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Shipbreaking and the Environment

Shipbreaking of obsolete vessels presents many challenges, including the structural complexity of the ships themselves and environmental, safety, and health issues. Although many recognized problems with past practices have been addressed, an ongoing effort is required to further improve the process.

The Occupational Safety & Health Administration [OSHA] has a National Emphasis Program (NEP) to reduce or eliminate workplace hazards associated with shipbreaking operations. In the OSHA FY 2003-2008 Strategic Management Plan, OSHA has committed to focused interventions in the shipyard industries (29 CFR Part 1915) to reduce injuries, illness and fatalities to support DOL Strategic Outcome Goal 3.1, Reduce workplace fatalities, injuries, and illnesses.

Also, OSHA entered into a Memorandum of Agreement (MOA) on Interagency Coordination and Cooperation for Ship Scrapping (i.e., shipbreaking) between DOD, DOT, EPA, and DOL-OSHA. This MOA requires OSHA to develop an emphasis program for scheduling programmed inspections of shipbreaking operations.

As of 2004 there were two active Navy locations covered by the MOA:

  • Metro Machine Corporation, 5195 South 19th Street, Philadelphia, PA 19112 ((757) 543-6801).

  • International Shipbreaking Limited, 18501 R.L. Ostos Road, Brownsville, TX 78526 ((956) 831-2299).

There were six active MARAD locations covered by the MOA:

  • All Star Metals LLC, 101 Boxcar Road, Brownsville, TX 78521 ((956) 838-2110);

  • Bay Bridge Enterprises, LLC, 4300 Buell Road, Chesapeake, VA 22324 ((757) 543-7464);

  • Esco Marine, Inc., 16200 Joe Garza Sr. Road, Brownsville TX 78521 ((956) 831-8300);

  • International Shipbreaking Limited, 18501 R.L. Ostos Road, Brownsville, TX 78526 ((956) 831-2299);

  • Marine Metals, 16901 R.L. Ostos Road, Brownsville, TX 78526 ((956) 831-4284);

  • North American Ship Recycling LLC, 600 Shipyard Road, Baltimore, MD 21219 [Sparrows Point Shipyard] ((410) 477-6260).

OSHA determined that this NEP was needed because of the continuing high incidence of injuries and illnesses related to shipbreaking operations. This instruction is issued in support of both OSHA's Strategic Management Plan (Shipyard employment is a targeted high hazard industry) and the Memorandum of Agreement on Interagency Coordination and Cooperation for Ship Scrapping.

In an effort to reduce work-related injuries and illnesses, along with the environmental hazards associated with shipbreaking operations of government-owned ships, OSHA entered into an MOA with the DOD [Navy, and DLA-DRMS], DOT [MARAD], and EPA. This MOA was signed in November 1999 and provides for a coordinated effort between the Navy, DRMS, MARAD, EPA and OSHA to use the resources of each Agency to more effectively identify and regulate environmental and hazardous working conditions associated with the shipbreaking of government-owned ships.

An environmental and worker protection document has been developed by the EPA to provide guidance to supervisors at shipbreaking facilities. This document, "A Guide for Ship Scrappers: Tips for Regulatory Compliance," is structured by specific processes (such as asbestos removal, metal cutting, and fuel and oil removal) that occur in shipbreaking operations. Employers conducting shipbreaking operations can review key environmental, safety and health requirements for each process and readily identify pertinent Code of Federal Regulations requirements.

Shipbreaking and Asbestos

During ship scrapping activities, the removal and disposal of asbestos is a primary environmental concern, as well as a health and safety concern for workers. Asbestos was widely used in construction and industry due to its unique properties, and because there were few other available substances that combined the same qualities. Asbestos is resistant to abrasion and corrosion, inert to acid and alkaline solutions, and stable at high temperatures. It is strong yet flexible, non-combustible, conducts electricity poorly, and is an effective thermal insulator.

During ship scrapping, the most significant asbestos concerns for workers arise when removing asbestos-bearing thermal insulation; handling of circuit breakers, cable, cable penetrations; and removing floor tiles (from asbestos in the mastic and in the tile). Additional concerns can arise from handling and removing gaskets with piping and electrical systems, as well as molded plastic parts.

Some people exposed to asbestos develop asbestos-related health problems; some do not. Some known diseases caused from asbestos exposure include: (1) asbestosis (scarring of the lungs resulting in loss of lung function that often progresses to disability and to death), and (2) cancer, such as mesothelioma (cancer affecting the membranes lining the lungs and abdomen), lung cancer, or cancers of the esophagus, stomach, colon, and rectum.

Shipbreaking and Poly-Chlorinated Biphenyls (PCBs)

The sampling, removal, storage, and disposal of polychlorinated biphenyls (PCBs) is a primary environmental concern, as well as a worker health and safety concern, during ship scrapping. As described below, PCBs are found throughout older vessels and it is likely ship scrapping facilities will be faced with managing large quantities of PCBs.

PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. They are basically mixtures of synthetic organic chemicals with the same basic chemical structure and similar physical properties. PCBs, which were domestically manufactured from 1929 until their manufacture was banned in 1979, can range in toxicity and vary in consistency from thin light-colored liquids to yellow or black waxy solids. While sold under the trade name "Arochlor," PCBs are known by many trade names.

Due to their non-flammability, chemical stability, high boiling point and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, plastics and rubber products; in pigments, dyes and carbonless copy paper; and many other applications. More than 1.5 billion pounds of PCBs were manufactured in the United States before production was stopped in 1979.

PCBs are toxic and persistent. They have been shown to cause a variety of adverse health effects, such as cancer in animals, as well as a number of serious noncancer health effects in animals (e.g., effects on the immune system, reproductive system, nervous system, and endocrine system). Studies in humans provide supportive evidence for potential carcinogenic and non-carcinogenic effects of PCBs. The different health effects of PCBs may be interrelated, as alterations in one system may have significant implications for the other systems of the body. In some cases, chloracne may occur in humans exposed to PCBs. Severe cases of chloracne are painful and disfiguring, and may be persistent.

Shipbreaking and Waste Water

An important activity during ship scrapping is the proper removal and disposal of wastewater, specifically bilge water and ballast water. The activities, if not conducted properly, may impact the environmental and present health and safety concerns for workers.

Typically, government-owned ships received for scrapping have minimal bilge water onboard. Bilge water consists of stagnant, dirty water and other liquids, such as condensed steam, and valve and piping leaks, that are allowed to drain to the lowest inner part of a ship's hull (i.e., the bilge). Bilge water may also be found in onboard holding tanks, often referred to as oily waste holding tanks or slop tanks.

Bilge water originates from many sources both when a ship is in operation and when a ship is being scrapped. It may contain pollutants, such as oil and grease, inorganic salts, and metals (e.g., arsenic, copper, chromium, lead, and mercury). When a ship is in operation, bilge water may originate from leaks and spills, steam condensate, and boiler blowdown. This drainage may include small quantities of oils, fuels, lubricants, hydraulic fluid, antifreeze, solvents, and cleaning chemicals.

During ship scrapping, bilge water is created through the accumulation of rain water (because the decks are open) and the collection of water from fire lines that leak, are left open or are used to wet down compartments. Additional bilge water may be generated during asbestos removal and metal cutting activities.

Ballast is typically water (e.g., port water, sea water) that is intentionally pumped into and carried in tanks to adjust a ship's draft, buoyancy, trim, and list, and to improve stability under various operating conditions. There can be several kinds of ballast water onboard a ship during its operation.

Clean ballast is seawater that has been pumped into dedicated ballast tanks. Because these tanks are dedicated to ballasting operations, the seawater is not mixed with fuel or oil. Clean ballast water may contain pollutants, such as metals (e.g., iron, copper, chromium) and chemical constituents. These can come from additives (e.g., flocculant chemicals that facilitate the separation of suspended silts) or from contact of the water with the piping systems and ballast tank coatings (e.g., epoxy coatings and rust inhibitors containing petroleum distillates). The concentration of these pollutants is expected to increase the longer the water is in the clean ballast system.

Compensated fuel ballast is seawater that is taken in by the ship to replace fuel as the fuel is used, thereby maintaining the ship's stability. The tanks are always full of fuel, seawater, or a combination of both. Depending on the seawater to fuel ratio at the time of scrapping, pollutants in compensated fuel ballast may include fuel, fuel additives (e.g., biocides added to control bacterial growth in the fuel oil), oil and grease, petroleum hydrocarbons and metals, which may result from leaching and corrosion of the fuel containment systems.

Dirty ballast is created when seawater is pumped into empty fuel tanks for the purpose of increasing ship stability. The seawater mixes with residual fuel producing "dirty" ballast. Pollutants in dirty ballast may include residual fuel, fuel additives (e.g., biocides), oil and grease, petroleum hydrocarbons, and metals (e.g., copper, nickel, silver, and zinc).

Ballast can consist of materials other than water, such as mud or concrete. Mud ballast usually refers to drilling mud used in the petroleum drilling industry to lubricate drill bits and remove drilling debris. This type of ballast is typically treated with lubricants and corrosion inhibitors. The term mud ballast may also refer to concrete, rock, water, and other forms of locked-in ballast.

Bilge and ballast water may both contain metals which cannot be removed through treatment or environmental degradation. Metals, if ingested, can cause various human health problems such as lead poisoning and cancer. Additionally, consumption of contaminated seafood has resulted in exposure exceeding recommended safe levels.

Bilge water may contain toxic organics, such as solvents and polychlorinated biphenyls (PCBs), which can be cancer-causing and lead to other serious ailments, such as kidney and liver damage, anemia, and heart failure. Discharges of toxic organics can also result in the release of poisonous gas, which occurs most often when acidic wastes react with other wastes in the discharge.

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