Marprof today published their discussion document on requirements for ship recycling facilities.  This includes definitive information regarding the acceptability of unsheltered tidal mud flats, exposed to excessive tides and currents, requirements for emergency access, hard standing and cranes, the criticality of proper contracts to protect

both the facility and the shipowner, and the indefinite responsibility of waste.  Many may say this goes beyond the minimum requirements of the Hong Kong Convention – but it doesn’t, it merely identifies the actual liabilities hidden within a proper implementation of the Hong Kong Convention and the associated EU Ship Recycling Regulation.  Copies available on request.  Comments welcome.