Platform News – ECSA’s Alang report turns a blind eye on problems of beaching method

The European Community Shipowners’ Association’s (ECSA) has published a report on their visit to the Alang shipbreaking yards in India last April. The NGO Shipbreaking Platform criticises the report for ignoring the many grave shortcomings of the beaching method, including its inability to ensure containment of pollutants and to guarantee occupational safety, and for simply echoing the yard owners' one-sided account of working and living conditions in Alang.

"This is not the report of a fact-finding mission, but a promotion brochure for the Indian beaching yards. There are no solutions provided to the serious concerns we have raised with ECSA, and no demands for improvement. The true intent is to gain support for the most convenient solution for ship owners: the continuation of the low-cost method of beaching that allows for maximum profit for shipping lines."
Patrizia Heidegger - Executive Director - NGO Shipbreaking Platform

The damaging environmental impacts of breaking ships in the intertidal zone of a beach are well known: slag, toxic paint particles and debris including metal scrap and plastics are released into the environment when the ship is torched and large metal pieces are simply dropped onto the sand or into the sea. Alarming levels of air, water and soil contamination at beaching yards are well documented [1].


Whilst some yards in Alang have cemented the areas where they conduct secondary cutting, all yards in Alang conduct the primary cutting of the ship in the intertidal zone. ECSA argues that pollution in the intertidal zone can be controlled by only letting ‘clean’ blocks fall into the sea or onto the beach. ECSA cannot, however, explain how blocks are actually 'cleaned' and where the chemicals necessary in this process end up. The contamination by toxic anti-fouling paints that are accumulated in the sediments is completely ignored by ECSA, as are the difficulties of preventing and remediating oil spills in the intertidal zone.


Instead, ECSA heavily relies on the Statements of Compliance (SoC) with the Hong Kong Convention which have been issued by consultants to some of the yards in Alang, including by the classification societies ClassNK and RINA in their private capacity, in order to claim that beaching practices are sound.  These SoCs, however, only look at procedures and not the actual performance of the yards. Environmental monitoring is required by Indian law and whilst most yards in Alang may conduct such monitoring – and thus tick a box in the checklist for the SoC – astonishingly, the findings of the local companies hired by the yards to conduct the samplings have hardly found any contamination, if at all. Apart from such meaningless monitoring of environmental impacts, ECSA also easily refers to the environmental monitoring of the Gujarat Pollution Control Board (GPCB). The data available on the GPCB’s website is, however, far from detailed and several years old.

The ship owners’ association is also very gullible when it comes to assessing downstream waste management in Alang. Even though the association knows that Indian law allows for the resale of asbestos-containing material and that there is no incinerator for PCBs in India, ECSA simply trusts that the yard owners will ensure environmentally sound waste management on a voluntary basis, even if this creates higher costs for the yards.


Likewise, ECSA’s account of the social welfare system that yard owners have reportedly “voluntarily” put in place raises concerns. First and foremost, workers in India have a legal right to most of the mentioned benefits. Second, ECSA has not checked whether informal migrant workers, who make up the large majority of Alang workers, actually benefit from social welfare. A report from the renowned Tata Institute for Social Science reported dire working conditions in Alang, including the lack of contracts, pension schemes and insurance. Most workers in Alang do not have access to decent accommodation but live in makeshift shacks. The yard owners have been promising for many years that accommodation blocks will be set up; however, the large majority of workers currently remain in roadside slums while proper housing is only slowly being built for a small number of the total workforce.


Instead of consulting the trade unions or researchers who have looked into these important questions, ECSA blindly trusts the yard owners who misleadingly portray obligations they actually have as employers under Indian law anyway as laudable corporate social responsibility. And, while ECSA praises the 'willingness and openness of the Indian yard owners to receive the delegation', Indian and international NGOs were excluded from participating to the visit and ECSA did not deem it necessary to meet with trade unions and workers themselves.

"It is particularity cynical when ECSA reports that the Gujarat Maritime Board (GMB) - a Government body that actively keeps NGOs and other critical voices outside the yards - was ‘liaising with numerous social and environmental NGOs’: GMB does not even answer an email when we request a copy of the accident statistics which they have to keep, and does not have a meaningful exchange with any of the civil society organisations that have been working on the issue for many years."
Patrizia Heidegger - Executive Director - NGO Shipbreaking Platform

Shipbreaking is a heavy industry with a high risk of accident. Though ECSA found that there is only a rudimentary first aid centre in Alang and no functional hospital in the close vicinity, the ship owners’ association does not demand an immediate remedy to the unacceptable situation. The GMB’s accident statistics that it shared with ECSA show that between May 2015 and January 2016 at least 5 workers were killed in the yards. During this period the local steel market was very weak and many Alang yards were forced to close. The workforce was at that time reported to have been reduced to less than 5.000 workers. The accident rate is thus alarmingly high, notwithstanding that the GMB statistics do not include severe injuries and maimed workers. The many toxic materials found within the ship structure pose further serious health risks to the workers, and while ECSA reports that there are medical check-ups for workers in Alang, it is doubtful whether specific tests such as for heavy metal poising are conducted and that occupational diseases are properly detected and reported.


"EU law-makers who have sought to regulate the substandard practices of European ship owners, by disapproving the beaching method, have been accused by ECSA of being ‘neo-colonial’. While the regulation of transnational business is actually a way to curb post-colonial exploitation structures perpetuated by European businesses, what is truly neo-colonial is ECSA's acceptance of lower environmental, health and safety standards for people and the environment in India. If European ship owners really want to be a driving force for sustainable development in India then why do they not ensure investment in and knowledge transfer for state-of-the-art ship recycling off the beach?"
Patrizia Heidegger - Executive Director - NGO Shipbreaking Platform
Leela yard_HKC ClassNK certified (©ECSA – 29.04.2016)

Press Release – European Commission report recommends the introduction of a Ship Recycling License

Ships regardless of their flag should not be allowed to call at any EU port without a ship recycling license to incentivise sustainable ship recycling, a European Commission report recommends.


The report written by Ecorys, classification society DNV-GL and the Erasmus University School of Law and published yesterday, looks into the possibility of introducing a financial incentive to enhance safe and environmentally sound ship recycling [1]. Ship recycling license fees would be earmarked to cover the cost-gap between substandard and sustainable end-of-life ship management. The capital amount accumulated during the operational life of the vessel would be set aside for the ship and only paid back to the last owner of the vessel as a premium if the ship is recycled in a sustainable facility approved by the EU.

"We call on the European Commission to follow-up this report with a legislative proposal. The effective implementation of European environmental policies has been dependent on making the 'polluter pay'. If the EU is serious about its commitment to sustainable ship recycling, all ship owners trading in Europe need to be held financially liable/"
Stephane Arditi - Products & Waste Policy Manager - European Environmental Bureau (EEB)

The 2013 EU Ship Recycling Regulation requires all vessels sailing under an EU flag to use an approved ship recycling facility [2]. A major shortcoming of the Regulation, however, is that shipowners can circumvent the law by simply flagging out to a non-EU flag. At end-of-life, cash-buyers act as intermediaries and sell the vessels to substandard yards in South Asia often using flags of convenience which are grey- or black-listed by European governments under the Paris Memorandum of Understanding. Last year, Bangladesh, where human rights abuses and pollution caused by shipbreaking activities are known to be the worst, was the preferred destination for end-of-life ships. EU owners account for around one third of the end-of-life tonnage beached in substandard yards in Bangladesh, India and Pakistan. Thus, the EU is the single largest market sending end-of-life ships for dirty and dangerous shipbreaking and has a particular responsibility to regulate ship recycling [3].

"EU shipping companies should not circumvent EU environmental laws and not utilise practices that would never be allowed in Europe. EU flag-neutral measures which apply equally to all ships calling at EU ports are necessary to increase environmental protection."
Sotiris Raptis - Shipping and Aviation Officer - Transport and Environment

European ports are not opposing the ‘ship recycling license’ [4] and SeaEurope, Europe's ship yard and maritime equipment association, has expressed enthusiasm towards ensuring better implementation of the Ship Recycling Regulation - last month they called for support to enhance ship recycling capacity and R&D towards more cost effective solutions in Europe [5].


"The upcoming EU list of approved ship recycling facilities will function as an important market differentiator for yards that have already invested in proper occupational health & safety and environmental standards. The use of the EU listed facilities will however depend on the introduction of an effective financial incentive that forces irresponsible shipowners towards better practices."
Ingvild Jenssen - Policy Director - NGO Shipbreaking Platform




[1] Article 29 of the EU Ship Recycling Regulation asks the European Commission to submit a report on the feasibility of a financial instrument that would facilitate safe and sound ship recycling, and to accompany this report by a legislative proposal if deemed appropriate. For Regulation text see For the report on a possible financial incentive see:


[2] A list of approved ship recycling facilities globally will be published by the end of 2016.


[3] Approximately 40% of the world fleet is controlled by owners based in the EU+EFTA, only 17% of the world fleet, however, sails under an EU+EFTA flag. The vast majority of EU-owned ships are sailing under the flags of states such as Panama, Liberia and the Marshall Islands during operational life. The percentage of EU flags drops to less than 8% at end-of-life.


[4] An earlier proposal for a 'ship recycling fund' was narrowly rejected by the European Parliament in 2013 with industry stakeholders, including the shipping industry and ports, strongly opposing the fund at the time. Whilst ship owners remain unwilling to bear the cost of sustainable recycling, both the public and private European port associations – ESPO and Feport – have now expressed that they are satisfied with the new license proposal. The license scheme will not be administered by the ports. It is also time-based, with the option of a monthly or yearly license, rather than based on the collection of a fee at each individual port call.

[5] See press release from 11 May 2016:

For more information see our “What a difference a flag makes” report on why ship owners need to be held accountable for sustainable ship recycling beyond flag state jurisdiction.