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Proceedings of MARTEC 2022
The International Conference on Marine Technology
21-22 December 2022, BUET, Dhaka, Bangladesh
Hosted on SSRN.com
Practice of green ship recycling in Bangladesh: a study on KSRM steel ltd. 56-1
PRACTICE OF GREEN SHIP RECYCLING IN BANGLADESH: A STUDY ON
KSRM STEEL LTD.
Asma Jarin1, Ataur Rahman 2
1Department of Business Administration,
Southern University Bangladesh
E-mail: asmajarin@hotmail.com
2Bay-Tech Ship Builders,
Bangladesh.
E-mail: ata786rah@gmail.com
ABSTRACT
It is now great concern to become a conscious about environment by all sector of the county for developing
sustainable environment of production and business. This is the driving force for changing the ship recycling
process and convert the recycling process to green ship recycling. Green ship recycling is environmentally
sound and safe recycling of a ship that offers methodical dismantling of the components with better care that can
be reused; procedural capturing of the toxic and hazardous waste which poses harmful and dangerous risks to
both marine and human health, safety and finally dispose them to mitigate the risks and protect environment.
There are around 150 ship-breaking yards in the country, and most of them are still reluctant to turn into green
facilities due to the high cost involved. Most yards are reluctant to adopt the green ship -breaking standards
because of the costs associated with the process. Currently, only three other yards are trying to achieve those
standards (The Business Standard,2018). To make the ship recycling industry as a green industry, associated
risks and hazards to be minimized up to an acceptable level. Green ship recycling gives a heads up to
sustainable business practices as it reduces the CO2 emission and reduces damage to the environment. The main
objective of the research is to analyze the green marketing practices of ship recycling industry in Bangladesh
through visiting Kabir Steel Ltd. The nature of the research is descriptive and qualitative. Data are collected
through observation on Kabir steel Ltd. Kabir Group Ship Recycling practices green ship recycling fully
equipped yard with required infrastructure according to national and international regulations which do not pose
health risk to the workers and surrounding environment and hazard materials are collected by the properly
trained personnel and stored in a safe container. and workers are well trained before going to the job and
wearing PPE is mandatory before performing job. For smooth practicing of green ship recycling the ship
recycling company must ensure waste management, workers safety, conscious about environmental impact.
Key words: Green ship Recycling, Ship breaking
1. INTRODUCTION
The recycling phase or the end-of-life phase is
important in any industry and for any product that is
produced. Ships are designed, engineered, built, and
operated, maintained and recycled. The end-of-life
value of large vessels correlates highly with the price
of steel. Ninety percent of shipbreaking in the world is
carried out in Bangladesh, China, India, Pakistan and
Turkey. These potential hazards to human life and
environment make national and international
attentions and regulatory framework is being
generated by many different international conventions
and organizations. Green ship recycling is now a
requirement due to enforcement of The European
Union Ship Recycling Regulation (EU-SRR) adopted
by the European Parliament and development of The
Hong Kong International Convention for the Safe and
Environmentally Sound Recycling of Ships, 2009
(IMO HKC, 2009). The convention defines
Hazardous Material as any material or substance
which is liable to create hazards to human health
and/or the environment. Green ship recycling helps
lower the adverse impact on the environment.
The government enacted the Bangladesh Ship
Recycling Act in 2018 and asked owners of ship-
breaking yards to adopt safe and environmentally
friendly methods as per the Hong Kong International
Convention,
Most yards are reluctant to adopt the green ship-
breaking standards because of the costs associated
with the process. Currently, only three other yards are
trying to achieve those standards. India, China and
Turkey have already turned their ship recycling
facilities green as prescribed by the Hong Kong
International Convention adopted back in 2009.
Bangladesh had set a target to turn all ship-breaking
yards into green facilities by February 2023, but the
current situation poses uncertainties that this target is
achievable within the deadline. (Business Standard,
2018).
2. SCOPE OF STUDY
Most of the ship dismantling now-a-days takes
place in South Asia, on tidal beaches and under
Electronic copy available at: https://ssrn.com/abstract=4446368
Proceedings of MARTEC 2022 hosted on SSRN.com
Practice of green ship recycling in Bangladesh: a study on KSRM steel ltd. 56-2
unacceptable conditions from the point of view of
safety and environmental protection. Different types
of hazardous materials and rubbish are disposed and
spilled from scrapped ships in a way that they often
get mixed with the beach soil and sea water around.
This way of disposal has a negative impact on our
coastal environment and marine biodiversity.
Moreover physical, chemical & biological
characteristics of the area are severely degraded.
Considering this background, the serious nature and
complexity of the problem at hand, this thesis looks at
the present scenario green ship recycling through the
management of that hazardous material and rubbishes
and improvement of working condition of the
workers. Here, in this report present situation green
ship recycling of Kabir Steel Ltd. (KSRM) was
analyzed for the future possibilities, and ways to make
this facility successful.
3. LITERATURE REVIEW
Worldwide, 674 ocean going commercial ships and
offshore units were sold to the scrap yards in 2019
(NGOSBP, 2019). The steel, machinery and other
scrap metals obtained from recycling ships are the
valuable raw material and capital machinery for the
country’s industrialization. But, most of the ship
dismantling now-a-days takes place in South Asian
tidal beaches under unacceptable conditions from the
point of view of safety and environmental protection.
The rate of accidents is high, many workers contract
lethal diseases, and water, soil and coastal habitats are
heavily polluted by hazardous materials from ships.
(Ahuja, 2012).
Ship breaking activities is the process of a series of
risky tasks because of existence of enormous quantity
of hazardous substances, which pose threats to the
environment and working people. (Zakari, 2012)
identified the underlying problems of ship recycling
industry and therein analyzed the nature of the
problems aimed towards overcoming the obstacles in
Bangladesh, suggesting that well designed plan
focusing on technological, safety and environmental
issues must be ensured to avoid human causalities of
ship-recycling industry in Bangladesh. Hossain, 2015
stated that the social and environmental impacts of the
ship recycling in Bangladesh considering the positive
economical contributions and negative effects like
lack of occupational health and safety standard.
(Mmereki et al., 2016) presented the scenario of
hazardous waste management in developing countries.
He identified that in developing countries, hazardous
waste management systems lack a systematic
approach to administer waste management programs;
inability to effectively collect and manage wastes as
well as to reduce the negative impacts of those
activities.
(Du et al., 2017) presented the challenges and
solutions for ship recycling in China. He identified
that Chinese large-scale ship recycling yards have
been taking advanced practices including site
environmental protection, dismantling procedures and
technologies, and safety management in ship
recycling industry for environmental protection and
the workers’ health and safety. (Du et al., 2018)
illustrated hazardous materials analysis and disposal
procedures during ship recycling. He pointed out
practical measures and suggestions to deal with the
hazardous materials in the ship breaking yards based
on two case studies on Chinese yards about green
disposal of the main hazardous materials during
shipbreaking. (Hossain, 2015) presented the map the
supply chain of ship recycling industry, considering
the trade-offs and combinations of financial and
sustainable values that, in many ways, determine
these inter-organizational arrangements. In the ship
recycling markets, the owner who is interested in
selling the vessel usually approaches the brokers who
are familiar with various cash buyers, who purchase
end-of-life vessels for reselling to recyclers. After
several rounds of negotiations with the cash buyers,
the ship broker mediates the sale, for which he obtains
a certain percentage of value of the contract as
commission for his services. The cash buyer takes the
legal ownership of vessel and resells it to recyclers.
The ship recycling yards compliant with either the
international standards for health, safety and
environmental (HSE) management or the international
ship recycling regulations (For example, HKC and EU
ship recycling regulation) are considered innocuous to
environment, health and safety of the workers, and are
referred to as ‘green’ recycling yards in this
dissertation. The green ship recycling yards are not
very popular among a large number of shipowners
due to their inability to offer a good price compared to
substandard yards. The price gap between the two is
mainly due to the extra cost of maintaining high HSE
standards and investment in recycling facilities and
workforce welfare required for green ship recycling.
Green ship recycling is the future for the
sustainable development in this industry. The shipping
companies in Europe are now under legal binding to
go for green recycling under the new regulation
European Union -Ship Recycling Regulation (EU-
SRR) for their own ships. Regulations worldwide are
now coming enforce in regular days that in near future
all the ships might be gone to green ship recycling and
ensuring that all our ships are recycled in the most
sustainable, safe and environmentally friendly way
possible. To take that advantage, the ship recycling
industry stake holder must implement the green
marketing to attract the foreign ship owners to come
to us for green ship recycling. The researcher
basically emphasizes here the practice of green ship
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Practice of green ship recycling in Bangladesh: a study on KSRM steel ltd. 56-3
recycling for KSRM steel ltd. The green ship
recycling has the vast prospect in the ship recycling
industry. From Bangladesh perspective still there is
huge ship recycling firm not implementing the green
ship recycling and this research basically beneficial
for those firms.
4. METHODOLOGY
The nature of the research is descriptive. This study
begins by providing a theoretical background based
on which the research methodology for this work was
chosen. This study uses documents, including
newspaper reports, literature from previous research,
reports from organizations like IMO and other
relevant documents. Further, this report uses
databases from several organization like NGO
PLATFORM, UNCSAT for gathering data. The
feedback from industry received during the visit in the
industry used as a source of data collection used in
this report. All the different sources of empirical data
have been used for data triangulation i.e. to confirm
the conclusions from the different sources for
increasing reliability. Relevant data was collected
through observation and other different sources
including literature from books, journals and
magazine using internet.
5. THEORITICAL FRAME WORK
(INTERNATIONAL GUIDELINES FOR
GREEN SHIP RECYCLING)
5.1 Ship recycling legislation
The global shift of the industry from developed,
highly regulated nations towards countries with weak
regulatory and enforcement systems came calls for
international regulation to ensure the protection of
human rights standards for occupational health and
safety as well as the environment. Undoubtedly ship
recycling is a representation of ‘green’ industry. So, to
protect the future of these potential industries,
international regulations regarding Shipbreaking
should strictly be followed.
5.2 The Basel Convention (BC)
The Basel Convention covers hazardous wastes that
are explosive, flammable, poisonous, infectious,
corrosive, toxic, or ecotoxic. It represents a systematic
effort to balance the desire to ship wastes
internationally with the desire to reduce the risks to
health and the environment caused by the
mismanagement of wastes. Three elements are crucial
for the application of the Basel Convention to the
issue of shipbreaking: (i) proof that the waste will not
be properly dealt with by the shipbreaking country,
(ii) the legal recognition that ships are waste & (iii) an
established ‘intention to discard’ by the owner of the
ship (Hossain, 2006).
5.3 The Hong Kong Convention (HKC)
Following increased international criticism of the
shipping industry’s scandalous scrapping practices,
the International Maritime Organization (IMO) Hong
Kong Convention for the Safe and Environmentally
Sound Recycling of Ships (HKC) was adopted at a
Diplomatic Conference held in Hong Kong, China, in
May 2009 but the convention is not yet enforced due
to the problem of ratification. The Convention sets
standards for ship recycling and puts responsibility for
enforcement on the vessel’s flag state and the
recycling state. After the entry into force of the
Convention, the development and maintenance of an
Inventory of Hazardous Materials, which identifies
the amount and location of hazardous materials
onboard a ship, will be required for all ships over
500GT
5.4 EU SRR
The EU Ship Recycling Regulation (EU
SRR) aims to reduce the negative impacts linked to
the recycling of ships by ensuring that proper vessel
dismantling methods are used to achieve safe disposal
or recycling of all ship components, including
hazardous materials. the EU SRR sets higher
standards than the IMO’s Hong Kong Convention –
the beaching method is not allowed and requirements
related to downstream toxic waste management as
well as labour rights are included.
5.5 ILO Guidelines
To address major occupational and environmental
health problem generated from Shipbreaking, the ILO
have produced their guidelines to deal with various
issues in this area. In 2003, as part of its “Safe Work”
agenda, the International Labor Organization (ILO)
established the Safety and Health in Ship breaking:
Guidelines for Asian Countries and Turkey. The ILO
Guidelines provide direction to those who have the
responsibility to ensure occupational safety and health
in the ship breaking yards.
5.6 Bangladesh Ship Recycling Act
The Ship Recycling Act 2018 Act of Bangladesh
has mostly dealt with allocation of plots between
recyclers and constitution of the Ship Breaking Board
(SBB) which is the Competent Authority for
regulating the shipbreaking activities in Bangladesh.
As per the act, the ship recycling plan is essential
which contains two parts as the Ship recycling plan
and Ship Recycling Facility's Plan. The shipbreaking
yard must have enough space for movement while
Electronic copy available at: https://ssrn.com/abstract=4446368
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Practice of green ship recycling in Bangladesh: a study on KSRM steel ltd. 56-4
cutting ship. "Gas-free and fit for hot work" certificate
is also essential which is issued by the Department of
Explosive for avoiding accidents concerned with fire,
explosion and deficiency of oxygen. However, the
ship recyclers are required to strictly provide the
environmental compliance in line with soil, water, air
under Environment Conservation Act 1995 and other
related national environmental act or law.
6. PRACTICES OF GREEN SHIP
RECYCLING IN KABIR STEEL LTD.
The company was incorporated in the name of
Kabir Steel Limited since its incorporation in 1985
and before it was operating in the different names.
The company is developing its ship recycling facility
in compliance with the requirements of Hong Kong
International Convention HKC 2009.Now a days
kabir steel practicing green ship recycling facility by
considering some important facts.
6.1 Yard Development
The facility uses the beaching / intertidal landing
method. Primary cutting of the hull is mainly
conducted in the intertidal zone using the interior of
the ship itself as an impermeable floor. The size of the
combined working areas is approximately 35,000 sq.
m. In addition to the working areas there are office
buildings and hazardous waste and waste storage
areas. The operation on dry shore is from built
structures with cranes, winches and trucks, on
concrete flooring. The secondary cutting area around
8,000 sq. m ends in an embankment towards the
intertidal landing area. A bigger portion of the
secondary cutting area are covered with concrete, with
steel plates in designated cutting areas. Storage tanks,
storage and separation areas, storerooms and offices,
sanitary equipment, workers rest and recreation
rooms, first aid room, emergency room and
emergency chests, worker facilities, workshops and
drinking water supply were identified on site.
6.2 Yard Equipment & Facilities
Dismantled materials after the primary cutting from
the ship to shore are transported by crane, in
appropriate containers for smaller parts, without
contact with the intertidal zone. So, equipment and
facilities for cutting & transportation of parts are the
big part for complete the job. Heavy Equipment: Jib
Crane: Sufficient, Mobile Crane: Sufficient, Magnet
Crane: Sufficient, Weight bridge: Sufficient. Boat /
Barge: Boat / Barge: Sufficient, O2 supply: In Bottles,
Gas supply: Fixed CNG Supply, Compressed air:
Portable Air Compressor, Fire extinguisher: Potable
fire extinguisher/ Fire Pump, Waste oil treatment: Oily
Water Separator, Electric power supply: National
Power Grid / Stand By Generators. KSRM yard also
include: Wastes Storage, Incinerator, Bale compactor,
Shearing Machine.
6.3 Workers facilities
The facility has a worker dormitory complex on the
plot with capacity of around 100 workers. This is
primarily reserved for supervisors or persons with
positions of similar responsibility. The rooms are
furnished with beds and wardrobe lockers and
sufficient light and fan. A separated dormitory is
available within the premises for workers. The facility
has common mess room, kitchen, toilets, recreation
area and seats, drinking water plant and wash area.
The yard is providing free accommodation and food
for the workers with complimentary drinking water
and electricity. The yard has planned to improve the
living quarters of the workers with improved
ventilation and wider sleeping space additional to the
guideline set by the International Labor Organization.
(ILO)
6.4 Personal Protective Equipment Facilities
The yard has prepared a PPE matrix based on all
kinds of hazards related to specific types of works
done within the facility by the HSE manager.
Accordingly, all kinds of PPE for that specific job are
provided by the yard to all the workers engaged with
that job. A designated PPE room is assigned to storage
and monitoring of the PPE.
6.5 Medical Facilities
The yard has permanent medical center run by an
MBBS doctor with sufficient trained medical assistant
for 24 hours service. The Centre has four bed and is
suitable for treatment of minor injuries and first aid.
The center has its own ambulance which is equipped
with blue light, ambulance bed, oxygen apparatus and
first aid locker, with one dedicated employee to
maintain and drive it. The driver is trained and
qualified for emergency evacuation, firefighting and
first aid for any emergency.
6.6 Workers Training
The facility has an implemented safety induction
training and re-training scheme for new and current
employees. Subcontractors, as for migrating workers,
must register with the required training certificates
before start of work. All subcontractors are given
safety induction training before commencement.
Considering the work type aligned with work group,
the yard has identified the training need for each type
of workers and conduct in house and external training
considering the TNI and Govt. requirements. No
worker is sent for work without training.
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Practice of green ship recycling in Bangladesh: a study on KSRM steel ltd. 56-5
6.7 Management of Hazardous Materials
Many of the materials produced from the recycling
possess hazardous properties. As such they require
appropriate management throughout their life cycle so
as to minimize adverse effects on public health and
safety or to the environment generally. The approved
SRFP describes the Ship Recycling Facility's process,
control procedures and abatement methodologies used
for the removal, labelling, storage, segregation,
transport, treatment and disposal of all such
Hazardous Materials, which is already by the
government of Bangladesh. The yard has several
following storage lockers for different type of
hazardous wastes as like Asbestos Containing
Materials (ACM), Oily Water Tank, Solid Waste,
Glass Wool, PCBs, Heavy metal and Chemicals.
7. SUGGESTIVE MEASURES FOR
IMPLEMENTATION
For smooth implantation of green ship recycling the
industry must change some factors. In this research
already researcher have been discussed the current
scenario of KSRM who is practicing green ship
recycling in their current infrastructure .But in real
sense green ship recycling needs more modification in
the infrastructure, process and management system
because of uneducated workers ,the yard owners are
not about the green ship regulation and lack of safety
precautions. In general, the ship recycling yard
doesn’t have a proper standard operational procedure
The following alternative measures should be
enforced during the practice of green ship recycling
by the authors:
Facility Management: For making green ship
recycling the ship breaking firm should develop clear
job description and worker responsibility through
proper training. Should also develop a written
procedure contains the proper way for acceptance of
ship and describe the procedures to be implemented
before ship arrives
Technical and IHM survey: For green ship recycling
the owner should prepare the brief technical and IHM
survey for the purpose of identifying the type,
location and quantity of any hazardous materials and
for making and/or labeling. All items should be
clearly marked in an easily identifiable manner. In the
preparation step includes sea and soil pollution. For
example, the installation of oil boom top prevents oil
spill.
Waste and Hazmat treatment: Ship recycling
activities are divided into three zones; offshore, inter-
tidal, and onshore. The recycling process consists of
several steps, such as cleaning, de-coating, cutting an
additional process such as hazmat and waste handling.
The HAZMAT can be found in various sections of a
ship such as; paint, insulation materials, toxic cargo
and fuel residues, etc. (Faria et al, 2019). The hazard
materials and waste should be applied after
segregation and wastes are handled environmentally
sound manner. It is necessary to ensure that all
categories of recycling yards hire enough certified
asbestos handlers. (b) Materials identified with the
dangers of PCBs and ODS should be handed over to
the approved vendors. In Bangladesh, the number of
authorized vendors is minimal, and as a result, some
yards adopt the process of landfills which is not done
by maintaining a proper plan. (Mehtaj,.etl, 2022). So,
Develop the ship recycling plan (SRP). For
implementing green ship recycling the ship breaking
company must make pretreatment before cutting and
incorporating HAZMAT and waste management
facility. It is also necessary to conduct a survey for
Hazard Materials by assigned person and ensure the
treatment of waste management in sound manner.
Workers Safety and health compliance approach :
Investigation of occupational noise exposure in a ship
recycling yard showed that ship recycling workers are
at risk of experiencing occupational noise and there is
a lack of appropriate hearing protection being used in
ship recycling yards (Kurt et al., 2017).Green ship
recycling implantation achieved by worker’s health
and safety plan, preparing job hazard assessment
document, ensure Safe-for-hot-work and safe-for-
entry Procedure and supplying proper personal
protective equipment for workers.
Develop the environment monitoring program: By
establishing safe and environmentally sound ship
recycling yards which are compliant with
international regulations. (Faria et al,2019). This
program aimed at prevent environmental pollution
and negative ship recycling impact on
environment .These Possible negative impacts during
ship recycling may be divided into four main
categories: 1. Releases of Hazardous Materials to
ground and sediments; 2. Releases of Hazardous
Materials to water; 3. Emissions of Hazardous
Materials to air; and 4. Noise/vibrations.
Final report is completion report is issued with main
particulars of ship recycling; qualification certificate
of ship recycle yard. For proper green ship recycling
the statement of completion of ship recycling,
qualification certificate of Ship Recycle Yard and
Sub-contractor, inventory of hazardous material
handled and reported to Competent Authorities.
In addition, the related ministries (ministry of
transportation, ministry of industry, ministry of
environment) should be prepared for the guideline
because there are lack of guideline and contradicting
regulation between among the ministries.
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Practice of green ship recycling in Bangladesh: a study on KSRM steel ltd. 56-6
8. CONCLUSION
The study represents the current scenario green ship
recycling for ship recycling industry from Bangladesh
perspective in reference to KSRM ship recycling. This
is basically a new movement for ship recycling
industry. By observing the Bangladeshi shipping
industry, it is found that the ship owners are unaware
about the green ship recycling for their recycling
activities, basically workers safety. Occupational
health and safety have been a highly discussed and
controversial topic within the ship recycling industry.
In the past, a public image of secrecy, stubbornness
and an overwhelming reluctance to change has been
felt by the international community from the ship
dismantling industry (Kurt et al, 2013). For green ship
recycling the firms are still unconscious the
environmental impact during cutting and after cutting
of ship. The major problem is that the use of beaching
method during ship recycling in Indonesia without
regarding health and safety, and environment aspects
(Makbul, 2010). At the end of a ship’s life cycle, the
ship contains not only various recyclable materials but
also a range of hazardous materials (HAZMAT) and
toxic substances (Krause, 2005). If the all firms of this
industry are conscious about above matters, then the
industry can capable to ensure proper practice of
Green Ship Recycling for ship recycling.
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