was
confirmed during the
site inspection.
ILO SHG: 8.8.11 Fire alarm system
on vessel
There was no large vessel to inspect.
N/A
Technical
guidance note
2.3.3, MEPC
210(63) Section
3.3.6, ILO SHG:
8.8
Fire prevention
measures general
The facility demonstrated its fire prevention by the visual site inspection, observing
cleanliness and tidiness.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.6,
ILO SHG 13.4.5
Combustible
materials and hot-
During the site inspection, it was explained that accommodation areas were stripped to
bare steel before cutting, and otherwise cleared out of combustible and flammable
Compliance was
confirmed in
response to the draft
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 35
work materials before cutting. The facility reportedly never had a fire.
The facility was requested to elaborate on this procedure in the SRFP.
In response to the draft report, the facility submitted a revised SRFP (revision 57), which
includes a procedure for stripping the accommodation areas to bare steel before cutting.
report.
MEPC 210(63)
Section 3.3.4.4,
ILO SHG 8.8.1,
13.5.2.
Condition of AC/OX
lines
AC / OX lines were found in good to very good condition. The hoses observed were brand
new.
Compliance was
confirmed during the
site inspection.
MEPC 210(63)
Section 3.3.4.4 Transporting/
storing flammable
gases
The centralized LPG- and oxygen storages were caged in and found in good condition. Compliance was
confirmed during the
site inspection.
MEPC 210(63):
p21: 3.3.5, p23:
3.3.6
Fire hydrants Tested and found in order. There were 2 fire pumps, all located in one shed. Fire hydrants
with hoses were fitted for every 20 metres down the facility, the densest the evaluators
had seen. The fire hydrants and pumps were checked and found in good working order.
Compliance was
confirmed during the
site inspection.
ILO SHG: p83:
8.8.10 Fire extinguishers Several fire extinguishers were checked, all with valid dates.
The foam concentrate in the foam tank and the foam in the mobile extinguishers on site
were recently bought and not taken from ships. The evaluators have seen the purchase
records.
The applicant forwarded the MSDS of the foam in response to the draft report. The foam,
Kolagom S 4000 6% is a fluorine free foam.
Compliance was
confirmed during the
site inspection.
MEPC 210(63):
p22: 3.3.6, ILO
SHG: p82: 8.8.3
Smoking areas Smoking was only allowed in a designated area next to the office building. Compliance was
confirmed during the
site inspection.
Security
management
N/A N/A
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Access control to
facility; security
patrols
The area was closed to the road by a guarded gate, otherwise the regular access scheme
to the Aliaga facilities was in force.
The evaluators were given access cards and were registered at the security gate.
Access control to
facility is not a
requirement.
Data security N/A N/A
ILO SHG 8.4.2 Entrances / gates,
fencing
See above. Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.3.3, 2.1.4,
2.3.1, MEPC
210(63) Section
3.1.2, 3.1.4,
3.3.4.3, 3.3.6,
3.4.4 / BC TG:
p3: figure 1, p84:
6.1, 6.2,
Training The training plan and schedule for 2019 was witnessed.
Toolbox trainings of about 10 to 30 minutes were reportedly held a couple of times in a
month, according to needs, held either in the canteen or in the field.
Records of toolbox training, main training and drills were kept by the Sales & Purchase
Manager. Records and signed participant lists were witnessed and found in good order.
The facility is assisted by OSGB in developing training programs.
Training plan must be included in the SRFP, which is a key document for the facility. In
the SRFP it is written that Financial Manager keeps the records of the trainings in the P
files of the workers.
The facility conducted two drills, one for sea pollution and one for man overboard.
The facility reported that they run the engine of the rescue boat at least once in a week.
During the drills they recorded that with crane it takes 1 minute 17 seconds to launch the
rescue boat, with wheel loader it takes 58 seconds. Placing the oil boom around the
vessel takes approximately 2,5 minutes when they throw it from the pier.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.3.2, MEPC
210(63) Section
3.3.4.10
PPE Use of PPE was observed to be good. Helmets, two-piece boiler suits, shoes, eyeglasses,
gloves and respiratory masks were seen worn throughout the operation. The cutters were
observed using half-face masks with gas filters. Reportedly, the applicant had started
using gas filtered mask 1 month ago, however the filtered masks were only provided to
Compliance was
confirmed during the
site inspection
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 37
cutters but not the cutter helpers or crane operators who were also on site during the
day. The workers use two-piece boiler suits, meeting the requirements of the national
regulations for shipyards and recycling yards.
PPE is unambiguously provided by the facility to the workers free of charge and replaced
as required. This was confirmed in interviews with workers on-site.
In the office the applicant had a cupboard used as a PPE storage. They only kept some
consumable PPE in that cupboard such as; gloves, face shields, masks (FFP1, FFP3 and
filters), high visibility vests, disposable overalls (white tyvek). The other PPE such as
shoes are immediately ordered. The Technical Manager was responsible for keeping the
cupboard, with the follow-up of the Financial Manager.
Only ship- and field cutters get filtered masks, not helpers. The other workers get FFP3.
The records of purchases of the last month was observed to check on how many filters
were ordered. 10 masks and filters were purchased June 10th, 2019 and 4 in May 2019.
The applicant reported that they had purchased the masks and filters directly from the
store, thus no purchase order records were available.
The applicant had a PPE matrix with different worker roles at the SRF. It is recommended
to include office staff and the management in the matrix as well.
No breach of PPE was observed during the site inspection, however little work was going
on in the secondary cutting zone.
PPE distribution records were checked for one selected worker from 24th June 2019
where it was signed off that he was provided with new shoes, boiler suit, helmet, gloves,
googles and mask. They did not keep old records of distributed PPE; therefore, it was not
possible for the evaluators to verify when was the last time the worker got a new set of
PPEs.
Article 13 (1) (j): it establishes records on incidents, accidents, occupational diseases and chronic effects and, if requested by its
competent authorities, reports any incidents, accidents, occupational diseases or chronic effects causing, or with the potential for
causing, risks to workers’ safety, human health and the environment; Technical
Medical Procedures for medical monitoring were documented. Worker accidents, injuries and Compliance was
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 38
guidance note
2.3.4, MEPC
210(63) Section
3.3.4.11 and
Appendix IV, ILO
conventions
monitoring, medical/health records such as occupational health examinations are recorded.
The facility followed OSHAS and Turkish law defined as a “hazardous workplace”.
In general, the medical monitoring schemes were found in good order and well
documented in organized records. Annual tests included hearing, vision, lung capacity,
blood test and lung x-ray. New hires were obliged to medical examination before starting
work. Blood, urine and lead was tested every third month.
The lead content in blood were for all the workers observed to be well below the national
limit.
confirmed during the
site inspection.
Incident
monitoring and
reporting
The SRF had implemented a system for incident monitoring and reporting. Records were
checked and found in order, systematically filed in folders. SRAT follows up on this.
1 accident and 11 near misses were reported in 2019. Facility keeps the overview of the
near missed through the form F - 10B Near miss follow up form.
Workers use the complaint forms or verbally communicate to Technical Manager or Sales
& Purchase Manager or Ship Foreman their complaints and Sales & Purchase Manager
documents them in form F18 Corrective Preventive Actions Form.
A few examples were witnessed in form F-01 work accidents reports, a burnt leg, smoke
poisoning, and falling object to foot.
Compliance was
confirmed during the
site inspection.
Statistics Statistics of 2018 were available and on-site statistics of 2019 were witnessed.
The facility reportedly had 7 accidents in 2018, and 1 accident YTD in 2019. One of the
accidents in 2018 was fatal, a housekeeping worker in the field was apparently hit by a
piece being lowered by the crane, the crane operator not seeing the worker. 3 of the
accidents in 2018 were burns, reportedly the most common injury at the facility.
LTIs in 2018 was 44,5 lost days.
Compliance was
confirmed during the
site inspection.
Near-miss A near miss reporting regime was implemented, and records witnessed. Compliance was
confirmed during the
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reporting 1 accident and 11 near misses were reported in 2019. Facility keeps the overview of the
near missed through the form F - 10B Near miss follow up form.
Workers use the complaint forms or verbally communicate to Technical Manager or Sales
& Purchase Manager or Ship Foreman their complaints and Sales & Purchase Manager
documents them in form F18 Corrective Preventive Actions Form.
The regime for near miss reporting was surprisingly good, as most facilities in any
country have difficulty implementing such reporting, cultural wise. This was a good
indication that the organization was one of small power distance, with good cooperation
and verbal communication.
site inspection.
Non-conformance
procedures
See comments on the QMS system. The facility had a system in place for handling non-
conformities.
Compliance was
confirmed during the
site inspection.
HSE Incentives The facility pays for health checks.
In addition, every month a random worker is selected to participate in a social project or
an occasion. The last activity was a scholarship award, but it can also involve a party or a
picnic.
Compliance was
confirmed during the
site inspection.
Corporate social
responsibility
There was no statement on CSR.
Not a requirement to
have a CSR policy or
statement.
Article 13 (2) (a): the operator of a ship recycling facility shall send the ship recycling plan, once approved in accordance with Article
7(3), to the ship owner and the administration or a recognised organisation authorised by it; MEPC 210(63)
Section 3.2.4,
3.4.2.1
Ship recycling plan At the time of the inspection, the SRP for the vessel VENTURER was seen. The vessel was
a Norwegian flagged and Norwegian owned seismic survey vessel, delivered in 1986, of
2800 LDT. It arrived at the facility in April 2019. The vessel arrived with an IHM Part I, II
and III, prepared by Maritime Asbestos solutions, however not certified by a recognized
organization. All the seismic equipment had been removed by the owner before it arrived
to the facility. The vessel came under its own power after having been laid up for 3
Compliance was
confirmed in
response to the draft
report.
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months.
The Venturer was the 4th vessel to be dismantled in 2019, by the facility.
A preliminary SRP was prepared by the facility after signing the contract with the owner,
prior to moving the vessel to the SRF. A final SRP was prepared after the landing of the
vessel, by the Sales & Purchase Manager in cooperation with the Technical Manager and
Ship Foreman.
The SRP was seen to be a more generic document with some general information on
arrival of the ship, some pre-cleaning activities, general cutting procedures including safe
for entry- and safe for hot work procedures, and waste management. The SRP was found
not matching one to one the facility’s actual methods stated in the SRFP and QMS
instructions, and not as ship specific as expected.
The evaluators recommended making an SRP template, harmonized with the SRFP.
In response to the draft report the applicant forwarded a SRP template, found to be
developed in line with Article 7.2 of the EU Ship Recycling Regulation and in the IMO
guideline MEPC.196(62).
Article 13 (2) (b): report to the administration that the ship recycling facility is ready in every respect to start the recycling of the ship; MEPC 3.2.3-3.2.6
Ready for recycling
certificate
The facility has experience in running projects in line with IMO/EU Regulation procedures
with IHM Part 1,2 and 3 and a SRP.
As part of the application file, the facility submitted the specific statement concerning the
recycling of EU Member States flag ships (part 5 of the application). According to the
signed statement, the facility will prior to any recycling of the ship
— send the ship recycling plan, approved by the competent authority according to the
procedure applicable, to the ship owner and the administration or a recognised
organisation authorised by it;
— report to the administration that the ship recycling facility is ready in every respect to
start the recycling of the ship
The evaluators are of
the impression that
the organisation can
adapt to new legal
regimes.
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The evaluators are of the impression that the ship recycling facility can adapt to these
new legal regimes.
Article 13 (2) (c): when the total or partial recycling of a ship is completed in accordance with this Regulation, within 14 days of the
date of the total or partial recycling in accordance with the ship recycling plan, send a statement of completion to the administration
which issued the ready for recycling certificate for the ship. The statement of completion shall include a report on incidents and
accidents damaging human health and/or the environment, if any. MEPC 210(63)
Section 3.2.7 Statement of
completion
A statement of completion for the M/V EXPRESS was witnessed, including a summary
table for accidents / near misses, and found in order.
Compliance was
confirmed during the
site inspection.
Lessons learned See comments under the QMS part in this report.
Suggestions for
improvements
A designated box for suggestions for improvement (or complaints) was posted in the
canteen. For comments, please see “near miss reporting” and the part on QMS in this
report.
Article 15(2) (a): identify the permit, license or authorisation granted by its competent authorities to conduct the ship recycling and,
where relevant, the permit, license or authorisation granted by the competent authorities to all its contractors and sub-contractors
directly involved in the process of ship recycling and specify all information referred to in Article 16(2); Technical
guidance note
2.2.1, MEPC
210(63) Section
3.2.2
Authorisation Found in order. Compliance was
confirmed during the
site inspection.
MEPC 210(63)
p8: 3.1.2, p10:
3.2.2 / BC TG:
p38: 3.4.3
Sub-contractors Does not use sub-contractors.
Compliance was
confirmed during the
site inspection.
Article 15 (2) (b): indicate whether the ship recycling plan will be approved by the competent authority through a tacit or explicit
procedure, specifying the review period relating to tacit approval, in accordance with national requirements, where applicable; MEPC.196(62)
Section 5 Explicit or tacit
procedure
Today the SRP is approved by tacit approval. The SRP is part of a wide set of documents,
surveys and permits/licenses that are submitted to the competent authorities for
obtaining permission to dismantle a ship. The SRP is neither explicitly approved nor
The evaluators are of
the impression that
the organisation
easily can adapt to
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rejected as a standalone document.
The evaluators are of the impression that the organisation can adapt to new legal
regimes with regards to approval of the SRP.
these new legal
regimes.
Article 16 (2) (a): the method of recycling; (b) the type and size of ships that can be recycled; (c) any limitation and conditions under
which the ship recycling facility operates, including as regards hazardous waste management; (d) details on the explicit or tacit
procedure, as referred to in Article 7(3), for the approval of the ship recycling plan by the competent authority; (e) the maximum
annual ship recycling output.
Method of
recycling
The operation is by landing the vessel. Cut pieces above the double bottom are lifted
across the permeable zone by crane on to the impermeable cutting zone. As the vessel
lightens, as much as possible of the remaining hull is pulled above the drainage line and
cut above the impermeable floor. The double bottom is cut entirely above the drain line.
Compliance was
confirmed during the
site inspection.
Type and size of
ships that can be
recycled
Reportedly, the facility can dismantle all ship types.
Maximum ship dimensions:
Length: no limit
Width: 50 meters
Draught: 15 meters
Compliance was
confirmed during the
site inspection.
Any limitation and
conditions
Rigs are usually not suitable for the facility due to their breadth. However, during the
inspection, the facility stated that they can also dismantle rigs by planning to use their
neighbour’s land.
The facility provided a procedure P-79 on dismantling of various types of ships, which
included rigs as well. It could not be confirmed if the cranes at the facility can reach the
top of a derrick to lift it down. However, the applicant explained that they would use the
cranes of the platform itself. The evaluators questioned what might happen if the rig
doesn’t have working cranes.
Upon request for further information the applicant forwarded a new procedure ‘D1-Oil rigs
purchasing decision and recycling method’. The procedure provides details on usage of
the rigs cranes and how the facility will rent crane(s) if required.
Compliance was
confirmed in
response to the draft
report.
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Maximum annual
ship recycling
output
The maximum annual ship recycling capacity was achieved in 2017, with 55,503 LDT; 4
ships were dismantled in 2017, harbour master completion reports were witnessed on
site.
The facility advised that that the Ministry of Transport has a system called ATLANTIS;
each ship recycling facility must, by compulsory order, enter data into this system
regarding type, tonnage, permission received, and completion dates of the ships
recycled. The evaluators witnessed the records from the ATLANTIS system, including:
Stjerneborg 8982 LDT
Ethan 30,600 LDT
Orelia 5278 LDT
Deep Pioneer 10,643 LDT
The facility’s production output was on average for dry bulk: 5000 tons per month; for a
cruise ship or Ro-Pax about 3000 ldt is processed monthly.
For theoretical maximum recycling capacity of 60,000 LDT was calculated as 5000 tons
maximum monthly output multiplied by 12 months = 60,000 tons.
Compliance was
confirmed during the
site inspection.
Article 15 (2) (c): confirm that it will only accept a ship flying the flag of a Member State for recycling in accordance with this
Regulation;
Confirmation Confirmation from the facility that it will only accept a ship flying the flag of a Member
State for recycling in accordance with this Regulation.
Now the facility doesn’t have a clause in their contracts about the EU SRR, however the
facility is aware of the requirement and will prepare the contracts according to EU SRR for
EU flagged vessels.
The desk assessment
showed compliance
with this point.
Article 15 (2) (d): provide evidence that the ship recycling facility is capable of establishing, maintaining and monitoring of the safe-
for-hot work and safe-for-entry criteria throughout the ship recycling process; HKC: p14: R1(7),
MEPC 210(63)
Section 3.3.4.2 /
ILO SHG:
Safe- for- hot work
certificate, warning
Safe-for hot work procedures were reviewed and records checked, all found in good
order.
Compliance was
confirmed during the
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p110:13.4 signs and labels site inspection.
HKC: p26:
R19(2), BC TG:
p47: 4.2.1
Confined spaces Confined spaces and gas testing regimes were reviewed, and records checked, all found
in good order.
Article 15 (2) (e): attach a map of the boundary of the ship recycling facility and the location of ship recycling operations within it; HKC: p43: 1.5,
MEPC 210(63)
Section 3.2.1
Map of facility A facility lay out plan was provided to the evaluators prior to the site inspection. The
same plan was observed on site at many different locations and proven to correspond to
the landscape and actual facility lay-out, containing all safety equipment- and other
information.
Compliance was
confirmed during the
site inspection.
(f) for each hazardous material referred to in Annex I and additional hazardous material which might be part of the structure of a ship,
specify:
(i) whether the ship recycling facility is authorised to carry out the removal of the hazardous material. Where it is so authorised, the
relevant personnel authorised to carry out the removal shall be identified and evidence of their competence shall be provided; MEPC 210(63)
Section 3.1.3,
3.1.4
Workers'
certificates/
licences
The desk assessment showed compliance with this point.
The desk assessment
showed compliance
with this point.
(ii) which waste management process will be applied within or outside the ship recycling facility such as incineration, landfilling or
another waste treatment method, the name and address of the waste treatment facility if different from that of the ship recycling
facility, and provide evidence that the applied process will be carried out without endangering human health and in an environmentally
sound manner; MEPC.210(63),
Section 3.1.1 Regulatory
requirements
environment
The facility operates in accordance with the Turkish Environment Law (No. 2872,
published on 11.08.1983 / Official Gazette No: 18132) and its respective regulations. Due
to given special conditions, ship recycling facilities in Turkey are exempted from some of
the requirements such as preparing an Environmental Impact Assessment, but SRF is
licenced by Ministry of Environment and all wastes are handled by SRAT which is
authorized by the Ministry of Environment for temporary storage of waste.
The desk assessment
showed compliance
with this point. This
was confirmed during
the site inspection.
Technical
guidance note
2.1.4,
Environmental Removal and management of hazardous waste is conducted by SRAT. The facility stores
various equipment for further dismantling, to separate metals, in a pile. In general, the
Compliance was
confirmed during the
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 45
MEPC210(63)
Section 3.4.1,
Appendix 1, BC
TG Executive
summary (p1),
4.3, 2.1, 2.5, 3.2,
3.4.2, 3.4.4, 4.1,
4.2.2, 4.2.5, 6.2,
7.1, 7.3,
management pile contained various types of metal equipment, but cables were also observed in the
pile.
site inspection.
Technical
guidance note
2.2.5,
MEPC210(63)
Section 3.4.2, BC
TG: p45: 4.2, ILO
SHG: p4: 2.3.2
Management of
hazardous waste
The facility does not manage any hazardous waste. This is only conducted by SRAT. Compliance was
confirmed during a
previous site
inspection of another
ship recycling facility
in June 2018.
Technical
guidance note
2.2.3,
MEPC210(63)
Section 3.4.3.1,
ILO SHG p90:
9.2.3
Management of
asbestos
The facility does not manage any hazardous waste. This is only conducted by SRAT.
The application file states that asbestos-containing waste is packed in 2 nylon bags with
200 microns thickness. Asbestos-containing waste is reportedly delivered to Süreko for
landfilling. Süreko has a valid license (cross-checked at Ministry of Environment’s
website. http://izinlisans.cevre.gov.tr/Sorgular/YazilimNetIzinLisansSorgula.aspx) and is
licensed to handle asbestos-containing waste in D5 - Industrial landfill. The evaluators
have reason to expect that asbestos-containing materials, delivered to Süreko, will be
handled in accordance with human health and environmental protection standards that
are broadly equivalent to relevant international and Union standards.
A previous site inspection in June 2018 included a site visit to the Süreko facility, but the
landfill could not be observed due to road works on-site.
Compliance was
confirmed during a
previous site
inspection of another
ship recycling facility
in June 2018.
MEPC210(63)
Section 3.4.3.2 Management of
PCB's
The facility does not manage any hazardous waste. This is only conducted by SRAT.
SRAT- workers are trained in the removal of PCB-containing materials, PPE is required
including respiratory protection and thermal protection. PCB containing waste above 50
mg/kg is delivered to Izaydaş for incineration. Information regarding Izaydaş has been
provided. It is described that wastes are incinerated at a temperature range between
Compliance was
confirmed during a
previous site
inspection of another
ship recycling facility
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 46
1000° C and 1200° C in a Rotary Kiln. Izaydaş has a valid license (cross-checked at
Ministry of Environment’s website
http://izinlisans.cevre.gov.tr/Sorgular/YazilimNetIzinLisansSorgula.aspx) and is licensed
to handle PCB containing waste.
in June 2018.
MEPC210(63)
Section 3.4.3.3 Management of
Ozone-depleting
substances (ODS)
The facility does not manage any hazardous waste. This is only conducted by SRAT.
Ozone depleting substances are removed by licensed experts, and temporarily stored
before sent to disposal at Izaydaş, and reportedly incinerated at a temperature range
between 1000° C and 1200° C in a Rotary Kiln. Rotary Kiln is one of the accepted
destruction technologies listed for ODS and Halon in Annex VII in the EU Regulation EC
1005/2009. Izaydaş has a valid license (cross-checked at Ministry of Environment’s
website http://izinlisans.cevre.gov.tr/Sorgular/YazilimNetIzinLisansSorgula.aspx) and is
licensed to handle ODS. Hence, the evaluators have reason to expect that Izaydaş will be
operated in accordance with human health and environmental protection standards that
are broadly equivalent to relevant international and Union standards.
SRAT has confirmed that insulation foam in cooling chambers that contain ozone
depleting substances used as blowing agents will be sent to Izaydaş for incineration. This
is stated within the revised procedure P-17 (ODS) of SRAT.
Compliance was
confirmed during a
previous site
inspection of another
ship recycling facility
in June 2018,
together with
additional information
received from SRAT
in October 2018.
MEPC210(63)
Section 3.4.3.4 Management of
paints and coating
including anti-
fouling with
organotin TBT
The facility does not manage any hazardous waste. This is only conducted by SRAT.
Paints and coatings are sent to Süreko where it is transformed to residual derived fuel for
the cement factories. This is considered broadly equivalent to Union standards. The
cement factories have air emissions limitations, continuously measured and reported to
the Ministry of Environment. Please refer to 15(5) below.
Compliance was
confirmed during the
site inspection.
MEPC210(63)
Section 3.4.3.5 Procedures for
operationally
generated wastes
The facility does not manage any hazardous waste. This is only conducted by SRAT.
SRAT has procedures for operationally generated waste. All liquid waste such as sludge,
bilge, remaining bunker, drained water etc. are collected and mixed in temporarily tanks
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 47
at the SRAT facility prior to further handling. The liquid is sent to Izaydaş or the cement
factories to be used as fuel additive. This is considered broadly equivalent to Union
standards.
Perfluorooctane
sulfonic acid
(PFOS)
The facility does not manage any hazardous waste. This is only conducted by SRAT.
SRAT has updated its procedures in accordance with European Union (Regulation (EU) No
757/2010; Fire-fighting foams containing PFOS that were placed on the market before 27
December 2006 may be used until 27 June 2011 after that it needs to be replaced.
In its updated P-20 procedure, dated 16.10.2018, SRAT has included references to
downstream waste management under “4. Hazard limits (Threshold value)”:
For material containing PFOS below 50mg/kg, including firefighting foam, the waste will
be used in RDF process at Süreko.
For material containing PFOS above 50mg/kg, including firefighting foam, the waste will
be sent for incineration at Izaydaş.
Compliance was
confirmed during a
previous site
inspection of another
ship recycling facility
in June 2018,
together with
additional information
received from SRAT
in October 2018.
MEPC210(63)
Section 3.4.3.6 Heavy metals
(lead, mercury,
cadmium and
hexavalent
chromium)
The facility does not manage any hazardous waste. This is only conducted by SRAT.
The metals are separated for metal recovery. For example, lead batteries are recycled
and lead reused. Fluorescent tubes and other mercury containing waste are sent to
Süreko. Süreko collect mercury gases in special tubes while the glass materials are sent
to landfill. The equipment was observed during the site visit to Süreko.
Electronic and electrical equipment is sent to Süreko and cables are sent to various
licensed companies.
Compliance was
confirmed during the
site inspection.
MEPC210(63)
Section 3.4.3.7 Other hazardous
materials in Annex
II
The facility does not manage any hazardous waste. This is only conducted by SRAT.
SRAT described during the site visit that electronic and electrical equipment is sent to
Süreko and cables are sent to various licensed companies that separate metal and
insulation. The insulation is sent to the cement factories to be used as fuel.
Süreko is licensed to handle EAL code 160215, 170204 and 200121. The treatment
Compliance was
confirmed during the
site inspection.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 48
methods described during the site visit, crossed checked with Süreko during the site visit,
and information from Süreko webpages are considered broadly equivalent to Union
standards.
SRAT has updated its procedure for PBB and PBDE based on the July 2018 comments.
MEPC210(63)
Section 3.4.2.2 Additional
sampling and
analysis
SRAT conducts an initial inspection of a vessel when it has arrived at the facility. SRAT
confirms the IHM or prepare an IHM if the vessel arrives without an IHM (possible for
non-EU flagged vessels). SRAT performs at such both initial and additional sampling as
required. SRAT is well experienced in this.
It was advised that the second paragraph in section 3.4.2.2 is rewritten or removed from
the SRFP as it is confusing. The applicant does not take air samples of asbestos. It is
enough to refer to the SRAT procedure on asbestos.
The above-mentioned section has been revised in the updated SRFP (‘10-19. SRFP v
12.pdf’).
Compliance was
confirmed during the
site inspection.
MEPC210(63)
Section 3.4.2.3 Identification,
marking and
labelling
The SRFP briefly describes identification, marking and labelling. SRAT marks and label
hazardous materials before the dismantling starts.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.2.5 (a),
MEPC210(63)
Section 3.4.2
Transport of waste Transportation of hazardous waste is by licensed trucks to licensed disposal facilities. All
vehicles are equipped with mobile tracking device by satellite that are available to the
Ministry of Environment (Çevre ve Şehircilik Bakanlığı). The waste transfer form is
completed on the webpages of the Ministry of Environment.
Compliance was
confirmed during the
site inspection.
Technical
guidance note
2.2.5 (c)
Applied process Please refer to Article 15 (5) below.
Article 15 (2) (g) confirm that the company adopted a ship recycling facility plan, taking into account the relevant IMO guidelines; Please refer to Article 13 (1) (e) above in this table.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 49
Article (2) (h): provide the information necessary to identify the ship recycling facility. Please refer to Article 13 (1) (a) above in this table.
Article 15 (5): For the purposes of Article 13, with regard to the waste recovery or disposal operation concerned, environmentally
sound management may only be assumed to be in place provided the ship recycling company can demonstrate that the waste
management facility which receives the waste will be operated in accordance with human health and environmental protection
standards that are broadly equivalent to relevant international and Union standards. Technical
guidance note
2.2.5 (c)
Waste
management
facilities
SRAT forwarded a document describing its procedures and downstream waste
management in more detail as a response to the desk assessment of application 15 and
16. The comments made for application 15 and 16 are also valid for the remaining
Turkish yards that have applied to the EU list.
DNV GL and the EU Commission had a meeting with the Ship Recycling Association of
Turkey (SRAT) on 6 June 2018 and visited the downstream waste management facility
Süreko on the same day. The temporary storage areas of SRAT were inspected by DNV
GL on 8 June 2018.
In connection with the inspection of application 14 and 18, DNV GL and the EU
Commission had a follow up meeting with SRAT on 16 October 2018.
Waste are only transferred to licensed facilities, cross checked by the evaluators on http://izinlisans.cevre.gov.tr/Sorgular/YazilimNetIzinLisansSorgula.aspx. This information is
now moved to the integrated portal “EÇBS” (Integrated Environment Information
System), which can be accessed through e-government website (licences “Çevre İzin
Lisans Uygulaması”).
Turkish waste regulations are broadly equivalent with Union Standards with identical
waste codes (EAL). Transport of waste is conducted by licensed trucks with mobile
tracking device by satellite that are available to the Ministry of Environment (Çevre ve
Şehircilik Bakanlığı). The waste transfer form is completed electronically on the webpages
of the Ministry of Environment.
Hazardous waste is transferred among others to Izaydaş, Süreko and cement factories.
Compliance was
confirmed during the
site inspection
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 50
In the cement factories waste are used as fuel, considered broadly equivalent with Union
Standards. Emissions from waste management facilities such as Izaydaş, Süreko and the
cement factories are monitored (recording devices placed on the chimney) recorded and
checked online by the Ministry of Environment (emissions information “Sera gazları
izleme, raporlama ve doğrulama”). These data are currently not available to the general
public.
As part of a GEF (Global Environment Facility) Project entitled “Persistent Organic
Pollutants Legacy Elimination and POPs Release Reduction Project”, a test burn program
was carried out at Izaydaş in December 2016, while the report was completed in September 2017 (https://www.Izaydaş.com.tr/defaultEn.aspx). The project was
supported by the United Nations Development Program (UNDP). The overall conclusion
made based on the results from the test burn program was that the Izaydaş facility more
than meets both national regulatory requirements and prevailing international standards
when applied to POPs pesticide and high concentration PCB oil wastes. The national
standards in Turkey have been harmonized with the EU Incineration Directive
(2000/76/EU) in respect to operating conditions, technical requirements and flue gas
emission limits. This Directive is however, no longer in force as it has been integrated
into the Industrial Emissions Directive 2010-75-EU.
International standards used for guidance in the project includes:
“General technical guidelines on the environmentally sound management of wastes of
wastes consisting of, containing or contaminated with persistent organic pollutants”; The
Basel Convention, UNEP/CHW.12/5/Add.2/Rev.1, Geneva, July 2015
“Selection of Persistent Organic Pollutant Disposal Technology for the Global
Environmental Facility, An Advisory Document”, GEF Scientific and Technical Advisory
Panel (STAP), November 2011
Directive 2010/75/EU of the European Parliament and the Council on Industrial Emissions
(Integrated Pollution Prevention and Control)
Per the website of Çimentaş İzmir (cement factory), the following substances are
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 51
monitored in the exhaust gas: Dust, TOC, CO, NOx, SO2, O2, flow rate, pressure,
humidity and temperature. All results are below the threshold levels.
Reportedly non-hazardous waste will be managed by Uzaylar Geri Dönüşüm or Aclev.
Licenses for both facilities are attached to additional received documentation from SRAT.
Steel is sent to 4 steel mills: Habaş, Özkan, İzmir Demir Çelik, and Ege Çelik Endüstri for
further processing. In Turkey, steel plants are regulated by “Sera gazi emisyonlarinin
takibi hakkinda yönetmelik” (Regulation on monitoring greenhouse gas emissions), http://www.mevzuat.gov.tr/Metin.Aspx?MevzuatKod=7.5.19678&MevzuatIliski=0&source
XmlSearch=sera and “Sanayi kaynakli hava kirlilignin kontrolu yönetmeligi”) (Regulation
on control of industrial air pollution) http://www.mevzuat.gov.tr/Metin.Aspx?MevzuatKod=7.5.13184&MevzuatIliski=0&
For the latter, emission limitations for dust, lead, cadmium, chlorine, hydrogen chloride
and gaseous inorganic chloride compounds, hydrogen fluoride and gaseous inorganic
fluoride compounds, hydrogen sulphide, carbon monoxide, sulphur dioxide, nitrogen
dioxide [NOx (in NO2)] and total organic compounds are set and monitored for
compliance. The monitoring is recorded and checked online by the Ministry of
Environment.
Based on the documentation received, the evaluators believe the applied processes will
be carried out without endangering human health and in an environmentally sound
manner.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 52
7 PHOTOS FROM THE INSPECTION
Overview over the
facility.
Clear access routes
for firefighting and
ambulances were
observed on-site.
Cutters were observed
to wear helmets,
shoes, eye protection,
gloves and masks with
gas filters.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 53
Eye wash station.
Side drainage
channels surrounding
the secondary cutting
zone.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 54
Drainage system runs
across the plot.
Drainage
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 55
Emergency room
Signage Hot-Work
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 56
Pile of non-ferrous
metals were the only
metal stored on site.
Canteen where
workers are served
hot lunch every day.
DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page 57
Wardrobe
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