Danish Ports' consultation response to the draft amended executive order on the reception of waste from ships
Danske Havne acknowledges the opportunity to submit comments on the draft revised executive order on reception facilities for waste from ships, on the delivery of waste from ships and on port waste plans.
It is noted with satisfaction that the suggestions made by Danish Ports in connection with the pre-consultation are largely included in this draft, and it is recognized that the proposal is part of a technical directive implementation.
However, Danish Ports would like the following suggestions for definitions and practical considerations to be included in the executive order so that the work of receiving and handling waste from ships at the ports can be carried out as efficiently as possible in practice. This can also reduce disagreements and increase the recycling of waste.
- §1(2). It should be more clearly stated that the port should only accept waste free of charge during working hours, as is also the case today.
- As a requirement under §3, it should be included that the ships' equipment for delivering the waste is in a suitable condition so that the port's reception facilities can actually receive and handle the waste in a responsible manner. There are examples of hoses from ships being far too short to reach the quayside, making it unnecessarily expensive and time-consuming to establish a connection to the ship. In addition, risks can arise regarding the working environment.
- Regarding the procedure with receipts, as described in section 11: The ports should not be burdened with unnecessary extra costs, such as the extra workflow in connection with waste receipts that is proposed in the proposal. It is proposed in the draft that the ship reports the waste quantities in SafeSeaNet, after which the waste is collected and the employee must report back on how much has been collected. This must be entered in a new form (Appendix 3) and handed in or sent to the ship. Danish Ports' suggestion: If data from SafeSeaNet can be included in Appendix 3, this can be adjusted and sent back to the ship if there is an e-mail to the ship in SafeSeaNet, and there should be.
- The word "operational waste" mentioned in §13 should be precisely defined in §4. This will prevent the doubts that currently exist at ports regarding wastewater from passengers on passenger ferries.
Environmental Policy Consultant, Danish Ports