Audible response

Port Denmark's consultation response regarding the draft for an amended reception order for waste from ships

Danish Ports acknowledges the opportunity to comment on the draft revised executive order on reception facilities for waste from ships, on ships' delivery of waste and ports' waste plans.

It is noted with satisfaction that Port Denmark's suggestions in the pre-consultation are to a large extent included in this draft and it is recognized that the proposal is part of a technical directive implementation.

However, Danish Ports would like to see the following suggestions for definitions and practical considerations included in the executive order so that the work of receiving and handling waste from ships at ports can be carried out as efficiently as possible in practice. This can also reduce disagreements and increase the recycling of waste.

  • §Section 1, paragraph 2. It should be made clearer that the port must only accept waste free of charge during working hours, as is currently the case.
  • A requirement under §3 should include that the ships' equipment for delivering the waste is in a suitable condition so that the port reception facilities can actually receive and handle the waste in a safe manner. There are examples of hoses from the ships being too short to reach the quay, making it unnecessarily expensive and time-consuming to establish a connection to the ship. It can also create health and safety risks.
  • Regarding the procedure with receipts, as described in § 11: The ports should not incur unnecessary extra costs, such as the extra workflow in connection with waste receipts that the proposal suggests. It is proposed in the draft that the ship reports the amount of waste in SafeSeaNet, after which the waste is collected and the employee must report back regarding how much has been collected. This must be entered in a new form (Appendix 3) and handed in or sent to the ship. Danske Havnes proposal: 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 for 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 in ports regarding waste water from passengers on passenger ferries.

Sincerely yours

Camilla Rosenhagen
Environmental Policy Consultant, Danish Ports