Audible response

Executive Order on requirements for certificates on board ships, requirements for ship recycling facilities, and designation of competent authorities pursuant to the Ship Recycling Regulation and the Hong Kong Convention, etc.

Danske Havne would like to thank you for the opportunity to comment on the draft executive order on the implementation of parts of the Hong Kong Convention in Denmark.

Danske Havne believes that the Hong Kong Convention for 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 promote safety and environmental considerations in connection with ship recycling.

General remarks

When designating competent authorities, Section 3 of the Executive Order states that the municipal council is the authority for provisions relating to environmental protection, and Section 4 states that the Danish Working Environment Authority is the authority for provisions relating to the working environment.

The purpose of the Hong Kong Convention is to ensure that ships are scrapped in a manner that is both safe and environmentally sound. Danske Havne therefore believes that the relevant commercial ports should be involved by the competent authorities in the processing of ship scrapping plans. This is to ensure that there is space for registered ships in the port.

For example, the municipality will assess cases based on environmental considerations, while the port is responsible for operational safety in the port area. Both considerations are key to ensuring responsible dismantling in accordance with the objectives of the Convention.

The safety challenge lies in the fact that shipbreaking facilities want to bring more elements into ports than there is physical capacity and safety basis for. This may pose a safety risk that goes beyond what the municipality assesses as an environmental authority.

Danske Havne therefore proposes that the executive order be clarified so that the competent authority is obliged to involve relevant commercial ports in cases concerning ship dismantling, including when approving ship dismantling plans and determining any conditions for dismantling.

Sincerely,
Christine Bjaldby Christensen