Final Site inspection report Application 026 V3...- Issue of draft report - Implement comments to the draft report - Final report The on-site assessment was performed according 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.

DNV GL Distribution: Keywords:

☒ OPEN. Unrestricted distribution, internal and external. Ship recycling, ship recycling facility plan,

hazardous waste, waste management,

health, safety, monitoring.

☐ INTERNAL use only. Internal DNV GL document.

☐ CONFIDENTIAL. Distribution within DNV GL according to applicable contract. *

☐ SECRET. Authorized access only.

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Rev. No. Date Reason for Issue Prepared by Verified by Approved by

0 2019-10-21 First issue aellef eifre tsv

DNV GL – Report No. 2019-0920, Rev. 0 – www.dnvgl.com Page ii

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.


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.


• 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


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


- 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


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.


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


site inspection


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


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


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.


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


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


site inspection.


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


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


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


site inspection.


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


report.


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


report.


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


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


site inspection.


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


report.


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


site inspection.


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.


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


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


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


site inspection.


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


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


site inspection.


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


report.


• 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.


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


site inspection.


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


site inspection.


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


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


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


report


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


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


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


report.

Technical Emergency access Evacuation routes and assembly stations were seen in place on site, marked with signage Compliance was


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


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


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


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


site inspection.


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),


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


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


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


site inspection.


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


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


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


site inspection.


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


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


site inspection.


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


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


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


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


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


report.


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


site inspection.

ILO SHG:

p108ff:13. Other machinery N/A N/A


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


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


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


site inspection.


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


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


site inspection.

MEPC 210(63)

Section 3.3.4.7 Housekeeping and

illumination

Housekeeping and illumination were found good to very good. Compliance was


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


site inspection.


ILO SHG: p49:

7.1.7 Instructions and

signage

Basic firefighting instructions and warning signage were seen to be in place. Compliance was


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


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


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


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



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


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


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


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


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


site inspection.

Security

management

N/A N/A


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


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


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


site inspection


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


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.


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


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


site inspection.

Near-miss A near miss reporting regime was implemented, and records witnessed. Compliance was



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


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


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


report.


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.


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


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


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


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


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


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


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


report.


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


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



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


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),


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



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



in June 2018.

MEPC210(63)

Section 3.4.3.2 Management of

PCB's


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




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)


Ozone-depleting

substances (ODS)


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



in June 2018,

together with

additional information

received from SRAT

in October 2018.

MEPC210(63)


paints and coating

including anti-

fouling with

organotin TBT


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


site inspection.

MEPC210(63)

Section 3.4.3.5 Procedures for

operationally

generated wastes


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


site inspection.


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)


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



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 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


site inspection.

MEPC210(63)

Section 3.4.3.7 Other hazardous

materials in Annex

II


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


site inspection.


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


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


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


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.


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


site inspection


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


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.


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.


Eye wash station.

Side drainage

channels surrounding

the secondary cutting

zone.


Drainage system runs

across the plot.

Drainage


Emergency room

Signage Hot-Work


Pile of non-ferrous

metals were the only

metal stored on site.

Canteen where

workers are served

hot lunch every day.


Wardrobe

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Documents

Final Site inspection report Application 026 V3...- Issue of draft report - Implement comments to the draft report - Final report The on-site assessment was performed according to