Shri G K Vasan
Union Minister of Shipping
Government of Inda
Subject-IMO Policy of Dumping Hazardous Ships on Alang Beach & European Double speak
This is to draw your attention towards the anti-environment and anti-labour stance of the recently concluded 4th TradeWinds Ship Recycling Forum that was held in Singapore during 12-13 March 2012, the Steel Scrap Summit held on February 9, 2012 in Gurgaon, IMO’s Marine Environment Protection Committee (MEPC), 63rd session held during February 27 - March 2, 2012 and the views of Shri Julio Garcia Burgues,Head of the Waste Management Unit. European Commission – DG Environment revealed in the letter of Shri Rajgopal Sharma, Advisor, Indian Embassy, Brussels dated December 20, 2011. It is revealed in the letter that most of the 200 dead and hazardous ships that are currently at Alang beach are in illegal traffic.
I submit that a letter dated December 22, 2011 sent by your ministry annexed Shri Sharma’s letter. He has sent a report on his conversation with Shri Burgues in the matter of ship breaking in India. The letter to the fact that 17 % of the international merchant fleet is flying EU flags and when after 25 years they become obsolete, most of them are transferred to Indian waters because of weak shipping, occupational and environmental health and regulations.
This letter reveals that “The EC (European Commission) is of the view that at present, most of the trade for recycling (dismantling) is illegal considering the provision of Regulation No. 1013/2006.” This regulation refers to EU Waste Shipment regulation. Although International Maritime Organisation (IMO)’s Ship Recycling Convention drafted and adopted in Hongkong at the behest of ship owning companies and developed countries is unlikely to be ratified by India due to resistance from industry groups and environmental groups, Shri Sharma’s letter shows that “the EC proposes to have a new regulatory regime based on key requirements of IMO Hongkong of 2009 on ship recycling (dismantling)”.
I submit that this conversation appears to be linked to the negotiations underway for India-EU Free Trade agreements.
I submit that NGOs and trade unions from Europe and US do not represent the migrant workers at Alang beach, Bhavnagar, Gujarat and the environmental health concerns related to ongoing pollution of the beach and other ports. The Northern civil society groups have co-opted the Southern civil society space by paying lip service with ulterior motives in furtherance of the cause of their funders.
I submit that on December 20, 2011, Shri Burgues informed Shri Sharma in Brussels that all the dead ships which come to India and other ship breaking states are illegal under European Commission's EU Waste Shipment Regulation, 2006 and in order to legitimize the same, EC has plans to start the process of diluting and amending its Regulation from April 2012 onwards. This insincerity and double speak of EC reveals that EC is under tremendous influence of ship owning companies so much so that it has chosen not defend its own Regulation. It plans to downgrade its Regulation to make it compliant with yet to be born Hong Kong Convention. The fact is that the Convention is unlikely to take birth because ship breakers and environmental groups in India, Bangladesh and Pakistan are bitterly opposed to it.
I submit that EC under the influence of companies feels that it is one of the ways to support its contracting economy and prolonged recession besides secretly signing free trade agreements with developing countries like India, Bangladesh and Pakistan.
It appears that economic crisis in Europe has turned environmental NGOs there to become nationalists and compelled them pay lip service to environmental and occupational health concerns in South Asia. IMO and its masters, the ship owners must be quite glad at the turn of the events.
I submit that the hollowness of proposed Guidelines for safe and environmentally sound ship recycling se guidelines, along with the Guidelines for the development of the Inventory of Hazardous Materials and the Guidelines for the development of the Ship Recycling Plan can be gauged from the fact that they are voluntary improvements meant to meet the requirements of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, which was adopted in May 2009 amidst opposition from labour, environmental and industry groups from South Asia.
I submit that Dr Nikos Mikelis, Head of the Marine Pollution Prevention and Ship Recycling Section of IMO’s statement, it was "neither logical nor ethical to stop sending ships to South Asia" has been made at the behest of European and Japanese ship owners demonstrating complete disregard to the fragile coastal environment of Alang beach, which has been heavily contaminated and it is crying for remediation.
I submit that the steps being envisaged by DG Environment's Office of the European Commission for a new EU Regulation in place of EU Waste Shipment Regulation currently being finalised in Brussels is diluting the latter to fine-tune European law with the regressive Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships that allows ship owners and ship breakers to pollute the South Asian beaches of Alang, Chittangong and Gadani in India, Bangladesh and Pakistan. In India, progressive steps like the ones taken in the matter of Sachana shipbreaking plots in Jamnagar district, Gujarat by its closure as per the order of Gujarat government merits attention.
“The ship-breaking is termed illegal because this breaking activity is going on in the water of Marine National Park. Unless and until, Government of India gives permission, such activity cannot be carried out in the Marine National Park area because Marine National park Jamnagar is a important sanctuary where marine life of excellent quality live,” states the order dated 22-11-2011 from the Office of Chief Forest Conservator “to cancel the plots allotted of Sachana ship braking yard. These plots are in the land of Forest/Marine Sanctuary”.
The order concludes, “GMB has never taken the official permission for the ship-breaking activity. Whatever activity is carried out by GMB is the violation of the rules of Marine National Park. So this activity must be stopped until the permission is granted. GMB must be careful regarding this. If they continue this activity, it will be violation of the rules and the authorities of GMB will be personally responsible for this violation. GMB has never taken the official permission for the ship-breaking activity. Whatever activity is carried out by GMB is the violation of the rules of Marine National Park. So this activity must be stopped until the permission is granted. GMB must be careful regarding this. If they continue this activity, it will be violation of the rules and the authorities of GMB will be personally responsible for this violation.”
The order reads, “Because of ship-breaking, harmful objects like arsenic, mercury, asbestos, oil, etc could harm marine life in the long time. This leads to complex problems for protecting and conserving the Marine National Park and Marine sanctuary.”These observations are quite relevant for the ship-breaking operations on Alang beach, Bhavnagar as well. IMO’s MEPC is meant to protect marine environment but its Hong Kong Convention is supporting status quo of ongoing pollution on South Asian beaches even as European beaches are fiercely protected. It is a classic case of double standard.
I have learnt that Parliamentary Standing Committee on Transport, Tourism and Culture is examining this matter.
In view of the above, I submit that IMO’s Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships that was adopted in May 2009 is unsafe, unsustainable. Government of India must realize that it is the child of ship owning companies of Europe and Japan and desist from signing or ratifying it.
I will be happy to share relevant papers in this regard.
ToxicsWatch Alliance (TWA)
Phone: +91-11-2651781, Fax: +91-11-26517814
Union Minister of Environment & Forests
Union Minister of Steel
Union Minister of External Affairs
Union Minister of Commerce & Industry
Chairman, Parliamentary Standing Committee on Transport, Tourism and Culture
Banning the bomb, smashing the patriarchy: Ray Acheson’s must-watch TED Talk - Ray Acheson challenges the foundation of international security to raise one simple question: do nuclear weapons really keep us safer? Her ambition: show...