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.

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.