Clean Ships, Clean Ports, Clean Oceans: Controlling Garbage and Plastic Wastes at Sea (1995)
Chapter: Analysis of Interventions
obtain such a certificate would be considered a violation of Annex V. (Apart from providing some international control over shipboard garbage management, the certificate approach also could be a mechanism for confirming whether a ship has a comprehensive capability to manage all its Annex V garbage and APHIS wastes on board. Such a capability could exempt a ship from any requirement to off-load garbage at U.S. ports [an option discussed in Chapter 5].)
The Animal and Plant Health Inspection Service exerts fairly tight control over cargo ships. Inspectors board many arriving vessels; for violations of APHIS disposal regulations, penalties may be assessed and fines must be paid within 72 hours. A "blacklist" is maintained of vessels with recent violations, and these vessels are monitored closely. During boardings, in addition to checking for compliance with quarantine regulations, APHIS inspectors also ask four questions concerning Annex V.7 However, any Annex V violations discovered must be referred to the Coast Guard, and a decision may not be rendered for months.
Shoreside garbage disposal can be a problem for cargo ship operators, because disposal costs often are perceived as too high (see Chapter 5) and port reception facilities may be inconveniently located or their use may be denied. The Coast Guard exerts some control over U.S. public ports and operators of large private terminals through the COA program, but cost and convenience levels are not regulated. Some cargo ships, such as bulk carriers and chemical tankers, never call at a public port; instead, they go directly to the private waterfront terminals of the cargo owner. Some private terminals have been reported to turn cargo ships away when they attempt to off-load garbage, while other facilities, notably refineries, are so remote that it is difficult to arrange for services, such as off-loading of food-contaminated plastics and other garbage that must be quarantined.
Analysis of Interventions
Table 4-3 outlines possible interventions to improve Annex V implementation in the cargo ship sector. Due to the international profile of this sector, the most useful options are those that can improve compliance by foreign-flag as well as U.S.-flag ships.
Technological innovations can be adopted by any ship operator. But it is clear that experts outside the merchant marine—designers, vendors, engineers—
TABLE 4-3 Applying the Hazard Evolution and Intervention Model to Cargo Ships and Their Itinerary Ports
|
Hazard Evolution Model |
Behavior that Encourages Generating Garbage |
On-board Generation of Garbage |
|
Intervention Model |
Modify Behavior that Encourages Generating Garbage |
Reduce Garbage Generation during Voyage |
|
Technological |
|
Reduce use of discardable packaging. Design packaging techniques and storage systems that minimize need for plastic wrappings and bindings as well as packing materials. |
|
Organizational and Operational |
Assure that organizational culture encourages commitment to proper garbage management at all levels, using TQM methods and expediting implementation of ISM. |
Use only vendors committed to packaging and storage techniques that minimize waste. Sort garbage at the site of generation. |
|
Educational (Target Population/Content) |
Modify crews' comfort expectations and attitudes about waste management. Encourage acceptance of need to avoid individually packaged items. Train shoreside personnel vessel operators, and crews in TQM/ISM principles. Train regulatory authorities at federal, state, and port levels in TQM principles to break down barriers and achieve regulatory synergy. |
Inform management about packaging alternatives. Encourage vendors to develop alternate packaging. Encourage packaging manufacturers to develop affordable, reusable containers. |
|
Hazard Evolution Model |
Breakdown in Compliance |
Discharge of Garbage into Sea |
Exposure to Discharged Garbage |
|
Intervention Model |
Prevent Breakdown in Compliance |
Block Discharge of Garbage into Sea |
Block Exposure to Discharged Garbage |
|
Technological |
Design garbage storage space into ships. Keep shipboard systems well maintained. Establish. system for garbage pickup at ports that meets Annex V and APHIS requirements. |
Develop and install appropriate garbage handling equipment, such as efficient, safe incinerators and reliable shredders and compactors. |
Promote affordable compactors that create non-buoyant waste slugs (with no plastics). |
|
Organizational and Operational |
Establish internal company penalties for noncompliance. Encourage commitment to garbage management at the level of the individual. |
Establish clear policies and procedures for a comprehensive garbage management system. Standardize port disposal services. |
|
|
Educational (Target Population/Content) |
Provide constant reminders via posters and placards aboard ships. Educate vessel operators and crews about the types of garbage subject to Annex V versus APHIS regulations. Require crew education for entry into U.S. waters or ports. |
Inform crews of compliance requirements and methods and the harm caused by improper discharges. Inform managers of compliance methods, both organizational and technological. Inform regulators about ways to improve integration of Annex V and quarantine regimes. Develop recycling programs for items (cans) often discarded overboard. |
|
|
Hazard Evolution Model |
Behavior that Encourages Generating Garbage |
On-board Generation of Garbage |
|
Intervention Model |
Modify Behavior that Encourages Generating Garbage |
Reduce Garbage Generation during Voyage |
|
Government or Private Regulation and Enforcement |
Change regulatory balance to emphasize cooperation rather than control. Clarify Annex V roles and relationships of federal, state, and port agencies. Coordinate efforts at ship/port interface. |
Restrict use of certain materials on ships. |
|
Economic (Market Forces) |
Include environmental impacts in cost-benefit analyses of garbage management systems (typically rated on profitability and efficiency). Establish cost benefits for all possible solutions (i.e., conduct impact analysis); identify optimal solution from cost benefit standpoint. |
Develop reusable packaging that is more cost effective than traditional materials or has a life-cycle cost benefit. |
are essential to technological advancement in this sector. For example, alternative packaging and storage systems need to be developed that minimize use of plastics. Appropriate garbage treatment equipment needs to be designed into new ships and, where necessary and feasible, purchased or developed and retrofitted on existing ships.
Because this is an industrial community, organizational interventions are important. Garbage management strategies must be integrated into standard and emerging industrial practices, such as Total Quality Management (TQM) and the International Safety Management (ISM) Code adopted recently by the Interna-
|
Hazard Evolution Model |
Breakdown in Compliance |
Discharge of Garbage into Sea |
Exposure to Discharged Garbage |
|
Intervention Model |
Prevent Breakdown in Compliance |
Block Discharge of Garbage into Sea |
Block Exposure to Discharged Garbage |
|
Government or Private Regulation and Enforcement |
Audit practices to ensure full compliance. Tighten inspection of port reception facilities. Require flag states to issue waste management certificates. |
Require logs of waste handling transactions. Tighten port state controls and inspections, Require off-loading of Annex V (and APHIS) garbage at port calls. |
|
|
Economic (Market Forces) |
Bounty provision in U.S. law may encourage peer surveillance and discourage violators. Return monies from recycling to vessel crew for their discretionary use. |
Make on-board waste treatment equipment and use of port reception facilities affordable. Incorporate disposal costs into port user fees/tariffs. Spread cost across entire port user base. |
|
tional Maritime Organization (1993). The ISM lays the foundation for a new organizational and cultural framework for ship management, requiring that policies and actions be consistent within an organization and focusing attention on human factors. Shipping company operators can establish an organizational culture that supports proper garbage management by using only vendors that minimize waste, establishing clear and effective policies and procedures, and imposing internal penalties for infractions of the rules.
Educational interventions must target not only vessel crews but also shipping
