The main defect of form is in the absence of a legal concept that embraces the term waste "end of life vessel". As adopted in the workshop of the member states in Lisbon and it is stated in the Hong Kong agreement, it is not only waste, but it is dangerous waste, and therefore it must apply for transboundary movement of residues, but, as there is no figure of residue " end of life vessel ", some member states decide to consider it as an “end of life vehicle” (which has been requested a written confirmation without success to countries like Portugal or Spain), others consider it as a "container" of various classified hazardous waste (ex. Belgium or the Netherlands) or as an "unlisted" residue (United Kingdom).This implies the absence of a legal term that embraces the authorized waste manager of " end of life vessels".
On the other hand, the competent authorities do not have a single criterion, clear and unambiguous on its procedures. In Spain, specifically in Galicia, it was confirmed to us that this was the first time they encountered this type of processing, although more than 400 vessels have been sent for scrapping in recent years. Among some EU countries no arrangements are asked for, others ask for way too much paperwork (as a normal move of hazardous waste). An atypical and non-formal assessment that becomes complex and for which the recycling of ships in various facilities, like the project Recyship, are blocked.
According to EC Regulation 1013, this processing requires a waste producer, which would be the Port Authority (in the case of abandonment), that at no time act as responsible for "their waste", or the owner, which is never considered as responsible (this ends up being the shipbreaker). It requires a transport / tug authorized to transport hazardous waste and requires an authorized agent for the management of the residue, figure that does not exist. Also needs a management cost estimate that, again, does not exist (the project Recyship aims to establish this calculation). Finally indicate that this regulation is proposed for normal transportation of waste: ie. is based on having a constant source of one type of waste, a constant method or means of transport, and a fixed destination for the waste produced. For this it demands a permanent permit, process that takes about 3 months and then the transfer only requires communications each time you will make another move (10 days for processing). Obviously, ships for scrap are located in many ports and locations, so any transfer of a ship "always" requires a long and tedious processing (something unsustainable for any industry).
Our experience during the Project Recyship
In the specific case of the Recyship project, the original producer were the different Port Authorities, which have never been involved nor have considered the vessel as waste, or "sell" them as waste. The transport was going to be done by tug companies that carry the vessels as ships and not as waste. And finally, the receiver of the waste is a repair yard that, while fully licensed for waste production but that has no residue management license yet (although granted after other practically eternal process), complies fully with everything you need to manage these wastes unlike the majority of "scrapping yards".
The first problem was that, unlike normal transfers, the producer of the waste here is never the same, only the receiver is constant. This forces that every time you want to move a ship, you must perform a process that takes more than 3 months, which is unsustainable for any installation.
The second problem has been that, since there is no figure of manager of ships out of use, and that the administration did not accept that the plan was to conduct a study for a project (because they only allow this for no more than 25kg of waste), had to get a license for hazardous waste management (end of life vehicles), a process that takes another 3 months, and for which finalisation we are waiting still.
The third problem was that during the summer, however, we have followed and watched how several vessels have been sold and moved to different scrap yards without any problem, consideration and, of course, administrative procedure for the transfer of waste.
With this situation, we are in October, pending various administrative rulings that may allow us to proceed with the project.
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