Clean Ships, Clean Ports, Clean Oceans: Controlling Garbage and Plastic Wastes at Sea (1995)
Chapter: Organizational and Operational Changes
and missions, (2) be sized to the space available on boats and ships, (3) be reliable and cost effective and (4) produce processed garbage in appropriate form for safe disposal as defined by Annex V (Smookler and Alig, 1992). Technologies tailored for use in port reception facilities also would support Annex V; existing technologies used to manage other waste streams need to be adapted for use in ports.
As valuable as technology may be, it is not a panacea for environmental problems. Research suggests there is a maximum 35 percent ongoing implementation level for federal environmental regulations that include technological applications (Burby and Patterson, 1993).1 Therefore, supplementary interventions are required.
Organizational and Operational Changes
Organizational and operational changes are crucial to the Annex V regime, which attempts to change some very old practices. Responsible handling of vessel garbage has not been emphasized in business or government until recently, and there is much to modify. Necessary organizational and operational changes that have been identified include (1) consistent articulation of commitment to comply with Annex V by top executives of corporations involved in marine activities, (2) standardization and closer integration of vessel and port garbage handling practices so that vessel operators know what to expect, and (3) improved coordination among the various federal agencies responsible for implementation of Annex V. The first of these factors is addressed here. The integration of garbage handling practices is addressed in Chapter 5, and the issue of coordinating federal agency activities is addressed in Chapter 7.
Bassow (1992) emphasizes that implementation of environmental regulations requires combining appropriate changes in technology with changes in corporate culture. He explains:
In the last 20 years, many U.S. companies have adopted comprehensive environmental policies. They have introduced new procedures and technologies to reduce and eliminate harmful impacts on the environment and human health. But these are technological fixes, engineering fixes. The much more difficult challenge is to change the way people within a company think about the company's environmental policies, to change their attitudes and their mind set, in effect, to change their collective beliefs about the way the company does business. We're now talking about changing the corporate culture.
TABLE 3-1 Applying the Hazard Evolution and Intervention Model to MARPOL Annex V Provisions
|
Hazard Evolution Model |
Behavior that Encourages Generating Garbage |
On-board Generation of Garbage |
Breakdown in Compliance |
|
Intervention Model |
Modify Behavior that Encourages Generating Garbage |
Reduce Garbage Generation during Voyage |
Prevent Breakdown in Compliance |
|
Technological |
Behavior modification is encouraged throughout guidelines but not mandated by Annex V regulations. |
While not mandated by Annex V regulations, waste reduction is encouraged explicitly by Guideline 3 (Minimizing the amount of potential garbage). |
|
|
Organizational and Operational |
No restrictions are imposed. As long as the garbage generated is disposed of properly, no on-board activities need be constrained. |
Waste reduction is encouraged but not required. |
|
|
Hazard Evolution Model |
Discharge of Garbage into Sea |
Exposure to Discharged Garbage |
Consequence of Discharged Garbage |
|
Intervention Model |
Block Discharge of Garbage into Sea |
Block Exposure to Discharged Garbage |
Diminish Consequences of Discharged Garbage |
|
Technological |
Guideline 4 (Shipboard garbage handling and storage procedures) and Guideline 5 (Shipboard equipment for processing garbage) address means for meeting the need to retain garbage on board for disposal in port reception facilities (addressed in Guideline 6). |
Pretreatment prior to release apparently is intended to minimize, although not block, the exposure to the garbage. Both food and nonfood garbage may be discharged after comminution to particles less than 25 mm in diameter. |
Guideline 4.3.5 encourages recovery of garbage at sea, but retrieval is not mandated. |
|
Organizational and Operational |
Discharge is only partially blocked. Overboard disposal of plastics is prohibited but many other items may be so discharged (Regulation 3). Pretreatment (i.e., grinding) is required in some cases. |
Restrictions vary by the location of discharge. Annex V provides maximum protection to coastal sea within 25 miles of shore. Floating non-plastic garbage may be discharged beyond 25 miles (Regulation 3.1.b.i). "Sinkable" garbage may be discharged beyond 12 miles (Regulation 3.1.b.ii). No discharges except ground food waste are permitted from fixed or floating structures. |
Annex V emphasizes the elimination of plastic discharges, which are judged most harmful. IMO guidelines encourage prevention and retrieval of lost fishing gear, even though such loss does not violate Annex V. |
|
Hazard Evolution Model |
Behavior that Encourages Generating Garbage |
On-board Generation of Garbage |
Breakdown in Compliance |
|
Intervention Model |
Modify Behavior that Encourages Generating Garbage |
Reduce Garbage Generation during Voyage |
Prevent Breakdown in Compliance |
|
Educational (Target Population/Content) |
Guideline 2 calls on governments to "develop and undertake training, education and public information programmes suited for all seafaring communities under their jurisdictions." Guideline 2.2 encourages exchange of information on compliance strategies. |
|
Placards and notices must be provided to crews of vessels over a certain size (under U.S. law). Annex V can be used as a tool in fostering public support for and raising mariners' environmental awareness. |
|
Regulation and Enforcement (by governments and private organizations in signatory nations, as required by the treaty and international law) |
|
|
Guideline 7.3 recommends that national governments assist and recognize compliance initiatives by private and professional organizations. |
|
Hazard Evolution Model |
Discharge of Garbage into Sea |
Exposure to Discharged Garbage |
Consequence of Discharged Garbage |
|
Intervention Model |
Block Discharge of Garbage into Sea |
Block Exposure to Discharged Garbage |
Diminish Consequences of Discharged Garbage |
|
Educational (Target Population/Content) |
To effect the changes mandated by Annex V, the guidelines encourage provision of both general information and specific education about means to comply. Guidelines also encourage technical exchange concerning improvements achieved in performance and equipment used for complying with garbage restrictions. |
|
|
|
Regulation and Enforcement (by governments and private organizations in signatory nations, as required by the treaty and international law) |
Annex V requires signatory nations to provide "adequate" reception facilities. Guideline 7.1 (Enforcement) suggests means to organize national authorities, record use of port reception facilities, and verify vessel operators' activities. |
Guideline 1.3 encourages the maximum use of port reception facilities rather than continued discharges at sea, even where legal. |
|
|
Hazard Evolution Model |
Behavior that Encourages Generating Garbage |
On-board Generation of Garbage |
Breakdown in Compliance |
|
Intervention Model |
Modify Behavior that Encourages Generating Garbage |
Reduce Garbage Generation during Voyage |
Prevent Breakdown in Compliance |
|
Economic (Market Forces) |
|
|
Guidelines include directions for estimating the required capacity of reception facilities but many uncertainties remain. Guideline 7.2 addresses compliance incentives, such as funding for capital investment in port facilities or garbage hauling infrastructure. |
It is likely that changing the orientation of personnel at all levels of an organization (i.e., changing the corporate culture) becomes more important when compliance with a regulation is very challenging, as in the case of Annex V.
Indeed, organizational and operational changes may be essential in order to engage personnel and other resources in the effort to comply with Annex V. Such changes can range from modifying a procurement officer's job description to specifying that suppliers use reusable packaging, to reorganizing a port's waste management operations so that services are integrated. Organizational activities also can include development of company rules for handling garbage and internal penalties for violations of the rules, up to and including dismissal (Estes, 1993). These approaches must be supported by training, to prepare the organization for
|
Hazard Evolution Model |
Discharge of Garbage into Sea |
Exposure to Discharged Garbage |
Consequence of Discharged Garbage |
|
Intervention Model |
Block Discharge of Garbage into Sea |
Block Exposure to Discharged Garbage |
Diminish Consequences of Discharged Garbage |
|
Economic (Market Forces) |
Annex V does not establish cost criteria for reception facilities but acknowledges implicit costs (delay to ships). Garbage hauling fees add to ship operating expenses. Annex V does not require ports to charge fees or ships to land garbage |
|
|
Annex V compliance, and commitment of organizational resources to develop new internal garbage management plans.
Again, Table 3-1 makes it clear that the drafters of Annex V expected seafarers to include organizational and operational changes in their compliance plans. No specific changes are mandated, however. By establishing performance standards, the drafters left managers and operators the flexibility to devise a compliance program that best suits their circumstances.
To effect a change in corporate culture, according to Bassow, there must be communication, involvement of all managers and employees, training and support, and system alignment to the new goals. "The experience of large corporations shows that synergy between technological change and a responsive corpo-
