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Notice of the USCG regarding possible data loss with "BilgMon 488"

Notice of the USCG for oil content meters type "BilgMon 488 "

The USCG published a notice regarding a possible data loss with oil content meters type "BilgMon 488" of the manufacturer Brannstrom Sweden AB.

If you use this device on board, please take notice of the statement of the USCG.

On 18 September, the promised policy of the Federal Government to financially aid ships of traditional build has entered into force. Operators of traditional ships will soon be able to apply for financial support at the "Bundesanstalt für Verwaltungsdienstleistungen" (BAV) for the continued safe operation of their ships.

Ships of traditional build are objects of national value in Germany and are part of its maritime tradition. Because traditional ships carry people, the level of safety is important. In this regard, the Federal Transport Ministry issued new requirements for the construction, equipment and manning of traditional ships. The intention of the Federal Government with its newly published financial aid scheme is to aid owners of traditional ships in their safety investments and create an incentive for a swift implementation of the new requirements.

Financial support of traditional ships

Operators of traditional ships will soon be able to apply for financial support of their projects at the "Bundesanstalt für Verwaltungsdienstleistungen" (BAV). The BAV will publish the respective application form on their website (www.bav.bund.de). The applications will be processed electronically via the system "easy-Online", but applications will additionally have to be submitted as hardcopy with a signature.

Eligible for the aid will be any expenses that have become necessary under the new requirements that have entered into force on 14 March 2018 with the "Verordnung zur Änderung der schiffssicherheitsrechtlichen Vorschriften über Bau und Ausrüstung von Traditionsschiffen und anderen Schiffen, die nicht internationalen Schiffssicherheitsregeln unterliegen" (Ordinance amending ship safety provisions on the construction and equipment of ships of traditional build and other ships which do not fall under the international ship safety rules and regulations). Expenses in relation with existing rules are not eligible for this funding.

An application will be successful if the owner of the traditional ship arranged the renewal survey by the BG Verkehr within the usual time frame of this periodic survey. The survey report shows which new requirements may be funded. Along with the application, the shipowner has to submit cost estimates for the implementation of the requirements. If all required documents have been submitted, the Federal Government can support the planned conversion measures as a "Fehlbedarfsfinanzierung" (i.e. the amount is dependent on the expense as well as the financial capability of the applicant).

The details of the funding are given in the funding policy.

Questions about the application process will be answered by the BAV staff:

            Bundesanstalt für Verwaltungsdienstleistungen (BAV)
            Schloßplatz 9, 26603 Aurich
            Phone:          04941/602-678 (Montag bis Freitag im Zeitraum 9:00 Uhr bis 15:00 Uhr)
            Fax:               04941/602-81799
            E-mail:           Traditionsschiffe@bav.bund.de

Questions about surveys and requirements of the Ship Safety Ordinance will be kindly answered by the Ship Safety Division of BG Verkehr:

            BG Verkehr / Ship Safety Division
            Brandstwiete 1, 20457 Hamburg
            Phone:            040/361 37-239 (Ms Oya Sönmez)
            E-mail:            oya.sönmez@bg-verkehr.de

On 17 and 18 October, experts and policy makers discuss the United Nations' International Convention on the Law of the Sea (UNCLOS) and its future at the International Tribunal for the Law of the Sea (ITLOS) in Hamburg. The organizers of the event are Indiana University's Hamilton Lugar School of Global and International Studies, the University of Hamburg and the International Foundation for the Law of the Sea. There are still spots available for the conference.

25 years ago, the United Nations adopted the International Convention of the Law of the Sea. To mark this occasion, an international UNCLOS Conference is held in Hamburg. UNCLOS stands for United Nations Convention on the Law of the Sea.

The venue for the conference is the International Tribunal for the Law of the Sea at Hamburg-Nienstedten. The white old-fashioned villa and the new building in a spacious park with view on the river Elbe house Germany's only international court of law. Since 1996, 21 judges of the Tribunal for the Law of the Sea have delivered judgements on disputes over the interpretation of the Convention of the Law of the Sea.

UNCLOS-Konferenz.jpg

The convention was developed in 1994, after nine years of negotiations as a reaction to a long lasting dispute about the size of the area of the coastal waters. These kinds of issues become more and more important because many countries use marine resources and want to increase the size of their fishing and oil production areas. 165 states have so far ratified the convention; incidentally, the USA are not among them.

Major aspects of the Convention of the Law of the Sea are the determination of a 12 nautical mile zone as coastal waters as well as a continuous 12 nautical mile zone. The coastal waters are territorial waters, which means that the coastal state is able to punish violations. In the continuous zone, the state can decree customs, health or immigration provisions. The convention also deals with rights and duties within the Exclusive Economic Zones (EEZ) as well as the exploitation of the high seas and the ocean bed.

At the conference in Hamburg, experts will review the current state as well as discuss the future of the Convention of the Law of the Sea. During the first day of the conference, the dispensation of justice regarding the usage of the sea areas and the settlement of disputes will be considered. The most prominent speaker of the day will be former US Secretary of Defense Chuck Hagel talking about the practical application of the Articles (altogether 320) of the Convention. Directing the focus onto the future, the second day features issues such as changes of marine policies as new technologies emerge.

Find out more under https://hls.indiana.edu/unclos/

In the course of the National Masterplan for Maritime Technologies (NMMT), the Federal Ministry for Economic Affairs and Energy together with the Free Hanseatic City of Bremen invites to a symposium in Bremerhaven during 23-24 October 2019. At this symposium, enterprises and authorities from various countries of Europe present their projects of maritime safety and security technologies.

Already a day before the actual commencement of the notes and presentations, on 22 October at 4 pm, a live demonstration at the outside area of the Forum Fischbahnhof marks the beginning of the symposium. This live demonstration will be open to visitors throughout the two-day symposium. The event addresses the achievements and challenges of digital ship safety and security.

The first day of the symposium is about how digitalization is utilized in marine traffic monitoring, management as well as logistic chains, about maritime infrastructures in ports, on ships and of waterways, and about innovations for safeguarding and protecting for example coastal and offshore installations. Enterprises and public authorities will present their projects in connection with these themes. For the evening of the 23rd October, the Senator for Economic Affairs, Labour and Europe of the Free Hanseatic City of Bremen invites the participants to a reception at the "German Immigration Centre" in Bremerhaven.

During the morning session of day two, risks and tasks of cyber security will be discussed. The speakers and participants will focus on digital avenues in environmental protection and the future of digital safety and security issues.

The symposium is part of the National Masterplan for Maritime Technologies (NMMT) of the Federal Ministry for Economic Affairs and Energy. With this masterplan, the coordinator for the maritime economy of the Federal Government Norbert Brackmann has set up a concept for the advancement of the maritime economy. As part of the Maritime Agenda 2025 of the Federal Government, the NMMT will depict the innovation and development requirements of the maritime sector.

The symposium takes place in English. Registration and the programme can be located on the website of the NMMT by the Federal Ministry of Economic Affairs and Energy.

Transitional rules by UK (MCA) and approval of marine equipment

A possible "No-Deal-Brexit" will affect the validity of MED approvals of notified bodies in the UK. After a Brexit, marine equipment can only continue to be produced if the existing Module D or Module E certificates of an UK notified body are replaced by those of a notified body of an EU state. For this reason, it cannot be entirely ruled out that there may be supply bottlenecks of marine equipment or problems regarding ship surveys.

Certificates of Modules B, G and F that were issued before the Brexit remain valid as long as they are not changed.

If the United Kingdom exits the EU without an agreement, it will no longer be part of the MED regime. For this scenario, the Maritime & Coastguard Agency (MCA) published transitional rules. These state procedures to ensure that the United Kingdom keeps its international obligations and that international standards for marine equipment will continue to be applied and enforced.

This year at the IMO is all about equality of women, because, even today, of the 1.2 million seafarers only 2 percent are female. The International Maritime Organization utilizes this year's theme to raise awareness of its various initiatives and programmes to empower women in the maritime sector and promote this crucial topic.

This year's World Maritime Day of the International Maritime Organization IMO is set for 26 September 2019. To celebrate this day, the authorities of the German coastal states hoist the state flag.

Every year the World Maritime Day focuses on a relevant topic. This year is dedicated to the major topic "Empowering women in the maritime community". Throughout the year, various events and campaigns incorporate the awareness-theme.

At the beginning of April, the World Maritime University held an international conference about women in the maritime industry. On the Day of the Seafarer on 25 June, the IMO gained wide social media attention with their slogan „I am on board with gender equality‟. Now, in September, a parallel event in Colombia accompanies the theme of the World Maritime Day and expands on it.

Weltschifffahrtstag 2019

Already at the end of the 80s, IMO started to support the integration of women in the maritime sector. Over several phases, it created the necessary framework conditions to get more women interested in work at sea. The goal has always been for more women to visit maritime training facilities and subsequently spent work experience time on board.

The IMO has gender-specific fellowships, facilitates access to high-level technical training for women in the maritime sector in developing countries and promotes the advancement of women in maritime authorities. In their programme "Women Maritime – IMO's gender programme" under the slogan "Training – Visibility – Recognition", IMO joins the agenda of the United Nations to implement the fifth of the seventeen sustainable development goals "to achieve gender equality and empower all women and girls". With their initiative, the IMO aims to overcome prejudices against women in maritime professions, to open up training opportunities to women and to facilitate female careers in technical and nautical professions at sea and at land.

Under IMO's auspices, seven regional maritime associations for women that want to strengthen employment opportunities in the shipping industry have been established. Reducing cultural stigmata and prejudices remains a challenge in their attempts. Only two percent of the 1.2 million seafarers worldwide are women. Of this already small proportion, most women work in the cruise industry.

Find out more about the IMO's gender programme "Women in Maritime" and the World Maritime Day 2019.

Germany has acceded the Ship Recycling Convention of the IMO as 13. State world-wide and seventh EU State. However, several other states will still have to ratify the Hong Kong Convention 2009 in order for it to enter into force.

In July 2019 Reinhard Klingen, head of the department Waterways and Shipping of the Federal Ministry for Traffic and Digital Infrastructure (BMVI), presented the IMO Secretary-General Kitack Lim with the instrument of accession. By depositing the instrument with the IMO, the binding accession of Germany to the Hong Kong Convention concludes.

Depositing instrument of accession with IMO

Currently the Hong Kong Convention is not in force. For it to enter into force, 15 states with at least 40% of the world merchant shipping tonnage and not less than 3 % of the combined maximum annual ship recycling volume need to join. With Germany's ratification almost 30 % of the world merchant shipping tonnage has been reached. The 3%-criterion, however, can only be fulfilled if India or other countries with large shipbreaking yards like Bangladesh and Pakistan accede.

More than 32 % of ships worldwide get recycled in India. Over the last years, India has invested heavily in the improvement of its ship recycling infrastructure. Since then the IACS, International Association of Classification Societies, has confirmed that many of the ship recycling facilities now meet the requirements of the Hong Kong Convention.

In spite of Germany's recent ratification, the Hong Kong Convention is not yet applicable for ships flying the German flag. Only when the Hong Kong Convention has entered into force will it become fully effective.

In accordance with the EU Ship Recycling Regulation (Regulation (EU) No. 1257/2013), existing ships from 500 GT entering an EU port (outside of their own flag state) need to carry an approved inventory of hazardous materials at the latest on 31 December 2020. Surveys confirm the inventory of hazardous materials on a regular basis. A certificate stating that the ship is ready for recycling is required before the ship enters, as is required, one of the recycling facilities on the European List (last updated 18 June 2019). New ships must already comply with the requirements.

Fixed gas fire-extinguishing systems

The Maritime Safety Committee (MSC) of the International Maritime Organization IMO has adopted a revised version of MSC.1/Circ.1395/Rev.3. The Ship Safety Division would like to notify about this revised version - MSC.1/Circ.1395/Rev.4 of 13 June 2019. 

The updated circular, which supersedes the previous, contains "Lists of solid bulk cargoes for which a fixed gas fire-extinguishing system may be exempted or for which a fixed gas fire-extinguishing system is ineffective".

In this publication an overview of the cargoes for which an exemption - subject to terms as appropriate - is granted in accordance with Regulation II-2/10.7.1.4 SOLAS (International Convention for Safety of Life at Sea).

Your contact for this topic is

Andreas Herold
Dienststelle Schiffssicherheit / BG Verkehr
Brandstwiete 1
20457 Hamburg 

Tel.: +49 40 361 37-258
Mail: andreas.herold@bg-verkehr.de

Raised security level

Changing the security level

Given the increased risk, the security level for German-flagged vessels has been set, with immediate effect and until further notice, to

SOLAS security level 2 (two)

This was decided in consultation with the Federal Ministry of Transport and Digital Infrastructure.

This applies to the following sea area: West of 060° E from the coast of Iran 25°22'46''N, 60°00'00''E of the coast of Oman 22°25'45''N, 60°00'00''E and further for the Persian Gulf.

Guidance and recommended behaviour:

Please refer to the recommendations issued by the industry associations OCIMF and INTERTANKO at: https://theseanation.gr/news-in-english/43935-intertanko-ocimf-update-followingrecent-attacks-in-gulf-of-oman.html

They recommend to

  • maintain a full and vigilant bridge watch;
  • maintain a strict communications watch and establish communication with all vessels coming close;
  • ensure strict boarding controls are in place;
  • only lower gangways when necessary;
  • rig outboard lighting where possible provided they do not interfere with keeping a safe lookout, particularly over the stern;
  • rig/use searchlights if available;
  • report any suspicious activity immediately to both the nearest port and UKMTO (+442392222060);
  • permanently monitor relevant communication channels;
  • keep all fire-fighting equipment available for immediate use;
  • make sure the emergency fire pump is available and keep the AIS signal on.

More than 30 representatives of the European and North American port state control (PSC) authorities have followed the invitation of the BG Verkehr to get together for a three-day seminar in Hamburg. The surveyors and coordinators caught up on the recent challenges for port state control.

The representatives of the PSC authorities of the area covered by the Paris Memorandum of Understanding on Port State Control (Paris MoU), which include the European states as well as Russia and Canada, get together twice a year for working seminars. This year Germany was host of this seminar.

The focus of this train-the-trainer seminar was the upcoming Concentrated Inspection Campaign of the PSC with the topic "Emergency Systems and Procedures" which is planned for September until November 2019. The PSC officers of the Ship Safety Division of BG Verkehr and their foreign colleagues discussed uniform procedures for the campaign.

The three-day session conducted in English was complemented with guest lectures on the tasks of the German Central Command for Maritime Emergencies (Havariekommando), on experiences with hybrid ferries, on rescue of persons over board from the sea and on ballast water management.

PSC-session

The revised Guideline on Food Hygiene give practical guidance and helpful procedures to make sure food is handled hygienically and safely on board of ships.

A well-balanced and healthy diet is important, especially when working hart. On board ships on weeklong voyages, it is necessary to plan ahead and store and prepare foodstuffs appropriately. That way, what ends up on the plate not only tastes good but is also healthy and wholesome.

The Guidelines on Food Hygiene by the Ship Safety Division of BG Verkehr explain in step with actual practice what is part of hygienic food provision on board. It presents comprehensively what the shipowner, the master and the galley and service personnel can and must do to make sure that the way food is stored and prepared does not pose hazards or health risks. Therefore, the main topics of the guidelines are clean drinking water, correct storage and hygienic preparation, which are key to achieving this.

Photos and illustrations depict how to do it properly and what needs to be avoided. Newly added annexes show how to wash the hands properly and how to keep the galley workplace clean and safe. A useful checklist helps control safe food storage and preparation on a regular basis and self-dependently.

Food hygiene

From 1 August, the BG Verkehr will survey ships under a foreign flag requiring a Certificate of Equivalence in German ports only. One reason being that the amount of surveys has escalated, another is the large expenditure of travel time to and from ports abroad.

Every ship without SOLAS certificates for international voyages only operating in German coastal waters requires a Certificate of Equivalence of BG Verkehr. This is supposed to ensure a comparable safety standard to German-flagged ships in coastal shipping. In practice, mostly offshore transfer vessels need a Certificate of Equivalence. The legal basis for the certificate is the Ship Safety Ordinance section 9 paragraph 6.

© DOTI / Matthias Ibeler www.offshore-stiftung.de

The BG Verkehr only issues Certicates of Equivalence after a survey on board the respective ship. The amount of surveys has escalated in recent years. In 2015/2016 the surveyors of the BG Verkehr left from Hamburg to 47 equivalence surveys – from January 2017 until June 2019 this number has risen to ten-times as many to 433 surveys.

In view of the unchanged number of surveyors as well as expenditure of travel time to ports abroad, the BG Verkehr will offer equivalence surveys in German ports only from 1 August. This change of survey practice regards both initial as well as renewal surveys.

Additional restrictions for sewage discharge

In our heading "Environmental protection" the current information about regulations for discharge of sewage of passenger ships in the Baltic Sea are given. 

With the Flag State Performance Table of the International Chamber of Shipping (ICS), shipowners can get a quick overview of the quality of the 117 flag states worldwide. The German Flag has long been exemplary in all areas and once more ranks among the best this year.

In their Flag State Performance Table, the ICS publishes a concise overview of how well the flag states organised their fleet over the last year. The performance table helps shipping companies choose a reliable and safe flag.

In the ICS ranking, a green marking represents positive performance of the individual criterion while a red one stands for failure of performance. Just as in the previous years, the German Flag is fully in the "green". Thereby, Germany in one of 22 of the best flag states among a total of 117 the ICS compared.

Germany has ratified all important maritime conventions and works actively in and with the IMO. German-flagged ships come off well in port State control inspections and the average age of the fleet is relatively low. The recognized organisations working for the German Flag also show good results. On the STCW "White List", Germany stands for high-quality training of the next generation of seafarers and assures fair working and living conditions on German-flagged ships.

It remains valid: You can rely on the quality of the German Flag!

Flag State Performance

Fire extinguishers

02/2019: Safety notice regarding fire extinguishers by the manufacturer Eversafe Extinguisher SDN BHD

The manufacturer Eversafe Extinguisher SDN BHD has published a safety notice regarding possible corrosion damage with the extinguisher models 

  • Brude EEF-9s and
  • Brude EEW-9s.

The serial numbers of the models potentially affected are known. Please note in particular, the advice of the manufacturer on page two regarding the annual service and restrictions regarding sunlight and heat.

Convincingly establishing safety awareness on board can only work if all crew members are actively involved. Hazards can be found anywhere safety provisions are only followed half-heartedly. With their new Safety Bulletin, the Ship Safety Division of BG Verkehr gives practical advice for sound safety awareness on board.

The first topic in line of the new Safety Bulletin is Enclosed Spaces. In the beginning of the notice, an example from day-to-day work on board shows how and where hazards may occur. Because, especially when something is done on a daily basis, carelessness easily creeps in. Moreover, the examples show with real incidents where potential weak spots of the occupational health and safety measures of specific operational procedures lie.

KW-Sicherheitskultur.jpg

The safety information is published as a bulletin, because a convincing and successful safety concept needs to be continuously further developed. The bulletin issues are supposed to instigate to always question and advance the existing occupational health and safety measures on board together. This means that crew and shipping company have to work together to ensure that safety measures are both suitable for every day work and at the same time meet the legal and company requirements. Where a safety measure proofs useless, a new way to implement safety needs to be developed together. Only if everyone supports the safety concept on board, will it be consistently implemented.

Read more about how to raise safety awareness on board under our heading "Occupational health and safety".

The Ship Safety Division of BG Verkehr has changed their approval practice regarding in-water surveys of German-flagged ships. As of now, the inspection of the ship's bottom can also be done inside the water if a ship does not have an additional class notation for in-water surveys (e.g. "BIS", "IW").

Under the SOLAS Convention (Regulation I/10(a) in part B), two bottom surveys have to be conducted for sea-going vessels within a 5-year period. For cargo ships younger than 15 years, the first survey is not required to be done in drydock but can also be conducted in the water by a diver.

So far, the German Flag demanded an additional class notation (e.g. "BIS", "IW") or appropriate structural conditions for an in-water survey – among other things, fixed markings at the hull below the waterline and safe access to the sea chests, rudder bearings and stuffing boxes for the diver.

Other flag states or classification societies use the current IACS UR Z 3 Rev.7 of January 2018 (the abbreviation "UR" means "Unified Requirements"). The Ship Safety Division also has decided to follow these rules of the International Association of Classification Societies (IACS) for sea-going vessels under German flag from now on.

Kirk Williams

In-water surveys are, inter alia, approved under the following circumstances:

  • survey in sheltered water, preferably with weak tidal streams and currents;
  • the in-water visibility and the cleanliness of the hull below the waterline are to be good enough to permit a meaningful examination which allows the surveyor and the in-water survey firm to determine the condition of the plating, appendages and the welding;
  • the diving survey shall be carried out by a company approved by the competent classification society under the supervision and to the satisfaction of the class surveyor;
  • if damages are detected during the in-water survey, the class surveyor may order a drydock bottom survey.

Further details are outlined in:

Maritime shipping too has to become (even) more environmentally friendly. Therefore, since the beginning of 2018, the EU prescribes that the shipowners have to trace the emissions of their ships. This requirement of the so called MRV Regulation are now supplemented with new rules by the International Maritime Organisation IMO. We explain the differences between the two systems.

The Regulation (EU) 2015/757 on the monitoring of carbon dioxide emissions from maritime transport applies since 2018. This regulation is better known under its abbreviation MRV which stands for monitoring, reporting and verification. Now the IMO has added another system: the Data Collection System (in short: DCS). In this system the fuel consumption of maritime ships is established.

Both procedures resemble one another and shipowners can use some of the collected data for both systems. But there are also differences. For example, in Germany different authorities monitor the compliance of the requirements.

We have compiled the most important differences for you in the following table. Below the table, you will find more detailed information about the two procedures.

Procedure: EU MRV Regulation IMO DCS (Data Collection System)
Monitoring of: carbon dioxide emissions IMO DCS (Data Collection System)
Application: from 5000 GT
commercial voyages to or from a port or between ports in the European Community
from 5000 GT
international voyages
(large fishing vessels and offshore jack-up vessels are also included)
Implementation with: verification of a monitoring concept by an accredited verifier with the SEEMP (Ship Energy Efficiency Management Plan), incl. part II, verified by a recognised classification society → survey report or Confirmation of Compliance to Ship Safety Division for approval (until 31. December 2018)
Start of data collection: since 1. January 2018 from 1. January 2019
Data submission: Emission report to Deutsche Emissionshandelsstelle (at the Federal Ministry for the Environment) until 30. April the following year to Ship Safety Division until 1. April the following year;
entry of the data into the IMO database by Ship Safety Division or commissioned class
First submission until: 30. April 2019 1. April 2020
Further information: ISM Circular 01/2018 ISM Circular 05/2018

MRV and DCS

EU MRV Regulation (carbon dioxide emissions)

The maritime transport regulation EU MRV ((EU) 2015/757) is applicable for ships of 5000 GT and above which conduct commercial voyages to or from a port or between ports in the European Community. The EU Regulation stipulates monitoring of carbon dioxide emissions from maritime traffic with a monitoring concept verified by an accredited verifier.

Annually, an emission report for the ship, based on the collected data and positively assessed by an accredited verifier with a Document of Compliance, is reported to the Deutsche Emissionshandelsstelle until 30. April of the following year. This Emissionshandelsstelle is part of the Federal Ministry for the Environment. The Document of Compliance is to be carried on board the ship.

Emissions have to be collected since 1. January 2018. The first Emission report is due on 30. April 2019.

Further information is given in our ISM Circular 01/2018.

IMO Data Collection System (fuel consumption)

The IMO has approved a system to record data about fuel oil consumption of ships (DCS) for ships on international voyages with 5000 GT an above and has included this in the MARPOL Convention Annex VI. For the implementation, the SEEMP (Ship Energy Efficiency Management Plan) has been extended with a part II: the ship fuel oil consumption data collection plan.

For sea-going ships under German flag, the shipowner submits the SEEMP with the supplemented part II to a recognised classification society for verification. The class submits their Survey Report or the Confirmation of Compliance - Ship Fuel Oil Consumption Data Collection Plan to the Ship Safety Division of the BG Verkehr for approval which issues the relevant confirmation for the ship. The approval by the Ship Safety Division has to occur until 31. December 2018.

The shipping company submits the collected data to the ship safety Division until 1. April of the following year. The first submission is due on 1. April 2020.

The collected data on the fuel oil consumption are entered annually into the IMO database of fuel oil consumption of ships by the Ship Safety Division or the commissioned class. For each ship under German flag, the Ship Safety Division issues a Statement of Compliance - Fuel Oil Consumption Reporting to confirm the proper submission of the annual consumption report to the IMO.

Further information and details about the required data and the various measuring methods are given in the ISM Circular 05/2018.

The German Bundestag paved the way for the German ratification of the convention with the unanimous adoption of the draft law on the Ship Recycling Convention of the IMO and takes a stand for safe and environmentally sound recycling of ships.

Since the 1970s, ship breaking has shifted from Europe to Asia. Shipyards in Europe had become too small for large sea-going vessels and an expensive work force as well as strict environmental provisions gradually drove up the costs.

In Asia ships are broken down on beaches instead of in shipyards. The work and wage conditions as well as the pollution by these ship breaking places has long been criticised internationally. With the Hong Kong Convention 2009, the IMO has created requirements and regulations for safe and environmentally sound recycling of ships.

© Naquib Hossain, https://www.flickr.com/photos/naq/4114723979/, Lizenz cc-by-sa-2.0

The Convention does not apply to ships under a gross tonnage of 500 and ships that have solely been deployed on national voyages. However, these ships should also be recycled in a sustainable way and with consideration for the environment.

Both the EU Ship Recycling Regulation (EU SRR) and the German law for the ratification of the Convention are supposed to raise awareness of the topic with other flag states so that they might join the Convention. The Convention will only come into force once at least 15 parties with a total of 40% of the world gross tonnage and at least 3% of the annual global total tonnage of recycled ships have ratified the Convention.

The Federal Ministry of Transport and Digital Infrastructure has entrusted the Ship Safety Division of the BG Verkehr and the Federal Maritime and Hydrographic Agency (BSH) with the enforcement of the Convention in Germany and on ships flying the German flag.

In the future, the Ship Safety Division will issue a document that certifies that an Inventory of Hazardous Materials exists and complies with IMO requirements. The Inventory lists all hazardous materials contained in the ship's structure or equipment, their location and approximate quantities. The inventory must be kept up-to-date throughout the whole operational life of the ship.

Prior to the voyage to the ship recycling facility, the Ship Safety Division conducts a final survey and declares the ship clear for recycling. During port state control inspections, the ship will also be checked for compliance with the Convention.

The BSH will be the competent authority for the authorisation of national ship recycling facilities. Prior to the recycling of a ship, the agency approves the Ship Recycling Plan of the recycling facility.

For a long time, asbestos was considered a miracle product: the natural mineral is fire resistant, an insulator, easy to process and inexpensive. But asbestos causes illness and can give rise to cancer. BG Verkehr summarized the things shipping companies have to observe when they flag-in a ship that is contaminated with asbestos.

Those who worked with asbestos in the past often used to breath in the dust and thereby the fine asbestos fibres. A possible result: malignant cancer tumours or changes in the lining of the lung. The employer's liability insurance associations recognize asbestos as a cause of a lung disease known as asbestosis, and as an occupational disease. Asbestosis is the most common cause of death among the terminal occupational diseases. There can be several decades between working with asbestos and the onset of the disease. On average the latency period is 38 years.

Since 1993, asbestos may not be produced or used in Germany, and on a European level since 2005. From 2019 all ships under EU flag from 500 GT must have an inventory of hazardous materials, which must also include asbestos. With the Regulation EU/1257/2013 the EU legally implements the provisions of the Ship Recycling Convention (“Hong Kong Convention”).

Globally, however, there is no ban on asbestos. So, there may still be asbestos present on older ships. If such a ship flags-in under the German flag, the shipowner will have to conduct a risk assessment, compile an asbestos cadaster and arrange mandatory medical check-ups for the seafarers. The prevention division at BG Verkehr has developed a compilation of the shipowner’s obligations when flagging-in a ship that is contaminated with asbestos (in German only).

The German flag is always available for you - on 365 days of the year. You can reach our specialists under the phone number +49 3190-7777 for all questions about maritime shipping under German flag

The maritime 24/7 hotline is offered by the Federal Maritime and Hydrographic Agency, BSH. In addition, the stand-by service of the Ship Safety Division of BG Verkehr is also available. More information is given under "Contact Details".

Hotline (klein)