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Abstract Title: The Gaps in International Regulations Being Exploited by Toxic Vessels Destined for Illegal Beaching Practices
Presenter Name: Lee Hunter
Company/Institution: Total Hazardous and Integrated Solutions (THIS)
Session: Mercury Regulatory and Policy Matters
Co-Authors: Lee Hunter

Abstract Information :

Multilateral conventions, regulations and guidelines such as the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (HKC) and the 2015 Guidelines for the Development of the Inventory of Hazardous Materials (IHM) are ?aimed at ensuring that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risk to human health and safety or to the environment?. While the HKC is written specifically to try and encompass all aspects of toxic materials and hazardous substances to be accounted for in the recycling of ships, there are still loopholes, which are continually being exploited by vessel owners, contract operators, scrap buyers and ship recycling facilities, which enables Mercury-laden vessels to ?skirt the rules? and very loosely claim ?compliance?. While the IHM is also written to try and encompass all aspects required under the HKC, and possibly due to a lack of knowledge at the time of writing, it lacks any mention of analysing or sampling for the likes of Mercury, or other contaminants, that are likely to contaminate the inner surfaces of cargo tank walls, piping or transfer systems. Especially since the only valid methods of analysis include either field analysis using a portable XRF analyser or controlled cold-cutting of samples for laboratory analysis. Naturally, obtaining samples of the tank walls for laboratory analysis is not always practical but the IHM survey does not include analysis of the cargo tank walls or even Mercury vapour analysis, as a minimum. In addition, the IHM references the RoHS Directive 2011/65/EU acceptance criteria for Mercury and Mercury Compounds which, relevant for the electronic and electrical equipment it was intended to cover, provides IDLH (Immediately Dangerous to Life and Health) levels of Mercury when performing hot work or abrasive cleaning of the tanks.

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