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					                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

PROCESS DESCRIPTION                                                manufacturing and maintenance shops, a
                                                                   galvanising operation and wastewater treatment,
This guideline focuses on the shipbuilding                         paint shop, various materials stores, boiler
processes and shipyards. This includes facilities                  house, compressors and gas production.
(wet and dry docks, marine railways, design
yards) which fabricate and dismantle floating                      The guidance outlines the processes, resources
vessels for inland and marine use vessels.                         and materials used during the construction
                                                                   process; the facilities and services needed to
The main inputs at shipyards are steel plate,                      enable the outputs and their environmental
energy and labour. Large quantities of steelwork                   context. Shipyards use a varied range of services
may be stockpiled, prior to shot blasting to                       for new vessel construction; hull cleaning and de
remove oxidised layers and application of primer                   commissioning.
coat. The activities can occur in the open air or
in purpose built facilities. There is likely to be a               Investment in shipbuilding varies internationally
press shop and a building dock where large                         with some regions investing heavily, others
sections of hull are assembled.                                    divesting and outsourcing. Typically, shipyards
                                                                   produce and build only 20-30% of the value of
The vessel is then transferred to another berth                    each vessel by themselves, the rest produced and
for fitting operations to be completed. These                      installed by suppliers, subcontractors and
activities typically occur on the seaward side of                  turnkey suppliers.
the yard.
                                                                   The industry is under close regulatory scrutiny
                                                                   and faces compliance requirements related to
                                                                   hazardous wastes, wastewater, stormwater, and
                                                                   air emissions generated by vessel construction,
                                                                   maintenance and repair activities

                                                                   Shipyards are usually located in environmentally
                                                                   sensitive areas.

                                                                   KEY ENVIRONMENTAL, HEALTH
                                                                   AND SAFETY RISK/LIABILITY ISSUES

                                                                   Water Pollution

                                                                   Oil spills during fitting operations may
                                                                   contaminate the waters surrounding the
                                                                   shipyard. Runoff water is likely to capture oils
                                                                   and debris that has accumulated on the dock

                                                                   The bottoms of vessels that have prolonged
The remaining area of the shipyard will support                    seawater contact commonly are coated with
ancillary activities including tank farms,                         "anti-fouling" paints containing chemicals that

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                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

inhibit the attachment of fouling organisms to                     disposal of grit a critical economic and
hulls. The active ingredients commonly found in                    environmental issue for shipbuilding and repair
anti-fouling paints are metal-based such as                        facilities. Air, drainage systems and coastal
cuprous (copper) oxide or tributyltin (TBT). The                   waters are vulnerable to contamination from the
pesticides are harmful to many types of marine                     process.
life as well as fouling organisms. Metals can
enter the water through discharge of anti-fouling                  Solid Waste
paint chips and paint removal materials during
vessel maintenance activities. TBT is now                          Spent grit needs to be tested for toxicity. If it is
banned globally but still remains as a hazardous                   regarded as toxic, it must be managed and
substance on the hull of older vessels and is a                    disposed of as hazardous waste. The likelihood
concern during maintenance and servicing of                        that grit will fail the tests depends on how it has
hulls in shipyards.                                                been used. Grit that has been used to remove
                                                                   anti-fouling bottom paints is more likely to fail
Waste water                                                        the tests than grit that has been used to strip
                                                                   topside surfaces.
Galvanising and other metal preparation baths
will discharge acid/alkali and metals laden                        Sludge from waste water treatment, possibly
waters. Water used in cleaning processes will                      with a heavy metal content, will need to be
also require treatment. Waste water treatment                      disposed through licensed contractors.
will be carried out either in a purpose built waste
water treatment plant or will discharge to a                       Hazardous Materials
municipal waste water treatment plant. In either
case it is likely that water quality conditions are                Solvents are commonly used to formulate both
defined, possibly in a permit.                                     bottom paints and coatings used for topside
                                                                   applications such as corrosion resistance.
Air Emissions                                                      Solvents are sources of hazardous waste and of
                                                                   volatile organic compounds (VOCs). These
Smaller vessels can be worked on beneath shop                      compounds are hazardous air pollutants.
roofs, but larger vessels are worked on in open
areas; on floating dry-docks or marine railways.                   Hazardous materials, such as solvents, present a
Blasting grit used in shipyards typically is a slag,               health and safety risk if incorrectly handled,
a by-product of ferronickel production. The                        stored and disposed of.
constituents of blasting grit vary, but in general
include oxides of silicon, iron, aluminium and                     Liquid Wastes
calcium. Some grits also may contain oxides of
zinc and magnesium, and trace amounts of                           •    Wash water, oily water from bilges and tank
copper, titanium, sulphur, and oxides of                                cleaning, and engine fluids such as oil,
potassium and sodium.                                                   hydraulic fluids, lubricants, and anti-freeze
                                                                        are among the waste liquids generated by
Paint stripping jobs require varying amounts of                         during maintenance shipyard activities.
grit. Stripping 280m2 of hull surface area, for
example, may require an estimated 60 tonnes of                     •    Fuelling facilities are another potential
grit. The large quantities make management and                          generator of waste liquids. Hydrocarbons,

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                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

    glycols and other pollutants in these liquids                  Poor management of materials, waste and
    can come into contact with waterways and                       discharges from production presents a potential
    aquatic life through spills and leaks from                     risk of soil contamination. Heavy metals and
    storage tanks.                                                 accidental discharges from spills and storage
                                                                   tank leakages may also contaminate groundwater
Noise                                                              in areas where soils beneath the site are
Pneumatic hammers, gouging tools and chipping
machines are sources of significant noise                          Contamination could arise from deteriorating
exposure in shipyards.                                             drainage networks.

Falls from height                                                  Radiation

Falls from height occur on shipyards while                         Some key workers, especially those associated
vessels are being constructed.                                     with submarine facilities, work with radioactive
                                                                   substances. Some cases of leukaemia,
                                                                   lymphoma, and lung cancer have been known to
Falling objects                                                    occur due to poor site radiation control
                                                                   protection and management practices.
As vessels are being constructed in many levels
falling objects are a hazard. In addition,                         Polychlorinated Biphenyls (PCBs) and
personnel can be hit by falling/moving objects                     Asbestos
during fabrication where failure of fixtures and
conveyance gantries can occur.                                     • PCBs are a group of substances which are
                                                                     good electrical insulators. Typically, PCBs
Confined spaces                                                      may be present as constituents of hydraulic
                                                                     oils or dielectric fluids in electrical
Many areas on a vessel are designated as                             switchgear, transformers and fluorescent light
confined spaces, which can result in vapour                          starters.
build up.
                                                                   • Asbestos has been used on a large scale for
Slips, trips and falls                                               many years as a fire proofing and insulation
                                                                     material and may be encountered in a wide
There is a high incidence of slips, trips and falls                  range of forms including asbestos cement
at shipyards as a result of uneven surfaces,                         boards, as fire retardant gaskets in pipework
unsteady walk ways and wet decks.                                    and as fire retardant insulation around boilers
                                                                     and furnaces.

OTHER POTENTIAL                                                    Particular attention should be given to
ENVIRONMENTAL AND HEALTH                                           refurbishment of vessels constructed before the
AND SAFETY RISKS/LIABILITY ISSUES                                  1980’s.

Ground Contamination

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                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

Machinery                                                          FINANCIAL IMPLICATIONS

All equipment should have safety guarding and                      •    IMO is focusing on global regulations
workers should be issued with appropriate                               (2009) for the design, construction,
personal protective equipment to protect against                        operation and preparation of ships to
unavoidable sharp items and edges. Particular                           facilitate safe and environmentally sound
attention should be paid to metal cutting                               recycling, without compromising the safety
equipment.                                                              and operational efficiency of ships. They will
                                                                        be establishing an appropriate enforcement
Inhalation                                                              mechanism for ship recycling, incorporating
                                                                        certification and reporting requirements.
Use of solvents in the process, creation of dust                        Ships sent for recycling will be required to
during shot blasting, machining and welding                             undertake an inventory for hazardous
activities can result in respiratory disease.                           materials. The new regulation will prohibit
                                                                        or restrict the use of certain hazardous
Occupational Dermatitis                                                 materials in shipyards. Shipyards converted
                                                                        to ship recycling yards will be required to
This can occur as a result of contact with                              have a ship recycling plan
antioxidants, chromates and solvents.
                                                                   •    New ships constructed after this regulation
KEY SOCIAL, LABOUR AND                                                  will have to de designed for deconstruction
COMMUNITY RISK/LIABILITY ISSUES                                         and recycling

Noise, odour and dust                                              •    The visual and olfactory impact of oily water
                                                                        releases could result in compensation for
Noise, odours and dust can cause nuisance                               loss of income and long-term damage and
issues for neighbours of the shipyard.                                  degradation of impacted infrastructure
                                                                        including restaurants, hotels, industries
Recreational activities                                                 abstracting water for processes, marinas,
                                                                        private home owners, and compensation of
Impact on recreational use of river banks,                              fishing industry for loss of fish stock and
shorelines, coasts and wetlands include                                 destruction of equipment.
interference with recreational activities such as
angling, boating, diving and bathing and walking                   •    Injuries may lead to increased payroll costs
due to the health and safety risks oily water                           to replace skilled workers and lost
presents to river bank, coast, wetland or                               production time;
                                                                   •    Capital investment may be required to
Migrant Labour                                                          comply with new environmental, health and
                                                                        safety requirements;
Shipyards might attract the skills associated with
migrant labour.                                                    •    Fines, penalties and third party claims may
                                                                        be incurred for non-compliance with
                                                                        environment, health and safety regulations.

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                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

IMPROVEMENTS                                                       • Regular inspection should be carried out of
                                                                     all bulk containment on site to prevent
•   Development of an innovative method to                           leakage and product loss;
    safely reduce the risk of toxic particulates
    from hull cleaning and maintenance                             • Provision of secondary spill containment for
    activities which, would greatly improve                          bulk storage tanks and silos;
    occupational health and safety, increase
    productivity and decrease overall cost.                        • Good housekeeping should be maintained at
                                                                     all times in all areas;
•   Wash wastewater treatment facility to reduce
    contaminant loading and potential release                      Health and Safety Improvements
    into watercourses and drainage systems.
    Have closed drainage systems on site.                          • Provision of personal protective equipment
                                                                     (PPE) that is fit for the task to prevent injury
•   Consider application of TBT removal                              and maintain hygiene standards. Staff should
    methodologies to treat waste waters from                         be trained in the correct selection, use and
    ship hull maintenance discharges to reduce                       maintenance of PPE. PPE should be
    environmental risk                                               inspected regularly and maintained or
                                                                     replaced as necessary;
•   Introduce maintenance, housekeeping,
    materials management and chemical and                          • Train workers in correct use of machinery
    materials inventory control practices that                       and safety devices;
    aim to minimize wastes from activities such
    as hull stripping and painting, dry dock and                   • Install mechanical lifting aids where possible
    marine railway maintenance, engine                               and rotate work tasks to reduce repetitive
    maintenance, and handling of hazardous                           activities;
    materials during shipbuilding and other
    waste liquids                                                  • Separation of people from moving
                                                                     equipment. Install walkways to separate
•   Apply closed-loop recycling for processing                       people from vehicles or moving parts to
    waste water, with oil/water separation and                       reduce risk of collision;
    waste oil reclamation
                                                                   • To reduce the risk of noise exposure isolate
•   Investigate environment friendly spent grit                      noisy equipment and rotate tasks to minimise
    recycling and disposal and the application of                    time spent in a noisy area over an eight hour
    alternative hull stripping methods such as                       period and provide personal protective
    use of high-pressure water, wetted grit, and                     equipment where people have to enter noisy
    media such as steel shot, plastic particles or                   areas;
    wheat starch.
                                                                   • Provide appropriate fall arrest equipment;
•   Note the condition of the sea around the
    shipyard, is there evidence of oil and/or                      • Install local exhaust ventilation;
    debris in the water;

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                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

• Ensure a safe means of access between vessel                     • Is fire fighting and first aid equipment
  and shore to prevent falls;                                        available?

•   Restrict access to confined spaces and other                   • Check the age and condition of equipment,
    high risk areas.                                                 look for signs of wear and tear, degradation,
                                                                     leaks and breaks;
SITE VISITS                                                        • Check that solid waste storage and disposal
                                                                     (storage equipment) is in a good condition;
During the initial site visit, the issues will vary
according to the specific processes being                          • Check that waste storage areas are clear of
adopted and depending on the level of                                debris and that skips are covered to prevent
environment, health and safety management                            waste escaping, for example, check that waste
already introduced. While visiting the site it is                    containers have lids or are stored in an area
important to discuss and review the following:                       with a roof;

• Note whether the plant discharges to water                       • Have the premises been inspected recently by
  or the municipal wastewater treatment works;                       the regulatory authorities for health and
                                                                     environment? What were their findings?
• Check the condition of storage facilities for
  bulk raw materials;                                              • Check for automatic safeguards on
                                                                     machinery to prevent accidental injury;
• Note the noise and dust levels at the site to
  determine whether abatement equipment is                         • Check that wages and working hours are
  in use or might be required;                                       consistent with the average for the sector and
                                                                     national standards;
• What is the standard of “housekeeping” on
  site? Do areas look clean and tidy? Look for                     • Does the organisation have insurance in
  evidence of any recent spills or releases of                       place to cover the recall of contaminated
  raw materials/product. ;                                           products? Have there been any recent
                                                                     product recall incidents?
• Are staff wearing Personal Protective
  Equipment?                                                       • Have there been any recent incidents on site
                                                                     such as fatalities, fires/explosions, spills? Is
• Check signage around the site:                                     insurance in place to cover such incidents?

    o Does it convey the health and safety                         • Does the business plan have line items for
      risks?                                                         Environment, Health and Safety
    o Are fire exits and/or evacuation routes
      clearly marked?                                              • Check the conditions and duration of validity
                                                                     for all permits;
    o Are there demarcated routes for
      pedestrians and vehicles?

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                                         Sub-sectoral Environmental and Social

                                         Guidelines: Shipbuilding and

• If the investment or refinancing will led to                     minimum, any business should be required to
  restructuring of the company, what will be                       have the following in place:
  the potential impacts on health and safety at
  the operational, employee welfare and wide                       • Operational procedures to manage
  community impacts level?                                           environmental, health and safety risks;

• If the company plans to invest in new                            • Monitoring programmes;
  technology, what will be the impact on
  human resources, in particular health and                        • Improvement objectives, targets and project
  safety and employee welfare?                                       plans;

• Check that labour standards, contracting and                     • Training for personnel;
  remuneration are in line with national law
  and are consistent with the average for the                      • Regular inspections, checks and audits with
  sector                                                             records to demonstrate achievement of the
                                                                     required level of performance against legal
• Check that hours, including overtime, are                          requirements and improvement action;
  recorded and staff should receive written
  details of hours worked and payment                              • Emergency plans for environment, health
  received                                                           and safety accidents or hygiene non-
• Has the company received inspections from
  the local labour inspectorate in the previous                    • Management review/demonstrated
  three years? Have these resulted in any                            involvement in environment, health, safety
  penalties, fines, major recommendation or                          and hygiene management.
  corrective action plans;

• Does the organisation have a grievance
  mechanism which allows employees to raise
  workplace concerns?

• Are employees free to form, or join, a
  worker’s organisation of their choosing?

Take note/ask questions relating to any activities
that address the improvements listed in the
improvements section of this document.


Dependent on the individual business and
nature of the shipyard/ship building activity,
select appropriate improvements from the list
above to include in the action plan. As a

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Sub-sectoral Environmental and Social Guidelines


European Bank for Reconstruction and Development (EBRD). Environmental and Social Policy May
2008. Performance Requirement 2: Labour and Working Conditions.

European Environmental Agency (2002) Accidental and illegal discharges of oil by ships at sea
Patin, Stanislav, Dr. (2002) Off-shor environment, pollution of the sea

European Metal Workers’ Federation. (Press article) “the Turkish shipbuilding expansion: putting profits
before health and safety and risking workers’ lives” 10.03.2009

European Metal Workers’ Federation FEM 34/2003 A future for the European Shipbuilding Industry:
LeaderSHIP 2015 needs a commitment for immediate action

IMO (1998) Annex VI of MARPOL 73/78, Regulations for the prevention of air pollution from ships
and NOx technical code
IMO (2004), Prevention of pollution by sewage from ships

IMO Adopted guidelines on Ship recycling 23rd Assembly, Dec 2003

MARIN Maritime Research Institute, Netherlands (

Shipbuilding and Shipyards Sub-sectoral Environmental and Social Guidelines                         Page 8

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