ShipsforScrap-lll Steel and Toxic Wastes for Asia

Item

Title: ShipsforScrap-lll
Steel and Toxic
Wastes for Asia
extracted text: Jr

ShipsforScraplll
1

SteelandToxic
WastesforAsia
FindingsofaGreenpeace
StudyonWorkplaceand
Environmental
ContaminationinAlangSosiya ShipbreakingYards,
Gujarat,India.

«■

1

«

Authors
Judit Kanthak
Nityanand Jayaraman
WithinputsfromAndreas

Bernstorff,Marcelo Furtado,PaulJohnston.Eco

Translation
ChristopherHay
WithsupportfromManuelFernandez

Photos
SantoshBane(pp7,12,14)
Judit Kanthak(pp12,13)
Publishedby
GreenpeaceGermany
GroBe Elbstrasse39

22767Hamburg,Germany
Phone:
++49(40)—30618—0
Fax:
++49(40)-30618-130
eMail:

mail@greenpeace.de

Greenpeacelnternational
Keizersgracht176
1016DWAmsterdam,TheNetherlands
Phone:
++31(20)-5236222
Fax:
++31(20)-5236200
eMail:
receptie@ams.greenpeace.org
*
©Greenpeace,2001

Matser

TableofContents

1. Introduction

4

2. Executivesummary

5

3. ScopeandObjectives

9

4. Methodology

9

5. Findings

11

6. Discussions

19

7. Recommendations

26

Annexurel

SampleDetailsa ndAnalysisMethodology

27

Annexure2

MoretoSafetythanMeetstheEye:ACommentary

28

AnnexureS

ChronologyoftheGreenpeace/BAN

shipbreakingcampaign

29

1.Introduction

In some cases, it takes more than 10
years for the symptoms to emerge. It
begins with an increasingly pronounced
shortness of breath, combined with
a
rasping, incessant cough.
A dry
crackling sound accompanies every
breath. The condition of the victim
rapidly deteriorates. Pretty soon, he
suffers significant weight loss, and
begins to bring up blood in the sputum
everytimehecoughs.

stripping entire ships with bare hands,
sledgehammersandgastorches.
They break other people’s ships,
inhaling poisons contained within the
structure of the ships that built the
empires of shipowners from far-away
countries. What doesn’t go into the
bodies of the workers ends up in the
environment. Many of the poisons,
including heavy metals and persistent
organic pollutants build up in the
environment. From here, they travel
through the foodchain damaging entire
sectionsoftheecosystem.

By now, it is probably already too late.
The asbestos he has inhaled in some
earlier part of his life has done its
damage. The fine and virtually
indestructible asbestos fibres are now
lodged inthemicroscopicairsacsofhis
lungs. The lung’s defence mechanisms
are faced with no option but to give up
theirfutileattemptstodestroythe
fibres.
Soon, a hardy scartissue forms around
the now inflamed lung walls, making
breathing less efficient, and increasingly
painful.

The ships are broken to recover
valuable steel. Steel, we hear, is what
goes into the building of a nation’s
economyandkeepsthe shipbreakers in
business. Fortheir efforts and for living
and working in highly poisonous and
physically hazardous surroundings, the
workers at the shipbreaking yards get
anywherebetween$2and$5aday.

Thevictimwillgothroughthemandatory
chest and/or abdominal pains, and if a
cardiacarrestdoesn’tkillhim.heisquite
likely to succumb to a lingering death
due to one or other forms of cancers
associated with asbestosis - an oftendeadly affliction caused primarily by
workplaceexposuretoasbestos.lfheis
asmoker.orisexposedtootherpoisons
and cancer-causing agents during the
course of his work or other activities,
cancercouldbecomeanearcertainty.

For these workers, destiny and global
inaction dictates a life in poverty and a
deathbypoisons.

Themigrantworkersattheshipbreaking
yards have a raw deal. In India, they
travel long distances, hundreds,
sometimes thousands of kilometers,
before landing a job at one of the
shipbreaking yards. Here, they end up

W"

Talk of improving the living and working
conditions of these workers, and
calculators materialize in the hands of
the shipbreakers, the steel tycoons, the
multinational shipowners, the global
regulators.

2.ExecutiveSummary
In June 2000, Greenpeace took up on
an official invitation by the
Gujarat
Maritime Board - the Government
agency entrusted with regulating the
Alang shipbreakingyards-toenterand
take environmental samples from the
yards in Alang, Gujarat. At the same
time.Greenpeacealsoenteredandtook
samples from the Mumbai (Bombay)
shipbreaking yards with the permission
oftheBombayPortT rust.

Theresultsoftheanalysesreconfirmthe
fmdingsof Greenpeace’s October 1998
investigation of these yards. If anything,
two years of inaction is likely to have
heightened the extent of toxic
contamination atthe shipbreaking yards
resulting in increased health risks to
workers and communities exposed to
the poisons released into the
environmentfromtheyards.

Popular pressure from workers unions
and environmental groups has led to a
positive momentum among various
stakeholders. Shipbreakers and even
cash-starved shipbreaking countries are
prepared to shoulder a part of the
responsibility. But the
shipowners,
whose
ranks
include
many
multinationals with stated commitments
to
environmental
and
social
responsibility, have stoutly refused to
have
anything
to
do
with
decontaminatingtheirshipspriortotheir
exporttoAsiaforbreaking.

In a submission dated 31 July, 2000, to
the Correspondence Group set up by
the International Maritime Organisation’s
Marine
Environmental
Protection
Committee, thelnternationalChamberof
Shipping shrugs off all its responsibility
inoneswiftstrokeofthepen:

‘‘Working conditions and employee
health and safety are not issues which
can be determined by shipowners. The
issue of worker safety is essentially the
responsibility. . . of legislators . .
employers.. .administrators.M 1

However, the popular sentiment may
well go against the recalcitrant
shipowners. Acrossthespectrum-from
shipbreakers, government functionaries,
trade union activists to environmental
andhealthactivists-supporthasgrown
for the demand that the “polluter pays,”
thatthe shipowners who profit from the
operation of the ship for more than 25
years must pay for decontamination
beforeexportandsafe shipbreaking.
TheGreenpeaceinvestigationconfirmed
that shipyard workers are exposed to a
deadly cocktail of toxic substances
released during the course of
shipbreaking. Heavy metals, asbestos,
dangerous levels of organotins, and
cancer-causing
poly
aromatic
hydrocarbons (PAHs), contaminate the
workplace. The levels of some of the
pollutantssuchas organotinsand PAHs
in the soil and sediment in and around
theyardsarehighenoughtowarrantthe
classificationofthesesoilsandsediment
as hazardous wastes. Many of the
poisons found will end up in the bodies
of the workers and remain available in
thelocalenvironmentforlongperiodsof
time.

Asbestos, the primary pollutant of
concern, was found even in the living
quarters of the workers. Given the
casual mannerin which largequantities
ofasbestosarestrippedfromtheships,
and the proximity of the workers
quarters to the shipbreaking yards, it is
highly likely that the asbestos in the
quarters are carried by air-borne dust
and/orbytheworkersontheirclothes.

5

Investigations
conducted
by
Greenpeace in China and Bangladesh
indicate that the conditions in these
countriesare fundamentally nodifferent,
at least as far as asbestos handling is
concerned. Our investigators report
extensiveandvisiblecontamination.and
patently unsound work practices in the
shipbreaking yards ofallthreecountries
- India, China and Bangladesh.
However, in China, the workforce was
bettertrained and the torchcutters were
better protected. Nevertheless, the
workforce and visitors not involved in
torchcutting were still exposed to the
fumes.

Environmentally too, the Chinese yards
offered slighter chances of marine
pollution because much of the
processing of the steel plates takes
place at a distance from the sea on a
concrete surface - rather than in the
vicinity of the intertidal zone as is the
caseinlndiaandBangladesh.

In fact, Greenpeace investigators
observed a consistent pattern of
hazardouspracticesrelatingtoasbestos
or insulation removal, torchcutting and
waste management in the Asian yards.
In human terms, these unsafe practices
translate, at a conservative estimate, to
100,000 workers in the three countries
who are directly exposed to workplace
and environmental poisons released
during the breaking of contaminated
ships-for-scrap.

Dr. Frank Hittmann, the Occupational
Health Officer of the German state of
Bremen, has publicly stated in an
interview with ARD-TV (First German
TV) that the lack of safeguards in
handling the various contaminants
meansthateveryfourth workerin
Alang
2
mustbeexpectedtocontractcancer.

Ki

Because many of the poisons released
in the course of
shipbreaking are
persistent and
bioaccumulative in
nature, the magnitude of environmental
and human impact should be assumed
to be far greater than merely on the
directly-affected workers.
That’sthebadnews.

The good news is that after more than
two years of name-calling and nay
saying, the shipping industry, the
shipbreakersandtheworldgovernments
seem ready to address the threats
posed by the breaking oftoxicships-forscraptotheenvironmentandworkers.
India requires special mention for the
small, butresolutestepsithastaken,to
unilaterally address the problem.
Besides mandating gas-free certificates
for all tankers - which has reportedly
brought down the number of worker
casualtiesduetoexplosionsandfiresthe Indian authorities, goaded by the
country’s judiciary and a vigilant press,
have also begun laying out guidelines
forsafeworkpracticesand penalties for
violationsofthesame.

Most notable among these initiatives is
that of the Gujarat Maritime Board
(GMB) which has issued a notification
with broad-ranging, albeit largely
unimplementable,regulations.
In Alang, Greenpeace found a marked
increase across the yard in the number
of workers using hard-hats, gloves and
boots. The yards visited also had basic
fire-fighting equipment. Although, the
typesand numbersofprotectivegear in
evidence is by no means adequate, the
increased use of protective equipment
indicates that with proper guidance, the
authorities and
shipbreakers will
cooperate to make the changes to
improveprotectionfortheworkers.

Workers using hard-hats(Photo: Santosh Bane)

The Gujarat Maritime Board had put up
anumberof colourful, simple messages
encouraging safe work practices among
workers. Several shipbreakers had also
put up signboards on safety issues,
althoughthelanguageofcommunication
(English) leavesone wondering whether
thetargetaudienceistheworker-who
speaks Hindi and/orhis native language
--orthecriticalEnglish-speakingvisitor.
Ironically, India’s unilateral moves to
enforce gas-free certification has
diverted tanker demolition business to
Bangladesh, where such regulations if
available are not properly enforced.
Clearly, anything short of a global
regime for decontamination
and
regulationwill merely serve to move the
problems from one country to another,
ratherthansolvethem.

Experience from industrialized nations
indicates that “controlled use” or
handling of asbestos with a view to
eliminatingdangerstoworkerhealthare
not possible by regulatory means. As a
result, the popular wisdom in Europe
and many other countries is to ban all
useofasbestos.

In other words, even the highly
sophisticated techniques of asbestos
removal,
performed
under
the
supervision of effective regulatory and
enforcement machinery by trained
workers and watched over by an aware
community, cannot completely eliminate
thedangerstothehealthoftheworkers.
Undersuchcircumstances.theproposal
from
various
quarters
that
decontamination should be done at the
Asian shipbreaking yards using better
techniques isfraughtwithdanger, given
the abysmal state of the enforcement

machineryandthedifficultythatworkers
haveinassertingthemselves.
Supported by the new
Greenpeacedemandsare:

evidence,

1. Shipowners/operators
must
present a complete inventory of
all hazardous material on board
the vessel, making a register of
thepollutantsandanalysisofthe
dangersfromtheships;
2. The
Polluter
(Shipowner/operators)
must
decontaminate the ships-forscrappriortoexport;
3. Shipbreaking
should
be
conducted without threat to
workerorenvironmentalhealth;
4. Tankers must be made gas-free
for hot works prior to export for
breaking;
5. Shipowners/operators
must
disclose
the
selected
shipbreaking facility and the
assessment done to ascertain
good working conditions and
environmentalrecord;
6. Shipowners and
shipbreakers
must carry out extensive
consultations on the breaking
plan and put in place expert
monitoring;
7. Shipbreaking facilities should be
freely accessible by citizen
groups,environmental NGOsand
tradeunionactivists;
8. Shipbreakingshouldbesubjectto
aglobalregulatoryregime, rather
than a matter of unilateral
measures.

Looking ahead, Greenpeace demands
that:
1. Existing ships should be made
progressively
cleaner,
by
systematically removing, and
replacing toxic and hazardous
substances during maintenance,
repair, refitting and rebuilding
programmes;
2. The “next generation" of ships
shouldbe“cleanships,”i.e. ships
that
are
designed
and
constructed with a view to
eliminating their environmental
andhealthandsafetyimplications
upondecommissioning.
As is evidentfrom ourdemands above,
Greenpeaceisneitheropposedtoeither
the shipping or the
shipbreaking
industry. We will, however, actively
oppose the export of ships that are not
decontaminated, and unsound breaking
practices that threaten the environment
andthehealthofworkers.

3.ScopeandObjectives

Greenpeace’s first visit to the Indian
shipbreaking yards, in October 1998,
was limited by the lack of official
permission. During this visit, samples of
seawater, soilandsedimentwere taken
only from one plot, the perimeterofthe
yard, and from the more distant
stretches of the coast and inland. As a
result, it was not possible to get more
thanaspotlightpictureofsoil, sediment
and seawater contamination. Neither
wasitpossibletoactuallydeterminethe
nature of contamination in the workers’
livingquarters.

Nevertheless, the 1998 investigation,
was successful in establishing beyond
doubt that ocean-going ships contain
substantial amounts of toxic and
hazardous substances within their
structures, and that the breaking of
these ships releases these toxic
substancesintotheenvironment.

1. To
assess
the
ambient
environmental conditions, with
special regard paid to toxic
contamination, in the workplace
andlivingquartersoftheworkers;
2. To assess the degree of
environmental pollution in the
intertidalzone.thescrappingplot,
workmen’s living quartersand the
immediatehinterland.
The assessment is not, and was not
intendedtobe.acompletemonitoringof
the state of the working and natural
environment in and around the
shipbreaking yards.
Rather,
the
objective was to generate sufficient
evidencesoastobeabletorecommend
immediate changes to improve the
environmental and workplace quality,
and identify problem areas, such as
long-term and persistent pollution, that
willprovemoredifficulttotackle.

4.Methodology
Following up on a public offer by the
Gujarat Maritime Board (the regulatory
authorities for Alang) in February 2000
topermit NGOstovisitthe shipbreaking
yards, Greenpeace revisited
AlangSosiya yards in June 2000, nearly two
years after its first visit. The visit to
Alang was preceded by a short
the
Mumbai
investigation
of
shipbreakingyard.
with
In
addition
to
meeting
Alang
representatives
of
the
Shipbreakers Association and the
GujaratMaritimeBoard.theGreenpeace
teamhadtwoimportanttasks:

Samples were takenonJune6-7,2000,
fromapproximatelypredeterminedspots
inandaroundthe shipbreakingyard.
4.1 The IntertidalZone:
Because ships are broken in the
intertidal zone, the highest degree of
contamination is assumed to be
contained withinthiszoneandalongthe
length of the shipbreaking yard. Along
theapproximatelyW-pluskilometerlong
spread of shipbreaking plots, it was
expected (at the time of sampling) that
theareawiththehighestdensityofplots
- between 2000 and 3000 meters from
the Eastern Fringe-would bethe most
contaminated.

GULF OF CAMBAY

Map1 :Samplingsitesatthe

Alang Sosiya ShipbreakingYardinthetidalrangearea

The sampling spots, “Eastern Fringe”
and the “Western Fringe,” were each
fixed at a distance of 500
metres
outward from the last plots on either
edgeofthelOkilometerstretch.

Within this belt, samples were taken of
seawater and sediment. Analysis and
evaluationofthesesamplesfocusedon
finding organotins, mainly Tri Butyl Tin
(TBT) and its degradation products.
These organotins are released from the
toxicandpersistent antifoulingpaintthat
is used on ships beneath the water line
to discourage the growth of marine life
on the ship’s surface. Isolated samples
were also tested for heavy metals and
polyaromatichydrocarbons( PAHs).

4.2WorkingAreaonthePlots
The greatest immediate toxic threat to
health at the workplace comes from the
handlingofasbestos. Insulationmaterial
found lying within a plot, and dust/soil
samples from the workers’ living
quarters, publicplacesandopendumps
for ship rejects, were collected for
analysesforthepresenceofasbestos.
In terms of ongoing and long-term
exposure to workers and impacts on

Id

environment, organotins, heavy metals,
PAHs, dioxins and furans are the most
criticalandrelevantpersistentpoisonsof
concern. Because chemicals under
thesecategoriesaregenerallylong-lived
in the environment and tend to
bioaccumulate
and
magnify,
an
understanding of the extent of
contamination of the environment by
these chemicals is important to
appreciate the potential long-term and
subtle effects on the environment and
humanhealth.

Therefore,soilsamplesweretakenfrom
the working area of the same
shipbreaking plots from where sediment
and seawater samples were collected.
These samples were tested for
organotins, PAHs, and dioxins and
furans.

This report does not disclose the
shipbreaking plot numbers. These plots
were chosen to get a geographic
representation of the spread of the yard
ratherthan to assess the environmental
state of individual yards. Given the
existing conditions where none of the
shipsaredecontaminatedpriortoarrival
at
the
yards
for
scrapping,

environmental pollution
avoidedinanyoftheplots.

cannot

be

4.3Workers’LivingQuarters:
Samplesofdustandsoilwerecollected
from two huts, one each close to the
Western and Eastern Fringe. The huts,
which are used by workers to sleep,
were expected to be contaminated by
asbestos dust, air-borne and/or carried
into the areas by workers on their
clothing,shoesand/orhair.

4.40therSamples:
Adustsampleforasbestosanalysiswas
taken from beneath the carpet at the
Gopnath Temple, which lies between
200 and 300 metres from the oldest
plots. A dust/soil sample was collected
from near a refuse dump about 200
meters inland towards the Eastern
fringe. The dump contained large
amountsofinsulationmaterial, including
material that was suspected to contain
asbestos.
4.5LaboratoryTesting:
All samples were taken by Greenpeace
campaigners
Marcelo
Furtado,
Shailendra Yashwant, Hemant Babuand
Nityan'and
Jayaraman, under the
supervisionof Judit Kanthak.achemical
engineer with Greenpeace. The
Alang
sampleswere takenon6-7 June,2000,
and the Mumbai samples on 4 June,
2000.

5.Findings
Three years in the limelight has proven
to be a positive force for the Indian
shipbreaking yards. While little has
changedsubstantivelyasfarastherisks
duetotoxicexposure faced by workers,
it is quite clear that
Alang is serious
about saving its business and coming
clean. Thisisevidentfromtheattitudinal
change among shipbreakers and the
Governmentregulatoryauthorities.From
a head-in-the-sand, devil-may-care
attitude,the Alangplayersarelookingat
the real causes of their problems, and
taking steady, if sometimes merely
cosmetic, steps to counter the
allegationsofabysmalworkconditions.
Clearly, though, some common-sense
and simple work practices that are now
mandatory pursuant to the GMB order
will serve to significantly reduce
workplace exposure to toxics among
workers. For instance, the notification
requires that “The shipbreaker shall
sprinkleseawaterovertheworkingarea
inordertominimizedustgenerationdue
tomaterialhandling.” 3

S.IVisuallnspectionReport
a
Greenpeace investigators found
marked increase across the yard in the
number of workers using hard-hats,
gloves and boots (see photo p.7) The
yards visited also had basic fire-fighting
equipment.

Thesamplesweresenttothelaboratory
used in 1998 - GALAB
Hightech
Laboratories, Geesthacht, Germany, for
analyses. The results were documented
in Protocol 1641-1, dated 03-09-2000.
[See Annexure 1: “Sample Details and
AnalysisMethodology”].

11

Oxygen and acetylene bottles were
found stored separately at designated
places. It was not possible, though, to
determine whether workers differentiate

between filled containers that must be
storeduprightandemptycontainersthat
can be horizontally stacked. All visible
bottleswerehorizontallystacked.

A

X

Oxygenandacetylenebottlesstackedhorizontally(Photo:

The Gujarat Maritime Board had put up a number of
encouragingsafeworkpracticesamongworkers.

liH
Educationalsignboard(GMB)(Photo:

12

SantoshBane)

Judit Kanthak)

colourful, simple messages

Several shipbreakers had also put up
signboards on safety issues, although
the
language
of communication
z

A s'

(English) leavesone wondering whether
thetargetaudienceistheworkerorthe
criticalvisitor.

HHHBI Hi Of

W’v- ’ 'f-' i

'"T
c‘

■ -

[4 no KNOW
safety
I
VAIN I

: IB/

J IN INDIJSTRIES

1 KNOW SAFETY
I
. NO T&FN J
r
&

I® n

0
r?

IH
II-

Educationalsignboards(shipbreakers)(Photo:

Judit Kanthak)

At the time of the visit, the
Gujarat
a
Maritime Board was also preparing
masterplan
for
revamping
the
infrastructure to deal with hazards and
hazardous
substances.
Several
shipbreakers were keen to implement
easy, immediate actions that would
significantlyimproveworkplacesafety.

witness any open burning in the few
yards it visited, it did encounter several
sites outside the plots where sundry
discards were either being burntorhad
beenburnt.

On the ground, though, little had
changed.
Whatever limited improvement or
changes were in evidence in the yards
wereorientedtoward providing marginal
protection for workers from the
ubiquitous
environmental
poisons.
Virtually no steps have been taken to
prevent environmental contamination.
Although the Greenpeace team did not

The beaches beyond the two edges of
a
the yards are littered for at least
kilometer with debris, foam and plastics
fromtheyards.
Asbestos continues to be handled and
discarded haphazardly. Open dumps
with insulation material, oily rags, foam
and asbestos dot the landscape. Face
masks and respiratory gear were
nowhere in evidence. No efforts had
beenmadetosuppressdust-generation
intheyardsortheroad.

[13|

Opendumps;asbestos(Photo:

SantoshBane)

The approach road to the plots and the
plots themselves remain dangerously
congested. This would prove to be
a
major obstacle to any meaningful
emergencyresponse.

Workers entering the
intertidal zone
during low-tidecontinuetodosowithout
adequatefootwearexposing themselves
tothetoxinsinthesedimentandtostray
piecesofmetals.
Most damagingly, village children from
nearby
settlements
were
found
collecting fish and shellfish from the

KES

severely contaminated beaches at the
fringesoftheyard.
5.2Asbestos
Theanalysesconfirmedthepresenceof
asbestos dust in the workplace, living
quarters and public areas, including the
hinterlandaround Alang.Outofatotalof
six samples taken, five tested positive
for asbestos. The implications of these
findings
for
the
workers,
the
shipbreakers themselves, and shop
owners/employees
along
the
shipbreaking yard are discussed in the
chapter6titled“Discussion.”

SampleNo.

Locationofsampling

18

ShipbreakingPlot

21

Openwastedump
200minland________
Livingareal
Outside___________
Livingareal
Inside,floor________
Livingareall
Inside,floor________
Livingarealll
Templeinside,carpet

23A

23B

47C
48C

of Description of Result
thesample
Chrysotile
Insulation
material______
Chrysotile
Dust+soil

Date
sampling
06.06.00

06.06.00
06.06.00

Dust

Chrysotile

06.06.00

Dust

Chrysotile

07.06.00

Dust

Amphibolite

07.06.00

Dust

Noasbestos

TABLE1:AnalysesResultsforAsbestos.
Alang-Sosiya ShipbreakingYard.
Note: Amphiboliteisthegroupnameforthefollowingcommercialtypesofasbestoscrocidolite, anthophyllite, amosite, acinoliteand tremolite.

hasseriousimplicationsforworkerswho
eitherwalkthroughthemarshy
intertidal
zone during low-tide or work there
draggingpiecesofshipsteeltoshore.

5.3 Organotins
The results indicate severe and
extensive contamination of seawater
and sediment by poisonous
organotin
compounds at all sampling sites. This

SampleNo.
Distance to the
westernfringe
Dateofsampling
Monobutyltin
Dibutyltin
Tributyltin
Tetrabutyltin
Triphenyltin

m

nq/l
nq/l
nq/l
nq/l
nq/l

39
600

19___
2,800

34A
4,600

29A
12,200

06.06.00

06.06.00

06.06.00

06.06.00

462
1,440
8,400
<20
<20

330
739
1,290
<20
<20

1,220
5,900
10,900
194
<1____

120
59.6
74.1
<1
<1

TABLE2: OrganotinsinSeawater, Alang

Thehighestconcentrationof tributyltin—
19,400 pg/kg in sample # 42A -- was
found in the yard area where most plots
3
are clustered together. [See Table
below] This lies approximately 2100
meters from the Eastern Fringe. The
level found here is approximately
between 10and100milliontimeshigher

than internationally recognized limits
(0.005to0.05 |ig/kg)forTBTin marine
_I4. 4
sediment.
Although the level (768 pg/kg) found in
the sediment taken from the Western
fringe, which is 500 meters away from
the last Westside plot, is substantially

15

hasapoliticaldecisiontoclassify grime
(dredging sludge from the river Elbe)
with more than 250 pg/kg as hazardous
waste.5

lower, port authorities and agencies
regulating industrial sites in the
European
Union
are
preparing
legislation that would classify such
sediments as a hazardous waste. For
instance, Hamburg, Germany, already

SampleNo.

Distance to the
westernfringe
Dateofsampling

m

Monobutyltin
Dibutyltin
Tributyltin
Tetrabutyltin
Triphenyltin

pg/kg
pg/kg
pg/kg
pg/kg
pg/kg

24A
western
fringe
0

20A

41A

42A

2,800

4,600

10,100

43A
eastern
fringe
12,200

06-06-00

06-06-00

07-06-00

07-06-00

07-06-00

4.7
55.1
768
18.3
<1

86.9
784
10,100
162
<1

41.1
311
2,320
31___
10.1

382
1,320
19,400
350
43.4

3.6
10.7
78.4
2.1
<1

TABLES: Organotincompoundsinmarinesediment.Alang
Implications for workers of such high
levels of organotins in the soil are
disturbing, especially since this soil
sample comes from a plot where
organotin levels in sediment are
relativelylowcomparedtothoseinother
samples. In other words, we can
assume that most plots are even more
pollutedthan indicated inthetestedsoil
sample.

Table 4 below lays out the
organotin
content in a soil sample taken from the
same plot where marine sediment
sample #41A was taken. Soil from this
plot was chosen for analyses because
the sediment sample here yielded
significantlylowerlevelsofTBTthantwo
othersamplesforthesamechemical.

35A

SampleNo.

Distancetothewesternfringe
Dateofsampling

m

4,600
06-06-00

Monobutyltin
Dibutyltin
Tributyltin
Tetrabutyltin
Triphenyltin

pg/kg
pg/kg
pg/kg
pg/kg
pg/kg

61.2
92.6
384
21.4
<1

TABLE4: Organotinsinsoil, Alang

16

Amoredetailedanalysesofthehuman
andenvironmentalimplicationsofthese
numbers is dealt with in the following
chaptertitled“Discussion.”

Levelsoflead.forinstance, arealready
closetotheupperlimitsmeasuredinthe
German North Sea sediment (250
mg/kg)between1994-1998.6

5.4HeavyMetals
Sediment samples taken from the
various plots indicate elevated levels of
heavy metals, including those like lead
that bioaccumulateinlivingtissue.

The levels of other metals detected in
the Alangsamplearetypicalofpollution
in regions with a long industrial history.
The levels are only likely to increase to
significantly higherlevelsif shipbreaking
continues with a business-as-usual
approach.

SampleNo.______________
Distancetothewesternfringe
Dateofsampling__________
Arsenic
Cadmium
Chromium
Copper
Iron_____
Nickel
Lead
Zinc

M

2QB
2,800
06-06-00

41B
4,600
07-06-00

42B
10,100
07-06-00

mq/kq
mq/kq
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg

30___
<10
140
270
162,500
80___
220
1100

<5___
<5___
40___
230
34,600
40___
110
670

20___
<10
70___
210
63,400
50___
180
530

TABLE5:Heavymetalsinsediment,

Alang

hydrocarbons
5.5
Polyaromatic
(PAHs)
The different profiles of the toxic
substances analysed in the soil and
sediment samples indicate that the
sources of contamination in the two
mediaaredifferent.Thesoilsample.for
instance, was contaminated with
PAHs
from combustion processes. The
PAHs
contaminating the sediment seem to
come from different sources, such as
leakedoil.

importantroleinlendingtotheprofileof
the PAHs found in the soil. The PAH
profileofthesoilsampleissimilartoan
analysisresultofcombustionresiduesof
an accidental fire at the Chang
Jian
shipbreaking yard on the banks of the
Yangtse River, North of Shanghai in
August 1999. The fire was caused
8
duringroutinetorchcuttingofshipsteel.

The practices of open burning — of
wastes using oil as a fuel -- observed
during Greenpeace’s first visit to
Alang
in 1998 7 is likely to have played an

a) the variety of contamination such as
bilgeoil, residualfuel, lubricantsand
greases;

The sediment samples do not show
specificpattern.Thismaybedueto:

a

17

However, these patterns are consistent
withthepracticeatyardswhereoilleaks

b) the constant movement in the
intertidalzone;
aquatic
c) the
influence
of
the
microorganisms
degrading
substancestodifferentdegrees.

No.________________
Descriptionofthesample
Distancetothewesternfringe
Dateofsampling__________

Naphtalene__________
Acenaphtylene_______
Acenaphtene_________
Fluorene____________
Phenantrene_________
Anthracene__________
Fluoranthene_________
Pyrene______________
Benz(a)anthracene
Chrysene/Triphenylene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene______
lndeno(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,l)perylene

pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg
pg/kg

TABLE6: PAHsinsoilandsediment,

from the ships end up in the tidal area,
whiletheplots.fromwheresoilsamples
were taken, are used for torch-cutting
thesteelplatesintosmallerpieces.

35C
Soil
4,600m
06.06.00

41C
Sediment
4,600m
06.06.00

138
69__
241
69__
2,827
241
3,171
3,102
1,206
1,827
1,792
793
1,275
1,034
655
896

661
839
839
679
822
393
929
893
911
911
929
875
911
893
697
732

Alang

TheOSPAR (Oslo Paris) Commission
on the Protection of the Northeast
Atlantics defines a maximum tolerable
levelofWO p.g/kgforsedimentforeach
PAH combination. The levels of
PAHs
found in the
Alang sediment are
betweenfourandninetimeshigherthan
theseprescribedlevels.Thesedimentof
the German North Sea, an area which
haswitnessedalongandintensehistory
of industrial contamination, also has
highlyelevatedlevelsof PAHs.

5.6Dioxinsand Furans
Combustion
processes
release
polyaromatic hydrocarbons, dioxins and
furans, often simultaneously. Dioxins
and furans (PCDD/F) are normally
incomplete
the
with
associated
organochlorine
of
combustion
compounds.

Shipbuilding in the 1970s involved the
use of a number of
organochlorines,
including chlorinated solvents in paints;
chlorinated
flame
retardants;
polychlorinated biphenyls in sealants.

levels of exposure to dioxins, and
because these chemicals are persistent
and bioaccumulative in nature, the very
presence of significant levels of dioxins
and furans requires that immediate
further evaluation be conducted into
identifying
possible sources
and
isolatingthesame.

plastics etc, and PVC in various
applications.
Concentrations of PCDD/F in the single
sample analysedforthechemicalswere
found to be low but not insignificant
compared to other dioxin hotspots and
dioxin-contaminated industrial sites.
Nevertheless,becausetherearenosafe

35B

SampleNo.

Distancetothewesternfringe
Dateofsampling__________

m

4,600
06.06.00

2.3.7.8- TCDD
1.2.3.7.8- PeCDD
1,2,3,4,-7,8-HxCDD
1.2.3.6.7.8- HxCDD
1.2.3.7.8.9- HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
_________

nq/kq
nq/kq
nq/kq
nq/kq
ng/kg
ng/kg
ng/kg

2____
8 ____
9 ____
38___
17___
1,230
9,680

2.3.7.8- TCDF
1.2.3.7.8- PeCDF
2.3.4.7.8- PeCDF
1.2.3.4.7.8- HxCDF
1.2.3.6.7.8- HxCDF
1.2.3.7.8.9- HxCDF
2.3.4.6.7.8- HxCDF
1.2.3.4.6.7.8- HpCDF
1.2.3.4.7.8.9- HpCDF
QCDF____________

ng/kg
ng/kg
ng/kg
ng/kg
ng/kg
ng/kg
ng/kg
nq/kq
nq/kq
nq/kq

50
45
52
61
59
4__
54
284
22

NATO/CCMS-TE

nq/kg

89

TABLE7:Dioxinsand

furansinsoil,

267

Alang

G.Discussions

6.1Asbestos
Asbestos-related illnesses pose
a
seriousandconstantlyincreasingriskto
the health of workers and people
frequenting the shipbreaking yards. If

anything, matters have worsened in this
regard since
Greenpeace’s
1998
investigations. That is because ships
containingasbestoscontinuetoarrivein
Alang, and are subject to the routine
by
grab-rip-dump
operations
barehanded, unprotectedworkers.

19

Asbestos was found strewn casually
around—inthe
shipbreakingplotandin
opendumpsfurtherinland.Thisposesa
serious health risk not only to the
shipyard workers, but also to the
shipbreakers, the roadside vendors, the
transport workers and the
Gujarat
Maritime Board workers stationed atthe
shipbreaking yard, not to mention
neighbouringcommunitiesofpeasants.

1920
1936
1940
1943

1960
1973
1976
1979
1989
1995

Toour knowledge, no medical check-up
hasbeencarriedoutamongtheworkers
and other people frequenting the
Alang
shipbreaking yard to assess the
prevalenceofasbestos-relatedailments.
Despitetheabsenceofsuchdata,given
the prevailing conditions (both natural
and human-induced) it wouldn’t be far
fetched to assume that the affliction
couldbeofseriousproportions.

Connectionestablishedbetweenasbestosandpulmonaryfib rosis
Recognitionofasbestosisasanoccupationalillness ___________________ _—
Connectionestablishedbetweenasbestosisandbronchialcarcinoma

Recognition of bronchial carcinoma in conjunction with asbestosis as an
occupationalillness
Connectionbetweenasbestosand

_______ __ ________________
mesotheliomaofthepleura
_______ _

Spray-appliedasbestosbannedintheUSA
—_
Recognitionof mesotheliomaofthepleuraasanoccupatjonalillness
Spray-appliedasbestosbannedintheFederalRepublicofGermany ___________
ManufactureandsaleofasbestosprohibitedintheFederalRepublicofGermany

(deadlinesfortransitionby1994)_________
. . -------------------------Banonthere-useofproductscontainingasbestosinGermany___________ ____

TABLE 8: Historical development of discoveries and bans relating to asbestos and
asbestos-relatedillnesses

The cancer-causing properties of
asbestos have been known to science
since the 1930s. In fact, few other
hazardoussubstancesintheworldhave
attractedsomanylaws, regulationsand
technical
guidelines
relating
to
identification, removal and liability, as
hasasbestos.
In the Netherlands, more than 10,000
estimated cases of asbestos-related
ailments were recorded between 1969
and 1994. This period corresponds to

theearlyyearsafterexposure. Because
many of the asbestos-related ailments,
in particular the cancers, manifest
themselves approximately 15 to 35

years after exposure, the number of
people succumbing to decades-old
asbestos exposure is likely to skyrocket
inthecomingdecades.Evidenceforthis
comes again from the Netherlands,
where42,600menandwomenarelikely
tosufferfromasbestos-related diseases
between 1996 and 2030. Of this, the
majority will be people who were
exposedtoasbestosintheworkplaceor
otherwise.
Of the total estimated number - of
52,600 - of asbestos victims between
1969 and 2030, less than 500 people
(those afflicted with asbestosis) are
likelytosurvivethedisease.Mostofthe

remainder, afflicted with cancers will
succumbtothediseaserapidly. 9

succeed in exporting the ships with the
asbestosintact.

In India, the figure is likely to be
substantially
higher,
with
the
shipbreaking industry accounting for a
significantnumber.

Lloyd's of London, which guarantees
unlimitedliabilityonitsinsurance,based
on the private fortunes of tens of
thousandsof investors, is having to pay
outincreasingamountsincompensation
-forasbestos-relatedillnesses.

Interestingly, although asbestos dust
and fibre wastes are patently hazardous
wastes banned for import into India, the
waste asbestos from ships are
convenientlyignoredbytheenforcement
authorities. Not only that, the asbestos
actually finds its way into the Indian
market after workers have manually
stripped these deadly fibres from ship
structures.

With a plethora of cheap insurance
policiesfromthepastintheirhands.US
lawyersaresecuringastronomicalsums
in compensationforclientswho became
ill after handling asbestos-containing
material. Claims by asbestos victims
havealreadyruinedanumberofLIoyd's
guarantors; some have even committed
suicide. Lloyd's is stricken: unlimited
a
liability and asbestos are clearly
dangerouscombination.

Shiv Gupta,an Alang shipbreaking plot
owner,inarevealinginterviewtoLloyd’s
Listsays:
“Dealerspayus Rs. 5(11 UScents)per
kilo, andinsistthatwedonotpackitfor
them. They prefer to scrape it off
themselves, so that they can retain as
muchofitspurityaspossible. w1°

Fortunately, the avenues for exporting
ships with asbestos to India are
graduallyclosingdown.AnAugust2000
notification11 by the Gujarat Maritime
Board requires that the Master of the
ship-for-scrap
“shall”
present
a
certificate that no dangerous gas, toxic
or any other hazardous chemical/waste
are present on board of the ship. While
this is not exactly an
implementable
clause given its vague and allencompassing nature, it adequately
reflects earlier Indian guidelines 12 and
the sentiment of the Indian Supreme
Court to prevent the import of any
hazardouswastesintolndia. 13

The.shipbreakingindustrywillbekilledif
and when the workers decide to lodge
compensation claims for asbestosrelated injuries against their employers.
[See box “Asbestos Liabilities: A heavy
pricetopay”]
Interestingly, shipowners and ship
operators, the prime culprits, will have
managed to pass on the compensation
liabilities to the shipbreakers once they

HO

1 (

/

AsbestosLiabilities:AHeavyPricetoPay
Millionsofworkershavebeenexposedtoasbestosdustsincetheearly 1920s. Among
shipyard workers, asbestos miners and millers, asbestos product manufacturers,
construction anddemolition workers, asbestos-related ailmentsarenotjust routine, but
increasingly acknowledged as an occupational disease warranting compensation from
the employer. In India too, a variety of national legislation—theairand water Acts, the
Hazardous Wastes(Managementand Handling) Rules(1989), the Factories Act( 1948)
-governstheimport.use.handlinganddisposalofasbestosandasbestoswastes.
It is generally accepted that the risk to workers increases with heavier and long-term
exposure. However, investigators have also found asbestos-related diseases in some
shipyard workers exposed to high levels of asbestos fibres for only brief periods (as
short as 1 or 2 months
14). Even workers who may not have worked directly with
asbestos but whose jobs were located near contaminated areas are known to have
developedasbestosis, mesothelioma,andotherasbestos-relatedcancers.

In six Western European countries (Britain, France, Germany, Italy, Netherlands,
Switzerland)asbestosexposurewillcause250,000deathsfrom
mesotheliomaoverthe
next 35 years. At least an equal number is expected to succumb to asbestos-related
lungcancer, suggestingthattherewillbemorethan500,000asbestos-relateddeathsin
WesternEuropeoverthenext35years.
15

The financial liabilities associated with asbestos-related compensation and phase-out
are mindboggling. ASeptember 1999 study by Greenpeace Netherlands on asbestosrelatedliabilitiesintheNetherlandsatNLG67billion(approx.$30billion)fortheperiod
1999-2045.16 Of this, a conservatively estimated NLG 7 billion (approx. $3 billion) is
expected to serve as compensation for victims and families. Although these figure are
an estimate of land-based asbestos liabilities, it is indicative of the magnitude of the
problem.
Theargumentsof shipowners that decontamination of ships ought to be done in the
Asian shipbreaking yards under an improved regulatory regime ignores these facts.
Moreover, the factthatthe European Union, and several other countries including the
USAhavebannedmost,ifnotall,usesofasbestosisproofthatregulatorymeansare
notcommensurate tothedangers posed byasbestos.lfthatistheverdictof countries
that claim to have stringent implementation of regulations, it would be hypocritical to
expect better handling of asbestos in countries like India, Pakistan, Bangladesh and
China.

6.2 Organotins
Tributyltin (TBT)
is an aggressive
biocide (kills living organisms) that has
been used in anti-fouling ship paints
since the 1970s. The toxicity of TBT
prevents thegrowthof algae, barnacles

22

and other marine organisms on
ship's hull.

the

In fact, after yearsof scientific backingand-forthing, the word is out that the
preponderance of evidence implicate
TBT as constituting an unmanageable

threat to the marine environment. Its
impacts on marine organisms range
from the subtleto the lethal. [See box:
“TBT: Deadlyat Sea”]

In 1998, the General Assembly of the
International Maritime Organisation
decided that the Marine Environment

Protection Committee (MEPC) should
workonagloballegal instrumentto ban
TBT. It was also decided that the ban
should be effective in 2003 when it
comes to the application of TBT paint
and in 2008 when it concerns the
presenceofTBT paintsona ship.17

TBT:DeadlyatSea
TBTisresponsibleforthedisruptionoftheendocrinesystemofmarineshellfishleading
tothedevelopmentofmalesexcharacteristicsinfemalemarinesnails.TBTalsoimpairs
the immune system of organisms. Shellfish are reported to have developed shell
malformations after exposure to extremely low levels of TBT in the seawater. Recent
studies conducted by the Dutch Institute forMarine Research and the Free University
(VU) of Amsterdam reveal thatsperm whales thatliveandfeed in thedeepocean far
from ports and shipping lanes have appreciable amounts of TBT and its breakdown
productsintheirbodies. This indicatesthatTBTmaybewidelydispersedinthe marine
environment, includingthedeepoceanswherespermwhalesnormallyliveandfeed.

TBT and its degradation products have been isolated from a wide range of marine
environmental samples. In many cases,a relationship between levelsof environmental
contaminationandthe intensityofshipping traffic can be detected.TBThas been found
in the tissuesof cetaceans, seals, sea ottersand water birdsina wide rangeof locations
around the world. Tissuesand sediments sampled from areas with heavy shipping
activity show the highest levelsof contamination.18______________________________

In
industrialised
nations,
legal
regulations are in place to protect
workers from exposure to
antifouling
paints containing the poisonous tributyl
tin (TBT). Skin, eye and lung protection
aremandatoryforanycontactworkwith
TBT-containingpaints.
That is because, even in small doses,
organotin compounds can damage
human health. In occupational health
parlance, the maximum workplace
concentration (i.e. the highest amount
thatahealthyworkercanbeexposedto
tributyl tin
for eight hours a day) for
oxide(TBT 0)is0.05mg/m3 ofair.

In Alang.thereisevidencethatthefloor
of the work area is contaminated with
TBT at levels (384^ g/kg) that would
render the soil a hazardous waste
requiring regulateddisposalundersome
European regulation. Not only that, in
the absence of protective masks,
workers torchcuttingmetalplatescoated
with TBT paints are constantly exposed
to metal and TBT fumes through
inhalation.
On the basis of peak values measured,
Greenpeace identified 10 TBT hotspots
in Europe in 1999/2000.19 Comparison
of the peak concentrations of TBT and
itsdegradationproductsinthesediment
at Alang with the values from European

23

both are found regularly in the tissue of
marineanimals.

hotspotsputs AlangatGthplaceamong
the top ten European TBT hotspots.
[SeeTable9]

Thepeakvalueisthesumof
tributyl tin
(TBT) and its degradation products
dibutyl tin (DBT) and
monobutyl tin
(MBT). MBT and DBT are also toxic;

PORT
Rotterdam
TheNetherlands
Thessaloniki
Greece_______
Rostock
Germany_____
Livorno
Italy__________
Odense
Denmark
Alang- Sosiya
Gujarat/lndia
Barcelona
Spain_________
Antwerp
Belgium_______
Piraeus
Greece_______
Hamburg
Germany_____
Marseille
France________

LOCALITY OF
SAMPLING
Eemhafenport

In Alang-thelargestscrappingyardof
the world - no TBT cleanup measures
are in place. Contamination levels in
seawater and sediment are already
substantial outside of the scrapping
yard.

ZMBT,DBT,TBT

SOURCE

Dutch Ministry for
Transport
and
Waterways, 1999
Greenpeace
Port-Dock24
10-08-00
Greenpeace
Neptunwerft
09-09-99
Floatinqdock
Greenpeace
Docks
17-08-00
Energy
Danish
Lindovaerflets
Ministry,2000
Greenpeace
Shipbreaking
06-06-00
Yard_________
Greenpeace
Fishing harbour
01-09-2000
Greenpeace
Port
2000_______
Greenpeace
Kinosoura
10.08.2000
harbour_______
Norderwerftyard Greenpeace
17-09-99
Avant Port Nord Greenpeace
FormelQ_______ 25-08-00

pg/kg

1,000
(TBTonly)

pg/kg

1,333

pg/kg

4,978

pg/kg

8,801

pg/kg

14,288

pg/kg

21,102

pg/kg

22,462

pg/kg

28,273

pg/kg

94,792

pg/kg

106,605

pg/kg

241,370

Table9: Comparison of peakconcentrationsofTBTanditsdegradationproducts in the
sediment of European ports withthe peaklevelfound in the
Alang-Sosiya shipbreaking
yard

The degree to which skin can absorb
TBT should not be underestimated.
Direct, unprotected contact to painted
surfaces or walking barefoot along the
beach or the intertidal zone (a normal
practice in Alang) can be a significant

24

source of exposure, causing local skin
irritation oraccumulation in the body of
theexposedworker. 20

An increased risk to health is to be
expected from the absorption of TBT
throughtheskin:
• Through exposure on palms and
soles because these parts of the
body have better circulation than
others;
• When heat, exposure to warmth
or physical exercise increase
circulationintheskin;
• When
work
in a
damp
environment or humidity swells
the top layer of skin, allowing
increased surface area for
absorption.
Allthreeconditionsapplysimultaneously
to workers exposed to TBT in
shipbreakingyards.

6.3 PAHs,Dioxins/Furans
The health hazard from
PAHs, dioxins
and furans comes from directly inhaling
fumes, which are released primarily
during torchcutting, after torchcutting
when paints continue to fume and
smoulder, or when wastes are
deliberatelyburned. Dioxins,like
PAHs,
accumulate in dust and sediment, and
tissuesof lifeforms.Asaresulttheyare
available for uptake either through
inhalation, dermal contact or via the
foodchain.

PAHs cause malignant tumours by
interfering with enzymatic breakdown,
affecting the lungs, stomach, intestines
and skin. The potential of substance
mixtures containing high PAH levels to
causeskincancerisknownsince1775.
Increased
incidences
of
certain
carcinomas of the skin and respiratory
tract have consistently been found
amongcertainoccupationalgroupssuch
as chimney-sweeps, coke oven workers
etc.21

The PAHs found in the soil samples at
the shipbreakingplotsareattributableto
combustion sources - i.e.
torchcutting
and/oropenburning.Besidestheimpact
on the environment, combustion as
a
source implies a double exposure for
workerstothepoisons-first.duringthe
cutting or burning operation through
inhalation of fumes; second, by
inhalation of PAH-laden dust from the
workarea.

Only one soil sample from
Alang was
analysed for dioxins. The fact that the
single sample of soil
analysed for
dioxins tested positive with significant
levels confirms our assumption that
shipbreaking as an activity should be
further evaluated as a potential dioxin
source. Simultaneously, efforts must be
made to pinpoint and isolate the
potential sources lending to the
formationofdioxinsduring shipbreaking.

Dioxins/furans are known to be among
the deadliest of persistent and
bioaccumulative poisonsforwhich there
are no safe levels of exposure. Dioxins
are known human carcinogens. Even at
lowdoses.thesepoisonsarecapableof
causing serious and often irreparable
damagetotheimmuneandreproductive
systems of lifeforms. Their ability to
interfere with the endocrine systems (or
hormone-regulating
systems)
of
mammals also means that they are
capable of causing sexual disorders
alongthefoodchain.
The current low levels should certainly
not be taken as indicative of the
absenceofaproblem.
In fact, owing to its highly toxic nature,
its mobility in the environment and its
ability
to
threaten
the
global
environment, dioxins and
furans are
amongthe12prioritysubstancesslotted

25

for global action under the United
Nations Environment Program’s Treaty
on Persistent Organic Pollutants. The
treaty that is expected to be finalized in
Stockholm in May 2001, callsforstrong
actionto minimize (withtheultimateaim
of elimination where feasible) the
release of industrial by-product POPs
likedioxins.
The Greenpeace investigation did not
focusspecificallyondioxinsand
furans.
However, the confirmed presence of
dioxins at the yards requires that more
indepth studies be conducted to assess
the dioxin contamination throughout the
yard. More importantly, because the
coastlinesurrounding Alangcontinuesto
support a dwindling, yet substantial,
number of sustenance
fisherfolk, it
would be important to investigate the
possible contamination of marine life by
dioxinsoriginatingattheyard.

/.Recommendations

Attheoutset.itmustbesaidthatunder
the given circumstances and conditions
at Alang and internationally (in the
absence of a global regulatory regime),
no recommendations can be made for
Alang that would eliminate health risks
andenvironmentalhazards.
A fully transparent regime allowing
publicscrutinyofthe shipbreaking yards
isamustforconditionstoimprove.The
shipbreaking yards cannot unilaterally
function in a manner that eliminates

threats to the environment and its
workers. Forthistohappen.shipsmust
arrive at the yard decontaminated.
Environmentally, very little can be done
to improve the situation at the
shipbreaking yards unless the ships
arrivedecontaminated.

Apreconditiontoworkplacesafetyisthe
decongestion of shipbreaking yards.
ThismaynotberequiredintheChinese
yards, where space is generously
available. But in Alang, the 30 meter
plots need to be joined with their
neighbours to allow for more space. In
the Mumbai shipbreaking yards, where
space is at a premium, it would be
virtually
impossible
to
improve
conditions significantly. Under the
circumstances as they exist in Mumbai,
closure of the yards may be the only
option to prevent further contamination
oftheenvironmentandworkers.
The shipowners claims that worker
safety is a problem of the
shipbreakers
and
the
shipbreaking
country
governments reflects the ignorance of
the commentators of local regulatory
conditions and climatic conditions. The
temperatures on the plot and on board
theshipcanreach50degreeCelsiusin
Alangsummersmakingitunbearablefor
workers wearing protective clothing
designedforNorthernclimates.
Internationally, itisimportanttoinvestin
thedevelopmentofsafetygearsuitedto
the climatic conditions of India,
BangladeshandChina.

Annexurel
SampleDetailsandAnalysisMethodology

SAMPLE SAMPLE
NUMBER TYPE
18
Insulation
material
19
Seawater
20A
Sediment
20B
Sediment
21
dust+soil
23A
Dust
23B
Dust
24A
Sediment
29A
Seawater
34A
Seawater
35A
Soil
35B
Soil
35C
Soil
35D
Soil
39
Seawater
41A
Sediment

41B

41C
42A
42B

43A
47C
47D
48C

DESCRIPTION

SAMPLING
DATE

Shipbreakingplot,2,800 metrestothewesternfringe

06-06-00

Shipbreakingplot,2,800 metrestothewesternfringe
06-06-00
Shipbreakingplot,2,800 metrestothewesternfringe
06-06-00
Shipbreakingplot,2,800 metrestothewesternfringe
06-06-00
openwastedam,200 metresinlandfrom scrapyard 06-06-00
Livingareal,outside______________________
06-06-00
Livingareal,inside,floor ______________________ _ 06-06-00
westernfringe,500 metresfromthelastplot________ 06-06-00
easternfringe,500 metresfromthelastplot________ 06-06-00
Shipbreakingplot,4,600 metrestothewesternfringe
06-06-00
Shipbreakingplot,4,600 metrestothewesternfringe
06-06-00
Shipbreakingplot,4,600 metrestothewesternfringe
06-06-00
Shipbreakingplot,4,600 metrestothewesternfringe
06-06-00
Shipbreakingplot,4,600 metrestothewesternfringe
06-06-00
Shipbreakingplot,600 metrestothewesternfringe
06-06-00
Shipbreaking plot, 4,600 m to the western fringe,
07.06.00
ebb-tide__________________________________
Sediment Shipbreaking plot, 4,600 m to the western fringe,
07.06.00
ebb-tide___________________________________
Sediment Shipbreaking plot, 4,600 m to the western fringe,
07.06.00
ebb-tide___________________________________
Sediment Shipbreaking plot, 10,100 m to the western fringe,
07-06-00
ebb-tide___________________________________
Sediment Shipbreaking plot, 10,100 m to the western fringe,
07-06-00
ebb-tide___________________________________
Sediment easternfringe, 500 metres from last plot, from the
07-06-00
ebb-tide___________________________________
Dust
Livingareall,inside,floor_______________________ 07-06-00
Dust
Livingareall,inside,bed_______________________
07-06-00
Dust
Livingarealll,temple,inside,beneathcarpet
07-06-00

Listofthe analysedsamplestakenatthe

■

Alang shipbreakingyard

All samples were taken in laboratory PP-bottles (manufactured by SARSTEDT) for
one-time use. The sampling equipment was recommended and made available by
GALAB HightechLaboratories.

■

Methods, detection limits and QA/QC procedures are described in the GALAB
analysisprotocol:

PARAMETER

DETECTION
LIMIT

UNIT

Organotincompounds
Organotincompounds
Dioxinsandfurans

1___
1___
1-50

pg/kg
ng/L
ng/kg

Asbestos_______________
Heavymetals____________ 0,01-0,005
j_______
Polychlorinated biphenyls
Polycyclic
aromatic 1
hydrocarbons
NOTE: Testprocedures marked
standards

fibre
g/kg
pg/kg
pg/kg

METHOD

hexaneNaBEt4,GC-AED DACh
DACh
hexaneNaBEt4,GC-AED
AbfKIarV Anhangl 1.3.3.2
(appendixtowasteordinance)
scanningelectronmicroscopy
DIN38414,TXRF DACh
soxhletextraction,GC-MSD
soxhlet-extraction,GC-MSD DACh
1

DACh are processes accredited in accordance with German DIN 17025

Processesusedanddesignatedlimits

ANNEXURE2

MoretoSafetythanMeetstheEye
Health and Environmental Hazardsat
Alang
A Commentary by
Judit Kanthak,
chemical engineerand Greenpeace’s
technical
person
in-charge
of
conductingthe Alanginvestigation.

Greenpeace campaigner
Nityanand
Jayaraman:“Sir,doyouknowtheoldest
plot in Alang? Where they first started
breakingshipsfromabroad?”

GujaratMaritimeBoard’sCapt.
“Yes...veryclean...nicepeople."

Deulkar:

Such
a
conversation
between
Greenpeaceactivistsand the topofficial
of Gujarat Maritime Board at the
Alang

shipbreaking yard would have been
inconceivable
in
1998,
when
Greenpeace first visited the world’s
largest yard. Things have obviously
changed. Today, the two are sitting
together at a table in Capt.
Deulkar’s
office located between two active
shipbreakingplotsin Alang.
Even a superficial look around the yard
gives the impression that some things
have changed since our last visit in
1998. In the last two years, people in
Alanghavestartedtotakestepsagainst
thevisibleandinvisiblehazardstowhich
workers are exposed both when
dismantling the ships and in their living
quarters. Most workers wear protective
helmets and working clothes; colourful
hand-painted pictorial signs warn of
falling parts and exhorting workers to

use helmets - elementary but crucial
lessonsinworkplacesafety.
Tidiness and cleanliness, too, seem to
be betterappreciated in Alang. Despite
ongoing work, most of the plots we
visited seemed tidy and well-swept. The
floors of the owners’ office - which are
located within the plots are freshly
mopped. Visitors are offered water
withintheminutesoftheirarrival.

Located amidst the noisy, smoky
ambienceoftheshipbreakinngplots.the
worker’saccommodationthough spartan
and unventilated seem tidy, albeit
exposed to dust. Apart from an
oversized hard-bed on which 3-6
workerssleep.thereisnootherfurniture
in the 100 square foot room. The
workers sprinkle water on the floor, of
packed mud, during the day to prevent
dustfromrising.
But the tragedy behind these honest
efforts becomes apparent only upon
evaluationofthechemicalanalyses.

than a comparable sample taken from
the eastern fringe of the 12 km long
stretchof shipbreakingplots.

The Greek word 'asbestos' means
unquenchable, eternal. In
Alang,
asbestos is omnipresent. Asbestos
fibres are carried by the fine dust to
contaminate the air, the soil and the
workers'huts. Outofsixsamples taken
and analysed for asbestos, only one
tested negative - from beneath the
carpet at the Hindu temple at the
shipbreakingyard.

By 'clean', Capt.
Deulkar obviously
means 'well-swept.' Keeping in mind the
mind-boggling quantities of hazardous
substances extracted from ships and
dumped here over the years, Capt.
Deulkar’s use of language is
understandable. Keeping things wellswept is hard enough. To keep things
trulyclean here is impossible unless the
shipscomeinclean.
ANNEXURE3

With the means at hand in
Alang, it is
impossibletoprotectthe workplace, the
living
quarters
and
the
yard
surroundings from ship contaminants.
With every passing day, the levels of
heavy
metals,
polyaromatic
hydrocarbons (PAHs) and tributyl tin
(TBT)inthesoil,coastalsedimentsand
seawaterareincreasing.
Despitetidalcurrentsandsedimentdrift,
the highest concentrations of persistent
pollutants in Alang can be expected
wherethelargestquantitiesofshipsteel
have been recovered over the years i.e.theoldestandmostactiveplots.
A seawater sample taken from the
oldest plot contained 120 times higher
levels of the hormone disrupter TBT

Greenpeace Activities Since 1998
Targeting
the
Shipping
Industry,
GovernmentsandShipbreakers to Seek
Commitment for Improvement to the
Ship Scrapping Practices
AMSTERDAM,FEBRUARY2001
Dutch
environmental
inspectorate
arrests Sandrien, a ship-for-scrap
claimed to be destined for breaking in
Asia.The Inspectorate is investigating if
the ship’s departure to Asia for
scrapping constitutes a violation of the
Basel Convention-based European
wastelegislationprohibitingtheexportof
hazardous wastes to non-OECD
countries. Greenpeace has demanded
that the Sandrien be decontaminated
priortoexportforscrapping.

29

HONGKONG,APRIL29,2000
PROTEST AGAINST P&O NEDLLOYD
SHIPINHONGKONGHARBOUR
Greenpeace activists take action to
protest
proposed
and continued
dumping of ships in China by P&O
Nedlloyd.

ROTTERDAM,APRIL2000
GREENPEACE
MEETS
P&O
NEDLLOYDTOCRITICALLYDISCUSS
COOPERATION
BETWEEN
THE
ANGLO-DUTCH
COMPANY
AND
CHINESEYARD
Greenpeace reiterates demand for
decontamination before export. P&O
Nedlloyd refuses to take hazardous
substancesoutbeforeexportingshipsto
Asia.
LONDON,MARCH2000
GREENPEACE PRESENTS VIEWS
AND
DEMANDS TO SHIPPING
INDUSTRY
AND
WORLD
GOVERNMENTS AT IMO MEPC 44 ™
SESSION
BHAVNAGAR, INDIA, 19 FEBRUARY
2000
INDIAN SHIPBREAKERS COMMIT TO
ENVIRONMENTAL QUALITY AND
WORKERSSAFETY
The outcome of a workshop on
“Challenge to Ship Recycling Industry:
EnvironmentandSafety ”wascelebrated
by industry, environmentalists and
government.
The
Shipbreakers
Association of Indiaagreedtoengagea
drastic transformation of their yards to
incorporate good working practices and
properenvironmental management. The
Shipbreakers also supported the
platform of decontamination of ships
priortodismantling. Maritime Authorities
agreed toaGreenpeace/Ban (and other
NGOs) team to run a fact-finding
missioninthelndianyards.

BELGIUM,21DECEMBER1999
BELGIUMGOVERNMENTARRESTUK
“TOXIC” SHIP BOUND TO INDIA FOR
SCRAPPING
The Belgium Government arrested the
bulk carrier MV FORTHBANK currently
docked in Antwerp after receiving an
unclearresponsefromitsUKownerson
their intention to scrap the vessel in
Alang, the largest shipbreaking yard in
India.
The
Belgium Government
understand that an European ship
a
bound for scrapping in Asia is
hazardous waste export and subject to
the EU hazardous waste export ban in
placesince1998.

NEWDELHI,10DECEMBER1999
GREENPEACE PREVENTS TOXIC
DUMPINGININDIA
Havingchainedthemselvestoananchor
line overnight, Greenpeace activists
successfully delayed the beaching of
cargo vessel 'Clare' destined for
breaking at Alang - the world’s largest
shipbreakingyard in India. Theexportof
hazardous ships-for-scrap to Asian
shipbreaking yards, such as the highly
polluted and unsafe facility in
Alang, is
effectively toxic waste dumping. Indian
Supreme Court orders an enquiry into
Greenpeace’s allegations of toxic waste
dumpingviaships-for-scrap.
NEWDELHI,8DECEMBER1999
WESTCONTINUESTOSEND'TOXIC"
SHIPSTOINDIA
Greenpeace today highlighted the
continuing dangerous practice of
sending Western-owned or operated
”toxic"shipstodevelopingcountriessuch
as India for dismantling. Workers in
developing countries are being exposed
toasbestosandother
poisons from ships broken up in
unsound labour and environmental
condition yards in India, Bangladesh,

China, Philippines and Pakistan. This
morning,at Alang in western India-the
world's largest shipbreaking yard
activists from the Greenpeace flagship
the Rainbow Warrior painted warning
signs on the hull of the Global Sao
Paulo, a Greek operated vessel waiting
to be dismantled. Another six vessels
were in the area ready to be scrapped.
Greenpeace displayed a banner in an
inflatable boat in front of the yard to
highlight the danger to workers caused
byscrappingof toxicsships.

ROTTERDAM,9NOVEMBER1999
GREENPEACE
PROTESTS
THE
DUMPINGOFTOXICSHIPSTOASIA
Greenpeace activists today protested
plans to scrap the ocean carrier
Tokio
ExpressinChinaanddemandedthatits
owner, Costamare Shipping and its
operator
Hapag-Lloyd ensure that
hazardous materials are removed from
the ship prior the scrapping. Activists
painted warning messages in Chinese
and Hindionthehulloftheship while it
dockedattheportofRotterdam.
HapagLloyd agrees to make an inventory of
hazardoussubstancesbeforetheshipis
sent for'scrap. The inventory will be
handedoverto shipbreakingcompany.
MUMBAI, INDIA,21SEPTEMBER1999
TRADE UNIONS AND GREENS JOIN
HANDS TO CHALLENGE DIRTY
SHIPBREAKINGINASIA
The International Transport Workers
Federation (ITF) hastodayjoined hands
with Greenpeace, Basel Action Network
and Indian trade unions to highlight the
occupational health and environmental
hazards caused by ships contaminated
with toxins exported to Asia for salvage
and disposal - an operation known as
shipbreaking.

BIELEFELD/HAMBURG,10MAY1999
GREENPEACE PROTEST GERMAN
FOOD CO'S EXPORT OF ASBESTOS
TOINDIA
The German food company,
Dr.Oetker,
plans to scrap
two asbestoscontaminatedshipsinAsia,disregarding
the fact that this endangers workers
there. Greenpeace exposed the plan
todayinadirectactionatthe
Dr.Oetker
officeonthe Jahnplatzin Bielefeld. This
morning, Greenpeace activists placed a
20 x 12 ft 'blow-up' photo under the
company logo depicting Indian workers
breaking up ships with the caption
reading, 'Dr.Oetker exporting cancer'.
Below the company was accused of
producing 'pudding powderforGermans
-asbestosdustforlndians'.

HONGKONG,12APRIL1999
P&ONEDLLOYD:STOPTOXICTRADE
Greenpeace activists today symbolically
returned highly carcinogenic asbestos,
containedinasealeddrumtoits rightful
owner,
shipping
company
P&O
Nedlloyd, in Hong Kong and urged the
company to stop dumping toxic waste
shipsinChina.Theactioncoincideswith
negotiations of a technical working
group on the
Basel Convention in
Geneva, Switzerland,
seeking to
address issues of waste dumping from
rich industrialised countries into less
industrializedcountries.
NEWDELHI.18FEBRUARY1999
SHIPBREAKING IS DANGEROUSLY
POLLUTING-GREENPEACEREPORT
FINDS
Greenpeace today released the first
ever technical and environmental data
on the toxic contamination caused by
shipbreaking in India through its
investigative report "Ships for Scrap:
Steel and Toxic Wastes for Asia." The
report which was presented at a press
conference in New Delhi confirms

31

• J

allegations by trade unions and non
governmental organisations (NGOs)
aboutthewidespreadcontaminationand
occupational hazards at the Alang and
Mumbai shipbreaking yards in India.
However its implications reach far
beyond India becausesimilarconditions
areknowntoexistinother
shipbreaking
states,
particularly
Pakistan,
Bangladesh, the Philippines, China and
Vietnam.
SINGAPORE,! 1JANUARY1999
ENVIRONMENTALISTS
PROTEST
TOXICSHIPEXPORTTOASIA
Greenpeace and Basel Action Network
(BAN) activists escorted the toxiccontaminated ship Encounter Bay as it
arrived in Singapore harbor this
morning, toprotestagainsttheexportof
toxic waste to Asia. In a daring
waterborne protest the environmental
activists flew banners reading "P&O
Nedlloyd Stop Toxic Trade" as the
vessel approached the harbor. After it
docked, they attached another giant
bannertothesideoftheship.Singapore
is the fifth city where Greenpeace and
BANhaveprotestedagainsttheshipas
it makes it final journey before being
scrapped.

AUCKLAND, NEW ZEALAND, 22
DECEMBER1998
GREENPEACE, BAN TAKE ACTION
AGAINST P&O NEDLLOYD SHIP
“ENCOUNTERBAY”
Police arrest Greenpeace activists
chained to ship to prevent ship’s
departuretoAsianscrappingyard.
SYDNEY,AUSTRALIA,18DECEMBER
1998
Greenpeace takes action against P&O
Nedlloydship“EncounterBay.”
Activists detain the ship by staying on
board the ship for a full-day to protest
the refusal of the company to

32

decontaminate the ship before exportto
Asia.
ROTTERDAM, THE NETHERLANDS,
17NOVEMBER1998
Action at P&O Nedlloyd headquarters.
Greenpeace submits and explains
demandstoDirectorVan Slobbe.

BARCELONA, SPAIN, 15N0VEMBER
1998
Greenpeace, BAN launch direct action
againstP&O Nedlloyd ship “Encounter
Bay”.
Company
refuses
to
decontaminate ship prior to export to
Asia.
Activists hang banner reading “P&O
Nedlloyd: Stop Dumping on Asia” on
ship.

NEW DELHI, INDIA, 21 JANUARY
1998.
Greenpeace, Basel Action Network and
Indian Trade Unions Join Hands to
Protest Against the Export of Toxic
ships-for-scraptolndia.
A wide spectrum of individuals and
organisations including activists from all
the Indian central trade unions, people’s
movements and citizens’ groups came
togethertodayinapeacefulandcolorful
protest against the US Government’s
decision to allow the US Navy and
Federal Maritime Administration to
export their toxic-laden ships to India,
BangladeshandPakistan.

NOTE:
InadditiontotheseactivitiesGreenpeacehas
given presentations at various global events
liketheNOR(wegian)SHIP fare in Oslo, the
First Global Shipbreaking Congress in
Amsterdam, the Green Shipping Conference
in Hamburg during the last 3 years.
Greenpeace has also successfully placed the
issueontheagendaofthe Basel Convent ion
onhazardouswastetradeandthelMO.

'SubmissionbythelntemationalChamberof
Shippingtothe“ShipRecyclingWorkingGroup”on
31July2000
2 ARD Erstes Deutsches Femsehen(FirstGerman
TV),ReportMainz,November23,1998
3ChapterXII,Sec 16( i)(d).Extraordinary Gujarat
GovemmentGazetteNotification, ExtraNo. 640,
dt/.
August31,2000. GujaratMaritimeBoard
OSPAR ComissionfortheProtectionoftheMarine
EnvironmentoftheNorth-EastAtlantic,
Agreement 1997-15
5B iirgerschaftderFreienundHansestadtHamburg
Drucksache 16/3080.September26,1999.“Hamburg
Baggergutkonzept”(HamburgParliamentDredging
SludgesConcept)
6 German EPA/Umweltbundesamt, Daten zur
Umwelt, Der Zustand der Umweltin Deutschland
2000,ErichSchmidt Verlag&Co.,Berlin
2001 .(Environmental Data)
7Seepagel9of‘ShipsforScrap:SteelandToxic
WastesforAsia-A factfindingmissiontothelndian
shipbreakingyardsin AlangandBombay.”
Greenpeace,March 1999.
8Seepagel3,“ShipsforScrapII:SteelandToxic
WastesforAsia-Workerhealth&safetyand
environmentalproblemsattheChang Jiang
ShipbreakingyardoperatedbytheChinaNational
ShipbreakingCorporationinXiagangnear Jiangyin.”
Greenpeace,Decemberl 999.
’Contrast AdviesforGreenpeaceNetherlands,
September 1999.“Asbestos:Deepinthevery
fibres
ofsociety-Asummaryreport”
Lloyd’sList(Markets:Demolition), Wednesday,
January 19,2000.“GreenpeacestrategyupsetsIndian
break'ers.”
11 “AcertificatefromtheMasteroftheshipshalIb<>e
presentedtothePortOfficer,atthetimeof
submissionofapplicationunderClause(a)above,
certifyingthatnodangerousgas,toxicoranyother
hazardouschemical/wastearepresentonboardofthe
shipandcertificateofentryaspersection36ofthe
FactoriesActbycompetentpersonareproduced.”
Extraordinary GujaratGovemmentGazette
Notification,ExtraNo.640, dt/.August31,2000.
GujaratMaritimeBoard.
‘“TheCentralPollutionControlBoardstatesinits
“EnvironmentalGuidelinesfor Shipbreaking
lndustries”that:“Oldvesselscontainingor
contain inatedwithanyoftheabovesubstances
[PCBs.wasteasbestosdustand fibre.leadandlead
compoundsjareaccordinglyclassifiedashazardous
materials.Thecustomsauthorityand/orthe
concemedStateMaritimeBoardshouldensurethis
andissueacertificatetothiseffectthatthevesselis
freefromtheprohibitedmaterials.”

13TheIndianSupremeCourtdecidedon5May 1997:
“Noimportshouldbemadeorpermittedbyany
authorityoranypersonofanyhazardouswastewhich
isalreadybannedunderthe BaselConventionortobe
bannedhereafterwitheffectfromthedatespecified
therein.”

(US)NationalCancerlnstitute, Questions
and Answers About Asbestos Exposure, last
modified27Nov2000,asdistributedby
www.meb.uni-bonn.detancernet/600321.html

15 PetoJ, DecarIiA,La VecchiaC,LeviF, NegriE.
TheEuropean mesotheliomaepidemic.British
JoumalofCancer, 1999;79:666-672.
l6Contrast AdviesforGreenpeaceNetherlands,
Septemberl999.“Asbestos:Deepinthevery
fibres
ofsociety-Asummaryreport”
17PublicationIMO1998.
18
Greenpeace Factsheet,September 1999:“TBT:A
GlobalProblemfortheMarineEnvironment.”
19 Maack,T.,GreenpeaceGermany:“TBTHotspots
inEurope”. September2000.
GermanTechnicalRegulationonHazardous
Substances,June 1996,relatingtoseveralhazardous
substanceswhichcanenterthehumanbodythrough
skin.
TRGS150, Technische RegelnfiirGefahrstoffe,
UnmittelbarerHautkontaktmitGefahrstoffen,die
durchdieHautresorbiertwerdenkonnen
(HautresobierbareGefahrstoffe),Juni 1996.
21 Mentionedin Kanthak,J.&A. Bernstorff,“Ships
forScrapII:SteelandToxicWastesforAsiaWorkerhealth&SafetyandEnvironmentalProblems
attheChang Jiang ShipbreakingYardoperatedby
ChinaNational ShipbreakingCorporation,at
Xiagang,near Jiangyin,China.

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