Kishorn Application 50 - Site Inspection Report - 0

A SHIP RECYCLING FACILITY IN UK
Site Assessment Report –

Application 50
European Commission Directorate-General for the Environment
Report No.: 2022-0220, Rev. 0

Date: 2022-02-21
Project name: A ship recycling facility in UK DNV AS Maritime
Report title: Site Assessment Report – Application 50 Environment Advisory
Customer: European Commission Directorate-General for the Veritasveien 1
Environment, 1363 Høvik
Customer contact: Norway
Date of issue: 2022-02-21 Tel:
Project No.: 10306030
Organisation unit: Environment Advisory
Report No.: 2022-0220, Rev. 0
Applicable contract(s) governing the provision of this Report:
Objective:
To document the results of the site inspection at Kishorn Port Limited, located in Kishorn (Scotland, UK) following the
facility's application for inclusion in the European List of ship recycling facilities.
Prepared by: Verified by: Approved by:
Principal Consultant Principal Consultant Head of Section
Copyright © DNV 2022. All rights reserved. Unless otherwise agreed in writing: (i) This publication or parts thereof may not be copied, reproduced or
transmitted in any form, or by any means, whether digitally or otherwise; (ii) The content of this publication shall be kept confidential by the customer; (iii)
No third party may rely on its contents; and (iv) DNV undertakes no duty of care toward any third party. Reference to part of this publication which may
lead to misinterpretation is prohibited.
DNV Distribution: Keywords:

☐ OPEN. Unrestricted distribution, internal and external. Ship recycling, ship recycling facility plan,
☐ INTERNAL use only. Internal DNV document. hazardous waste, waste management, health,
☐ CONFIDENTIAL. Distribution within DNV according to applicable safety
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☐ SECRET. Authorized access only.
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Rev. No. Date Reason for Issue Prepared by Verified by Approved by
0 2022-02-21 First issue mardav eifre tsv
DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com Page i

Table of contents
1 EXECUTIVE SUMMARY................................................................................................................................... 1
2 INTRODUCTION ............................................................................................................................................... 2
3 OBJECTIVE ...................................................................................................................................................... 2
4 SCOPE OF WORK ........................................................................................................................................... 2
5 METHODOLOGY AND ACTIVITIES ................................................................................................................. 4
6 RESULTS OF THE ASSESSMENT .................................................................................................................. 5
7 PHOTOS FROM INSPECTION ....................................................................................................................... 29
DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com Page ii

1 EXECUTIVE SUMMARY
The objective of this report is to document the results of the site inspection at Kishorn Port Limited (Kishorn), located in
Scotland, UK, following the facility's application for inclusion in the European List of ship recycling facilities. The on-site
inspection took place on the 8th and 9th of February 2022.
During the site inspection, the applicant demonstrated their management and execution of ship recycling performed at
their facility, together with their interaction with relevant governing authorities.
The applicant appears to have a well running facility, has procedures with regards to health and safety and has in place
facilities which one would expect for a facility applying for inclusion in the European List of ship recycling facilities.
The facility is utilised by primary contractors who are responsible for the recycling projects being executed. The facility
performs a thorough evaluation of all primary contractors in advance of recycling project to ensure that the facility’s
requirements with regard safety, health, environment and quality are met. Throughout the recycling projects there is
daily collaboration between the primary contractor and the facility, and the facility performs regular inspections of the
recycling operations to verify compliance with the agreed methods.
Primary contractors were present during the site inspection and provided verbal and documentary evidence of their
competence, qualifications, training, planning, execution and record keeping.
The governing document for the site inspection, defining the baseline of the facility’s performance, is the Ship Recycling
Facility Plan (SRFP). A principal task of the site inspection was to verify that the SRFP is a living, logical and systematic
document accurately reflecting the operational practices at the facility.
Based on the site inspection and additional information received from the applicant, the evaluators find that the applicant
fulfils the relevant requirements of the EU Ship Recycling Regulation.
DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com

2 INTRODUCTION
The European Commission DG Environment (hereafter referred to as The Commission) has contracted DNV to conduct
a site inspection of the recycling facility Kishorn Port limited, located in Scotland, UK, hereafter referred to as the
Facility. An application for inclusion in the European List of ship recycling facilities has been registered for this facility
under application number 50.
3 OBJECTIVE
The objective of the on-site inspection is to verify compliance of the facility with the requirements set out in Article 13, 15
and 16 of the Ship Recycling Regulation and clarified in the 2016 Technical guidance note1.
Hereunder the objectives of DNV’s methodology is to:
• Verify the Facility’s capability to comply with the regulations and requirements listed in the assessment scope
• Assure that documented recycling processes, work procedures, quality controls and document handling are
managed and implemented as specified in the regulations and requirements
• Ensure that the Facility has sufficient knowledge and understanding of the regulations and requirements for
recycling facilities
• Assure consistent evaluation of facilities on equal terms
4 SCOPE OF WORK
The scope of the assessment is, according to contract:
• Ship recycling regulation (EU) No 1257/2013
• Technical guidance note under Regulation (EU) No 1257/2013 on ship recycling
This inspection also considered article 13(1) of the Ship Recycling Regulation: "In order to be included in the European
List, a ship recycling facility shall comply with the following requirements, in accordance with the relevant Hong Kong
Convention provisions and taking into account the relevant guidelines of the IMO, the ILO, the Basel Convention and of
the Stockholm Convention on Persistent Organic Pollutants".
The scope for the assessment methodology is divided into three main elements and a number of second and third level
sub-elements. These practical steps ensured that all article 13, 15 and 16 SRR requirements for inclusion of a ship
recycling facility in the European List were checked.
1. Management
• Facility business model and quality statement
• Policy
• Management, ownership and organisation
• Quality assurance systems and certificates
• Human resources (availability, skills and experience, training, stability etc.)
1 C/2016/1900, Communication from the Commission — Requirements and procedure for inclusion of facilities located in third countries in the European List of ship
recycling facilities — Technical guidance note under Regulation (EU) No 1257/2013 on ship recycling.

2. Safety, security and the environment
• Safety & health (PPE, hazardous materials, fire safety, medical services etc.)
• Security
• Environment (spills, emissions, etc.)
• Emergency preparedness and response (fire, medical, environmental etc.)
• Regional conditions (acts of nature, political, etc.)
3. Vessel demolition
• Applied rules, regulations and internal standards
• Recycling control, inspection and supervision regime
• Non-conformities and corrective actions
• Document control
• Facilities (methods, capacities, condition of equipment, logistics, etc.))
• Maintenance
• Recycling planning and execution
• Methodology, criteria and performance regarding:
- Project start-up, commercial process etc.
- Ship Recycling Facility Plan (SRFP)
- Contract review, verification and acceptance criteria owner / cash-buyer / facility
- Pre-planning
- Vessel preparation (IHM, Ship Recycling Plan, flag state clearance, pre-cleaning etc.)
- Vessel arrival and securing
- Demolition management (methodology, “safe for entry”, “safe for hot work”, working at heights, lifting,
supervision and reporting)
- Waste disposal (sorting, sub-contractors, end users)
- Completion instruction
- Project close-out with de-briefing, lessons learned, suggestions for improvement

5 METHODOLOGY AND ACTIVITIES
The methodology followed the framework of DNV’s facility assessment protocols and reporting formats, calibrated with
the requirements and criteria of the Ship Recycling Regulation as clarified in the 2016 Technical guidance note.
Activities:
- Preparations, scheduling, travel arrangements, fact-finding, etc.
- Issue objective, scope and schedule to facility in advance
- Site assessment (2 days; 3 assessors)
- Reporting
- Issue of draft report
- Implement comments to the draft report
- Final report
The on-site assessment was performed according to a schedule advised to the Facility in advance, incorporating:
• Opening meeting
- Introductions, present objective, scope and methodology, agree on schedule
- Review of facility history, current activities, future ambitions
• Interviews with key responsible personnel in all relevant disciplines, including
- Ownership and management
- Contracts
- Planning, preparations, vessel arrival and securing
- Quality assurance, quality management systems
- Human resources
- Health, safety, security and environment
- Vessel dismantling management
- Quality control, document control
- Project management
• Document review
- Spot checks and evaluation of consistency, content, validation and language. Traceability
• Facility site inspection
- Inspection of Facility, all workstations and worker facilities
- Inspection of vessel, for access and escape-ways
- Spot-checks of worker certificates and permits, crane certificates
- Lifting equipment, fall barriers, safe for entry, safe for hot-work etc.

- Questioning (brief) of foremen / supervisors on key procedures
• Closing meeting
- Reiterate the objective of the inspection and present preliminary results in way of initial observations and
findings
- Facility may respond to the initial results, and agree to rectify non-conformities including deadlines and
corresponding responsible persons
- Acknowledgements and departure
6 RESULTS OF THE ASSESSMENT

The site inspection of the facility was carried out on the 8th and 9th of February 2022 at Kishorn Port Limited, located in
Kishorn, Scotland, UK.
The Facility is located by the Loch Kishorn which is a sea loch in the north-west Highlands of Scotland. Kishorn used to
be a fabrication yard for oil platforms and other offshore facilities, with an associated port and dry-dock facility.
Leiths and Ferguson Transport have created a new joint venture company, Kishorn Port Limited, which will use the dry
dock for recycling of vessels, while other parts of the facility is planned for manufacturing to the offshore renewables
industry.
The facility has major port developments planned, including extending the dry-dock to be able to accommodate vessel
up to 250 meters of length. The facility had a few full times employees at the time of the site inspection. The operation of
the facility will rely heavily on licensed contractors for all aspects of the recycling process.
The main representatives from the facility during the inspections were
and all from Kishorn Port Limited. In addition, (Marine
Consultant), ) and participated in parts of the
inspection.
The evaluators from DNV were and .
The evaluators have previously, in connection with a separate assessment, held an online meeting with the national
authority Scottish Environmental Protection Agency (SEPA) on 11th May 2021.
The table below summarises the results of the site inspection with respect to article 13, 15 and 16 of the SRR
requirements for inclusion of a ship recycling facility in the European List.
DNV wishes to thank the management and key personnel at Kishorn Port Limited for the friendly reception and good
cooperation and assistance during the inspections, ensuring that we were well cared for and that everything went
smoothly. The facilities for the assessment were excellent and the fullest degree of access to all aspects of the facility’s
areas and management was offered.

Site inspection results Compliant?
Article 13-1 (a) it is authorised by its competent authorities to conduct ship recycling operation
Technical
guidance note Authorisation The facility is authorised to conduct ship recycling operations by the national authority Scottish Compliance was
2.2.1, Environmental Protection Agency (SEPA). confirmed during the
MEPC 210(63)
Section 3.2.2
inspection.
Article 13-1 (b) it is designed, constructed and operated in a safe and environmentally sound manner
Technical
guidance note Measures and The facility uses the dry-dock method for ship recycling. Once in the dry-dock the vessel is contained Compliance was
2.2.1 infrastructure within an impermeable floor with drainage. Dismantled materials from the vessel are stored in the dry- confirmed during the
dock before it is transported out. For the first dismantling project, scrap steel was loaded to a vessel inspection.
transporting the steel directly to the steel mill.
The FPSO was laid up in the dry-dock during the site inspection and the dry-dock was
flooded.
No dismantling were taking place during the inspection; hence the evaluators did not witness any lifting
of cut materials nor the transfer of any waste materials. It was however perceived during the site visit
that the facility’s shipyard operating methods were comparable with those encountered at other UK
shipyards.
The site was found well maintained in good service and with clean conditions. Attention to safe
working standards appears to be a focus point for both the facility and its contractors.
Article 13-1 (c) it operates from built structures
Technical Operates from built The facility will use the dry-dock method for ship recycling. The operations are performed from built Compliance was
guidance note structures structures, with cranes. confirmed during the
2.2.4 inspection.
The facility will hire in cranes with the lifting capacity to satisfy the needs of individual projects. The
facility had a crane on-site with 100 tons capacity, which was found well maintained in certified order
with the updated service and maintenance records.
DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com Page 1

A FPSO undergoing repair work was in the dry-dock at the time of the inspection.
The solid and clean environment seems to confirm good implementation of working orders and safe
practices.
Article 13(1) (d) it establishes management and monitoring systems, procedures and techniques which have the purpose of preventing, reducing, minimising
and to the extent practicable eliminating health risks to the workers concerned and to the population in the vicinity of the ship recycling facility, and adverse
effects on the environment caused by ship recycling
Technical
guidance note General The evaluators find for operations in the dry-dock that the physical infrastructure lessens the potential Compliance was
2.1.4 (a), (b) impact on the environment with regards soil and sediment. confirmed during the
MEPC210(63)
inspection.
Section 3.4.1 / The applicant has conducted ground water monitoring and commissioned a company to prepare an
BC TG 6.2
ecological survey report, including otter, pine marten and badger.
The facility has forwarded a Site Monitoring Plan in SHEQ09.4 10/10/21 and price quotes from
Derwentside Environmental Testing Services Ltd (DETS). This company is part of the Suez Group and
is accredited to analyse all relevant parameters.
Noise The facility has previously contracted the company to conduct noise measurements. The Compliance was
report is titled ‘Assessment of the Environmental Impact of Noise, Kishorn Port and Dry Dock, confirmed during the
Highland’. This measurement was conducted prior to any demolition on-site, but with the quarry in full inspection.
operation.
The Site Monitoring Plan in SHEQ09.4 10/10/21 describes the noise monitoring adequately on page
10. Noise monitoring will be conducted as per SHEQ79 Scheme of Noise Monitoring which details the
sampling and set locations around the perimeter and out with the dry dock at certain sensitive
receptors across the Loch. Appendix 2 shows sampling point locations. All equipment used is
reportedly externally calibrated.
Air The Site Monitoring Plan in SHEQ09.4 10/10/21 describes the dust monitoring adequately on page 8. Compliance was
confirmed during the
Dust sampling pads will be installed for 14 days prior to a project being undertaken, to provide an
inspection.
understanding of background dust levels. When potentially dusty activities are ongoing, the sampling

pads will be changed and analysed every 14 days. The sample interval may be reduced if required, in
the event that high emissions are suspected, or if complaints are received from the local community.
The dust sampling pads will be sent back to the supplier's laboratory for analysis. Results will be
compared to the background dust levels, and if the dust loading is higher than background, the
direction of the dust loading will be considered to identify the source, so that appropriate improvements
to dust management can be made.
Dust will also be included on the Environmental Walk Round check list to allow prompt action to be
taken. Complaints or incidents regarding dust will be investigated and recorded in the facility’s non-
conformance log.
Where required water spray dust suppression will be utilised sparingly, to minimise solids entering the
facility’s drainage system.
Water The facility conducted ground water monitoring in 2017 to establish groundwater quality. The facility Compliance was
contracted the third-party . The results showed that the groundwater had good quality. confirmed during the
inspection.
The applicant will reportedly sample the surface drainage system in the start and end of each project.
In addition, additional sampling may be taken if there were to be a loss of containment or similar event
that could lead contaminated water entering the surface system.
All trade effluent in the bunded work area is collected and pumped into storage tanks and transferred
to an appropriate licensed waste receiver and sent for disposal.
The surface water (rain water) from outside the bunded work area will be pumped into the settlement
tank and through the interceptor, where under the General Binding Rule 28, under The Water
Environment (Controlled Activities) (Scotland) Regulations 2011, it will be discharged. The applicant
has forwarded engineering plan of settlement tank, interceptor and outfall.
Soil The facility has described that due to the design of the site and that the decommissioning / dismantling Compliance was
will be carried out on impermeable base of the dry dock, it is highly unlikely that any contaminates will confirmed during the
be able to reach any unmade area of the site, however to confirm this, samples of soil will be taken inspection.

from various points around the site during and after any project, under the guidance of
and sent to their Laboratory for analysis.
The evaluators agree that it is unlikely that any contaminates will be able to reach soil as the operation
is conducted in an impermeable floored dry-dock.
Sediment The facility has described that due to the design of the site and that the decommissioning / dismantling Compliance was
will be carried out on impermeable base of the dry dock, it is highly unlikely that any contaminates will confirmed during the
be able to reach the sediments. inspection.
The facility has described that samples of sediment will be taken from the water channel base and
from the settlement tank after any project under the guidance of
and sent to their Laboratory for analysis.
The evaluators agree that it is unlikely that any contaminates will be able to reach sediments as the
operation is conducted in a dry-dock. Should the operation on-site change, e.g., if any cutting will be
performed above water, sediment sampling would then be expected.
Technical
guidance note Health The contractors actively involved in recycling, , conduct Compliance was
2.1.4 (b), regular medical monitoring of their employees. The facility also conducts health monitoring of its confirmed during the
employees. inspection.
Medical surveillance is performed annually, by a doctor, in accordance with health and safety at work
regulations. Records are held in secure personnel files. An example was forwarded upon request and
found in order.
2.1.4 Technical
guidance note ISO / management The facility is ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018 certified by , an Compliance was
2.1.4 (b), MEPC system / QMS Accreditation Services for Certification Bodies (ASCB) accredited provider of management systems confirmed during the
210(63) 3.1.1 (5),
certification. inspection.
(7) and (8).
Document control is conducted with the necessary revision and approval dates, management
signatures and other formalities were found in order.

ILO SHG p21-23,
p138:18.1, 18.3, Workers facilities The applicant has welfare facilities on-site. The welfare facilitates can accommodate up to 128 Compliance was
p139:18.5 persons. The welfare facilities include toilets, showers and wardrobes and were found in good confirmed during the
condition. inspection.
The canteen serves three meals a day and was found in good order. Drinking water is available.
In their HSE Policy document it is stated that “Smoking is strictly prohibited in the workplace.”
Article 13 (1) (e) it prepares a ship recycling facility plan

Technical
guidance note SRFP The SRFP is the cornerstone document of the ship recycling facility and should fully describe the Compliance was
2.1.2 operations and procedures that are in place at the facility to ensure compliance with the EU Ship confirmed during the
Recycling Regulation. inspection.
The SRFP, dated 24.01.2022, is found to cover the key chapters required, and that the description of
the methods employed is clear and logical.
MEPC 210(63)
Section 3.1.1 (1) Ownership Kishorn Port Ltd is a joint venture company by Leiths (Scotland) Ltd. and Ferguson Transport. The desk assessment
showed compliance with
this point.
MEPC 210(63)
Section 3.1.1 (3), Facility organisation An updated organisation chart was forwarded in ‘8. SHEQ27.4 KPL Organisational Chart’. The facility Compliance was
(4) organization was found to represent the organisation at the time of the site inspection. The head of confirmed during the
SHEQ is responsible on-site with different roles reporting to him, including the contractors for cutting inspection.
operations.
MEPC 210(63)
Section 3.1.1 (4) Roles and Based on the provided information, the evaluators find that the applicant has provided an adequate Compliance was
responsibilities overview of the roles with transparently delegated responsibilities at the facility. confirmed during the
inspection.
MEPC 210(63)
Section 3.1.1 (6) Policy The facility has a SHEQ Policy Statement in the SRFP page 24. The policy is for the facility’s overall Compliance was
operations, and not ship recycling specific. confirmed during the
inspection.

Working hours and According to a sample contract forwarded by the facility, core working hours are Mon-Fri 8am-6pm. Compliance was
annual leave Working hours must reportedly be registered on the time sheet to show the overtime and the workers confirmed after the
are compensated according to the requirements of the Working Time Regulations 1991. inspection.
The annual holidays for full time employees are 28 days. This includes Christmas Day, New Year’s
Day and all bank and public holidays.
The facility will have an extensive use of contractors and sub-contractors on-site. Fair labour rights are
vetted as part of the evaluation of sub-contractors (Decommissioning Contractor & Sub-Contractor
Audit Stage 1).
Contracts and A sample contract of employment was provided to the evaluators. Compliance was
minimum wage confirmed during
inspection.
MEPC 210(63)
Section 3.1.1 (7) Instructions and Working instruction, warning signs and posters are clearly visible at working places. Posters with basic Compliance was
procedures information and daily instructions are displayed in the reception area of the Main Building. Safety confirmed during
Posters and reminders were found well displayed in appropriate work-locations. inspection.
The instructions and procedures presented by the facility are of good quality.
MEPC 210(63)
Section 3.1.4 Project management Project management including progress monitoring is performed by the SHEQ. Compliance was
progress reporting confirmed during
inspection.
Article 13 (1) (f): it prevents adverse effects on human health and the environment, including the demonstration of the control of any leakage, in particular in
intertidal zones;
Technical
guidance note Intertidal zone The applicant has stated that all recycling operations are performed in the dry-dock. The dry-dock floor Compliance was
2.2, 2.2.1, p8: is impermeable and is equipped with a fully encompassing drainage system. The facility demonstrated confirmed during the
footnote (26), Control of leakage
2.2.2 (f), MEPC
sound management of preventing adverse effects to health and environment. inspection.
210(63) Section Preventive actions
3.4.4.3/BC TG:
p13: Table 1,
p33: Table 5,

p44: 4.1 / ILO
SHG: p65:
7.2.4.4
Article 13 (1) (g) (i); the containment of all hazardous materials present on board during the entire ship recycling process so as to prevent any release of those
materials into the environment; and in addition, the handling of hazardous materials, and of waste generated during the ship recycling process, only on
impermeable floors with effective drainage systems;
Technical
guidance note Cutting areas The dry-dock was flooded at the time of the inspection, and thus the condition of the surface could not Compliance was
2.2.2, MEPC be sighted during the inspection. Based on information and photos received it is seen that primary and confirmed during the
210(63) Section
3.3.4.3 / BC TG:
secondary cutting is performed in the dry-dock only. inspection.
p78ff: 5.3, p67:
figure 6 Steel work is said to be lowered down to the dock floor for cutting into smaller sections mainly by
shear. The small sections are lifted onto trucks in the dry-dock. For the first dismantling project, the
facility loaded steel directly onto a ship by the dock gates.
Technical
guidance note Drainage The dry-dock was flooded at the time of the inspection, however the drainage system for the dry-dock Compliance was
2.2.2, is well described in the SRFP. confirmed during the site
MEPC210(63)
inspection.
Section p34: The applicant has forwarded additional information of the drainage system in ‘Engineering Plan Site
3.4.4.1
Drainage’, ‘Photos to support Document Dry Dock Base and Surface Water Drainage’ and ‘The Dry
dock base and surface water drainage information’ which appears to be adequate.
Technical
guidance note Waste and hazardous The applicant describes extensive use of sub-contractors for removal of waste, such as Compliance was
2.1.4, 2.2.2, waste storage This company will remove the waste and transport it to the waste management confirmed during the
2.2.3, 2.2.5, 3.5,
facility. If storage on-site is required temporarily, e.g. in the event of large quantities, it is understood inspection.
MEPC 210(63)
Section 3.4.2.5 / that storage in adequate containers will be provided by e.g.,
BC TG 3.1, 3.3,
3.4.3, 4.1, 5.1,
5.2 (Zone D), 5.3
(Zone D), p92,
Table 11

Article 13 (1) (g) (ii): that all waste generated from the ship recycling activity and their quantities are documented and are only transferred to waste management
facilities, including waste recycling facilities, authorised to deal with their treatment without endangering human health and in an environmentally sound
manner;
Technical
guidance note Waste management It is a requirement that all wastes generated from the ship recycling activity are properly documented. Compliance was
2.1.4, 2.2.2, The Commission 2016 Technical Guidance clarifies this further in section 2.2.2, where it is written: All confirmed during the
2.2.3, 2.2.5, 3.5,
elements separated from the ship, including large blocks, constitute either ‘hazardous materials’ or inspection.
MEPC 210(63)
Section 3.4.2, ‘waste generated during the ship recycling process’.
3.4.3/ BC TG
p11, p12, p48ff: No storage of used components for reselling was described by the facility.
41, p50ff: 4.2,
Technical
guidance note Waste disposal The facility has explained and demonstrated, through provision of copies of waste disposal companies’ Compliance was
2.1.4, 2.2.2, Waste Management Licenses that they utilise waste disposal facilities authorised by SEPA. confirmed during the site
2.2.3, 2.2.5, 3.6,
MEPC 210(63)
inspection.
Section 3.4.2, Please refer to Article 15(2) (a) below for further details.
3.4.3/ BC TG
p11, p45ff: 7. /
4.2
Article 13 (1) (h); it establishes and maintain an emergency preparedness and response plan; ensures rapid access for emergency response equipment, such as
fire-fighting equipment and vehicles, ambulances and cranes, to the ship and all areas of the ship recycling facility;
Technical
guidance note Emergency The SRF’s Emergency Preparedness and Response plan (EPRP) is referenced in the SRFP as a Compliance was
2.1.3, MEPC preparedness and separate document (SHEQ07).The referenced document SHEQ07.3 “Kishorn Port Incident Plan” confirmed during the
210(63) Section
3.3.5/ BC TG p3,
response plan contains details of the roles and responsibilities in case of an incident. Further, document SHEQ04.2 inspection.
p5/6, p47, p56, “Safety, Health & Environmental Guidelines for Tenants & Facility Users” outlines key areas for
p63/64/65/66/6 consideration by other companies utilising the facility, as well as the minimum SHE expectations of the
7, p70, p81, p83,
p87, p89/ ILO facility. .
SHG p32: 4.6, p
49: 7.1.8, p It was explained to the evaluators that the primary sub-contractor will create their own SHE Plan for
128:16.
each recycling project, with consideration of the facility’s SHE requirements. This plan will then be
evaluated together with KPL, and a “SHE Bridging Plan” will be created as found necessary. The

intention of this approach is to allow the sub-contractor’s workers to follow their own company’s
management system, whilst ensuring that the facility’s requirements are also adequately covered.
A SHE Plan from a tenant utilising the facility was sighted during the site inspection. Whilst this
document was not pertaining to a ship recycling project, the typical scope and level of detail presented
could be evaluated, and was found to reflect the current layout of the facility and to be adequate.
A “Generic Site Operational Plan” was also provided during the inspection, identifying the locations of
pollution control equipment, fire fighting points and muster points.
The applicant is advised to also include the locations of first-aid equipment and evacuation routes.
Technical
guidance not Emergency access The dry-dock has an access road that can be used by emergency vehicles. The facility described that Compliance was
2.2.4, MEPC routes escape from a dry-docked vessel is assured by two access points. confirmed during the
210(63) Section
inspection.
3.2.1 The access route to ships for ambulances and fire trucks was seen to be good during the inspection.
MEPC 210(63)
Section 3.2.1 Access and logistics The main accessways were found to be open and tidy at the time of inspection. Compliance was
within facility confirmed during the
inspection.
Technical
guidelines Medical services and Medical assistance is available in Lochcarron, approximately 10km away. More advanced hospitals Compliance was
2.1.4 (b), MEPC facilities are located in Inverness approximately 100km away. Medical helicopters are available in the event of confirmed during the
210(63) Section
3.2.1, 3.3.5, ILO
emergency. The site can accommodate landing of helicopters in several locations close to the dry- inspection.
SHG, Section 3.6 dock.
Technical
guidelines 2.1.4 Regulatory The facility is certified to ISO 45001. Much of the UK’s health and safety law has originated in Europe Compliance was
(b), requirements health – and is considered on this basis to be broadly equivalent to EU requirements. confirmed during the
MEPC.210(63),
Section 3.3.1,
and safety inspection.
The basis of the UK health and safety law is the Health and Safety at Work Act of 1974. The Act
3.3.4.11
defines the general duties which employers have towards employees and members of the public, and
employees have to themselves and to each other. These duties are qualified in the Act by the principle
of “so far as is reasonably practicable”.

The UK Health and Safety Executive (HSE) is the national regulator. The Scottish Environmental
Protection Agency (SEPA) is the competent authority in Scotland.
Article 13 (1) (i) it provides for worker safety and training, including ensuring the use of personal protective equipment for operations requiring such use;
Technical
guidance note Safety inspectors on During recycling operations it is said to be the principal contractor that is responsible for day-to-day Compliance was
2.3.1 site safety of the recycling operations. The number of safety inspectors and their specific roles would be confirmed during the
determined on a project by project basis. The facility is responsible for vetting the principal contractor inspection.
and their project execution documentation, including safety inspection plans, to ensure these meet the
relevant requirements. This process is led by the facility’s “Head of SHEQ””, who also performs daily
safety and compliance inspections.
Technical
guidance note Condition of safety Safety equipment was in general found in good condition, kept well maintained and controlled. No Compliance was
2.3.2 equipment overdue items were identified by spot-checks during the site-tour, including periodical examinations of confirmed during the
portable fire-fighting equipment . inspection.
Technical
guidance note Safety induction and The facility has an extensive Training & Competency procedure. A training matrix is also maintained. Compliance was
2.3.3, MEPC training, employees Particular provisions and practical training are made for new employees. confirmed during
210(63) Section
inspection.
3.1.2/3.2.2 Both these documents were discussed during the site inspection, and the facility demonstrated good
management of the identification of the need, implementation and maintenance of training activities.
Technical
guidance note Safety induction and All visitors (non-employees) are subject to an induction presentation. Compliance was
2.3.3, MEPC training, confirmed during
210(63) Section
3.1.2/3.2.2
subcontractors inspection.
Technical
guidance note Safety induction, All visitors are subject to an induction presentation. Compliance was
2.3.3, MEPC visitors confirmed during the
210(63) Section (The evaluators attended induction training shortly after arrival.)
3.1.2/3.2.2
inspection.
Technical
guidance note Risk Assessment The facility operates an integrated management system certified to ISO 9001, ISO14001 & ISO45001. Compliance was
2.3.3, MEPC The management system includes procedures & processes for hazard identification & risk confirmed during the site
210(63) Section
3.1.2/3.2.2
assessments. inspection.

The facility has a document SHEQ05 “Management of Risk Plan” which details their approach to risk
management. Generic risk assessments are maintained in the quality system, and risk assessment
method statements (RAMS) are to be prepared prior to any task being undertaken.
All sub-contractors / third parties are required to submit their RAMS in advance of the start of any
project.
Risk assessments included in the facility’s lifting operations plan and Active Waste
Management Plan for the vessel were sighted.
MEPC 210(63)
Section 3.1.2 Hazardous waste The facility’s workers are not licenced to handle hazardous materials. All removal of hazardous Compliance was
handling training materials is said to be performed by licensed contractors. The facility has forwarded SEPA licenses for confirmed during the site
the companies that can be contracted for hazardous waste removal. The facility explained how they inspection.
check that the sub-contractors hold the required qualifications and are adequately trained, this process
is presented in the facility’s document SHEQ 100 Decommissioning Contractor & Sub-Contractor
Approval Process.
MEPC 210(63)
Section 3.3.5 Ship access control The facility advised that they determine the ship access control requirement on a project specific basis. Compliance was
It was seen during the inspection that the vessel currently in lay-up in the dry-dock utilised a T-card confirmed during the
system. inspection.
MEPC 210(63)
Section 3.3.4.5 Prevention of falling Prevention of falling from heights is covered in the SRFP, with reference to a separate Working at Compliance was
from heights Height policy document. It is stated that all tasks that require working at height shall be risk assessed confirmed during the
and requires a working at height permit-to-work. It is a requirement through the Decommissioning inspection.
Contractor and Sub-Contractor Approval Process (SHEQ 100) that all contractors and sub-contractors
will as a minimum follow the facility’s working at height procedures.
It should be noted that the facility utilises the services of specialists in the fields of scaffolding and
rope-access in connection with operations that require working at height.
MEPC 210(63)
Section 3.3.4.1.8 Safety signage on Found to be at a satisfactory level (equivalent to that at other UK shipyards). Safety signs, safety Compliance was
site posters and warning labels were sighted and found satisfactory. confirmed during the
inspection.

MEPC 210(63)
Section 3.3.4.1.8 Safety signage on There was no vessel being recycled at the time of the inspection. Compliance was
vessel confirmed during the
The facility has explained however the type of safety signage that would be used, this was confirmed
inspection.
through explanations provided by sub-contractors present during the inspection.
MEPC 210(63)
Section 3.3.4.6 Lifting equipment and All lifting operations at the facility are governed by the UK HSE Lifting Operations and Lifting Compliance was
instructions Equipment Regulations 1998 (LOLER). These regulations place duties on persons and organisations confirmed during the
who own, operate or have control of lifting equipment. inspection.
The facility demonstrated their management of lifting operations by presenting a “Lifting Operations
Planning Form” for a lifting operation involving their 100te mobile crane lifting a load from the dockside
to a vessel currently occupying the dry-dock. This document was found to be comprehensive, covering
elements such as persons involved, roles & responsibilities, tool-box talk, details of the lift, lifting
equipment and certificates, weather conditions, PPE, method, rigging statement, risk assessment,
details of the crane and operator.
The facility’s rigging store was inspected and found to be orderly with equipment marked for safe
working load and colour coding to indicate equipment approved for use.
The facility documented that the lifting equipment is subject to periodic inspection on a 6-months cycle.
The records provided relevant details including description, identification, examiner, examination date,
next examination date and certificates.
MEPC 210(63)
Section 3.3.4.6 Crane operators’ Crane operators’ certification was presented during the site inspection. Compliance was
certification confirmed during the
The cranes and operators from approved suppliers are also used at the facility. The qualifications of
inspection.
the operators is assessed as part of the approval process (ref. SHEQ100.1).
MEPC 210(63)
Section 3.1.2 Training of forklift Forklift operators’ certification was presented during the site inspection. Compliance was
operator confirmed during the
inspection.

MEPC 210(63)
Section 3.1.2 Certification/ Certification for oxy propane cutting techniques for 3 employees, and certification for mechanical shear Compliance was
cutting for 1 employee, of were made available. confirmed during the
training of cutters
inspection.
MEPC 210(63)
3.4.3 Cutting procedures The contractors and sub-contractors performing the recycling operations will prepare the cutting Compliance was
methodology. A sample method from is presented in the active waste confirmed during the
management plan for the vessel recycled at the facility in 2021. This method is built upon the inspection.
standard operating procedures (SOPs) of the contractor. have also made available
a sample of their SOPs including “Oxygen/propane gas cutting”. The method and adherence to SOPs
is said to be the responsibility of the contractors project manager on site. Tool-box talks and other
meetings will be used to convey the details to those executing the work.
MEPC 210(63)
Section 3.3.4.3 / Steel cutting Mechanical shears were the primary cutting method on the vessel recycled at the facility in Compliance was
ILO SHG: machines 2021, this has been evidenced through photos and videos of the operations and confirmed during the confirmed during the
p108ff:13.
inspection. inspection.
No cutting operations were though seen during the inspection.

ILO SHG:
p108ff:13. Other machinery A visual examination of selected machinery across the site was concluded without findings. Compliance was
inspection.
ILO SHG:
p67:7.2.4.4, Winches, mooring Vessels to be recycled are said to be manoeuvred into the dry-dock and set down (by way of pumping Compliance was
p108ff:13. gear out the water from the dry-dock) either directly onto the impermeable floor or onto supporting blocks to confirmed during the
ensure stability. As such contracted tugs provide the manoeuvring force rather than winches. There inspection.
does exist numerous mooring points around the edge of the dry dock which may be utilised in addition.
These were observed, to the extent possible, to be in good order.
MEPC 210(63)
Section 3.3.4.6. Ropes/chains/ Visual spot checks of loose gear for lifting equipment was concluded without findings, observations Compliance was
and/or remarks. Periodical examinations are carried out by independent licensed organisations. confirmed during the
slings
inspection.
The system for traceability of equipment in use was found to be in order. Any faulty equipment is said
to be removed from site, a dedicated quarantine area was sighted for such equipment. A few items to

be quarantined were found in the storage area. These were immediately removed by the facility and
quarantined.
MEPC 210(63)
Section 3.3.4.8 Maintenance and The facility explained that all equipment is inspected for defects prior to use, and if so found will be Compliance was
decontamination of taken out of use. Machinery is inspected daily by the operator and results recorded. confirmed during the
tools and equipment inspection.
ILO SHG 16.1.6
Eyewash Eyewash (full bottles, in date) was found to be available at several locations around the facility, Compliance was
primarily in the vicinity of the main office building and at the storage container near the dry-dock. The confirmed during the
number and location of eyewash kits is said to be established on a project-by-project basis. inspection.
MEPC 210(63)
Section 3.3.4.8 Condition of electrical No findings and/or observations by visual spot checks. Compliance was
equipment confirmed during the
inspection.
MEPC 210(63)
Section 3.3.4.7 Housekeeping and In general, good housekeeping was observed during the site inspection, in way of cleaning and Compliance was
illumination tidiness. Lighting was provided around the office buildings. Lighting of other areas is on a project-by- confirmed during the
project basis, with lighting established as deemed necessary. inspection.
Technical
guidance note Fire station It is stated in the facility’s Port Incident Plan (SHEQ7.3) that the public fire brigade can be at the facility Compliance was
2.1.3, MEPC within 15-20mins. The facility advised that they have held familiarisation exercises with the fire brigade, confirmed during the
210(63) Section
3.3.5/3.3.6 / BC
who are also invited to the facility in advance of projects to discuss and agree on emergency inspection.
TG: p63: 4.5 preparedness and response.
ILO SHG: p49:
7.1.7 Fire instructions and Basic firefighting instructions and warning signage were seen to be in place. The permit to work Compliance was
signage process for hot work also includes relevant precautionary information with regards fire. confirmed during the
inspection.
Technical
guidance note Fire station manning, Selected workers are trained in basic firefighting. The facility’s fire fighters will only attempt to put out Compliance was
2.3.3, MEPC fire-fighters minor fires. If a fire escalates, or is considered to be more significant, the local fire brigade is called. confirmed during the
210(63) Section
inspection.
3.1.2 ILO SHG: The facility explained that they cooperate with the local fire brigade. The facility will call in the local fire
8.8
brigade for a briefing and discussion at the start of a new project.

MEPC 210(63)
Section 3.3.6, Fire alarm system on Air horns sighted at several locations around the site. Compliance was
ILO SHG: 8.8.11 shore confirmed during the
inspection.
ILO SHG: 8.8.11
Fire alarm system on The facility explained that fire alarms would be manually released on board in case of fire. This would Compliance was
vessel either be the vessel’s own alarm system if operational, or alternatively an air horn would be used. confirmed during the
inspection.
Technical
guidance note Fire prevention In addition to the permanent fire prevention measures at the facility, a project fire risk assessment is Compliance was
2.3.3, MEPC measures general said to be prepared prior to commencement of operations. Part of the risk assessment is to evaluate confirmed during the
210(63) Section
3.3.6, ILO SHG:
the need for temporary fire-fighting equipment. inspection.
8.8
MEPC 210(63)
Section 3.3.6, Combustible Reportedly all combustible materials would be removed before cutting. Compliance was
ILO SHG 13.4.5 materials and hot confirmed during the
work inspection.
MEPC 210(63)
Section 3.3.4.4, Condition of AC/OX No recycling work was going on at the time of the site-inspection and no AC/OX were present. Due to Compliance was
ILO SHG 8.8.1, lines the stringent health and safety laws in the UK it is expected that the condition of such equipment is confirmed during the
13.5.2.
sufficiently maintained. inspection.
MEPC 210(63)
Section 3.3.4.4 Transporting/ storing No recycling work was going on at the time of the site-inspection and no transporting/ storing Compliance was
flammable gases flammable gases was observed. Due to the stringent health and safety laws in the UK it is expected confirmed during the
that transporting/ storing flammable gases is sufficiently maintained. inspection.
MEPC 210(63):
p21: 3.3.5, p23: Fire hydrants The facility advised that they possess a 19.000 litre trailered water tank and pump. This is said to be Compliance was
3.3.6 deployed to locations considered to be high risk. Photographs of this unit in place beside the vessel confirmed during the
Kaami have been provided. inspection.
ILO SHG: p83:
8.8.10 Fire extinguishers Found to be maintained in good service. Spot checks carried out without findings and/or remarks. Compliance was
Periodical service labels in place. No overdue items identified. confirmed during the
inspection.

MEPC 210(63):
p22: 3.3.6, ILO Smoking areas The HSE Policy document states that “Smoking is strictly prohibited in the workplace.” Compliance was
SHG: p82: 8.8.3 confirmed during the
No smoking was observed on-site.
inspection.
ILO SHG 8.4.2
Entrances / gates, The facility is located within the Kishorn Port area. Kishorn Port maintain access control to the harbour Compliance was
fencing area – this is a gated entrance with manning. The dry-dock itself is fenced and access road to the dry- confirmed during the
dock will reportedly be guarded during recycling projects. inspection.
Technical
guidance note Training The facility is checking that the sub-contractors hold the required qualifications and are trained in their Compliance was
2.3.3, 2.1.4, Decommissioning Contractor & Sub-Contractor Audit Stage 1 and 2. confirmed during the
2.3.1, MEPC
210(63) Section
inspection.
3.1.2, 3.1.4,
3.3.4.3, 3.3.6,
3.4.4 / BC TG:
p3: figure 1, p84:
6.1, 6.2
Technical
guidance note PPE Although no recycling was ongoing at the time of the inspection it could be observed during the site Compliance was
2.3.2, MEPC tour that the use of PPE was well implemented, freely and readily available as needed. No person confirmed during
210(63) Section
without PPE are allowed to enter production areas. Automatic inflatable life jackets are required for any inspection.
3.3.4.10
work on the dock gates.
Article 13 (1) (j): it establishes records on incidents, accidents, occupational diseases and chronic effects and, if requested by its competent authorities, reports
any incidents, accidents, occupational diseases or chronic effects causing, or with the potential for causing, risks to workers’ safety, human health and the
environment;
Technical
guidance note Medical monitoring Procedures for medical monitoring are documented and form part of the Decommissioning Contractor Compliance was
2.3.4, MEPC & Sub-Contractor Audit Stage 1 and 2. Worker accidents, injuries and medical/health records such as confirmed during the
210(63) Section
3.3.4.11 and
occupational health examinations are recorded. inspection.
Appendix IV, ILO
conventions In general, the medical monitoring schemes were found to be adequate. A redacted example record
for a employee was forwarded for review.

Incident monitoring All spills are said to be investigated and recorded under the facility’s non-conformance procedures. Compliance was
and reporting confirmed during the
Co-ordination of incident reporting and subsequent root cause analysis is said to be the responsibility
inspection.
of the “Head of SHEQ”. This person is also the SEPA liaison, and in the event of a significant spillage
would inform SEPA immediately. In any case the facility is required to report all activity to SEPA on a
quarterly basis.
The facility provided the document HS28 Accident and Incident Reporting and Investigation
procedures to support the information received during the inspection.
Statistics The “Head of SHEQ” explained how monthly policy objective monitoring and reporting is performed. Compliance was
The facility provided the document ‘SHEQ66 KPL Accident and Incident Statistics 2019-2021’ to
inspection.
support the information received during the inspection with regards to recorded number of near
misses, lost time events and major accidents. KPL experienced one slips, trips and fall accident in
2020 and the cook caught her foot in a container door due to wind causing the door to close
unexpectedly in 2021. These incidents did not result in any time off work.
Near-miss reporting All workers are said to be responsible for reporting all accidents, incidents and near misses. A Safety Compliance was
Action Card system is utilised to obtain input from the workforce. The facility has after the inspection confirmed during the
forwarded supporting documents in HS128 Health and Safety Action Card Procedures, QD04 Non- inspection.
conformance Report 163 and e-mail confirmation to close out NC 163. Additionally, the applicant
forwarded photos of safety action card locations.
Article 13 (2) (a): the operator of a ship recycling facility shall send the ship recycling plan, once approved in accordance with Article 7(3), to the ship owner and
the administration or a recognised organisation authorised by it;
MEPC 210(63)
Section 3.2.4, Ship recycling plan The facility has forwarded ‘C 10 SHEQ88 1 Ship Recycling Plan Template’. This template is found to Compliance was
3.4.2.1 be good and developed in accordance with the requirements of Article 7.2 of the EU SRR, including confirmed during the site
information of the type and amount of hazardous materials and waste to be generated (including inspection.
location on the vessel) and safe for entry and safe for hot works.

Article 13 (2) (b): report to the administration that the ship recycling facility is ready in every respect to start the recycling of the ship;
Commission
Implementing Report of planned As part of the application file, the facility submitted the specific statement concerning the recycling of Compliance was
Decision (EU) start of ship recycling EU Member States flag ships (part 5 of the application). According to the signed statement, the facility confirmed during desk
2016/2324
will prior to any recycling of the ship assessment.
— send the ship recycling plan, approved by the competent authority according to the procedure
applicable, to the ship owner and the administration or a recognised organisation authorised by it;
— report to the administration that the ship recycling facility is ready in every respect to start the
recycling of the ship (Please see the format of the report of planned start of ship recycling as set out in
Commission Implementing Decision (EU) 2016/2324).
The facility has included a procedure for the report of planned start of ship recycling according to the
EU Commission Implementing Decision on page 16 of its ‘2,.SHEQ84 2 Vessel Acceptance Gate
Review process’.
The evaluators are of the impression that the ship recycling facility can adapt to these new legal
regimes.
Article 13 (2) (c): when the total or partial recycling of a ship is completed in accordance with this Regulation, within 14 days of the date of the total or partial
recycling in accordance with the ship recycling plan, send a statement of completion to the administration which issued the ready for recycling certificate for
the ship. The statement of completion shall include a report on incidents and accidents damaging human health and/or the environment, if any.
Commission
Implementing Statement of As part of the application file, the facility submitted the specific statement concerning the recycling of Compliance was
Decision (EU) completion EU Member States flag ships (part 5 of the application). According to the signed statement, the facility confirmed during desk
2016/2322
will: “(b) when the total or partial recycling of a ship is completed in accordance with this Regulation, assessment.
within 14 days of the date of the total or partial recycling in accordance with the ship recycling plan,
send a statement of completion to the administration which issued the ready for recycling certificate for
the ship. The statement of completion will include a report on incidents and accidents damaging
human health and/or the environment, if any.”
The Statements of Completion for EU Member States flag ships provided by the facility shall be
prepared in the required format set out in Commission Implementing Decision (EU) 2016/2322.

The facility has included a procedure for the statement of completion according to the EU Commission
Implementing Decision on page 18 of its ‘2,.SHEQ84 2 Vessel Acceptance Gate Review process’.
The evaluators are of the impression that the ship recycling facility can adapt to these new legal
regimes.
Article 15(2) (a): identify the permit, license or authorisation granted by its competent authorities to conduct the ship recycling and, where relevant, the permit,
license or authorisation granted by the competent authorities to all its contractors and sub-contractors directly involved in the process of ship recycling and
specify all information referred to in Article 16(2);
Technical
guidance note Authorisation Scottish Environmental Protection Agency (SEPA) Waste management licence WML/L/1175043, Compliance was
2.2.1, MEPC issued 29.03.2019. confirmed during desk
210(63) Section
assessment.
3.2.2
MEPC 210(63)
p8: 3.1.2, p10: Sub-contractors The applicant describes extensive use of subcontractors. The applicant has listed the following Compliance was
3.2.2 / BC TG: companies which will be directly involved in dismantling operations: confirmed during desk
p38: 3.4.3
assessment.
•
The applicant has provided environmental permits and registrations for a number or waste handling
companies performing carriage of waste. The permits and registration are with the Scottish
Environmental Protection Agency (SEPA):

Article 15 (2) (b): indicate whether the ship recycling plan will be approved by the competent authority through a tacit or explicit procedure, specifying the
review period relating to tacit approval, in accordance with national requirements, where applicable;
MEPC.196(62)
Section 5 Explicit or tacit The UK List of Ship Recycling Facilities indicates that explicit approval of the SRP is to be provided. Compliance was
procedure confirmed during the
The facility advised upon request for clarification during the desk assessment that SEPA provide tacit
inspection.
approval of the SRP.
The facility advise that SEPA are said to not require to be notified and have advised the applicant that
they will not approve every SRP – rather the applicant’s Waste Management Licence being in place is
their approval.
The applicant has advised that they will carry on sending the SRP to SEPA. SEPA are said to have
advised the applicant that if they don’t hear from them with 14 days that they can assume it is
approved.
The evaluators have discussed the approval procedure with SEPA previously, who advise that during
the COVID-19 pandemic, and as a result of the cyber-attack they have experienced, that recent ship
recycling plans were tacitly approved only. SEPA advised that it is their intention that all SRPs will be
approved explicitly in future.
Article 16 (2) (a): the method of recycling; (b) the type and size of ships that can be recycled; (c) any limitation and conditions under which the ship recycling
facility operates, including as regards hazardous waste management; (d) details on the explicit or tacit procedure, as referred to in Article 7(3), for the approval
of the ship recycling plan by the competent authority; (e) the maximum annual ship recycling output.
Method of recycling The recycling operation is by dry-docking of the vessel to be recycled. Compliance confirmed
during the inspection.
Type and size of All types of ships. The facility can accept ships with the following maximum ship dimensions: Compliance confirmed
ships that can be during the inspection.
- Width: 100 metres
recycled
- Length: 140 metres

- Draught: 12 meters
Any limitation and The facility can accept all types of ships with a length limitation of 140m and with limitation of 100m. Compliance was
conditions confirmed during the
inspection.
Maximum annual ship The applicant has to date only recycled the 1,200 LDT Compliance was
recycling output confirmed during the
From the licence provided by SEPA the maximum total tonnage of any ship or ships to be recycled in
inspection.
any one year is limited to 40,165.
Article 15 (2) (c): confirm that it will only accept a ship flying the flag of a Member State for recycling in accordance with this Regulation;
Confirmation Confirmation from the facility has been received that it will only accept a ship flying the flag of a Compliance was
Member State for recycling in accordance with the EU Regulation. Ref. Part 5 of the Application Form. confirmed during desk
assessment.
Article 15 (2) (d): provide evidence that the ship recycling facility is capable of establishing, maintaining and monitoring of the safe-for-hot work and safe-for-
entry criteria throughout the ship recycling process;
HKC: p14: R1(7),
MEPC 210(63) Safe- for- hot work The safe-for-hot work regime was well explained by the facility and its contractors and the evaluators Compliance was
Section 3.3.4.2 / certificate, warning find that the facility has a well implemented system. confirmed during the
ILO SHG:
p110:13.4
signs and labels inspection.
HKC: p26:
R19(2), BC TG: Confined spaces The confined space / safe for entry regime was well explained by the facility and its contractors and the Compliance was
p47: 4.2.1 evaluators find that the facility has a well implemented system. confirmed during the
inspection.
Article 15 (2) (e): attach a map of the boundary of the ship recycling facility and the location of ship recycling operations within it;
HKC: p43: 1.5,
MEPC 210(63) Map of facility The facility has included a map of the facility in the original application file in Appendix 5. The applicant Compliance was
Section 3.2.1 has later supplemented more details of the dry-dock. confirmed during the
inspection.

(f) for each hazardous material referred to in Annex I and additional hazardous material which might be part of the structure of a ship, specify:
(i) whether the ship recycling facility is authorised to carry out the removal of the hazardous material. Where it is so authorised, the relevant personnel
authorised to carry out the removal shall be identified, and evidence of their competence shall be provided;
MEPC 210(63)
Section 3.1.3, Workers' certificates/ Only fully licensed contractors will be used for handling and disposal of hazardous materials. SEPA Compliance was
3.1.4 licences license for various contractors have been forwarded by the facility. confirmed during the
inspection.
(ii) which waste management process will be applied within or outside the ship recycling facility such as incineration, landfilling or another waste treatment
method, the name and address of the waste treatment facility if different from that of the ship recycling facility, and provide evidence that the applied process
will be carried out without endangering human health and in an environmentally sound manner;
MEPC.210(63),
Section 3.1.1 Regulatory The facility complies with the SEPA requirements for waste management, demonstrated by the Compliance was
requirements issuance of the Waste Management Licence (WML) to the facility. The WML is regulated by the confirmed during the
environment contents of the Waste Management Licensing (Scotland) Regulations 2011 (SI2011 No.228). inspection.
All details of waste accepted, treated at or transported from the facility is to include the relevant
European Waste Catalogue (EWC) Code.
The facility is certified to ISO 14001 for Environmental Management and ISO 45001 for Occupational
Health and Safety.
Technical
guidance note Environmental The facility is required to comply with legislation relating to industrial discharge and has satisfied SEPA Compliance was
2.1.4, management as to its capability in meeting these requirements with Waste Management Licence (WML) being confirmed during the
MEPC210(63)
Section 3.4.1,
issued in 2019. inspection.
Appendix 1, BC
TG Executive
summary (p1),
4.3, 2.1, 2.5, 3.2,
3.4.2, 3.4.4, 4.1,
4.2.2, 4.2.5, 6.2,
7.1, 7.3,

Technical
guidance note Management of Prior to any project the vessel inventory of Hazardous materials will be studied to identify any Compliance was
2.2.5, hazardous waste hazardous materials within the vessel. Based on this, fully licensed and experienced contractors will be confirmed during the
MEPC210(63)
identified. The use of licensed contractors will vary from project to project but would include a specialist inspection.
Section 3.4.2, BC
TG: p45: 4.2, ILO cleaning company. One of the companies the facility may work with is Denholm MacNamee LTD.
SHG: p4: 2.3.2
The Head of SHEQ at KPL holds a WAMITAB certificate of technical competence (CoTC) for the
transfer of hazardous waste and the holder of Radiation Protection Supervisor competence certificate
and will oversee the contractors to ensure full compliance with the sites permits and licences.
Technical
guidance note Management of The SRFP section 4.3.1 describes how the facility will remove asbestos and materials containing Compliance was
2.2.3, asbestos asbestos. confirmed during the site
MEPC210(63)
Section 3.4.3.1,
inspection.
Reportedly, only fully licensed contractors will be used for handling and disposal of asbestos. The
ILO SHG p90:
9.2.3 Asbestos Licensing Unit (ALU) operates a permission regime that issues licences to carry out
licensable work with asbestos as defined in regulation 2 of The Control of Asbestos Regulations 2012.
Any storage on site will be in closed and bunded areas in full compliance with all regulations and in full
compliance with the Site Waste Management Licence.
The facility has clarified that the use of licensed contractors will vary from project to project.
MEPC210(63)
Section 3.4.3.2 Management of The SRFP section 4.3.2 describes how PCBs and materials containing PCBs will be managed. Only Compliance was
polychlorinated fully licensed and experienced contractors will be used for handling and disposal of PCBs. Any confirmed during the site
biphenyl (PCBs) storage on site will be in closed and bunded areas in full compliance with all regulations and in full inspection.
compliance with the Site Waste Management Licence
MEPC210(63)
Section 3.4.3.3 Management of The SRFP section 4.3.3 describes how ODS will be managed. Reportedly, all ozone depleting Compliance was
Ozone-depleting substances and related products will be handled and removed by a fully licensed contractor/waste confirmed during the site
substances (ODS) remover to prevent any damage or release, any storage on site will be in closed and locked skips. All inspection.
ozone depleting substances and WEE containing ozone depleting substances will be transported by a
licensed waste carrier and disposed of at a fully licensed waste receiver where the ozone depleting
substance will be treated accordingly.

MEPC210(63)
Section 3.4.3.4 Management of The SRFP section 4.3.4 describes how paints and coatings will be managed. Prior to any cutting, Compliance was
paints and coating samples of paint will be taken and tested for any lead or other hazardous content. The results from confirmed during the site
including anti-fouling these tests will dictate how the cutting processes are conducted. A full fire plan will be prepared inspection.
with organotin TBT specific to the vessel taking into account all flammable substances and surface coverings. Initial
downsizing will be completed using a mix of mechanical methods and hot cutting depending on the
material being cut. Where possible, hot cutting will be kept to a minimum.
The facility has clarified that the use of contractors will vary from project to project.
MEPC210(63)
Section 3.4.3.5 Procedures for The SRFP section 4.3.5 describes how operationally generated waste will be managed. Only fully Compliance was
operationally licensed contractors will be used for handling and disposal of hazardous waste. Fully licensed and confirmed during the site
generated wastes experienced hazardous waste remover will be utilised to remove any hazardous liquids or sediments, inspection.
these will be transported by fully licensed waste carriers to licensed waste receiver. Any storage on
site will be in closed and bunded areas in full compliance with all regulations and in full compliance
with the Site Waste Management Licence.
Management of PFOS will only be removed by fully licensed and experienced contractors. Any storage on site will be Compliance was
perfluorooctane in closed and bunded areas in full compliance with all regulations and in full compliance with the Site confirmed during the site
sulfonic acid (PFOS) Waste Management Licence. inspection.
MEPC210(63)
Section 3.4.3.6 Management of The SRFP section 4.3.6 describes the management of heavy metals (lead, mercury, cadmium and Compliance was
heavy metals (lead, hexavalent chromium). confirmed during the site
mercury, cadmium inspection.
All heavy metals substances and related products will be handled and removed where necessary by a
and hexavalent
fully licensed contractor. Any storage on site will be in closed and locked skips in full compliance with
chromium)
all regulations and with the Site Waste Management Licence. Waste electrical equipment that contains
heavy metal substances will be transported by a licensed waste carrier and disposed of at a fully
licensed waste receiver where heavy metals will be removed and treated accordingly.

Any equipment and fittings that contain mercury will be transported in their entirety to a waste receiver
who specialises in the removal of mercury.
MEPC210(63)
Section 3.4.3.7 Other hazardous The SRFP section 4.3.7 describes how other hazardous waste will be managed. Compliance was
materials in Annex II confirmed during the site
The site has a SEPA approved NORM Permit for the handling, storage and forward transport of NORM
inspection.
contaminated items, a fully licensed, experienced and competent Hazardous waste remover will be
utilised to remove the NORM or radioactive substance. Radioactive waste will be handled by
License from SEPA has been forwarded by the facility.
MEPC210(63)
Section 3.4.2.2 Additional sampling Only fully licensed contractors will be used for sampling hazardous waste. The applicant explained a Compliance was
and analysis thorough evaluation of the IHM and how they will select a laboratory with all relevant analysis in their confirmed during the site
scope of accreditation. inspection.
The facility will charge the vessel owner additionally if more hazardous materials are found onboard
compared to the information provided in the IHM. The facility has at such an incentive to find additional
hazardous materials.
MEPC210(63)
Section 3.4.2.3 Identification, marking Identification, marking and labelling and potential on-board locations is described in section 4.2.2 in the Compliance was
and labelling SRFP. confirmed during the
inspection.
It was described during the inspection by the licenced contractors that they will mark and label
hazardous materials onboard the vessel to be dismantled.
Technical
guidance note Transport of waste The facility explained the chain of responsibility for transportation of waste. All waste is said to be Compliance was
2.2.5 (a), transported by licensed contractors. confirmed during the site
MEPC210(63)
Section 3.4.2
inspection.
have been presented and licenses from
SEPA forwarded.

Article 15 (5): For the purposes of Article 13, with regard to the waste recovery or disposal operation concerned, environmentally sound management may only
be assumed to be in place provided the ship recycling company can demonstrate that the waste management facility which receives the waste will be operated
in accordance with human health and environmental protection standards that are broadly equivalent to relevant international and Union standards.
Technical
guidance note Waste management The facility has explained and provided documentation to show that licensed contractors remove, store Compliance was
2.2.5 (c) facilities and ensure transportation of hazardous waste to downstream waste management facilities. The facility confirmed during the
also explained and provided thorough documentation to demonstrate how they evaluate their sub- inspection.
contractors.
Ensuring sustainable downstream management of wastes generated by the ship dismantling activities
is an important requirement under the EU Ship Recycling Regulation.
Section 2.2.5 in the EU Technical guidance note provides specific information on the requirements for
non-EU facilities to demonstrate that the waste management facilities follow standards broadly
equivalent to international and EU standards. The requirements/standards applied in the waste
management facilities must ensure a similar level of protection of human health and the environment
as in international/EU standards. The various international and EU standards are listed under section
2.2.5.
UK waste regulations are considered to be broadly equivalent to the relevant EU standards with
identical waste codes (EAL).
The facility has provided the details of the licences and permits for the waste management facilities
used.
In the context of a previous site inspection of another facility, the evaluators also had a separate
meeting with SEPA. The regulatory regime and monitoring processes was explained and found to be
broadly equivalent to EU standards.
According to the information provided, the facility will use the following waste management companies:

It is understood that will not dispose waste directly themselves but transport it to
the Tradebee Fawley Incinerator based in Hampshire, the Avondale waste treatment facility or to
Taylors Environmental Services.
Tradebee Fawley Incinerator is one of UK’s largest facilities for the final disposal of hazardous waste.
Tradebee Fawley operates a rotary kiln incinerator. It is reportedly classified as an upper tier COMAH
(Control of Major Accident Hazards) site, processing difficult chemical and industrial waste streams not
suitable for alternative treatment or disposal options.
Avondale Environmental Ltd is a leading waste treatment facility, with operations in non-hazardous
and hazardous landfill, material recycling and RDF production, soil treatment and landfill gas-to-energy
generation. Avondale has been processing waste since 2000. Asbestos will be landfilled at Avondale
landfill.
Taylors Industrial Services will process and recycle oils and oily water. This company also offers tank
cleaning services and bulk liquid transfers.

Based on all the available information, it is expected that the waste management facilities utilized will
be operated in accordance with human health and environmental protection standards that are broadly
equivalent to relevant international and EU standards.

7 PHOTOS FROM INSPECTION
# Photo Description
1 Dock gates, and flooded drydock

with temporarily moored FPSO.
2 Flooded drydock with temporarily

moored FPSO.
3 Dry-dock gates, from inside the

dry-dock

4 Dry-dock view
5 Dry-dock view
General view of Storage Unit and

6
transportation area.

Manhole cover to sump drain water
7
oil separator system.
View of access road to dry-dock.

8
9 View of access gate to dry-dock.

10 Gangway to sea-level on outside of
dry-dock gates.
Oil pollution emergency response

11
container.
12 Slings and shackles storage

13 Working at height safety
harnesses. Quarantine area for
faulty equipment in background.
14 From left; Facility’s fast rescue

boat, dumper truck and crew
transfer vessel.
15 Facility’s 100te mobile crane and

loader.

16 Entrance to main office building.
Safety posters and emergency
contacts and procedures on the
walls.
17 Induction, training room and first-

aid room.
18 Cloak room for persons utilising the

welfare facilities.

19 Typical room in welfare
accommodation units
20 Typical room in welfare

accommodation units

About DNV
DNV is the independent expert in risk management and assurance, operating in more than 100 countries. Through its
broad experience and deep expertise DNV advances safety and sustainable performance, sets industry benchmarks,
and inspires and invents solutions.
Whether assessing a new ship design, optimizing the performance of a wind farm, analyzing sensor data from a gas
pipeline or certifying a food company’s supply chain, DNV enables its customers and their stakeholders to make critical
decisions with confidence.
Driven by its purpose, to safeguard life, property, and the environment, DNV helps tackle the challenges and global
transformations facing its customers and the world today and is a trusted voice for many of the world’s most successful
and forward-thinking companies.

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A SHIP RECYCLING FACILITY IN UK

Site Assessment Report –

Report No.: 2022-0220, Rev. 0

Prepared by: Verified by: Approved by:

Principal Consultant Principal Consultant Head of Section

DNV Distribution: Keywords:

Rev. No. Date Reason for Issue Prepared by Verified by Approved by

0 2022-02-21 First issue mardav eifre tsv

DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com Page i

4 SCOPE OF WORK ........................................................................................................................................... 2

5 METHODOLOGY AND ACTIVITIES ................................................................................................................. 4

6 RESULTS OF THE ASSESSMENT .................................................................................................................. 5

7 PHOTOS FROM INSPECTION ....................................................................................................................... 29

DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com Page ii

DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com

Hereunder the objectives of DNV’s methodology is to:

• Assure consistent evaluation of facilities on equal terms

• Ship recycling regulation (EU) No 1257/2013

• Technical guidance note under Regulation (EU) No 1257/2013 on ship recycling

• Facility business model and quality statement

• Management, ownership and organisation

• Quality assurance systems and certificates

• Human resources (availability, skills and experience, training, stability etc.)

DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com

• Environment (spills, emissions, etc.)

• Emergency preparedness and response (fire, medical, environmental etc.)

• Regional conditions (acts of nature, political, etc.)

• Applied rules, regulations and internal standards

• Recycling control, inspection and supervision regime

• Non-conformities and corrective actions

• Facilities (methods, capacities, condition of equipment, logistics, etc.))

• Recycling planning and execution

• Methodology, criteria and performance regarding:

- Project start-up, commercial process etc.

- Ship Recycling Facility Plan (SRFP)

- Contract review, verification and acceptance criteria owner / cash-buyer / facility

- Vessel arrival and securing

- Waste disposal (sorting, sub-contractors, end users)

- Project close-out with de-briefing, lessons learned, suggestions for improvement

DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com

- Preparations, scheduling, travel arrangements, fact-finding, etc.

- Issue objective, scope and schedule to facility in advance

- Site assessment (2 days; 3 assessors)

- Issue of draft report

- Implement comments to the draft report

- Introductions, present objective, scope and methodology, agree on schedule

- Review of facility history, current activities, future ambitions

• Interviews with key responsible personnel in all relevant disciplines, including

- Ownership and management

- Planning, preparations, vessel arrival and securing

- Quality assurance, quality management systems

- Health, safety, security and environment

- Vessel dismantling management

- Quality control, document control

• Facility site inspection

- Inspection of Facility, all workstations and worker facilities

- Inspection of vessel, for access and escape-ways

- Spot-checks of worker certificates and permits, crane certificates

DNV – Report No. 2022-0220, Rev. 0 – www.dnv.com