Consultation Responses

The Executive Order on Requirements for Certificates on Board Ships, Requirements for Ship Recycling Facilities, and the Designation of Competent Authorities Pursuant to the Ship Recycling Regulation and the Hong Kong Convention, etc.

Danish Ports would like to express its gratitude for the opportunity to submit comments on the draft executive order implementing parts of the Hong Kong Convention in Denmark.

Danish Ports believes that the Hong Kong Convention on the Safe and Environmentally Sound Recycling of Ships is an important contribution to maintaining commercial ports as active business areas and safe workplaces. Danish commercial ports therefore wish to support efforts to ensure safety and environmental protection in connection with ship recycling.

General Remarks

With regard to the designation of competent authorities, Section 3 of the executive order states that the municipal council is the competent authority for provisions concerning environmental protection, and Section 4 states that the Danish Working Environment Authority is the competent authority for provisions concerning the working environment.

The purpose of the Hong Kong Convention is to ensure that ship recycling is carried out in a manner that is both safe and environmentally sound. Danske Havne therefore believes that the competent authorities should involve the relevant commercial ports in the review of ship recycling plans. This is to ensure that there is sufficient space in the port for registered ships.

For example, the municipality will assess cases based on environmental considerations, while the port is responsible for operational safety within the port area. Both considerations are essential to ensuring responsible shipbreaking in accordance with the Convention’s objectives.

The safety challenge lies in the fact that shipbreaking facilities want to bring more equipment into ports than the physical capacity and safety infrastructure can accommodate. This may pose a safety risk that extends beyond what the municipality, in its capacity as an environmental authority, assesses.

Danish Ports therefore proposes that the executive order be clarified so that the competent authority is required to involve relevant commercial ports in cases involving shipbreaking, including when approving shipbreaking plans and establishing any conditions for shipbreaking.

Sincerely,
Christine Bjaldby Christensen