Posted: October 20th, 2022

The Role of the Ship Breaking Industry in Bangladesh and its future with special emphasis on capacity building through Education and Training

The Role of the Ship Breaking Industry in Bangladesh
and its future with special emphasis on capacity
building through Education and Training

ABSTRACT
Title of Dissertation: The Role of the shipbreaking industry in Bangladesh and
its future with special emphasis on capacity building
through Education and Training.
Degree: MSc
The ship breaking is considered to be the most sustainable way of disposing end of life ships.
Incentives behind the development of the shipbreaking industry are multi-faceted, among
which economic benefits and employment opportunities are most prominent. Yet the
industry received much attention globally due to many fatal accidents causing loss of life,
degradation of environmental due to the prevailing unsafe working practices especially in
south Asia.
This dissertation is a study to understand the shipbreaking in general with influencing factors
for driving and holding its position in south Asia particularly in Bangladesh. The shipping &
demolition market dynamics analyzed with future trend of the industry.
This study focuses on the occupational health and safety issues involve in this industry and
how this has been addressed by the government of Bangladesh. The transition from past
practices towards green recycling is demonstrated by examining the drastic actions taken by
the competent authority. The formation of new rule and its application with Education and
Training of workers has been analyzed to find out the gaps.
Finally the critics and recommendations of the author in relation to capacity building through
Education and Training of shipbreaking workers has been emphasized for sustainability of
this industry.
KEYWORDS: Shipbreaking, Training and Education, Issues, Rule, Transition,
Sustainability.
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TABLE OF CONTENTS
DECLARATION ……………………………………………………………………………………………………… ii
ACKNOWLEDGEMENT ………………………………………………………………………………………… iii
ABSTRACT……………………………………………………………………………………………………………..iv
TABLE OF CONTENTS…………………………………………………………………………………………… v
LIST OF FIGURES …………………………………………………………………………………………………viii
LIST OF TABLES……………………………………………………………………………………………………. x
LIST OF ABBREVIATIONS AND GLOSSARIES ………………………………………………………xi
Chapter I………………………………………………………………………………………………………………….. 1
Introduction……………………………………………………………………………………………………………… 1
1.1 Background …………………………………………………………………………………………………….. 1
1.2 Aims and objectives of the study. ………………………………………………………………………. 4
1.3 Methodology of the study. ………………………………………………………………………………… 4
Chapter II …………………………………………………………………………………………………………….. 6
The Role of the Ship Breaking Industry in Bangladesh………………………………………………. 6
2.1 Background of ship breaking in Bangladesh………………………………………………………… 6
2.2 The advantages derived from the geographical location …………………………………….. 10
2.3 Economic interest of this industry in local and global context……………………………… 11
2.4 Rationale for locating the ship breaking industry in Bangladesh…………………………… 20
Chapter III……………………………………………………………………………………………………………… 28
Major Issues in shipbreaking industry and Addresses by local Authority……………………….. 28
3.1 Two major concerns related to the shipbreaking business……………………………………. 28
3.2 Environmental Impact of Ship Breaking……………………………………………………………. 29
3.3 Workers Health and Safety Issues…………………………………………………………………….. 32
3.4 Addresses/Response by local Authority…………………………………………………………….. 36
Chapter IV……………………………………………………………………………………………………………… 45
Ship Breaking Yard…………………………………………………………………………………………………. 45
4.1 Introduction to yard structure…………………………………………………………………………… 45
4.2 Permanent workers…………………………………………………………………………………………. 48
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4.3 Migrant workers…………………………………………………………………………………………….. 49
4.4 Procedures involved in shipbreaking stages……………………………………………………….. 53
Chapter V………………………………………………………………………………………………………………. 60
Existing conditions of SBRI – Observations and remarks…………………………………………. 60
5.1 Remarks on the observed yard infrastructures……………………………………………………. 60
5.2 Observation on the present operational practices………………………………………………… 67
5.3 Comments and perception on safety awareness after the yard visit and interviews …. 70
Chapter VI……………………………………………………………………………………………………………… 71
Present development of capacity building and training infrastructure…………………………….. 71
6.1 Legal background and sustainable requirements ………………………………………………… 72
6.2 Evolution of training infrastructure and Current developments…………………………….. 77
6.3 The voices and comments about the current training system………………………………… 81
Chapter VII ……………………………………………………………………………………………………………. 89
The road for improvement ……………………………………………………………………………………….. 89
7.1 A maritime-inspired training system to support SBRI………………………………………….. 89
7.2 Conclusion ………………………………………………………………………………………………….. 100
References……………………………………………………………………………………………………………. 104
Appendix A………………………………………………………………………………………………………….. 108
Details of research conducted in Chittagong……………………………………………………………… 108
Appendix B………………………………………………………………………………………………………….. 110
List of Hazards identified by ILO in “Safety and Health in Shipbreaking, Guidelines for
Asian countries and Turkey”…………………………………………………………………………………… 110
Appendix C………………………………………………………………………………………………………….. 111
An example of soil contamination found in sites in Bangladesh and estimated Accumulated
hazards. ……………………………………………………………………………………………………………….. 111
Appendix D………………………………………………………………………………………………………….. 112
Amount of hazardous materials per million GT on merchant and navy vessels……………… 112
Annexes (1 to 5)……………………………………………………………………………………………………. 113
Details of sample questionnaires used for interviews with different stakeholders. …………. 113
Annex 1 ……………………………………………………………………………………………………………. 113
A set of questionnaire to the workers group as a qualitative approach:………………….. 113
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Annex 2……………………………………………………………………………………………………………….. 114
A set of questionnaire to the workers group as a quantitative approach:……………………….. 114
Annex 3……………………………………………………………………………………………………………….. 115
A set of questionnaire for the Employer/Yard Owners as a qualitative approach …………… 115
Annex 4……………………………………………………………………………………………………………….. 116
A set of Questionnaire for the representative of Bangladesh Ship Breakers Association…. 116
Annex 5……………………………………………………………………………………………………………….. 117
A set of questionnaire for the training institute as a qualitative approach ……………………… 117
Annex 6……………………………………………………………………………………………………………….. 118
Employment generation in shipbreaking linkage domain……………………………………………. 118
Annex 7……………………………………………………………………………………………………………….. 120
Showing the market share of five major shipbreaking nations in %age GT & DWT………. 120
Annex 8……………………………………………………………………………………………………………….. 121
Table showing the analysis from the quantitative research on 100 workers…………………… 121
Annex 9(A) ………………………………………………………………………………………………………….. 122
Pictures showing various equipment and machineries usability in the local market
(pictures taken by the author between 17 May to 7 June 2012)………………………………… 122
Annex 9(B)…………………………………………………………………………………………………………… 125
Picture gallery of the current yard infrastructure developments…………………………………… 125
Annex 9(C)…………………………………………………………………………………………………………… 128
General Overview of a Yard and yard structures with current working practices:………….. 128
Annex 9(D) ………………………………………………………………………………………………………….. 135
Training infrastructure development………………………………………………………………………… 135
Annex 9(E)…………………………………………………………………………………………………………… 137
Qualitative and Quantitative Interview by Author……………………………………………………… 137
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LIST OF FIGURES
FIGURE 1: A BEACHING YARD IN CHITTAGONG, BANGLADESH (PICTURE TAKEN BY
AUTHOR JUNE 2012). ……………………………………………………………………………………………. 3
FIGURE 2: SHOWS COUNTRY WISE COMPARATIVE DATA OF GDP PER CAPITA, (DATA
SOURCE: WORLD BANK, 2011)…………………………………………………………………………….. 7
FIGURE 3: SHOWS COUNTRY WISE %AGE OF POPULATION BY LITERACY RATE AND
LIVING BELOW POVERTY LINE…………………………………………………………………………… 7
FIGURE 4: SHOWING THE SCRAPING SEQUENCE. (COURTESY: CAPT.ANAM
CHOWDHURY, BSBA)…………………………………………………………………………………………. 10
FIGURE 5: SHOWS THE TREND IN POPULATION GROWTH AGAINST RURAL AND
URBANIZATION DEVELOPMENT WITH PROJECTION. ……………………………………… 13
FIGURE 6: SHOWS STEEL EXPORT FROM BANGLADESH BETWEEN 2004-2009 (THE
DAILY STAR 6 MARCH, 2010). ……………………………………………………………………………. 16
FIGURE 7: SHOWS THE SHIPPING CASH FLOW FROM DEMOLITION MARKET (MARTIN
STOPFORD , 2009). ………………………………………………………………………………………………. 21
FIGURE 8: SHOWING THE TRENDS OF DEMOLITION MARKET IN LAST FORTY YEARS
(LLOYDS LIST 8 MARCH, 2012)…………………………………………………………………………… 22
FIGURE 9: AVERAGE DEMOLITION MARKET OF CARGO VESSEL PRICE PER LDT,
COUNTRY WISE. SOURCE: EA GIBSON SHIPBROKERS. (COURTESY:
N.MIKELIS) …………………………………………………………………………………………………………. 24
FIGURE 10: AVERAGE DEMOLITION MARKET OF TANKER PRICE PER LDT, COUNTRY
WISE. SOURCE:EA GIBSON SHIPBROKER. (COURTESY: N. MIKELIS)………………. 25
FIGURE 11: GLOBAL STATISTICS OF 5 MAJOR SHIP BREAKING NATION, (SOURCE:
LLOYDS LIST SPECIAL REPORT, 8 MARCH, 2012)…………………………………………….. 25
FIGURE 12: DETERMINING FACTORS OF SUPPLY AND DEMAND FOR SHIP BREAKING
(WORLD BANK, 2010) …………………………………………………………………………………………. 26
FIGURE 13: STATISTICS OF DEATH TOLL FROM 2003-2011 (SOURCE: LOCAL POLICE
STATION, COURTESY: BSBA). ……………………………………………………………………………. 33
FIGURE 14: WORKERS TAKE OUT ASBESTOS AND GLASS WOOL FROM ENGINE ROOM
OF SCRAP SHIP, (PHOTO: MM HOSSAIN AND MM ISLAM, 2004). ……………………… 35
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FIGURE 15: SHOWS THE USE AND STATUS OF PPE AT WORKPLACE. ………………………………… 36
FIGURE 16: ORGANOGRAM OF SBSRB (CHOWDHURY I. U., 2011)……………………………………….. 44
FIGURE 17: A BASIC COMMON YARD STRUCTURE, ORGANOGRAM PREPARED BY
AUTHOR. …………………………………………………………………………………………………………….. 47
FIGURE 18: SHOWS A BASELINE SURVEY ON EDUCATION LEVEL AND AGE GROUP OF
SHIPBREAKING WORKERS IN CHITTAGONG (YPSA, 2005). ……………………………… 50
FIGURE 19: AN EXAMPLE OF YARD LAYOUT PLAN TO BE ATTACHED AS PART OF SRFP
(SOURCE: SBRR, 2011) ………………………………………………………………………………………… 56
FIGURE 20: SHOWS THE EXAMPLE OF ZONING OF THE YARD, A REQUIREMENT AS
PART OF SRFP (SOURCE: SBRR, 2011)………………………………………………………………… 56
FIGURE 21: SHOWING LOCATION OF SHIPBREAKING YARDS IN CHITTAGONG BESIDE
MAIN HIGHWAY, PHOTO GOOGLE MAP……………………………………………………………. 61
FIGURE 22: SHOWS THE CURRENT TRAINING STATISTICS (SOURCE: AUTHOR’S
QUANTITATIVE RESEARCH)……………………………………………………………………………… 75
FIGURE 23: SHOWS %AGE OF WORKERS AGE GROUP AND EXPERIENCE………………………….. 81
FIGURE 24: SHOWS %AGE OF WORKERS EDUCATION LEVEL. …………………………………………… 82
FIGURE 25: SHOWS PERCENTAGE OF WORKERS COMMENTS ON TRAINING CONTENTS … 83
FIGURE 26: SHOWS PERCENTAGE OF WORKERS COMMENTS ON CURRENT TRAINING
PROGRAM AND ABILITY TO IDENTIFY HAZARDS. ………………………………………….. 83
FIGURE 27: SHOWS PERCENTAGE OF WORKERS COMMENTS ON FURTHER
IMPROVEMENT IN CURRENT TRAINING PROGRAM. ……………………………………….. 84
FIGURE 28: A COMPARATIVE DATA OF ACCIDENTS/INCIDENTS PRIOR AND AFTER
TRAINING. PREPARED BY ASTI ACCIDENT INVESTIGATION CELL BASED
ON INFORMATION RECEIVED FROM WORKERS /TRAINEES. (COURTESY:
TRAINING COORDINATOR). ………………………………………………………………………………. 92
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LIST OF TABLES
TABLE 1: NUMBER OF SHIPS AND VOLUME OF LDT HANDLED BY BANGLADESH
BETWEEN 2000 AND 2011 …………………………………………………………………………………… 12
TABLE 2: GLOBAL STATISTICS: %AGE SHARE (LDT) BY FIVE MAJOR SHIPBREAKING
COUNTRIES. ……………………………………………………………………………………………………….. 12
TABLE 3: COMPARATIVE DATA OF POPULATION DENSITY BETWEEN THE MAJOR
SHIPBREAKING AND OECD COUNTRIES. …………………………………………………………. 13
TABLE 4: SHOWS COMPARATIVE NATURAL RESOURCES NEEDED FOR STEEL PLANT
OPPOSED TO SCRAP METALS ……………………………………………………………………………. 17
TABLE 5: SHOWS THE USE OF MATERIALS/MACHINERIES COLLECTED FROM
SAMPLE SHIP. …………………………………………………………………………………………………….. 18
TABLE 6: SHOWS THE AMOUNT OF MATERIALS/SUBSTANCES COLLECTED,
RECYCLED, AND DISPOSED FROM THE SAMPLE SHIP. ……………………………………. 19
TABLE 7: SHOWS THE COST DISTRIBUTIONS AND PROFITABILITY IN BANGLADESH
AND PAKISTAN…………………………………………………………………………………………………… 23
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LIST OF ABBREVIATIONS AND GLOSSARIES
AESL Amader Environmental System Limited. A limited company duly approved
by SBSRB to conduct Education and Training program for SBRI workers
and removal of HAZMAT from scrap ships.
ASTI AESL Safety Training Institute, an institute under AESL Company
designated for SBRI workers training.
BC Basel convention on the control of Transboundary Movement of Hazardous
Wastes and their disposal, 1989.
BELA Bangladesh Environmental Lawyers Association.
BILLS Bangladesh Institute of Labor Studies.
BN Bangladesh Navy
BSBA Bangladesh Ship Breakers Association, A trade body recognized by
Ministry of Commerce and duly approved by SBSRB.
BUET Bangladesh University of Engineering and Technology. A public
Engineering University in Bangladesh.
CIA Central Intelligence of America.
Daily Azadi A Chittagong Based daily local newspaper published in Bangla.
DNV Det Norske Veritas, A classification society.
DOE Department of Explosive. A government agency responsible to inspect scrap
vessel for any explosive substances. Agency provides Gas Free and Hot
Work Certificate for recyclers.
DS The Daily Star, nationwide daily English newspaper in Bangladesh.
DWT Deadweight Tonnage is used extensively as a measure of cargo carrying
capacity in bulk shipping and is expressed in metric tons.
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FBCCI Federation of Bangladesh Chambers of Commerce and Industry. Is the apex
representative organization safeguarding the interest of the private sector in
trade and industry.
FE The Financial Express, A nationwide daily English newspaper in
Bangladesh, mostly covers financial news.
FFA Fire Fighting Appliances.
FIDH The International Federation for Human Rights is a non-governmental
federation for human rights organizations.
GDP Gross Domestic Product.
GT Gross Tonnage is a measure of the volume of a ship’s enclosed spaces. IMO
uses extensively the units of Gross Tons for entry into force and for various
regulations’ cut-off criteria.
HAZMAT Hazardous materials are the list of waste as described under Bangladesh
environmental conservation act 1995 (Act 1 of 1995 amended on2010).
HKC Hong Kong International Convention for the Safe and Environmentally
Sound Recycling of Ships, 2009
ILO International Labor Organization.
IMO International Maritime Organization.
ISM International safety management
ISO International Organization for Standardization.
LDT Lightship Displacement Tonnage, gives an estimate of the quantities of
materials to be obtained from a ship. Almost all recycling sale & purchase
transactions are conducted on the basis of prices per lightship ton (long ton,
i.e. 1.016 tons). Lightship is the mass of the ship’s structure, propulsion
machinery, other machinery, outfit and constants. On average about 95% of
LDT is recyclable steel.
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LSA Life Saving Appliances.
MME Department of Materials and Metallurgical Engineering, BUET
MOEF Ministry of Environment and Forest, Bangladesh.
MOI Ministry of Industry, Bangladesh.
MRCC Maritime Rescue Coordination Center, of Bangladesh.
MT Metric Tons.
M.T Motor Tanker.
NAME Department of Naval Architect and Marine Engineering, BUET
NBR National Board of Revenue, of Bangladesh.
NGO’s Non-Government Organizations.
OECD Organization for Economic Cooperation and Development.
OHSAS Occupational Health and Safety Advisory Services.
OSHA Occupational Safety and Health administration.
OSH Occupational Safety and Health.
PAHs Poly-aromatic hydrocarbons
PCBs Polychlorinated Biphenyl.
POPs Persistent Organic Pollutants.
PPE Personal Protective Equipment.
PVC Polyvinyl chloride.
SBRR The Ship Breaking and Recycling Rules’20ll is the Rule under national
legislation which is applicable for all ship breaking and recycling activities
in Bangladesh.
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SBRI ship breaking and recycling industry in Bangladesh.
SBSRB Ship Building and Ship Recycling Board is a special board under Ministry
of Industry, Bangladesh to provide one stop service to the industry.
SRFP Ship recycling facility plan, under the meaning of SBRR it includes the yard
for ship recycling as per approved lay out and equipment with various
facilities prescribed by SBSRB.
SRP Ship Recycling Plan, under the meaning of SBRR, is a plan document
developed by ship recyclers with information provided by ship owner to
recycle a ship in safe and environmentally sound manner.
STCW Standard of Training, Certification and Watch keeping. An international
convention on seafarers training, certification and watch keeping for uniform
standard.
TBTs Tributyltin, Organometallic substances.
TSDF Treatment, Stowage, Disposal Facilities.
UNCTAD United Nations conference on trade and development.
UNDP United Nation Development Program.
YPSA Young Power in Social Action. A NGO in Bangladesh working on social
development.
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Chapter I
Introduction
This chapter will be an introduction to the ship breaking in general and will highlight
the aims and objective of the study and the methodology that is applied to
accomplish the study.
1.1 Background
Ship recycling, shipbreaking, scrapping and dismantling are used as synonyms.
However these words are used by different organizations to express the ultimate
process through which a ship is dismantled or deconstructed at the end of her
operational life. Bangladesh commonly use the term as shipbreaking, hence the term
‘Shipbreaking’ will be the preferred term used later on throughout the studies.
Usually the economic life of a commercial vessel is averaging 25-30 years. But
sometimes the owner may find it economically not viable to operate and sell out.
Very recently a 13 year old box ship was sold for scrap in early May,2012 making it
the youngest merchant vessel to be demolished since the global financial downturn
took hold in late 2008.It marks the extreme of a growing trend for ever-younger
vessel heading for recycling yards (Lloyds, 2012).
Out of 103,392 (UNCTAD, 2011) seagoing ships across the world, about 700 to 800
ships larger than 499 GT are scrapped annually (Sarraf, 2010). At the end of their
sailing life these ships are sold so that the valuable steel about 95% of a ship’s mass
can be recovered (Dao, 2005). Virtually every part of the ship and other machineries
and equipment, tools are refurbished and made used as secondhand utility in the
shipping industry as well as in other industries or recycled as scrap metal. The
process is done either in dry dock, slip ways, alongside quay or at beach yards.
2
In the early 1970s ship breaking was a highly mechanized industrial operation
carried out in the shipyards of Great Britain, Taiwan, Mexico, Spain and Brazil. But
as the cost of upholding environmental and health and safety standards in developed
countries has risen, ship breaking has increasingly shifted to poorer Asian states. In
the late 80’s however this industry has mostly shifted to 5 major countries such as
India, China, Bangladesh, Pakistan and Turkey. Among them India, Bangladesh and
Pakistan accounts for 70-80% of the international market (Sarraf, 2010).
For better economic return, ship owners prefer to send their vessels to the scrap yards
of the Indian subcontinent because the local breakers pay as much as ten times higher
than the recyclers in developed countries (Platform on Shipbreaking, 2009). They
pay on an average of $450-500/LDT (depending on the type of ship) for instance a
ship of 10,000LDT is worth of $5mil, which might be a good return for the ship
owners, even at the end of her commercial life.
Shipbreaking is a highly labor intensive business and hundreds of thousands of
peoples are engaged in this industry. Also the cheap labor cost and lower level of
compliance with health and safety standards, weak law enforcement are of added
advantage to the business.
Due to prevalent huge unemployment in India, Bangladesh and Pakistan workers are
desperate to find a job regardless of associated work hazards. The work force in each
country of Indian subcontinent varies according to the volume of work undertaken
but however an estimated (2008/09) range between 8,000-22,000 is directly
employed with 200,000 in the supply chain. Shops and re-rolling mills with
dependents in extended families estimated to reach over 500,000 in Bangladesh
alone with fewer figures in Pakistan (Sarraf, 2010). In India, Bangladesh and
Pakistan the breaking activities are done at beaching yards using the intertidal zone
in an uncontrolled environment. It is estimated that up to 95% of the work force is
migrant labors comes from poorer regions of each country (Sarraf, 2010). An
example of beaching yard in Bangladesh. (See Figure: 1)
3
Figure 1: A beaching yard in Chittagong, Bangladesh (Picture taken by author June 2012).
Although ship recycling is considered to be the most sustainable and efficient way of
disposing a ship at the end of her life, Shipbreaking/dismantling is one of the most
hazardous occupation (ILO, 2004) as well. Because of the complexity of the ship
structure, inherent materials attached to the vessel during building, the work process
and the locations do involve numerous environmental, health and safety issues.
Therefore Workers are often exposed to associated work hazards which has
significant detrimental effects on human health as well as on the environment if not
handled properly.
Historically working conditions have been very difficult in these major shipbreaking
countries because of limited or no use of personal protective equipment, lack in use
of mechanized equipment, remote location of the industries to obtain adequate shore
4
support as well as proper enforcement. Social conditions associated with low
education level, availability of information, lack of training and education has further
aggravated the situation.
The working conditions and negative impacts on the environment have been a
growing concern over the past by the industry, social groups, NGO’s and local and
international media. A comprehensive plan of actions needs to be in place to
improvise the current situations in those countries where proper training and
education has been spotted to be of utmost priority.
1.2 Aims and objectives of the study.
There have been several studies on the economic, social and the environmental
aspects of this industry. But the developments of the training relating to occupational
health and safety are less documented.
The aim of the study is to identify the training needs and to analyze the existing
practices in order to find the way of improvement.
To achieve this goal and to improve the validity/accuracy of the work, this research
will cover:
The history and processes of ship breaking industry in Bangladesh
Evolutions of the industry since inception to the current dates
Present transitional status of the Industry
Legal status and directives by competent authority
Examining the existing facilities for education and training
1.3 Methodology of the study.
A literature review will be carried out encompassing both Bangla and English
literature and published articles, reports, media report, local information, various
5
reports from NGO’s, print and electronic media, government statements, newspaper
articles (Including Bangla), various documentaries and seminars, research online,
where possible in Bangla. This documentation review will provide an overall idea of
the shipbreaking activities in general and in particular about Bangladesh breaking
yards.
In addition, following has been examined and investigated:
Examined the legal instruments and directives by Bangladesh authorities with
regard to this industry.
Investigated the yard structures with identification of working groups.
Investigated the present training facilities and training curriculum.
Investigated the administrative network and support.
Investigated the principles of maritime training institute and training
programs to find possible similarities with the shipbreaking activities.
An on field qualitative research was also conducted by author from 16 May – 7 June,
2012 with practical visits to the yards, training institute and other offices. Above
research focused on workers within and outside the yards including training institute
but not excluding other important stakeholders. In addition to the main focus group,
author also interviewed four other important stake holders.
Additionally author conducted a quantitative interview of 100 workers within and
outside the yards and in training institute.
Information concerning details of this qualitative and quantitative research in
Chittagong is available in Appendix A.
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Chapter II
The Role of the Ship Breaking Industry in Bangladesh
This chapter is outlined to introduce the ship breaking industry in Bangladesh and its
geographical advantages with economic aspects in local and global context and
finally will make a rationale for locating the industry in Bangladesh.
2.1 Background of ship breaking in Bangladesh.
A certain number of socio economic parameters prompted the industry to develop in
Bangladesh and flourished in fast.
Basic social and Geographical parameters:
Bangladesh is situated in a delta region connected to the Bay of Bengal with
bordering country of India and Myanmar. Bangladesh has a total area of land
147,570 sq.km with its capital in Dhaka. The population is approximately 160
million with GDP per capita $735. Over 40% of the total population lives below
poverty line where the literacy rate is about 48% only (The World Bank, 2011).
On the other hand India and Pakistan in this region has a GDP of $1489 and $1194
with population below poverty line 25% and 24%respectively. The literacy rate of
these countries is 61% and 50% respectively compared to Bangladesh with 48%. If
we compare this region with any of the OECD countries, as for example the ‘United
Kingdom’ whose GDP $38,818 with literacy rate of 99% and population below
poverty line is 14%, it is quite distinctive of the comparative position of these three
countries (Index Mundi, 2012). (See Figure 2 and 3).
7
Figure 2: Shows country wise comparative data of GDP per capita, (Data source: World Bank, 2011).

Figure 3: Shows country wise %age of population by literacy rate and living below poverty line.
(CIA World Factbook 2011)
The poverty of the population and the unemployment rate participate in the
competitiveness of Bangladesh in the shipbreaking industry.
735 1194 1489
0
2000
4000
6000
8000
10000
Bangladesh Pakistan India United
Kingdom
GDP/Capita ($)
GDP/Capita
38,818
48 50
61
99
40
24 25
14
0
20
40
60
80
100
Bangladesh Pakistan India United
Kingdom
Population(%),Below Poverty Line & Literacy Rate
Literacy Rate %
Below Poverty Line %
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The country’s main sea port is Chittagong, which is close to the beaching yard
approximately 10 km away from Chittagong Metropolitan City .The main bay is
connected to the river Karnafuly giving the gateway of Chittagong Port and the rest
flows parallel to the coast and gradually emerges into main river streams. The major
breaking yards are situated between Fauzdarhat and Kumira under Shitakunda
Upazila.
History of ship breaking in the Chittagong area:
In 1960 when a devastating cyclone gave birth to a misfortune, blowing and
grounding of ‘M.V Alpine’ near Shitakunda, a coastal belt of Chittagong. Eventually
the owner abandoned and sold the vessel to local metal workers called “Chittagong
steel house” who scrounge it for scrap metal and materials, and it took them several
years to completely dismantle the vessel. This led the misfortune to turn into a
fortune for the local population and the entrepreneurs. During the liberation war in
1971 ships were also bombarded and obstructed the navigation channel which
prompted salvage of wrecks, thus cementing the way for dismantling. This has
encouraged the local entrepreneurs who found it a business opportunity in terms of
re-roll able scrap metals and other fittings, fixture and equipment which could be
sold as secondhand utility. A huge number of workers could manage to get a steady
job unlike farming where there is off seasons. Gradually a large infrastructure, a
significant number of linkage industries and supply chain shops developed. By the
80’s Chittagong ship breaking yard commercially entered into the business which
boomed by the mid 90’s and became one of the leading ship breaking nations in the
world.
Back in the 90’s there had been only 36-40 yards operating in this business.
Currently due to increasing urbanizations and growing demand of scrap metals and
profitability, the number of registered yards between 2009-11 increased to 125 (The
Daily Azadi, 2011). Some of the yards are big enough to accommodate 3-4 ships at a
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time. The expansion of this growth has certainly increased the global capacity as a
whole.
Currently 44 yard has been awarded with ISO 30000:2009 and 13 yards are in the
process of obtaining same. Thirteen yards have been issued with ISO 9000-2008,
ISO-14001 and OHSAS 18000; others have applied for same (Captain Anam
Chowdhury, 2012).
Process of scrapping ships:
The process of breaking in Chittagong involves initially physical beaching of the
vessel to the specific yard and this is generally done during maximum high water
time, which is about 50-100 meters (depending how efficiently is beached) from the
main yard. In the next high water the vessel is further pulled towards the yard with
the help of mechanized winches and the same continues as the vessel is lightened by
removing of stores, machineries and all other removable items.
Primary cutting is done during the intertidal zone at the beaching yard with big
chunks of section about 20-50 MT each, which are pulled on to the shore yard for
additional cutting known as secondary cutting area. The customized cutting, resizing
the plates into truckable size, sorting, segregating, loading, delivery is done in the
secondary cutting area. On an average, a 10,000 LDT size ship takes around three
months to complete the whole process. (See Figure 4).
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Figure 4: Showing the scraping sequence. (Courtesy: Capt. Anam Chowdhury, BSBA)
2.2 The advantages derived from the geographical location
Geographically, Chittagong ship breaking yard is situated near the port city of
Chittagong which is connected to the Bay of Bengal. A gradual continental shelf, the
width and depth of water allow even to accommodate the largest tankers of the
world.
Moreover, it is located in the middle hub of the main stream of east ~ west bound
traffic routes, as well as at the intermediate distance from the main sale and purchase
market of scrap vessels based in Singapore and Dubai. This allows ship owners to
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take advantage of the sailing time and cost for their vessels to be destined for
beaching.
Chittagong breaking yards are soft, sandy and muddy marshy land with an
appropriate slope as better resting ground. It has an extended uniform long intertidal
flat beach with 6 meter tidal gauze. Generally the weather is stable round the year
and there is no particular sensitive area around the breaking yards. It is connected to
main (Dhaka-Chittagong) highway giving easy accessibility for connecting
transportation. Numerous linkage industries have developed on both sides of the road
centering the breaking industry.
The Industry also generates various job opportunities for the skilled, semi-skilled and
unskilled workers. An estimation of 24, 41,000 workers with additional 8, 00,000
daily wage laborers are employed in the total linkage domains. If considering 6
persons in a family, than over 19 million people are earning their basic bread and
butter (Rice and Dhall) from ship breaking and linkage industries (ALAM, 2011).
(See Annex 6).
2.3 Economic interest of this industry in local and global context.
In a global context there has been a global shift of this industry since the 80’s and
currently these activities are concentrated mostly in 5 major nations: India,
Bangladesh, China, Pakistan and turkey. These five major countries contribute 97%
(GREY, 2012) of global volume where Bangladesh takes a share of about 30%.
Since 2004 there has been a remarkable increase in the volume handled by
Bangladesh which never fall below 40% of the market share and eventually in 2009
became the top leader in this industry. (See Table 1 and 2).
12
Table 1: Number of ships and volume of LDT handled by Bangladesh between 2000 and 2011
YEAR NO. of Ship Dismantled Amount of LDT(MT) handled
2000 73 892,756
2001 152 1,909,055
2002 84 1,519,735
2003 88 1,088,338
2004 145 1,333,667
2005 94 840,927
2006 187 132,0170
2007 103 774,065
2008 172 1,660,212
2009 175 2,192,751
2010 107 1,296,831
2011 150 1,898,102
TOTAL OVER THE
YEARS
1530 167,26,609
(Source: BSBA administration)
Table 2: Global Statistics: %age share (LDT) by five major shipbreaking countries.
YEAR BANGLADESH CHINA INDIA PAKISTAN OTHERS
2000 5 26 44 5 6
2001 28 21 36 10 4
2002 22 26 44 4 4
2003 14 31 42 3 10
2004 40 19 27 2 12
2005 45 7 24 1 23
2006 57 5 29 2 7
2007 42 5 35 10 9
2008 49 9 36 3 3
2009 38 15 36 10 1
Data source: EA Gibson ship brokers. (Courtesy: BSBA administration)
Further details of market share in terms of DWT and GT can be found in Annex 7.
This situation as major shipbreaking nation is related to socio-economic factors of
Bangladesh.
13
Labor market driver:
Bangladesh is one of the most densely populated countries with nearly 160 million
people. Table 3 shows the population density of Bangladesh ranking as the top
compared with other nations of the world.
Table 3: Comparative data of population density between the major shipbreaking and OECD countries.
Country Bangladesh India Pakistan China Turkey USA Norway
Density of
population
in World
Ranking
12
(1101/
sq. km)
31
(362/
sq. km)
51
(235/
sq. km)
76
(139/
sq. km)
97
(100.5/
sq. km
173
(32/
sq. km)
201
(14.49/
sq. km)
(Data source: CIA world fact book 2011)
In 2011, it is estimated, Bangladesh population growth of is 1.5666%. Urban
population is estimated to be 27% of the total population. The rate of urbanization is
estimated 3.5%, annual rate of change estimated between 2005-2010 (The World
Bank, 2012).
Figure 5: Shows the trend in population growth against rural and urbanization development with
projection.
14
This upward and downward trend of urban and rural development with steady
population growth is likely to increase the number of unemployed people. This large
population growth leads to huge unemployment as well as development which
eventually create job opportunities in return for the unemployed people. Moreover
the urbanization growth rate has triggered the much needed infrastructure
development with an increasing demand for steel.
Bangladesh is a developing nation with an emerging economy where the GDP
growth rate is less than 7%. As such, growing infrastructure development with
continuously expanding urbanization is underway.
Job scarcity and wages structure driver:
Bangladesh needs to create up to 1.5 million new jobs each year for the next 20 years
(The World Bank, 2012).There is currently limited number of jobs in both the public
and private sectors. As such a high degree of competition is evident to find a job.
Moreover certain educational qualification and skills are pre-requisites even to find a
job at the bottom scale.
With more than a 50% of illiteracy rate there is huge scarcity of jobs especially for
the unskilled category. Because of lack or no education they remain mostly as
floating workers. They do not hesitate to undertake any odd jobs for survival. They
are mostly employed through various labor markets on a daily basis. The general
conditions of this type of job is such that there are rarely employment agreement and
related job benefits thereto other than earning agreed daily wages and extra through
overtime.
The minimum wage structure in public sector starts with Taka 4000/month as basic
salary (eqv. $47) with other government applicable allowances and service benefits
and job security. They generally work for 5 working days in a week with 2 days
holiday. The average daily income on the basis of gross monthly salary is estimated
to be about Taka 350 /day (eqv. $4/day).
15
The general unskilled labor wages vary widely according to the nature of job.
However minimum average daily wage outside the shipbreaking industry is around
Taka150-300 (eqv. $1.8-3.6)/day but with no guarantee for a next day job.
On the other hand, ship breaking workers minimum wages stipulated by government
is Taka4625/Month. However usual pay system for most of the workers is on hourly
basis which begins with taka 25-30/hour, with 2-4 hours overtime i.e. for 10-12
hours works/day, SBRI workers can earn on an average Taka300-360/day. That
makes them earn more than $100/month with steady job security and increased
remuneration with experience.
So with no skills and education shipbreaking workers can earn more than in other
equivalent minimum wage sector. Additionally, workers are also provided with free
accommodation either inside or outside the yards. Moreover, working together with
their known natives, communal living is also an added attraction to find a job in the
shipbreaking industry.
Steel and infrastructure driver:
Basically country does not have any iron ore as raw materials of steel. There is
growing demand for construction materials in the local market. Against the yearly
demand of approximately 5milion MT of steel, the ship breaking industry alone
supplies more than 60% to the local steel production (Shaber, 2009). In addition,
90% of the local/coastal vessels are constructed, repaired and supplied with
equipment from the steel and equipment recovered from the breaking industry
(Chowdhury I. u., 2011).
Ships destined for breaking also contains non-ferrous metal like copper, brass,
aluminum, bronze, nickel and lead. They also contain other non-ferrous items like
gun metal and white metals which are precious and expensive. Depending on the
ship, there is 1-3% non-ferrous metal in every ship according to local ship breakers.
The price for the non-ferrous metal varies between $1000-$5000per ton depending
on the size and quality (Haroon, 2010).
16
These are very attractive items to the local traders although locally there is very little
use of them. However most of them are exported to Europe, Japan and the
neighboring country India. According to Captain Anam Chowdhury, a senior
consultant to BSBA says about 40,000-50,000MT of such metal lands each year in
the breaking yard. According to a local exporter 100 containers of such metals
weighing about 2000MT are exported every month (Haroon, 2010).
Further Bangladesh is also gradually emerging into a steel exporting nation. In 2009
about 85,000 tons of steel were exported to African Countries (Khan J. U., 2010).
Low production cost and quality has made the country a competitor to major steel
making countries (See figure 6).
Figure 6: Shows Steel export from Bangladesh between 2004-2009 (The Daily Star 6 March, 2010).
A Seminar presentation on ‘Ship Breaking and Its Impacts on Steel Sector of
Bangladesh’ organized by Materials and Metallurgical Engineering (MME), BUET
on 27 May, 2011 shows, against 5million tons of steel demand per year, would
require additional energy of 12.5mil MW yearly with greenhouse gas emission of 29
million tons per year which would eventually drain of 2.5billion USD/year. A
country like Bangladesh is not in a position to afford this (Islam, 2011).
17
An EIA study by MECON-1997 was conducted with Gujarat Maritime Board shows
the environmental assessment comparison between natural resource consumption and
the associated cost involved in producing One million ton of steel through steel plant
versus ship scraping metals (Sharma, 27-28 February,2009). (See Table 4).
Table 4: Shows comparative natural resources needed for steel plant opposed to scrap metals
Natural Resources Requirement for steel plant Requirements for Ship
recycling
IRON ORE 1.75 million MT NIL
FUEL (coal &
Furnace)
1.55million MT NIL
Process Chemical 40,300MT NIL
Electricity 2,300MW 450MW
Water 25-60MMC 913MC
Solid waste aspects 4,39,500MT 6250MT
Land Requirements 5000Hectors 120Hectors
Cost Aspects Taka 30 Bill, equivalent
$429Mil
Taka 1.5Bill,equivalent
$22Mil, i.e 1/20th
(Source: Atul Sharma, Gujarat Maritime Board, And Courtesy: BSBA)
Ship breaking scrap products are cheaper than ingots from the electric arc furnaces,
billets and the semis from the integrated steel plants. However they do not produce
high grade of steel but rods of various grades such as 40 and 60 TMT bars and angles
which are popular as local construction materials.
Second hand machinery and equipment driver:
According to local perception, ship’s equipment and machineries are believed to be
more robust and durable. They are much cheaper than new purchases. As such there
is strong demand for machineries such as generator, boilers, pumps and electrical
fittings to the local industries as well as export of the same after
overhauling/reconditioning. Other fitting fixtures such as kitchen fitting, furniture’s
18
and bath room fittings have very high demand locally as household utility. Other
items like LSA, FFA and bridge equipment are sold locally to the merchant vessels
and to the local coastal vessels. 99.9% of a large ship finds a secondary and
productive use in the dismantling countries (GREY, 2012). A case study by BUET
was conducted with a sample ship of a 5000LDT multipurpose vessel and shown the
usability of materials and percentage of recyclable items (Kh. Akhter Hossain, 2010).
(See Table 5 and 6).
Table 5: Shows the Use of Materials/Machineries Collected from sample ship.
(Source: Dept. of Naval Architect & Mar. Eng, BUET)
19
Table 6: Shows the Amount of materials/substances collected, recycled, and disposed from the sample ship.
(Source: Dept. of Naval Architect & Mar. Eng, BUET)
To conclude, the ship breaking industry plays a valuable role in a country’s economy
at both the micro and macro level. It generates revenues of about 118-132mil USD
per year for the government through various tax mechanisms (Chowdhury I. u.,
2011).
The industry employs over 300 people for every 150,000USD invested in this
industry (Chowdhury C. A., 2010). In Addition, Re using of the machineries and
other items encourages the small scale industries by reducing their capital
investment. This Sector also provides about 35,000tons of processed wood and
furniture’s annually and hence preventing deforestation. Industries yearly turnover
20
and contribution to the national economy is about 1.5 billion USD. Annual export of
precious materials recovered from scrap ship is about 32 million USD (Chowdhury I.
u., 2011).
In addition, the industry also provides business opportunities locally and
internationally to shipping agents, financial institutes, banks, cash buyers, ship
brokers, marine traders, transporters and gas plants. Ultimately, it brings a significant
value for the ship owner at the end of life ship.
However, a strong market competition exists between the neighboring countries of
India and Pakistan who also use the same beaching method as Bangladesh. On the
other hand, China and Turkey having different methods of the dismantling process
do not directly fall in the same competition and category.
2.4 Rationale for locating the ship breaking industry in Bangladesh
This chapter will highlight the linkage between the shipping and ship recycling
industry showing market dynamics and modalities. It will also analyze the current
recycling market with future trends. Finally a rationale of this industry with the local
market will be made.
The direct link with shipping trends:
The Shipping industry is a dynamic business sector mostly driven by world
economic growth. It is also a capital intensive business. Capital cost is a major part
of the investment made by a ship owner. Ship owners always look for pay back
taking into account depreciation and value recoverable from the demolition market.
Shipping markets experience ups and downs which conversely influence the
demolition sector. Between 2004 and 2008 shipping saw unsurpassed freight rates as
a result of high demand for maritime transportation. This high demand kept even
older ships in operation during that period. This results in a record low number of
vessels being offered for scrapping.
21
On average 700-800 ships of larger than 499GT are scrapped annually, but during
that booming period demolition market was offered with 300-400 ships only (Sarraf,
2010). The shipbreaking industries do go along as reversal with such trends. Martin
Stopford’s, (2009) model which shows how cash flow has interplay in four different
markets (the freight, demolition, sale purchase and shipbuilding). (See figure 7).
Figure 7: Shows the shipping cash flow from demolition market (Martin Stopford , 2009).
The demolition market reflects closely with the trend of the freight market.
Generally, if the freight market is high, then there will be less business for ship
scrapping and subsequently the price in the demolition market may go high and vice
versa. In addition the oversupply of tonnage also drives the demolition market
eventually for a market balance. In the wake of the 2008 global financial crisis, the
international trade shrunk and shipping market suffered, but the demolition market
was quite active. Regulatory regime such as phasing out of single hull tankers by
2015 has significant volume of impact on the demolition market as well.
22
The general expected volume of the demolition due to ageing of ships is added with
further increase in volume depending on the global economy. The continued
weakening of charter hire rates in 2011 became the third biggest year ever for
demolition of 41Mil DWT. The first being in 1986 with 44Mil and second being in
1985 with 43Mil DWT (MCCARTHY, 2012). “If past experience is anything to go
by steel traders can look forward to a bumper 2012 for the supply of vessels for
recycling. If macroeconomic conditions in 2012 continue to underwhelm and scrap
prices stay at their recent high levels, this year could easily surpass 1985 as a peak
year for demolition (Braemer Seascope)” (MCCARTHY, 2012).
Figure 8: Showing the trends of demolition market in last Forty years (Lloyds list 8 March, 2012)
The trend in near future:
It is estimated that over the next five years, the number of ships being sent for
demolition will increase dramatically as a direct result of the over-building capacity
between 2008 and today. As freight rates climbed during the early and mid-2000,
ship owners increased their orders for new builds to accommodate the anticipated
increase in trade.
23
As a result the number of new ships entering the global fleet each year has grown
significantly since 2008. It is estimated that in 2011 a new bulk carrier is being
commissioned every eighteen hours. With freight rates still quite low, these new
building programs have created a large overcapacity. Ship owners are being forced to
re-evaluate their profitability of their fleets. One obvious outcome will be that older
vessels will be sold for recycling. This will greatly increase the supply of the ships
for the shipbreaking industry.
On the demand side, the demand for ship recycling is driven primarily by the demand
of scrap metal in South Asia. Driven by economic growth in these countries, the
demand for demolition vessels is a direct function of the steel price in these
countries. Importantly it is also a function of the cost associated with the breaking
industry itself in particular the labor cost which is one of the important cost factors in
the equation (https://monkessays.com/write-my-essay/dtashipping.com/).
Table 7: Shows the cost distributions and profitability in Bangladesh and Pakistan.
(Source: World Bank, 2010)
Despite the various influencing factors on the demand sides, with the current trend an
increase of ships for recycling is inevitable (MCCARTHY, 2012).
24
The five major countries India, Bangladesh, Pakistan, Turkey and China take the
major market share of 97% (GREY, 2012). India, Bangladesh and Pakistan alone
take a share of 70-80% of the global volume (World Bank, 2010). From 2004 to
2008 the Bangladesh market share was never below 40%, which made the country
leading in 2005-06 (See Table 2). All major ship breaking nations are emerging
economies and therefore the global economy has a knock-on effect.
There is huge potential in SBRI both locally and in a global context in terms of
business and financial return for the ship owners. There is strong market competition
between India, Pakistan and Bangladesh in the demolition market and Bangladesh
most of the time being bullish (upward market trend) paying on average the highest
per LDT (See figure 9 and 10). This strong proposition has kept the country as
major ship breaking nation over the past three decades.
Figure 9: Average Demolition market of Cargo vessel price per LDT, Country wise. Source: EA Gibson
Shipbrokers. (Courtesy: Dr. N. Mikelis, IMO)
25
Figure 10: Average Demolition market of Tanker price per LDT, Country wise. Source: EA Gibson
Shipbroker. (Courtesy: Dr. N. Mikelis, IMO)
In terms of global capacity four major Asian Ship breaking nations of India,
Pakistan, Bangladesh and China have the capacity of 12m LDT. In 2011 alone 8.5-
9.0 mil LDT was sold for recycling (LEANDER, 2012). In the current scrap trend, it
is not unlikely to accommodate an expanded volume in the near future.
Figure 11: Global statistics of 5 major ship breaking nation, (Source: Lloyds list special report, 8 March,
2012)
26
The impact of local markets on breaking yards:
The basis for the sustainability of this industry is the demand of end products and the
downstream industries. For shipbreakers, otherwise there is little point in purchasing
vessels if they cannot sell the scrap to be remolded into new plates or rods or the
materials/machineries cannot be resold. So steel demand in individual recycling
nations has a direct impact on the volume of ships that the yards will be interested in
purchasing for dismantling. (See Figure 12)
Figure 12: Determining factors of supply and demand for ship breaking (World Bank, 2010)
The demand for construction materials in Bangladesh is underpinned by the
continuously expanding urbanization process in a country with very large population.
The downstream demand for steel scrap has been a major driving force in the growth
of SBRI in Bangladesh. Also low labor costs, huge numbers of laborer availability,
technical know-how gained over the years, willingness to work in hazardous
atmosphere and growing infrastructure development, coupled with socio economic
conditions have contributed a lot towards sustainability of the industry locally. In
addition, the natural conditions of high tidal gauge and wide beaches with
appropriate slope are unique for Bangladesh. Hence it is not likely that SBRI will
27
relocate on a large scale from Bangladesh in the immediate future (World Bank,
2010).
In conclusion, the ship demolition market usually moves contra-cycle with the
shipping market even in global economic downturn. The major market share remains
mostly in five major countries without much to build in any other region. The major
driving force for this industry is the local steel demand, abundance of workers with
cheap labor coast, downstream industries, and geographical features. Considering all
these factors Bangladesh remains as one of the strong competitors in this industry
and is likely to sustain in the future as well.
28
Chapter III
Major Issues in shipbreaking industry and Addresses by local
Authority
This chapter will highlight the major issues such as workers’ health, safety and
environment involved in ship breaking industries and how these have been addressed
by the local government.
3.1 Two major concerns related to the shipbreaking business
Shipbreaking is considered to be the most sustainable way of disposing end of life
ships. The majority of these find their final destination on the beaches of south Asian
countries. These ships contain many hazardous wastes as defined by international
law. Consequently, various NGO’s have identified the environment and occupational
health and safety (OHS) as major issues in shipbreaking industries.
Environmental effects:
The dismantling process in this region is carried out on the beach yards without
containment. The soft, sandy, muddy tidal flats thus allow the sludge and other
contaminants to directly flow into the marine environment affecting the coastal
ecosystem.
A few studies in the past have shown high level of contamination causing the
pollution of essential groundwater reserves as well the tragic loss of local fisheries
and associated jobs (DNV 2000, Greenpeace 1999, 2001, 2002, YPSA, 2006).
29
Occupational health and safety:
The workers involved in this industry are often exposed to the hazardous materials
inevitably leading to occupational diseases and illness. Chronic health affects results
from physical exposure to asbestos, lead and other heavy metals and organotins such
as TBT, PAHs and PCBs (Greenpeace, September,2002).
Furthermore, workers are most vulnerable due to low level of education, lack of
information and adequate training, limited or no use of PPE and lack of emergency
response capacity. Frequent accidents are common causing loss of lives in this
industry.
ILO in 2004, listed a high number of hazards that are likely to cause work related
injuries and death, illness, diseases and incidents among shipbreaking industries.
They are grouped in different categories (See Appendix B).
The combination of beaching methods and exposure to hazardous wastes makes the
working environment of ship breaking very dangerous. This has been on the
spotlights around the world. The two main issues are discussed separately in the
following sections.
3.2 Environmental Impact of Ship Breaking
Historically, ship breaking in Bangladesh has been done in yards located on beaches.
Most of the job is done manually. There is no hard barrier along the yard which
otherwise could protect the contaminant, soil and others to directly fall into the sea.
The process is carried out in an open environment where there is no method of
containment.
Much of the material assumed to remain on the beaches will be due to
the quality of yard housekeeping practices, allowing spillages and
leakages of hazardous materials or their escape during normal handling,
for example, torch cutting of painted metals not mechanically cleaned
30
before cutting. The lack of hazardous waste disposal and treatment
facilities in Bangladesh and Pakistan means that wastes produced must
nevertheless be disposed of somewhere. Therefore informal disposal may
also occur on the beaches themselves, on adjacent unused plots, or on
other nearby land” (World Bank, 2010, p-32).
While stringent environmental regulations were redefined in China, the country
modified its industry practices .The recent introduction of stricter environmental and
safety laws in China has arguably made the industry less profitable, but has in no
way brought it to a halt (L.Jones, 2007).
Today, Turkey and China use different methods of scrapping to fulfill their national
requirement and promote their practices to attract some segment of the ship owning
community. They use containment so that contaminants are controlled from directly
flowing into the water. Turkey uses the hard land for cropping the big section and
secondary cutting area is protected with a deep drainage system. On the other hand,
China uses floating docks and alongside quay where the sections are cropped
horizontally downwards from top thus the hull itself acts as retainer.
In Bangladesh, the lack of containment generates serious worries concerning the
impacts of hazardous materials in the coastal zone of Chittagong.
Most of the shipbreaking yards have neither any containment to prevent pollution of
soil, air, marine and freshwater resources, nor the technology needed to ensure the
environmentally safe management and disposal of hazardous wastes and materials.
Heavy metal, PCB’s, POP’s, sludge and bilges contained in ships are often released
in the open beaches and spread by seas affecting the marine environment. Improper
storage and disposal of scrap metal and waste contaminates the soil and groundwater
resources, causing acute and long-term pollution. (Platform on Shipbreaking, 2009).
31
“Wastes of the scrapped ships are discharged directly into its adjacent
areas which are ultimately draining into the Bay of Bengal. These
wastes especially oil and oily substances, PCBs, TBTs, PAHs etc. and
different types of trace and heavy metals (Cd, Pb, and Hg) are being
accumulated into the marine biota. As a result, marine fisheries
diversity of the Chittagong coast that supports highly diversified
marine water fishes, mollusks and benthic organisms etc. is at stake
right at the moment” (Prabal Barua, 2012).
Recent World Bank research (2010) found soil contamination in beaching sites of
Bangladesh and Pakistan. This contamination is indicative of the threats to the
environment caused by the practices and improper management of hazardous
materials during the dismantling of ships.
Moreover, large amounts of hazardous materials are likely to accumulate in both
Bangladesh and Pakistan if the prevailing practices continue over the next 20 years.
Based on the ship breaking work likely to be carried out in the yards in Bangladesh
and Pakistan between 2010 and 2030, an estimate was prepared about accumulation
of hazardous materials in the three countries assuming continuation of the prevailing
practices (World Bank, 2010). The parameters of soil contamination and the table of
estimated accumulated hazardous materials can be found in Appendix C.
Shipbreaking activities contaminate the coastal soil and sea water environment and
thus impair ecological settings. The problem mainly associates with the discharge of
ammonia, burned oil spillage, floatable grease balls and metal rust (iron) and various
other disposable refuse materials together with high turbidity of sea water (Dr. Md.
M. Maruf Hossain, 2006).
The oils on the water surface severely reduce the primary productivity, thus affecting
the phytoplankton; zooplankton and turbidity of contaminant soil affect the intertidal
benthos community. The shipbreaking activities also affect the coastal area of
Chittagong, including all kinds of marine algae, kelp, seagrass, marshgrass and
32
mangroves. Because of the contaminants, the fish community has almost disappeared
and the local fisher folks have changed their livelihood to some other alternative
means. (DNV, 2001).
3.3 Workers Health and Safety Issues
The extent of occupational health and safety in the shipbreaking industry is a serious
concern in Bangladesh.
Dismantling of oceangoing ships that are likely to pose hazards to the
general health of the people at large. Government is concerned
about the health hazards that the industry entails. Health hazards are
admittedly associated with the way ships are dismantled by our ship
breakers. Securities of the workers who are deployed in ship
breaking industries are also often put on stake. Admittedly there
have been disastrous accidents even in the past causing loss of life.
It is an admitted fact that ships are embedded with such hazardous
as asbestos, PCB, TBT, LEAD and other heavy metals which pose
serious threat to the health of the peoples. It is also not in qualm that
the forces employed for the industry are treated in an inhuman
manner, where they are exposed to grave risk” (First Extension
order, 2011){Cited from the contents of Hon’ble High Court
judgment}.
The above extract clearly indicates the public concerns related to workers health and
safety issues involved in SBRI which needed to be addressed meticulously.
In SBRI, workers suffer from various chronic diseases, illness and injuries.
According to a study carried out by Roy (2003), it is indicated that, 88% of the
workers suffered from some form of accidental injury from foot injury to larger
accidents. 87% suffered from muscle pain, 72% have problems with eyesight, 52%
33
have breathing difficulty, and gastric problems occur in 81% of the laborers.
Whereas, 56% of them suffered from skin diseases, 28% have other infectious
diseases (Hossain, 2006).
Also frequent accidents are common causing loss of lives, loosing organs and
becoming incapacitated. The reason is the exposure to hazardous working conditions
and the vulnerability of the workers due to lack of information, inadequate training,
fire protection measures, lack or limited use of PPE and lack of appropriate
emergency response. The above phenomena are common in the breaking activities in
developing countries.
Because of such working conditions, there have been numerous fatal accidents
causing deaths and serious injuries in the past. Although there is no official statistics,
it is assumed many of the accident are under reported or even not reported. However
according to national newspaper, 43 workers died and 92 others were injured in
several accidents from 2008 to 2010 in the ship yard (The Daily Star, 2011). Roughly
1000-1200 people died over three decades (Greenpeace, FIDH and YPSA, 2005).
See Figure 13 for death casualties per record in local police station. Majority of the
accident caused due lack of awareness and unsafe work procedure. The death toll
gives a glimpse of the dark side of this industry.
Figure 13: Statistics of death toll from 2003-2011 (Source: local police station, Courtesy: BSBA).
4
10
7
5
6
9
20
13
16
0
5
10
15
20
25
2003 2004 2005 2006 2007 2008 2009 2010 2011
Death casualties in SBRI (2003-2011)
34
Scrap vessels contain a wide range of hazardous materials; particularly on ships built
before the 70’s. (See Appendix D).
Therefore, during the dismantling process, workers are often exposed to a large
number of hazardous materials. They have little or no knowledge about the
occupational health and safety which makes them vulnerable to harmful substances.
In addition, the workplace generates excess heat, noise, radiation and vibration,
which are also likely to cause deterioration of health conditions with short and long
term diseases.
A high number of hazards identified by ILO in 2004 are likely to cause work related
injuries and death and ill health. They have been grouped in seven categories such as:
1) Hazards with the potential of causing accidents, e.g. fire and explosion,
falling and tripping, snapping of cables, trapping in oxygen depletion
compartment, lack of PPE and housekeeping practices.
2) Hazardous substances and waste, e.g exposure to asbestos, heavy metal,
PCB’s, PVC, batteries, fire fighting liquids and welding fumes.
3) Physical hazards, e.g noise, vibration, radiated heat and radiation.
4) Mechanical Hazards, e.g lack of safety guards, equipment machinery failure,
trucks and transport vehicles.
5) Biological hazards, e.g toxic marine organism, animal bite, risk of
communicable disease and vectors of infectious diseases.
Ergonomic and physical hazards, e.g repetitive strain,
6) Monotonous work, excessive work load, long working hours, temporary
employment and lack of education and social environment.
7) General concerns, e.g Lack of safety and health training, poor working
organization, inadequate accident prevention and inspection, inadequate
housing and sanitation, lack of emergency preparedness and lack of medical
facilities.
35
In Bangladesh, because of low labor costs and lack of available machinery in yards,
most of the breaking process is done manually. It is also understood that the
application of the beaching method makes the accessibility of heavy equipment
difficult, especially in the primary cutting area. Thus workers are very often exposed
to various hazards.
Lack of Training and Personal Protective Equipment (PPE)
A vast majority of the workers involved in this industry have no or very low level of
basic education. They are hardly aware of their occupational health and safety. The
consequences of exposure to hazardous waste without protective measures are not
known to them. Prior to 2011, there was no education and training scheme for these
workers, as such they probably were not aware of associated work related hazards.
Moreover, workers are provided with limited or no protective gears leaving them
exposed to these hazardous working conditions. This exposure to hazardous working
conditions is further amplified by the inadequacy of training, limited or no use of
PPE, lack of appropriate measures with regard to fire protection and emergency
response (ILO, 2004). Therefore, they become particularly vulnerable to
occupational hazards and hazardous materials.
Figure 14: Workers take out asbestos and glass wool from engine room of scrap ship, (photo: MM Hossain
and MM Islam, 2004).
36
Figure 15: Shows the use and status of PPE at workplace.
Among others a comprehensive education and training program must be established
for the improvement of occupational health and safety standards and also for the
sustainability of this industry.
There are a number of other internal and external issues, all of which cannot be
addressed in this study. This study will mainly focus on the education and training
with regard to workers health and safety issues.
3.4 Addresses/Response by local Authority
As discussed in earlier chapters, the death toll in SBRI due to poor working
conditions, and environmental degradation of fragile coastal area of Chittagong
generated public concerns both locally and internationally. The media as well as
several local and international NGO’s, like BELA, YPSA, Greenpeace, NGO
platform on shipbreaking and social activists were active in these issues and were
trying to draw public attention known as a common NGO’s strategy. During the
23%
52%
25%
Status of PPE at workplace
Provided
Not Provided
Partly Provided
Finding from quantitative interview with
100 workers. (Further ref:Annex-02 &
06).
Inference: 52% of the workers still not provided with PPE.
37
2000s and early 2010s, clear signals were sent to the industry: the past practices
should change for the sustainability of the whole industry.
The beginning of the change:
The turning point of the industry evolves following various petitions by BELA which
is enumerated in this discussion (BELA, 2004).
Writ petition:No.2991 of 2003 was filed by BELA before Honb’le High Court
Division against various Government agencies and BSBA as
Respondent.
Purpose: For legal protection on environment and labor in SBRI.
Main Urges:
– Shipbreaking activities causing pollution damages to coastal and marine
eco system of Shitakunda area.
– Shipbreaking yard not having Environmental clearance despite national
requirement under industry and factory law.
– Violation of labor related law and cause of fatal accidents.
Verdict: Rule Nisi (A court order to “show cause”) was issued to the respondents
asking for show cause in the following cases.
– Why the agency responsible will not be directed to ensure that
shipbreaking operations is undertaken only after obtaining Environmental
clearance Certificate(ECC) under national Environmental Conservation
Act’1995.
– Why they should not be directed to adopt detailed and appropriate Safety
and Labor welfare measures under national legislation of Factory
Act’1965.
38
– Why shipbreaking shall not be undertaken only after obtaining Gas Free
certificate from DOE in order to prevent fatal accidents.
– Why import of scrap ships shall not be regulated in line with the
requirements of the Basel Convention, 1989.
The concern on ships with hazardous materials
Writ Petition:No.3916 of 2006 was filed by BELA before High Court Division
against responsible government agencies.
Purpose: To prohibit entry of Greenpeace listed hazardous ships.
Main Urges: Challenging the legality of the Entry of M.T Alfaship which was one
of the 50 hazardous ships listed by Greenpeace.
Verdict: Subsequent ruling by the Court on 06.07.2006 stopped the said vessel
entering into Bangladesh territory along with banning of import of all
those 50 ships.
Concerns about workers Bill of Rights
Writ petition:No.23 of 2008 was filed by BELA before High Court Division against
responsible government agencies.
Purpose: To establish Compensation for the deceased and injured labors in
SBRI.
Main Urges: Appeal for Protection of the workers in the ship breaking yards
seeking for adequate compensation to the deceased and injured
laborers/workers against damages caused by explosion or otherwise in
the yards.
Verdict: On 07/01/2008 the Hon’ble Court ruling served notice to the
administrative bodies asking for show cause:
39
– Why they should not be directed to take measures to protect
the workers employed in the breaking yards.
– The Court also directed to file a report before the Court stating
number of workers died so far or injured as a result of
casualties in the yards, reasons for such loss of life and or
injury, amount of compensation given to the deceased families
and the measures taken by them to prevent such incidents of
loss of life and injury.
Significant ruling and reshape of the industry
The major significant change brought about in the industry follows the case below:
Writ petition:No.7260 of 2008 filed by BELA before High Court Division, versus
15 different responsible government agencies/departments and 4 other
stake holders as respondents.
Purpose: Challenging the entry of the Greenpeace listed ship M.T. Enterprise
into Bangladesh.
Main urges: Despite the previous High Court directives regarding refusal entry of
“M.T Alfaship & SS Norway” and prohibition to further import of
Greenpeace listed ship yet M.T. Enterprise made its entry into
Bangladesh and was substantially dismantled.
Verdict: The High Court Bench delivered verdict on March’ 2009
disposing the Writ Petition 7260 of 2008 gave as many as 9 (nine)
directives, which are quoted below for ready reference (M.T
Enterprize, 2011):
(1) So far as the vessel M.T. Enterprise is concerned the injunction on
further dismantling of the ship will continue until such time as the
respondent No. 17 (yard owner) obtained a clearance certificate from
40
the Department of Environment for the purpose of dismantling the
remaining of the vessel.
(2) The Ministry of Environment and Department of Environment are
directed to immediately take steps to ensure closure of all ship
breaking yards which are operating without necessary Environment
Clearance.
(3) The law-enforcing agencies, including the Police, Magistrate and
local administration are directed to accord cooperation and Helpance
to the Department of Environment as enjoined by section 4(Ka) of the
“Environment Conservation Act 1995 and the Rules framed there
under1997” in ensuring the closures of ship breaking yards operating
without prior clearance from the Department of Environment.
(4) The Department of Environment is directed to file compliance within
2(two) weeks giving details of what steps they have taken in this
regard.
(5) If and when the ship breaking yards or any importer of any vessel
apply for clearance certificate, then the Department of Environment
shall deal with the application expeditiously and supply the clearance
certificate only upon satisfaction that all the facilities required for
proper dismantling of the vessels, taking into consideration whether
safety measures for the workers and the conservation of the
environment and in particular disposal of hazardous waste generated
by the dismantling process, are in place.
(6) The Ministry of Environment is hereby directed to frame Rules and
regulation for the proper handling and management of hazardous
materials and wastes, keeping in view the Environment Conservation
Act 1995 and the Rules framed there under, the BASEL Convention,
1989, the Factories Act, 1965 and Labor Act, 2006.
41
(7) Thereafter the Ministry of Environment is directed to file compliance
in this regard within 3(three) months from receiving a copy of the
judgment.
(8) The Ministry of Shipping and Department of Shipping are directed to
ensure that hazardous vessels enlisted in the Greenpeace list of
vessels containing hazardous materials are not imported into the
country and when such vessels are imported after having been
decontaminated at source or outside the territory of Bangladesh, the
prior Environment clearance has been obtained on showing that
adequate safety and precautionary measures have been taken for their
dismantling in accordance with law.
(9) The Government is directed to set up a High Level Technical
Committee comprising representatives from the Ministry/ Department
of Shipping, the Ministry/ Department of Environment, Ministry of
Labor and Manpower, Retired Naval Officers, Academicians/Experts
in the field of Marine Engineering, Marine Biology, Specialists in the
field of Environment, Soil Science and Ecology, Hazardous Waste
Management and relevant NGOs, such as BELA.”
Following the judgment, all 36 ship breaking yards had to close down their
business as none of them had the environmental clearance. This decision by
Hon’ble High Court triggered the industry to reshape and things started to take
positive change.
Response by different stakeholders:
Subsequently, BSBA appealed to The Hon’ble High Court. BSBA sought short lived
dispensation by way of some relaxation to the directions passed earlier so that they
can import ships until such time the new Rules is formulated. They argued not only
their members suffering financially but also the general peoples due to the ban. They
aver that the Ban has created pressure on the job market, reduced supply of raw
42
materials to certain industries causing price hike of essential items and affecting
country’s economy.
Considering all the facts and circumstances and of the recent declaration of the ship
breaking as an industry by Hon’ble Prime Minister’s and Her Unequivocally
expression that the ship breaking industry shall be subject to maintenance of
congenial working Environmental and Safety standard, The Hon’ble High Court
Conditionally relaxed the previous order for a limited time till the new Rule is
framed.
Among other conditions a clear directives came with regard to workers
training.
Subsequent to the court directions, on 26 January 2010, the government also formed
a high-powered committee comprising various relevant agencies. Its purpose is to
monitor and to take necessary steps in the interim period with regard to ship-breaking
activities in the country.
Stringent regulation under construction:
However, the kind attention was further drawn to the Hon’ble Prime Minister
forwarding a letter by ‘NGO platform on shipbreaking’ on 13 December, 2010
requesting intervention against the dumping of end of life ships, which exploit the
workers and harm Bangladesh environment. Subsequently on13 February, 2011 the
Hon’ble Prime Minister declared the ship breaking as an Industry. Following this
declaration, a gazette notification was published under the Ministry of Industry
(MOI) on 21 April, 2011.
On 20 October, 2011 the Ministry of Industry, as the concern Ministry , has declared
the ship breaking yards as “Industrial Zone” comprising 07 Mouzas under
SitakundaUpazila, Chittagong with a total land area of 317.73 acres comprising 125
registered yards.
43
After gazette notification by MOI, the dilemma of responsibility shifted from the
Ministry of Environment and Forest (MOEF) to the Ministry of Industry. Since then
Ship Breaking and Recycling Industry (SBRI) is administered and regulated under
the jurisdiction of MOI.
The MOI under the earlier Directives from Hon’ble High Court finally formulated
the long awaited. “The Ship Breaking and Recycling Rules, 2011” (SBRR) published
under gazette on 12 December, 2011. Currently SBRI is regulated under the above
mentioned legal instrument.
This rule also emphasizes on the terms and meaning of existing national and
international instruments such as (Government Gazzete, 2011):
i) “National”: Petroleum Act 1934, Explosive Act 1884, Bangladesh Environment
conservation Act 1995(1
stamended in 2010), Labor Act 2006(BLL), National Import
policy order.
ii) “International”: The ILO guidelines for Safety and Health in Ship Breaking
activities, The Hong Kong International Convention for Safe and
environmentally sound recycling of ship’s 2009, BASEL convention 1989.
Formation of Special Board:
The formation of a special board, “SBSRB” within the scope of this law is another
significant step. SBSRB will be acting as one stop service under the Ministry of
Industry in integration with other government agencies. This board is the main focal
point for the ship breaking and recycling activities. All the official formalities of
arrival ship and subsequent breaking permission and monitoring will be done by this
board. The board is headed by a chairman followed by a Director General with 4
different directorates. The organizational flow chart is shown in Figure 16.
44
Figure 16: Organogram of SBSRB (Chowdhury I. u., 2011).
Conclusion:
The outcome of this long judiciary and political process is hoping to improve the
industry through a better involvement of the government and its related
agencies. The shipbreaking industry is currently taking a different shape than
in the past. The changes are becoming more and more visible. However, it is an
ongoing process which may require a considerable amount of time. There is
presently a transitional period. This is a period of construction and definition of
the future practices. The yards are slowly modifying their practices and
relationships with the environment and workers. The goals are to enhance the
reputation of the shipbreaking industry and to maintain its sustainability by
addressing environmental and social issues and by developing transparency.
45
Chapter IV
Ship Breaking Yard
This chapter will give an overview of the yard structure and their mode of operation.
Different working groups within yards and their work procedure will be identified.
4.1 Introduction to yard structure
There are presently 125 (The Daily Azadi, 2011) registered ship breaking yards in
Chittagong, but not all of them are in operation. Some of the yards are owned by
individual owners, some are with joint ownership and some owners own a few
different yards at the same time. Some of the yards are large enough to accommodate
3-4 ships simultaneously and some are of the standard size prescribed by the
authority.
A few yard owners have their own downstream linkage industries such as re-rolling
mill and steel plant, gas plant but most of them do not have these facilities. Yards
and yards owners are all different. It is hard to identify a uniform management set up
of this industry. There is no hard and fast rule how the management system should
look like. As such it all varies with the taste of individual yard owners. They are
presumably free to manage their business in their own way.
However, recent SBRR, 2011 Chapter VII Para.30 requires “OSH management
systems should be implemented by each recycler for achieving acceptable level of
occupational safety and health and environmentally sustainable conditions”. Main
components of OSH management system should include:
– OSH policy
– Establishment of responsibility and accountability, awareness and training,
documentation, communication and information.
46
– Hazard and Risk assessment; planning and implementation of OSH
activities.
– Assessment, Review and corrective action for improvement.
Despite their differences, yard structures share some similarities. The author had
personal interaction with yard owners, managers, supervisors, foremen, so some
common points were found. They will be enumerated in the following discussion in
order to provide a general idea of the management set up.
The majority of the yard owners have a corporate head office in the main city of
Chittagong who controls and administers their business. Each yard has a site office
that looks after the day to day operational activities, local administration including
delivery and receiving of materials.
Each site office is headed by a manager with supporting staff. They maintain the
accounting of the scrap materials and keep record of the attendance of the laborers
engaged in the yard.
On field there are four key personnel namely yard supervisor, ship supervisor, shift
in-charge and safety officer. They are the main coordinators for all the activities
carried out on board and in the yard.
The safety officer concept is newly introduced and is a consequence of the ship
breaking and recycling rule that came into effect from December 2011.
The organogram in Figure 17 show the basic structure of a yard in Bangladesh but
may slightly vary from yard to yard.
47

Figure 17: A basic common yard structure, organogram prepared by author.
As enumerated in the organogram, the yard uses mainly two categories of workers:
The operation group and the support group.
48
4.2 Permanent workers
Every yard has some core people who are basically appointed by owners and are paid
monthly. There are approximately 80-100 people per yard in the category of
permanent workers. The figures provided are not absolute. However, they can be
considered as an average for standard yards. These permanent workers can be
divided in two groups
Educated, skilled and experienced workers. About 20-30 people close to the
owners form this first group. These skilled workers play a very important role
in the management system. They are office managers, accountant, yard
managers, supervisors, winch operators, cutter foremen, magnetic crane
operators, fitter foremen, loading foremen, shift in-charges and safety officer.
There are about 60-70 other unarmed security personnel. They act as
watchmen on board as well as in the yard. They are mostly unskilled workers
but trustworthy people for the owner.
The managers are qualified people with university level of education and some of
them are MBA also. The yard supervisors and other foremen may not possess a high
degree of education, but they have vast area of experience in this field, and are
promoted on this basis.
The cutter foreman is the key person who designs the cutting plan. He does not have
any institutional degree but his knowledge through experience dictates the quality of
his job. There has been no such big inclination of vessel due to wrong cutting plan so
far.
No wonder the other foremen are of similar standing although they had to learn a lot
through the mistakes over the years of time. Every yard owner prefers to keep them
under permanent employment for the key functionality of the breaking process.
49
A handful of people remain as regular/permanent employees with good skills and
competence. These core people with necessary education and training can be further
developed and utilized as resource personnel to ensure workplace safety. They can be
better integrated to the management of the safety and health policy.
4.3 Migrant workers
This second category of workers represents the vast majority of the manpower in the
yard.
Seasonal worker:
They are mostly migrant workers who often come from far northern district of
Bangladesh. They account for about 95% (World Bank, 2010) of the work force in
semi-skilled and unskilled category. They are basically farmers and jobless people
from backward and drought prone regions where there are farming seasons for 6
months and rest of the years is off seasons. During the off seasons these people hunt
for jobs through their predecessors in the Chittagong breaking yards. They are
seasonal workers.
50
Education level:
They have no or very little basic education. In addition, they do not have any specific
knowledge concerning ships, ship breaking conditions and elementary principles of
OSH. A base line survey shows the different percentage of age group and the
education level of the workers in Chittagong breaking yards (YPSA, 2005). (See
Figure 18)
Figure 18: Shows a baseline survey on education level and age group of shipbreaking workers in
Chittagong (YPSA, 2005).
Age distribution:
As the data shows the majority of the workers fall in an age group between
18~22.Their lack of experience and awareness makes them particularly vulnerable to
accidents. Moreover child labor, age below 18 has been an issue in this industry.
Several studies especially FIDH and YPSA in “Child Breaking Yards’08” have
enumerated thousands of child laborers engagement in Bangladesh ship breaking
yards. “When we conducted field investigations in 2000, 2002 and 2005, we
repeatedly noticed children among the workers involved in shipbreaking activities”
(YPSA, FIDH and International platform on shipbreaking, 2008).
51
Due to the severity of the financial crisis in their families, the parents/guardians are
unable and often unwilling to provide education to their children. This lack in
educational expenses and other “Pull Factors” encourages them to work in this
industry to financially support their families. Working in the same hazardous
conditions as adults, the children and teenagers who lack the physical strength and
are still growing are even more vulnerable to accidents and illnesses.
However, this has been an issue not only in shipbreaking industry but also in other
sectors of Bangladesh. According to the Bangladesh Labor Law (BLL-2006) the
minimum age for admission to work is 14 years and 18 years for hazardous work.
Further, light work for children between the ages of 12 – 14 years is defined as nonhazardous work that does not impede education. The UN Committee on the Rights of
the Child expressed concern in 2009 that many Bangladeshi children continue to
work in five of the worst forms of child labor, namely welding, auto workshops, road
transport, battery recharging and tobacco factories.
The government has prohibited child labor for the children aged below 14 according
to the BLL 2006 and adopted the ‘National Child Labor Elimination Policy, 2010’
with a view to withdrawing children from hazardous and the worst forms of labor.
The policy is aimed to support families to break the vicious cycle of poverty so that
children remain out of labor.
In addition, in the recent years a government initiative for ‘free primary education’
coupled with adoption of ‘National Child Labor Elimination Policy’ has significantly
reduced the number of child workers in this industry which is much more visible in
the current state.
As a result of the new legislation, child labor is now clearly regulated in SBRI as per
SBRR, 2011 Ch.-III, Para.15 (e). This Rule states that “No person under the age of
18 shall be employed and no female worker shall be allowed to enter into the yards”
(SBRR, 2011). However, proper monitoring and enforcement of the Rule should
demonstrate the effectiveness of this policy.
52
Language and cultural difficulties:
For most of these workers, language is an issue. These migrant workers have a
language barrier in the work place. They speak particular Bangla which is clearly
different them from Chittagong locals. If both ends of the people try to communicate,
it is obvious they have difficulty to understand each other. Their food habits and
behavioral pattern also vary distinctively.
Employment system:
This category of workers is mostly engaged through local contractors on an hourly
basis. Some are engaged for particular jobs under the supervision of foremen on sub
contracts. The primary contractor works on contractual agreement with the yard
owner on the basis of tonnage.
However, there are no particular rules of engagement between contractors and the
floating workers. There is neither any system of employment letter nor contract of
agreement signed in paper form between contractors and the workers (YPSA, 2005).
As such workers are not aware of their legal rights of employment such as working
hours, night work, overtime, break, lunch, accommodation, holidays, equipment,
service benefit and compensation. Although in SBRI all of the above criteria are
maintained mostly in verbal form and according to general norms and practices;
however that may not guarantee any legal protection for the workers if there is any
such deviation from the norms. Moreover there is no labor union system within yards
which otherwise could negotiate and protect such rights.
In the above circumstances the unskilled non-permanent workers do not always stick
to one contractor. They rather like to move from yard to yard when there are better
opportunities. Once more, the new regulation should modify this practice by
establishing minimum standards of employment.
The Hon’ble Court decision dictates that “NONE shall be employed without duly
executed contracts of employment. Master roll and all forms require by labor law
53
must be maintain by employer” (Extract from the Hon’ble High Court Verdict on
06/04/2011).
Duties in the yards:
Migrant workers mostly remain as helping hands to various cutter and fitter groups
or as utility hand on demand from any group leader. They are also engaged as
manual labors such as diggers, sweepers, cleaner, wire pullers, sorting groups,
electric cables carrier, housekeeper, weight lifter and kitchen helper. There is no
clear work description. They are used as per job request.
Many of them do not continue to this job when they need to go back home in the
farming season. This always makes a new group of entrants in the breaking yards
making the system more vulnerable.
To conclude, the migrant workers are the vast majority of workers in this industry.
They are mostly floating and lack in education and experience. They do not belong to
any particular working category. They do not possess a formal agreement of
employment other than being on the mercy of the contractor. Although they account
for vast majority of workforce, the circumstances and conditions often neglect their
rights and make them more vulnerable. However, the new Rule is expected to
improve their standards of employment and bring more discipline into the system.
4.4 Procedures involved in shipbreaking stages
Since the Ship Breaking and Recycling Rules came in effect from 12 December
2011, the previous procedures have been modified/changed. SBSRB being the
central focal point are responsible for providing all necessary permissions relevant to
ship breaking and ship recycling in co-ordination with other government agencies.
A ship destined for Chittagong beach yard is subjected to undergoing various stages
upon arrival until the completion of the cutting process under the current regulatory
54
regime. The stages are: i) Preparatory stage ii) Operational stage iii) Cutting stage iv)
Reporting stage.
Preparatory stage:
In the preparatory stage most of the official formalities are completed. They involve
the following:
– Arrival notification to MRCC, coastguard, port authority, Custom, SBSRB
and other officials as required by the local regulations. Usually this is done
through local shipping agent.
– Arrive and drop anchor in Chittagong port limit.
– Submission of all necessary documents through agent including list of
hazardous material (i.e. operational waste, bunker, CO2, Freon, luboil,
chemicals, paints etc)
– Inspection by custom authority for contraband/illegal items against import
policy
– Inspection by SBSRB along with other members from NBR, DOE&F,
DOE and technical personnel from SBSRB
– Cross examine of the documents including details records of bunker, lube
oil, grease, chemical, bilge, ballast, oily sludge and gases are recorded by
Dept. of environment and forest.
– DOE inspect all tanks, cofferdam, engine room and other area of interest
and provide Gas free and hot work certificate on satisfactory results.
– On completion of satisfactory survey and payment of govt. taxes and levies
vessel is permitted to proceed for beaching.
Operational stage:
Operation stage starts with the physical beaching of ship at the specific yard. Mean
time breakers have to submit a ship recycling plan (SRP) and a copy of ship
recycling facility plan (SRFP) to SBSRB to accord necessary permission to
physically start the job on board. The operation stage involves followings:
55
– Proper securing of the vessel at yard.
– Disembarkation of the crew, if foreign crew through immigration department.
– Removal of left over bunker to registered dealer.
– Removal of oily sludge and used oil to yard facilities.
– Removal of all CO2 bottles to authorize dealers.
– Removal of all radio and pyrotechnics (Distress signals) by Bangladesh navy
(BN).
Cutting stage:
In the cutting stage ship breakers have to obtain permission from SBSRB prior
commencement of actual cutting, this involves the following:
– Submission of SRP to SBSRB
– Submission of environmental clearance certificate of the yard to SBSRB
– Certificate from BN as evidence of removal of radio and pyrotechnics.
– Treasury Receipt as evidence of payment of government taxes.
– Workers registration.
– Proof of removal of bunker, lube oil (vendor Receipt).
– Gas free and hot work certificate from DOE.
See Figure 19 and 20 to understand the general layout of the yards which need to be
submitted prior obtaining cutting permission. Once SBSRB is satisfied with the
above documents, then the cutting permission is issued. On receiving the cutting
permission, actual dismantling process begins.
56
Figure 19: An example of yard layout plan to be attached as part of SRFP (Source: SBRR, 2011)
Figure 20: Shows the example of zoning of the yard, a requirement as part of SRFP (Source: SBRR, 2011)
Beginning of Dismantling:
Under local regulations no fitting fixtures are allowed to land at anchorage other than
bunker fuel, oil sludge or residues to enlisted vendors.
57
Because the ship contains a lot of equipment and material that the yard owner cannot
process directly themselves, independent traders or trading companies are expected
to take charge of numerous lucrative items such as accommodation fitting fixtures,
tools decorative items, outfitting, engine, machineries, electrical and electronics
goods, furniture’s, kitchen utensils, sanitary items, accessories, navigational
equipment and paints chemicals. These items are sold to different traders in a spot
tendering process. The open tendering process is usually done at the beach yard after
beaching but sometimes at Chittagong anchorage while the preparation stage is
underway. However, the yard owner can remove these items and later calls for
auction.
Therefore, removal of fittings and dismantling/cutting can be of two different
operations.
Once the awarding process is over and depending on the condition of sale, the
removal can be done either through deploying the buyer’s own people or through
various labor contractors. If the buyer of some particular items engages their own
people, the yard staff remains as security to make sure that none of the buyers can
take any other items not belonging to their tender schedule. But some of the yards
owners prefer do this under their strict supervision deploying their own staff and
workers to avoid any unwanted situations and prevent damage to other types of
equipment.
Generally the cutting operations are conducted through contractors under agreement
with yard owners on a tonnage basis. Cutting contractors deploy laborers according
to the delivery demand and time frame stipulated by the owner. Initially it takes 1
to 2 weeks to plan various dismantling preparations, which include some gas freeing
operation as well. Another 2 weeks is required for removal of all fittings by various
interested traders including removal of hazardous materials by special agency under
current the Rule.
58
However, from these points onwards hundreds of workers step into the ship. The hot
and cold work continues simultaneously. Altogether the whole dismantling operation
can take more or less 2-3 months depending on the size of the ship.
The number of people engaged on board and in the yard depends on the size of the
ship and volume of work corresponding to the scrap demand from downstream
industries. The steel delivery rate imposes the rhythm of the breaking process and
therefore the number of workers in the yards varies. Usually 50-60 fitter groups and
4-6 cutter groups are engage simultaneously on board and in the yard. Each fitter and
cutter is Helped by at least 3 helping hands that are unskilled or semi-skilled
laborers. The fitters are numerous on board because they have a short allocated time
frame to remove fittings, equipment and machineries in preparations for the cutting
operations. Usually, one or two week is necessary to remove the fittings.
On the other hand cutter groups multiply in the yard where they process the steel.
Major cutting, resizing and customizing of plates are carried out at secondary cutting
areas. In addition, there are wire groups, loading groups, bottle groups, and forward
groups continuously Helping in the whole process.
Therefore, the determination of the average number of workers at any one time is
difficult to establish. Although the figure may vary depending upon the yard
management strategy and volume of work, generally a 10,000LDT vessel when
working in full swing engages between 400-500 workers at a shift.
Reporting stage:
To improve the transparency of the industry and to provide accurate data and
statistics, the new regulation emphasizes on the reporting and monitoring process. In
the reporting stage the ship breakers have to report of any occupational health and
safety related issues such as accidents involving death, serious injury, diseases and
illness to SBSRB. They also have to record and demonstrate the proper management
of hazardous waste with the quantity disposed to the central TSDF system. This is to
keep track of the quantity of HAZMAT handled.
59
Conclusion:
The composition of yard structure and methodology applied through the
current Rule seems to bring more discipline in the working environment. It is
understood that a large number of manpower is engaged through various
sources into the process. The involvement of various categories of workers
under different working conditions and experience should be reviewed in order
to improve transparency and to establish lines of responsibility to protect
workers’ health, safety and environment.
Appropriate education and training can transpose this workforce to more
reliable resources. They can be better utilized towards management of safety
and ultimately reduce the vulnerability.
60
Chapter V
Existing conditions of SBRI – Observations and remarks
This chapter will give an overview of the existing facilities in SBRI and will describe
the real life scenario in and outside the yard. This will also cover the training
infrastructure development. This description merges the visit of three sites in the
Chittagong shipbreaking area. Numerous pictures are available in Annex 9(A~E) to
make this yard visit easier to understand. The intention of this chapter is to shortly
describe breaking yards operations in order to provide a general idea of such location
and to observe the workers conditions particularly their relationship with hazards and
safety.
5.1 Remarks on the observed yard infrastructures
It is currently difficult to enter a yard without prior notification. To overcome this
difficulty the author interacted with some yard owners and was helped by BSBA.
Finally, three yards visits were conducted between 17 May to 7 June 2012. Despite
the limitations and lack of extensive on-site visits, some key elements became
visible, which are described in the following discussion.
Observations:
Chittagong SBRI is situated along the coast between Fauzdarhat and Kumira
comprising 125 registered yards. To reach the location and yards, author had to take
a narrow strip road of 2-3 km in length from Chittagong highway to the yard
premises. This road passes through local villages.
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Figure 21: Showing location of shipbreaking yards in Chittagong beside Main Highway, (Photo Google
Map).
These narrow roads are the only available connecting road to the shipbreaking yard.
They are used for general road communications as well as transportation and the
delivery of goods to and from the yards.
Most of the yards are restricted premises with fencing at the outskirt with an
individual yard/company name. The general lay out of the yards are of similar
pattern with little variance according to the size and configuration of the land.
Description along the passage:
As author was going along from the main city, purposely took a road through
Pahartali area which is the main stock pile area of various traders. They are mainly
retailers of scrap metals and machineries after resizing and overhauling machineries.
Hundreds of such retailer shops can be found on both sides of the roads.
On reaching the high way, along the main road on both sides many furniture shops
could be seen in a few kilometers. Close to the Bhatiyari area and onwards on both
sides numerous shops could be found with paints, chemicals, kitchen utensils, LSA
62
and FFA items, ships equipment and antiques. This amount of equipment, material
and items for sale demonstrates the magnitude of the activity and its importance for
the area. Pictures of some vendor shops and materials for onward utility can be found
in Annex 9(A).
From the main highway it is not identifiable which yard someone is heading for as
there is no sign board on the leading roads. However on all the occasions the author
was accompanied by a guide.
While passing through the narrow strip road author could see some areas where
people were manually extracting copper from electric cables without any equipment.
Only after being close to the yards industrial sounds could be heard, otherwise it was
calm along the road.
Description of yard infrastructure:
On reaching one of the yards author encounter a manned security gate with an
archway. Anyone could clearly identify them as security guards with specific
uniform. Identifying author and explaining the purpose of visit led me passing
through. Having registered in a visitor’s book author was provided with a pass card.
Looking around, could see the general layout of the yard is painted on a wall or on
large frame. Various safety posters in Bangla and emergency contact telephone
numbers were posted or hanged on the walls around the main gate. (See picture
gallery in Annex 9(B).
The general atmosphere of the yards was busy. The breakers pile up ships before the
monsoon (June-August) to take advantage of the weather. During the monsoon
shipbreaking is a dull season. However, in all three yards there were ships in
different stages of the dismantling process. All the yards were active with 2 ships
Observation: A preliminary sign of security & safety measures seen in place.
63
each in two yards and 1 ship in other yard. Delivery of scrap metals was
simultaneously and continuously in progress with number of trucks in the queue.
A yard office was adjacent to the main gate. The manager of the yard met me and
introduced me to some other office staff members. While discussing with the yard
manager author was given an introduction of their safety and welfare policy in
general as well as their future plans for improvement.
In the office a few staff members were busy with their day to day jobs while one was
sitting in dedicated computer room monitoring weighbridge of the trucks. Besides
the office materials there were a daily rooster and attendance board showing the
number of peoples engaged in different categories, and their spot of work. This way
to record the workers seems common to the yards that author visited.
After this short presentation close to the office location, a further guided tour around
the yard was given.
The physical infrastructure development was visible within the yards. In all three
yards they had portable generators for backup power. An electrician and a fitter with
minor maintenance capacity look after the generator. There are a number of electric
poles fitted with flood lights visible around the yard. I was told the lights are
collected from scrap ships.
In addition to the needed installations as office, entrance gate and storage place, it
was visible to see the development of infrastructures associated with workers utility
(See picture gallery in Annex 9(C) such as:
Dormitory for living: In one yard author saw a two story building and another two
with 3 stories as a dormitory complex. General appearance gives an impression that
Observation: A rush of local demand for scrap metal was observed and workers were found busy.
Observation: Gives impression on the realization of past practices and intentions for future improvement.
Observation; A system of work force attendance record seen in place.
64
the construction was not that long ago. Inside arrangements were with a number of
beds side by side as well as bunk beds. All the rooms were not furnished completely.
Toilets and bathrooms: Separate toilets and bathrooms were found adjacent to the
dormitory complex. Author was given the impression of a ratio of 1:5. A separate
pond was also found in two yards for those not comfortable with showers in enclosed
bathrooms.
Mess room with cooking facilities: Common mess rooms were found with cooking
facilities with a mini grocery shop attached. Author was talking with some of the
workers while they were having afternoon tea and it looked they were happy having
a mess inside where they can relax and share their joys and sorrows. In one yard
there was a separate mess for office staff and supervisors.
Recreation room: In all three yards a common recreation room was seen with TV
and VCD player and some indoor games. With my visual estimation they were not
spacious enough to accommodate more than 30 people.
First aid room: All three yards were found with a medical first aid room manned by
a medical Helpant. They were equipped with stretcher, a bed and medicine chest
board which looked collected and installed from scrap ships. I was told they can only
provide preliminary first aid but for serious injury they have to send the patient to
hospital facilities either in BSBA hospital or any other hospital nearby. Currently
they shift those serious patients to Chittagong city as BSBA hospital’s in-house
facilities are under construction. None of the yard has an ambulance. They need to
seek help from a general ambulance service or a private vehicle.
Medical Facility outside yards: On the way back author travelled to Bhatiary
station road to see the status of BSBA hospital. It was late in the afternoon. On
reaching to the site there was no responsible personnel except a security guard who
said that construction of a 5 story hospital was nearly completed. They have
arrangements for 150 beds with in-house facilities, which are yet to be equipped.
65
Presently BSBA have appointed a doctor with an outdoor facility opened for limited
period of time during the day. They still do not have an ambulance.
Drinking water facility: Separate drinking water facilities were seen with temporary
plastic tanks. In one yard they also had water purification plant. During authors visit,
numbers of workers were found using them and collecting water in small bottles.
Safety officer’s room: A compulsory safety officer in every yard is a new concept
under SBRR. They are appointed by SBSRB but paid by the yard owner. In two yard
safety officers were found. Author was told engagement of safety officers in other
yards are in progress. There were limited PPE and some fire extinguisher in one of
the safety officer’s room.
In an interview they both mentioned they are retired personnel from BN and did not
have working experience on board merchant vessel. However, they are trying to cope
with the industry and at the same time trying to improve the working system. They
also mentioned the role of safety officer in the organogram still not clear to them.
They also lack in logistics, resources and supporting hands as they mentioned.
Fire fighting facility: All three yards had a fire pump connected to a deep well. The
hydrants were seen around the yard, which are mostly used for fire fighting in the
yard. On board fire fighting is limited with a number of ships extinguishers and
buckets of water as was intimated. Sometimes they use portable submersible pumps
but that is limited during high tide only. In case of a big fire they seek Helpance
from the nearest fire brigade station situated in Fauzdarhat and Kumira which is
within 5-10 Km range.
In-house training: In one of the yards author saw an in-house training center. The
room was about 200 sq. feet with a few safety poster and some hand gloves and
rubber boots. A VCD and some ships publications were found, which looked not
touched in the near past. In interviewing some staff they mentioned this will be used
Observation: A transparent role for safety officer is apparently absent.
66
by safety officers in the future. In the other two yards the safety officer’s room is
used for mini conference/meeting.
In addition, separate prayer room and barber shop in the dormitory complex was also
seen in one of the yards.
In addition to the above installations, waste management facilities were also
observed as described below:
HAZMAT handling facility: In all three yards author could see the physical
installation of negative chamber room for asbestos, separate room for battery, heavy
metals, glass wool, well for oil and oily sludge, sorting and separating room. Almost
all the rooms were found closed except the oily sludge room with a portable pump
outside for transfer to lorry. In an interview it was understood no one really knows
the operation and handling of asbestos room. Author was told almost all the yards
have similar facilities with few exceptions as these have become mandatory
requirements under SRFP.
General overview of the Yards:
Around these facilities, workers were seen having various types of clothing. Very
few of them had complete industrial dress with appropriate PPE but some cutters and
welders had. Many were absolutely with no PPE other than traditional clothes.
Seeing the visitors, some workers were busy in collecting hard hats.
Observation: A good arrangement and ideas in place but effectiveness yet to come.
General observations/remarks: Physical infrastructures developments are more visible than in the past. Most
of the developments give an impression of newly construction in the recent past probably after the
legislative requirements. However, a sign of improvements is visible with regard to workers welfare, health
and safety matters.
Observation: Facilities developed gives an impression of recent additions under the requirements of SBRR but
less effective use of them were seen, probably due to lack of adequate knowledge and training in this aspect.
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After this short view of the yard entrance and surrounding facilities, the visit
continued on the location of the operations.
5.2 Observation on the present operational practices
Reality of the operation procedures:
This will give a general overview of the yard operational practices involving
workers. This observation is solely based on the author’s personal visit to three
yards, which may not reflect the overall practices of this industry:
Unfortunately, it was not possible to see on board operations. However, visual
inspection of the cutting, loading, waste management facilities, workers
accommodations, mess room, safety officers’ room and areas surrounding was
conducted to grasp the working reality within yards.
Dismantling, cutting, removing and delivery were simultaneous operations involving
hundreds of people working in different stages. A vast majority of general workers
were observed wearing traditional clothes and partly or without proper PPE except
cutters and fitters. General body language of the workers was hurried and busy ( See
Annex 9C for pictures).
While taking a tour around author tried to take a short interview of workers in
different groups:
Author saw about 40-50 people in a wire group that were arranging a cable on a large
winch in order to pull a ship in the next tide which was beached a day before. Most
Observation: The impact of observer shows the urgency to follow safety procedures. Because of not having
PPE in work place, certain inspector’s visit can impose penalty under current penalty provision in SBRR. It is an
indication of either sufficient PPE not in place or workers are not aware of their use and importance. They
rather seem more respectful to the penalty provision.
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of these workers were found without PPE and boots. Author had the opportunity to
talk with a few of them in a group. They said that they rather feel comfortable
without boots in this clay/muddy and slippery condition. In addition, they mentioned
there are not many in the yards to provide such large number of workers and
personally to buy them is expensive.
Another group was in charge of carrying electric cables in round coils. Each coil was
carried by two individuals working in pairs. They were travelling to and from the
ship and were stacking the coils in a single location. The load was lying on their
shoulders that they protected with ‘hand-made’ pads. They had basic rubber slippers
and no PPE.
There were at least 10 cutter groups found working in different places. They were
busy in resizing the plates in truckable size. Most of the plates come as a big chunk
in the secondary cutting area which needs to be resized as per customers demand.
All the cutters were having proper PPE including safety goggles. They were Helped
by 3-5 helping hands in each group. These Helpants were rarely wearing any sort of
PPE. In addition, there was no fire fighting appliances nearby the cutting areas; and
even less designated precautionary area or warning signs around.
One of the groups author saw two workers were working on a bulkhead which still
had the insulation materials attached, probably glass wool or asbestos. However, the
workers seemed not disturbed by this material and no additional precaution was
taken.
Observation: Lack of safety/precautionary measures for hot work. Unskilled workers seem not aware of
the use and importance of PPE.
Observation: Not all workers wear PPE because of either availability or affordability.
Observation: Lack of knowledge about identifying hazardous materials and their associated health risk.
May be due to lack of awareness and training.
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Sorting group: In one of the yard, an eight member group was found in the
designated room for sorting out various small parts of the machineries. They usually
disintegrate some small parts of machineries to separate the precious metals such as
stainless steel, copper, nickel, nuts and bolts for better economic return. They were
completely without any PPE, not even gloves. Some of them were just wearing jeans
and T shirts. In the other two yards a group of a few people were seen busy with
sorting items on the yard and also doing some activities in housekeeping. A few of
them were found with helmets.
Machine shop: In one yard a designated machine shop with Lathe machine and
other repair tool kits were seen. The workshop seemed like recovered from a ship
and installed. Very few workers were seen involved in this workshop. They were
welding and machining some parts. In an interview they said they support their inhouse mechanical machineries with minor repairs as and when required. In addition,
they conduct overhauling of some machineries for better selling price. They were
seen with PPE and welding screen/goggles.
Yard Equipment/Mechanization: In all three yards some mechanical equipment
such as magnetic crane loader, mobile cranes of two types both hydraulic and
mechanical, multipurpose lifters and tractors were seen. In all the yards both
magnetic loader and mobile cranes were found loading trucks and shifting/sorting big
plates. During the visit, yards were found with clay and mud because of the previous
rainfalls. Big steel slabs were used for walkway and truck mobility. None of the
truck helpers were seen with PPE.
Observation: Lack of knowledge about the general concept of wearing PPE (probably not trained), a
housekeeping procedure seen around the yards.
Observation: Most of the skilled workers seem aware of the use and importance of protective gears.
Observation: Use of more mechanized equipment was seen. Outsiders such as truck drivers and helpers
seem not aware of the workplace safety.
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5.3 Comments and perception on safety awareness after the yard visit and
interviews
After this short tour in the yards, it is clear/obvious that the industry is passing
through a transitional phase with construction stage. Under the current regulatory
regime the industry seems to be putting more efforts for transformation towards
green recycling as the state suggests.
However, the general body language of most of the workers indicates they lack
safety awareness and are unable to identify or realize the risks they are exposed to.
The lack of PPE also deemed related to the cost of such equipment for the workers
and/or the owners. It seems that the equipment is either not available in numbers or
the workers do not use the existing equipment properly. It is difficult to understand
why?
However, in the authors’ opinion the change of behavioral pattern of the long
persistent practices is crucial in this transitional stage. It requires lots of motivational
training emphasizing the importance of using proper PPE which does not seem to
reflect in the operational environment. Mostly the cutters fitters and welders do use
their PPE. Nevertheless, the vast majority especially the unskilled (migrant) workers
who are engaged through contractors lack safety awareness and are not provided
with PPE. Understandably they are still out of the training umbrella.
Conclusion: It is clear that due to the Hon’ble Court intervention and
subsequent formulation of new regulations (SBRR) have compelled the industry
to develop various infrastructures with regard to workers accommodation,
safety and waste management facilities. These physical infrastructure
developments are more visible. But regarding occupational health and safety
measures much needed afford yet to be in place with positive aptitude of all
stakeholders. The effective implementation of the OSH policy up to the grass
root level needs to be further emphasized through enforcing and proper
monitoring.
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Chapter VI
Present development of capacity building and training
infrastructure
This chapter will highlight the importance of capacity building in terms of human
resource development through necessary education and training and its importance
for sustainable growth.
Introduction:
Capacity building refers to strengthening the skills, competencies and ability of the
people so that they can improve the performance, reduce the vulnerability of
occupational risk and overcome the cause of their exclusion and sufferings. Capacity
building as an individuals or a group of people within the organization can enhance
the organizational ability to achieve the desired goal and perform in an effective
manner. It can be described as the strategies or actions that an organization takes to
ensure that it has the resources needed to succeed and that these are properly
allocated and used.
These actions can include resource management, organizational learning, human
resource development, leadership development and other activities. In other words,
capacity building is any set of actions that an organization takes to improve its ability
to perform successfully in its chosen area. Knowledge is the foundation of capacity.
Knowledge comes through proper education and training. For sustainability of this
industry, capacity building could be one of the important measures involving
allocation of resources for education and training of workers.
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6.1 Legal background and sustainable requirements
The competent authority of Bangladesh has spotted the education and training of the
shipbreaking workers to be at the fore front for sustainable development.
Legal background
Prior to 2011, there were no legal requirements to train SBRI workers. Since the
High Court Verdict in 2009 and enforcement of the new Law in 2011, clear
directives (both from the Hon’ble High Court and SBSRR) were issued in order to
provide education and training to SBRI workers. Therefore, education and training of
shipbreaking workers became a mandatory requirement. Among nine other Court
directives, the first directive was with regard to education and training as follows:
A system of comprehensive training must be introduced to impart
training to those who shall be employed for ship breaking activities.
An Institute will be set up for the training purposes by BSBA at their
cost for training such persons. The training period shall be at least 3
months duration. First 20 days shall be allocated for theoretical
training, while the rest of the period shall be involved in practical
vocational courses. No workers shall be allowed to be employed in
the ship breaking yards without certificate showing completion of the
course (Hon’ble High Court Verdict on 6/4/11, regarding workers
training).
Also Ch.IV, Para. 17.1 Of SBRR, 2011 states that “Only the trained workers shall be
employed in the breaking yard. The workers must undertake theoretical and on job
73
training from a designated training institute supervised by SBSRB. It also states that
unskilled workers supplied through contractors also have to undergo training”.
In short, no person should be allowed to be employed without training and
certification.
Sustainable requirements
Sustainability is the capacity to endure. To achieve that, all training needs
longitudinal reinforcement. In the context of shipbreaking workers’ training in
Bangladesh, the following few parameters described gives an idea of the existing
conditions.
Execution of Training
Following the Hon’ble High Court directives in March 2009 the trade body ‘BSBA’
undertook the responsibility to establish a training center, and later they delegated the
job to a group of marine professionals under their control and administrative
authority. BSBA considered the professionals would be in a better position to deliver
the necessary training to the workers. It was the starting point to establish a SBRI
workers’ training center.
However, it is understood the training institute started with not many preparations
and foundation studies with regard to identifying the stakeholders and main audience
group. It is also understood there had been no such institute existing in the past,
particularly for SBRI workers’ training. As such the training institute did not have
ready materials/aids to execute the training effectively. Nevertheless, it was needed
at the time to establish a training center under the current regulatory regime.
Henceforth, the training continued with the aid from their professional knowledge
and experiences. At the same time the institute was trying to develop training
curriculum and organize the staff for effective training delivery.
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To make the training effective and sustainable, a good foundation studies are
important to identify and understand the various stakeholders and main audience
group considering the local environment and working conditions.
Control and monitoring:
Since the intervention by the High Court and until today the control and monitoring
of the training institute came through two phases. Since the inception of training
institute in February 2011, the training activities were controlled and supervised by
the Director of Environment, Chittagong under MOEF. Later from 12 December
2011 the authority shifted to SBSRB situated in Dhaka, under MOI. It may be
difficult on the SBSRB part to effectively monitor the training processes because of
the distance apart. Moreover in the author’s understanding all the members of
SBSRB are yet to be recruited following government procedures which may take
some time.
However, under the current legislative requirements, control and monitoring
criteria are in place but the effectiveness yet remains as a challenge in this
transitional stage.
Record keeping:
Transparent records of all training activities including record of accidents and
injuries are very important for further improvement in the system. Currently, this job
is mostly done by the training institute itself. Understandably, only few workers have
been trained since the inception of the institute. However the directives on training
are compulsory for all the workers in SBRI. Because of no particular record of
workforce engaged in this industry, it is difficult to trace who is yet to undergo
training. Yard owners also do not have complete records of trained personnel
engaged in their premises other than those of their regular employees.
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Further there is no central database for the records of workplace accidents/incidents.
The accident analysis is very important to find the causal effects, gaps, loopholes and
lacks in the current system. As such review for further improvement is currently
limited. Training Institute has recently opened a dedicated accident analysis and
prevention cell. The aim is to investigate all forms of accidents/incidents for root
cause analysis in order for future prevention and transfer of information across the
industry.
However, under SBRR Ch.VII, Para-30.4,5 and 6, ship recyclers are required to
report, record and notify work related injuries and diseases, ill health and incidents to
SBSRB. Also under Ch.IV, Para 17.22 of SBRR 2011 a record of attendance register
is required for the workers engaged in the yards to be maintained in accordance with
the provision of BLL2006.
However, the author’s practical visit to the yards suggests that not all of the people
engaged in the yards are trained (See Figure 22). A proper record keeping system
and effective monitoring of all training activities is expected to demonstrate more
transparency under the current Rule.
Figure 22: shows the current training statistics (source: author’s quantitative research)
36
52
12
Current Training Statistics(%)
Trained
Not trained
Under training
Finding from quantitative interview with 100 workers.further ref:Annex-02 & 06.
Inference: 52% of the workers yet to be trained under current training system.
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Financing:
Financial support is a big factor in the equation for sustainability. A training institute
with such a huge task cannot just be born. It requires extensive research primarily to
understand the working environment and conditions. It also requires a lot of
infrastructure developments, especially in the preparatory stage and henceforth to the
training delivery. The process should be continuous for further review and
development with the trending demand, which may require continuous financial
support.
In a qualitative interview, the training coordinator mentioned “We have all positive
intentions to develop the training institute from current state to a proper institute
which require huge financial involvement. Since inception in nearly two years we
could not make any significant progress in developing the training materials/aids
other than procuring some safety posters locally”. He also mentioned unlike the
initial stage the flow of trainees also is reducing with the time and the institute has
monthly fixed overhead costs which they still need to maintain even if there is no
training. With such financial burden the existence of the training institute is matter of
a question.
According to the High Court directive, it was the trade body (BSBA) who was to
establish a training center and the expenses to be borne by them. However, ultimately
the fees/expenses are borne by the yard owners for their regular staff and skilled
laborers. In a qualitative interview with two yard owners and a senior consultant to
BSBA (see details in Annex 3 and 4), it was understood from their opinion that the
job seekers should have certain pre-qualification like in any other job sector.
However, still for their mutual benefit and reputation of the industry, they are bearing
the expenses for their regular staff that are limited in numbers. They also mentioned
that unskilled workers engaged through contractors are mostly floating and not
consistent in the industry. Moreover, it is the contractor who engages them, so the
question of training expenses should lie on to them or through other patronization or
even from ship owners under corporate social responsibility (CSR).
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To conclude, providing education and training for SBRI workers is currently a
legal requirement. The execution of this requirement is just in place which seem
passing through developing stage. For sustainability of the process more
supervisory and control, financing and record keeping mechanism is expected to
effectively demonstrate under current legal system. In both cases for sustainable
development of the training institute and training expenses especially for migrant
workers, probable technical and financial support is likely absent in the existing
facilities which need to be further explored.

6.2 Evolution of training infrastructure and Current developments
Background:
Formerly there had been no training scheme for ship breaking workers other than a
few workshop organized in the past by BILLS in collaboration with ILO, UNDP and
NGO’s.
Following the Hon’ble High Court order in March, 2009, among other directives,
providing education and training for the SBRI workers became compulsory. It also
became one of the pre-requisite for the yards to apply for environmental clearance in
order to resume their business.
Establishment of First training center and location:
The first formal training institute came in effect on 21 April, 2011 in the name of
“BSBA Training Center” with no particular infrastructure as such.
The training program was guided and supervised by the Director of Environment
under MOEF. The resource personnel of that institute are composed of a group of
master mariners, marine engineers and some retired naval personnel.
In a qualitative interview with the chief training co-coordinator while he mentioned
“we indeed kicked off the training program almost empty handed with no ready or
approved training curriculum in hand. Eventually we had to develop our own training
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curriculum based on our ship board experience and following various guidelines such
as ILO, IMO and industrial best practices”.
Having no designated premises of their own, the institute initially started the training
program in JUBA Bhaban, Halishahar in Chittagong city far away from breaking
yards.
Method of enrollment and training package:
Workers had to register through BSBA under the banner of associated yard owner.
The same list was then forwarded to the training institute for necessary training. In
the beginning there was rush of workers queuing for the training as it was one of the
requirements to obtain cutting permission. Under such pressure the Institute had to
run two parallel courses in the morning and afternoon sessions.
Initially the training package started with duration of 20 days as general class room
teaching and additionally on the job training program in the yards. The delivery of
the training was mainly on the basis of situational and safety awareness with regard
to various health and safety issues such as personal, professional and physical safety
of the workers, knowledge on management of hazardous waste and conservation of
the environment. The composition of the program was supplemented with lectures
from relevant govt. entities such as labor office representative, a representative from
the environmental department, representative from the national fire and civil defense,
representative from the maritime academy and community doctor to highlight
various relevant issues involved in ship breaking activities.
The first batch of BSBA training ended in May 2011 with a total of 571 workers
mainly cutter foremen, supervisors, leading foremen, fitter foremen, shift-in-charges,
cutter men and riggers of different ship breaking yards. Two hundred and fifty other
workers were enrolled to receive training under the second batch and so the training
program continued (Daily Sun,, 2011).
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Shifting of Authority and Transition:
In the meantime shipbreaking was declared as “Industry” on 13 February 2011 which
was Gazette on 20 October 2011 under the Ministry of industry (MOI). Following
the declaration, the new SBRR was published and came in effect from 12 December
2011. This new rule demands that the training institute should be recognized and
approved by SBSRB.
The same former ‘BSBA training institute’ with its existing set up was renamed as
AESL Safety Training Institute (ASTI) under the AESL Company. It was relocated
at KadamRasulPur under shitakunda Upazila. The present institute started in a new
rented house almost midway between the yards. The same institute was finally
approved by SBSRB.
Visible Developments
Since 25 March 2012 this is the only approved and recognized training institute by
SBSRB to undertake Education and Training for SBRI workers. Author visited both
the institutes in April 2011 and May 2012 while training activities were in progress.
It has been seen, the BSBA training institute class room was full with more than 100
workers participating in training program (See Annex 9D). The delivery of training
was mostly based on the theoretical lectures with safety videos used for shipping
industry. No formal class routine and segment of program was in printed form. No
books, handouts or safety posters were available in the class. Few PPE were
available for practical demonstration. The chief training coordinator was responsible
for the organization and distribution of classes according to the availability of
resource personnel.
Class room activities were seen enthusiastic. For example, most of the workers were
keen on sharing their various experiences and they were asking many questions with
curiosity. It was observed the lecturers were trying best to explain them verbally
without any supporting teaching aids. Workers were seen sometimes not able to
80
visualize and follow the lecturer even though the workers looked very proud of
acquiring knowledge. Author heard some workers were saying “If we were given
some awareness before provably we could avoid lots of accidents”. At the end of the
course a certificate was issued to all the participants’ there were no particular
Assessment criteria.
Author also visited the new training institute (ASTI) from 29 May to 7 June 2012,
while a training program was in progress with 15 participants. The course duration
has been squeezed to one week. The enrollment process has been modified;
participants can directly enroll through the yard owner.
There were various safety posters seen hanging inside the class room. No other
visible development could be seen, especially the structuring of training curriculum
and teaching aids. The mode of training delivery still remained the same (See Annex
9D).
The chief coordinator claimed that the majority of the workers are yet to be trained.
Especially workers engaged through various labor contractors are not in the
enrollment list. Since the inception of training program so far they trained only about
2700 workers (From April 2011 to May 2012), they are mostly skilled laborers
employed in various yards.
There is currently only one common course for all category of workers at a cost of
Taka3500 (equivalent to $40).There is no further course developed for different
working groups. The education and training program is limited to one time only.
There are no particular student Assessment criteria and no provision for a refresher
course.
To conclude, the establishing of a training institute currently satisfies the
national legal requirements. For sustainability of the institute and the training
program, appropriate logistics and support seems insufficient in this
transitional stage. The institute needs to be more formalized and composed for
effective delivery of the training program. Therefore, a comprehensive plan of
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30
36
40
Percentage of age Group
18-20
21-30
31-40
40 above
action should be undertaken identifying all stakeholders and finding possible
financial and technical support to strengthen the institutional capacity.
6.3 The voices and comments about the current training system
As mentioned in Methodology, author has conducted qualitative interviews of 35
workers from different age and experience groups. Details can be found in Appendix
A & Annex 1. Author also conducted quantitative research on 100 workers randomly
chosen from different groups (Details can be found in Appendix A, Annex 2 & 8).
Most of the interviews were related to OHS training which is highlighted in the
following discussion.
Needless to mention that due to resources and time constraints, this is limited
research. The author’s personal effort to collect data may not necessarily reflect the
whole industry. In order to preserve the anonymity of the interviewers, the names
stated below were altered.
Findings in Quantitative interviews: 100 workers were given with various
questionnaires relevant to the following is furnished below (Table of contents can
be found in Annex 2 & 8 for further reference).
First set of data about workers basic information:
Figure 23: shows %age of workers age group and experience
Inference: Vast Majority of the workers are age 31 and above. Inference: Majority of the peoples are having more than
2 yrs of work experience
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Figure 24: shows %age of workers education level.
On the age and education of group statistics, it can be noticed a small discrepancy
between my data and data shown previously (Ch-4.3, fig-20). This discrepancy can
be explained by the fact that my data were mainly collected inside the training
institute in which the trainees are often skilled and experienced workers with higher
experience and age.
In the above basic information it shows that the majority of the workers are aged
above 31 with more than 2 years of working experience while a two third majority of
the workers have no or very low level of education.
Second set of data concerning the training content:
100 Workers were given various questionnaires regarding their comments on current
training facilities such as:
i) Is the current training understandable to them?
28
44
20
8
0
5
10
15
20
25
30
35
40
45
50
No Education Primary Secondary Hsc and above
Workers Education Level
Inference: 44% of the workers only have primary level of education.
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Inference: 46% of the workers are satisfied with current
training program.
Inference: Vast Majority of the workers are not aware of
occupational hazards.
38%
46%
16%
Hazards Identification
Knows
Partly Knows
Not Know at
all
46%
42%
12%
Sufficiency of Training
Yes
No
No
Comment
The results are shown in Figure 25.
Figure 25: shows percentage of workers comments on training contents
Is the training structure sufficient? iii) Do they know all the hazards?
Figure 26: Shows percentage of workers comments on current training program and ability to identify
hazards.
34
51
15
0
10
20
30
40
50
60
Understandable Not Understandable No comment
Understanding on the Training program
Inference: Current training contents are not understandable to over 50% of the workers.
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iv) Workers comments for improvement if any.
Figure 27: Shows percentage of workers comments on further improvement in current training program.
From the figures above it may be said that, the current training content is
insufficient to meet the demand of the workers. Most of the workers either do not
understand the teaching pedagogy or the contents. Supporting teaching
materials/aids may not be appropriate to reach up to their knowledge level. To
make the training program effective further improvement is required which may
demand in depth study to find out the possible solution with a pragmatic approach.
Main findings from qualitative interviews with workers:
Appreciation towards changes was expressed by the workers. Almost all the
workers admitted that they had benefitted from the training. They all
appreciated the intervention by various agencies and government steps
towards OHS. Mr. Ali generally comments on behalf of many workers “We
are very happy that authority is looking after us. Recently lot of changes has
come for us and we started to use those facilities in the yards, we expect to
have better life than in the past”.
80%
60%
60%
20%
Workers comments/suggestion for Improvement
Training & Drills
Information Sharing
Forming association
Other measures
(Each worker had mutiple option
to comment on)
Inference: Vast Majority of the workers are in the proponent of simultaneous training, drill and sharing of
information & knowledge.
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The close relationship between workers and trainers was highlighted. This
link was deeply appreciated because now, the workers have some contact
points. Mr. Salim was exited, he says “Beside what we are taught, we have
the contact number of training co-coordinator and other teachers; we can
directly phone them for any suggestion. Before nobody could tell us which
was right way of doing things. We are very happy to have a training institute,
it is opening our eyes”.
Workers expressed their concerns about the current training program. The
majority of the workers consider that training should be more customized and
delivered to different groups in relation to the nature of their jobs. Mr.
Kashem with 12 years of experience in this industry said “I work mostly in
cutting operation, I must know more on the cutting safety”. It seems the
training provided is very generic and not sufficient precise for some workers
that require more specific and adapted knowledge. Mr. Rashed, 32yrs said “I
work with bulkheads and dismantling of pipes, I would prefer to know more
on the hazards associated to my work but other knowledge is also good for
me”. The minority of the workers did not have any comment on that.
Workers expressed concerns about the take home training materials. All of
them mentioned they are not provided with hand books, no leaflets, no take
home materials. They expect the above materials should be made available to
them for better understanding and sharing information and knowledge.” this
comment made by Mr. Kolimollah expresses the general view of the workers.
The lack of supportive material was clearly highlighted by a lot of trainees as
well as the course coordinator. “The teachers are very good but they do not
have supporting materials to show us. For us it is difficult to visualize what
they are saying” (Mr. Karim).
Language issues: It is understood that the education level of the workers is
very low, such as not being able to understand the video contents that are
shown. Mr. Rahim said “The video they are showing is in English which
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make no sense to us, we prefer to have video materials in Bangla and more on
job specific”.
Lack of education needs adaptive pedagogical material, Mr. Jabbar said.
“Most of us cannot read and write, we prefer to have many posters which can
be understandable for us”.
Practical and specific pedagogical training material seems absent in the
training program. Workers do prefer to have a practical model of ships or
sections to visualize along the lecture. Mr. Alam said. “This is a new training
scheme, the teachers try very hard to make us understand but if they have a
model ship we could go close and learn better”.
Size of the classroom needs to be adapted. The number of trainees in the
classroom looks overcrowded and student teacher ratio is not optimal. Mr.
Rauf said “There are too many peoples in the class room, very hard to follow
lecture from back bench”.
Workers preference towards practical training. A small majority of the
workers were in support of more practical oriented training and drills while a
minority stated the program should be a combination of both class room and
practical teaching. Mr. Yasin with 3 years of experience in this industry
mentioned “For us it is easy to understand onsite training while we are
working, teacher can observe and explain the safety matters”.
All of them also appreciated the involvement of visiting lecturers from the
local ILO office, community doctor, environment department, national fire
brigade, Marine Academy which they feel has amplified their knowledge in
different areas. Mr. Abideen said “We found the combination of various
knowledge is fruitful for us, because we are facing injuries and small fire
almost frequently. We do most of the things from our common sense but with
current knowledge we will be able to operate some extinguisher and be able
to give some better first aid, this is good for our personal life also”. He also
mentioned “there are plenty of extinguishers on the ship, instead of selling
them right away they can be kept for use till the dismantling process is over”.
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Main Findings from a qualitative interview with chief training coordinator
(Further ref to Annex 5):
A qualitative interview was conducted with the training coordinator to understand the
existing training facilities and their ongoing process.
From the interview it is clear that the training institute is recognized as
‘ASTI’ and approved by SBSRB. The training curriculum is still under
construction and yet to be approved. Currently, they are following ILO, IMO
and GOB guidelines pertaining to training delivery. The teaching pedagogy is
mostly class room lectures sessions with audio visual aids in English used by
the shipping industry. No customized audio visual aid is currently available to
them. On completion of theoretical sessions a supplementary on the job
training is also provided for a day.
The training coordinator mentioned, “We have all positive intention to
develop the institute but we are facing challenges with appropriate training
materials and resources which are not readily available in this context. The
institute has just begun without much background preparations and logistic
supports. This might require some time to establish as a proper institute. It is
also subjected to the availability of financial & technical support. I feel there
is lot of rooms for improvement”.
He also mentioned, “We are also planning for additional courses for various
stakeholders and special category of workers but these are our future plan.
We are also looking for a special course for the HAZMAT handling peoples.
Currently we are lacking in technical support and logistics.”
From the above research it is understandable that the industry is actively working
on the workers training issues. Workers looked happy and morally boosted finding
the opportunity to gather information and knowledge. However, it seems the
establishment of the training institute was needed at the time and was hastily set up
without much primary research.
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The use of Training materials/teaching aids looks insufficient and not adapted in
accordance with the workers knowledge level and understanding capacity.
Transfer of knowledge and information should reach the grass root level in an
adapted manner to have better industrial output. Also it looks the general
perception and demand of the workers is more than the existing training facilities.
A general common course alone does not reflect to satisfy the different category of
workers. In these circumstances the purpose and effectiveness of the training
program may not contribute sufficiently towards enhancement of workers
knowledge and competence.
The data collected from different methodology suggests that the purpose and
objective of the training program may not been appropriately adapted in the
current context. The teaching pedagogy and the contents deem not satisfying the
demand of the main audience group. Most of the workers demand for more
practical oriented program either onsite or using various models which shows lack
in the current facilities. Moreover training for one time without further refreshing
may not sustain for longer period of time.
To make the training program effective further improvement is require in the
current system. The structuring of the training program and delivery materials
should be tailored made considering trainees level of knowledge and experience.
They should be constructed as such so that they are easily understandable to the
audience group. In the above circumstances the institute may redefine the program
introducing basic and advance courses according to the different level of workers
considering specific nature of their jobs under local circumstances and conditions.
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Chapter VII
The road for improvement
This chapter will highlight some similarities and possible correlation between
maritime training and shipbreaking workers’ training to support the ideas. It will also
give recommendations how to improve.
7.1 A maritime-inspired training system to support SBRI
Ship breaking is recognized as one the most hazardous occupations (ILO, 2004). It
involves a wide range of activities which encompasses OHS and environmental
issues. Therefore the workforce engaged in these activities should know the
associated hazards and its implication on the environment in order to avoid
hazardous exposure. Appropriately the shipbreaking activities largely involve ships
as main focal point and a portion of its related hazards.
Findings in the interviews:
The author interviewed a number of experienced workers to understand the industry
practices and to grasp the workers’ knowledge in relation to the identification of
safety and hazards and their way of approach. Some of the interviews are highlighted
to show how callously they used to work in this industry because of not having
education and training in the past.
One of them Mr. Rafiq, a cutter foreman with eight years of experience in the
industry described an accident while a worker was suffocated in empty ballast.
Before he witnessed this accident, to his understanding water ballast tank cannot
contain gas inside. Therefore, his perception made him confused. Following the
argument I asked him: “Have you ever heard about depletion of oxygen that may
happen even in ballast tank if it was kept closed for long period of time?” The
accident may still happen even in the ballast tanks if not sufficiently ventilated and
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the atmosphere is tested for safe entry. This was surprising for him as he never
thought of such conditions neither was he educated with such information before.
It is obvious they have very limited knowledge of hazards and confined spaces in
particular. They are not aware of safe entry procedures and the use of testing
equipment.
Another very experienced worker Mr. Karim, fitter foreman was interviewed to
know about the tanker and the tank cutting procedure. He also has witnessed many
accidents before. He was describing the entry and hot work procedure in a tanker
where they rely solely on the gas free and hot work certificate issued by DOE. Once
that certificate is made available to the yard, the cutting operations start. But to the
author’s understanding the explosive certificate is valid for a limited period. In
addition, specific conditions are highlighted such as proper procedures to follow
regarding ventilation and periodical measurement of the tank atmosphere. Therefore,
the certificate does not guarantee the tank will remain safe for entry and hot work if
the tank atmosphere is changed for any reason and proper procedure is not
maintained.
Moreover, most of the tankers are not absolutely clean and there remain sludge/
sediments in various corners which can emit toxic vapors while heated up during the
day. In questioning Mr. Karim, he further described a dangerous and cruel method of
testing a tank atmosphere:
– Use of short spark of a lighter in the upper level of the tank and;
– Lowering a live chicken in the bottom half to estimate the tank atmosphere.
It is needless to mention how suicidal and heart throbbing this attempt could be. He
has also witnessed many small and big tanker explosions causing loss of many lives.
To his experience he has also seen workers fainted inside cargo tanks. However, Mr.
Karim is fortunate to survive in many accidents and near misses.
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To the author’s understanding, tanker operations are considered as highly
sophisticated and particularly dangerous. Therefore, international standards require
specific training for the crew working on such ships. Not all general seafarers can
serve on board a tanker unless they receive additional courses on tanker operations
and procedures despite the fact that a scrap tanker is a dead operational ship. Such
vessels require safe dismantling procedures because they might not be properly
cleaned and de-sludged which may create explosive atmosphere and toxic vapors.
Additional training and information on tankers should be included in the training
schemes in order to avoid tanker explosion and enclosed space casualties.
A recent accident on 16 September 2011 caused 4 lives (Daily Purbakone, 2011)
while workers were dismantling ship’s fixed CO2 installation. This accident
happened well after the High Court directives were in place and training activities
were underway. The author learnt from the course coordinator of the training
institute that out of 4 casualties involved in that accident, one was a trained worker
from his institute and the 3 others were unskilled labors without training.
Nevertheless the accident happened because of someone’s mistakes in the group.
The voices and comments depicted above show a clear necessity of transferring
knowledge and information to improve the working atmosphere.
The SBRI workers did not have any formal training in the past other than learning
through their experiences. The complexities and nature of the industry is such, if the
people are not aware of the associated work hazards and do not know how to analyze
and manage the risk there is every chance of encountering serious accidents and
injuries. Despite the lack of accurate statistics, the accidents are supposed to be
numerous in this industry.
Training presents a unique opportunity to expand the knowledge base of all
employees in any industry. It brings benefits for both individuals as well as for the
whole industry. Individuals are expected to raise their situational awareness and
therefore could protect themselves in hazardous environments. The industry should
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benefit from fewer accidents which can be disruptive for the working processes and
should benefit from the higher skilled worker who may improve the overall
productivity of the yard and enhance the working conditions. These hypotheses seem
to be verified by the statistics provided by ASTI.
Figure 28: A Comparative data of accidents/incidents prior and after training. Prepared by ASTI accident
investigation cell based on information received from workers /trainees. (Courtesy: Training coordinator).
However, a proper education and training scheme for such hazardous industry needs
to encompass a large variety of components likewise in the shipping industry. The
wishful list is based on the training system developed in the maritime field to
enhance safety system on board and ashore.
Shipping is a global business and shipboard atmosphere is multicultural with various
nationals with different knowledge and background. But for the safe operation of
ships, seafarers’ knowledge is blended to a common consensus for smooth conduct
and operations. IMO has extensively worked on this issue and implemented the
STCW Convention for common knowledge and understanding of shipboard safety.
Similarities can be found in the shipbreaking industry with workers under various
levels of knowledge, skills and background. The most important link between
seafarers and breakers is the vessel. A systematic approach with such maritime
education and training model can be followed in SBRI to enhance safe working
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practices. The following discussion will try to find some correlation between seafarer
based maritime training and SBRI workers’ training.
Improve general knowledge:
Such element is clearly perceptible in the STCW Code and its numerous tables
describing the basic knowledge and skills of seafarers.
As discussed in the previous chapters, the work force involved in this industry is
varied in skilled, semi-skilled and unskilled laborers. 95% of whom are migrant
workers with no or low level of basic education. They probably never saw a ship and
its structural components. Therefore, they do not have any idea of the hazards they
will have to face. They mostly rely on the group leader’s work and guidance. But
ultimately everyone in a group is working at the sharp end.
Also a vast majority of the workers are engaged through labor contractors and
immediately placed for the job without even having opportunities to understand work
place ethics. Unlike other industries, shipbreaking is unique because of its nature and
multiple functions in different stages.
Training will enhance the general knowledge and skills of workers at each level. It
will also help them to expand their horizons of human intellect and an overall
personality while increasing their morale. The improvement in knowledge will
encourage them to exercise safe working practices while they would be much more
aware of safeguarding their personal safety.
In this context a basic foundation course like seafarers’ basic training may be
adopted for the SBRI workers with necessary changes in the contents. Also a
system of familiarization can be introduced like the ISM Code for the new
entrants/new joiners, also for different types of ships.
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Identify hazards:
The shipping industry developed the Formal Safety Assessment (FSA) which could
help to support hazard identification in the shipbreaking context.
As discussed earlier there are number of hazards involved in Shipbreaking processes.
Workers are more often exposed to these hazards because of the nature of this
industry. This exposure poses both health and safety at risk. Workers suffer from
various illnesses and chronic diseases as they lack knowledge about the HAZMAT
and their effects on health. Moreover, the vulnerability of workers because of not
being able to identify the hazards has caused many lives through explosions, trapping
inside tanks, confined spaces, falling and tripping which is common and a day to day
phenomenon in this industry. This has stigmatized the image of this industry. A
formal safety assessment (FSA) tool can be used for this industry for the need of risk
reduction.
However, with proper education and training, workers would be able to identify the
common hazards and the risk associated in it. Accordingly workers would be able to
analyze and manage risk. Knowledge on such hazards will also encourage them to
take precautionary and additional protective measures to mitigate such risks.
Safety awareness:
Maintenance of equipment, training and drills, and numerous safety devices are
described in the various IMO conventions and particularly SOLAS.
A good variety of workers with different behavioral pattern work in this industry.
Appropriate training will help to grow safety awareness amongst workers. The
perception of the workers will gradually transform towards safe industrial practices.
This will help to develop a safety culture within the industry; eventually the quality
of work will be improved and a learning culture will develop within the organization.
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Seafarers’ participation in various drills as well as use and maintenance of
shipboard safety equipment has vastly contributed to the safe and efficient running
of ships, which may also be introduced in the SBRI. The different methods of
research in this study also support such ideas of practical oriented training and
drills.
Understand the Use and Importance of PPE:
Both, IMO and ILO instruments promote the use of personal protective equipment to
reduce personal injuries.
In order to avoid occupational health related accidents and injuries, using PPE is
most important in any industry. The workers involved must understand the use and
applicability of such PPE. In SBRI it seems the majority of the workers are not aware
of such use and importance. Probably they never saw and are not used to this
equipment. With education and training workers would be able to practically see the
equipment and learn about the importance to avoid occupational injuries. Safety is
paramount and that can be achieved through workers’ safe practices and encourage
them to use proper PPE.
Industrial safe practices, pictures, photos, illustrations, shipboard safety videos on
PPE and safe working practices can be introduced in SBRI.
Understanding and use of safety equipment:
As a general principle, seafarers are expected to know the generic safety equipment
on board. In addition, through a familiarization process, they learn to use the
equipment specifically designed for the ship. Ships operate remotely away from land
resources and an operational emergency may still occur which the seafarer mitigates
using on board safety equipment.
Likewise the applicable beaching method in Bangladesh makes the fire safety and
other logistics difficult to be made readily accessible especially on the beach yard. In
these circumstances the workplace safety largely depends on the skills and
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competence of workers involved at the sharp end. For instance, if there is a small fire
in the cutting process, which may easily be extinguished with the use of a fire
extinguisher provided somebody knows how to operate it. Training can demonstrate
such knowledge to the workers to effectively extinguish such fire before escalating.
This in turn will reduce the number of fire incidences at the work place and may
prevent fatal accidents.
STCW fire prevention and fire fighting course module can be useful in this
context.
Teamwork spirit:
Bridge and engine resource management training exists in the maritime industry and
is considered important tools to develop teamwork spirit.
In SBRI the workforce involves comes from various backgrounds and skills. They
have linguistic & cultural problems amongst them. There are a number of groups that
work simultaneously on board and in the yards. Any mistake by one in the group
may affect others. So an effective workplace communication is important in this
complex situation. The work place safety does not solely rely on one individual.
Therefore team work and coordination is vital in such hazardous environment
because even the most skilled and experienced worker may find himself in danger
due to other unskilled workers’ acts, mistakes, mishaps or omissions.
Knowledge of understanding the safety sign and symbols and knowing the safe
working procedure can be a common language in the first place. Education and
training can help in inculcating the sense of team work, team spirit, and inter-team
collaboration. It will help in inculcating the zeal to learn within the employees and
thus help to create a safe team working environment.
The bridge and engine resource management course idea may be useful to guide
some courses in the SBRI context.
97
Knowledge of first aid:
In order to keep with the isolation of ships at sea, the seafarers must demonstrate
medical skills to support their colleagues in case of emergency. In the context of
present ship recycling methods, the distance from shore support may request such
basic training.
Understandably, accidents and injuries are common in this industry. The use of basic
first aid tools/techniques may in the first instance increase the chances of survival of
a critically injured person. With proper Education and Training workers can receive
such information on how to use the first aid techniques and tools, giving lifesaving
support such as artificial respiration, cardiac massage and stoppage of bleeding prior
getting to shore medical facilities.
STCW training on elementary First Aid may be introduced in this context.
Contribution to Management safety:
The ISM is considered a way to involve the management in the safety of ships.
Therefore, such formal system may be useful in the shipbreaking context to develop
safety awareness at all levels. The Hong Kong Convention also promotes such an
idea.
According to SBRR Ch-vii.Para-30 expressly mentioned that all recycling facility
must implement occupational health and safety management system to improve the
working condition to reasonable standards. If considering the management structure
of any yard, it is ultimately the majority and vital people at the cutting edge who may
contribute a lot to the management safety.
Management responsibility is to set up a well-balanced transparent policy with
particular goals which in this case is accident prevention and preservation of workers
health and the environment. To achieve this common goal top down responsibility
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must be in place clarifying what is expected from the work force. This approach will
allow the workers to clearly understand the organizational health and safety policy.
The workers will feel more responsible towards their job. This will also help the
organization to develop a safety culture within a reasonable time. A safety culture
promotes continuous improvement, efficiency and effectiveness (O’Neil, 2002).
Such a move is highly beneficial because it will reduce the vulnerability of the
workers and most probably will enhance their productivity. This should improve
organizational efficiency and mitigate various issues such as occupational health,
safety and environmental damage through an awareness campaign. This should also
enhance the livelihood, security, health care, wellbeing and empowerment of the
disadvantaged.
In order to achieve the above organizational goals workers need to be effectively
involved in the management safety system. Workers need to understand the
management strategy and learn how they can contribute to the safety system by their
safe working practices and quality of work. With proper education and training
program both institutional and in-house training, workers will gather knowledge
about the management safety system and will be more encouraged and participatory
to achieve desired goals.
The role and responsibilities of individuals prescribed in ISM code may support
the idea to establish a safety management system for SBRI.
Training Program/Institute:
The current education and training scheme for Chittagong shipbreaking yards seems
to focus only on workers, but others stakeholders of this industry also need
information and to some extent training for effective implementation of management
system towards common understanding of workplace safety. Analyses and
identification of correct stakeholders, selection of the target audience groups with
understanding of their characteristics and behavior, local working conditions and
environment needs to be considered prior design, development, and delivery with
99
further scope for Assessment and review which in this system seem absent. For
effective and sustainable training program, a more systematic and methodological
approach needs to be in place for which further research and in-depth studies are
required.
A budget allocation/financing needs to be explored for sustainable development
which may be supported through key stakeholders and or donor agencies.
Safety officer position in Occupational Health and Safety policy
The introduction of safety officers’ position in SBRI is a positive step to enhance
workplace safety. Role of such position has been emphasized in the current
regulation. However, management commitment should clearly define such position
empowering him to work independently.
In a complex situation like SBRI in Bangladesh where many small groups work
independently under no central supervision but a safety officer role can bridge them
together for better performance towards OHS. All activities in the yards may be
centrally controlled and managed by a safety officer ensuring all precautionary
measures and necessary resources are available. He may be Helped by a group of
trained staff to co-ordinate all shipbreaking activities while onsite monitoring and
enforcement can be done effectively. A small group on site may co-ordinate him as
central focal point/control room. However, such position needs adequate resources
and trained staff to support such idea.
The idea of such safety officer exists in the shipping industry under safety
management system (SMS) on board. The definition and job scope clearly describes
his position and importance in relation to safety matters. He/she remains independent
who regulate safety matters, conduct safety meetings and conduct risk analyses prior
undertaking any job. He has the freedom to intervene any unsafe practices and
exercise his empowerment in order to restore safety.
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Such idea under ISM can be helpful for establishing safety management system in
the yards defining roles and responsibilities of safety officer in the organogram.
To conclude, training has multidimensional positive impact in any organization.
A pragmatic and effective training program can reduce the number of injuries
and deaths, property damage, legal liability, illnesses, workers’ compensation
claims, and missed time from work.
A knowledge based supportive workplace is the key especially in the SBRI
where most of the workers lack or have limited basic education. With proper
education and training the vulnerability of workers can be minimized.
Workplace accidents and injuries can be reduced to a reasonable level if not
eliminated completely. This will also help strengthen those who are skilled and
others to enhance their knowledge regarding work place safety as well as to help
achieve organizational goals. Appropriate and effective education and training
programs under local circumstances will certainly improve workers common
skills and competence which eventually will contribute vastly towards
sustainable development of this industry.
Relevant training existing in the maritime training field which may be perceived
for the Shipbreaking industry to improvise safety standards.
7.2 Conclusion
Shipbreaking is considered to be the most sustainable way of disposing end of life
ships. Almost every parts and machineries of the ships can be recycled or reused.
More importantly for Bangladesh, the industry generates hundreds and thousands of
direct and indirect job opportunities for the disadvantaged.
With significant amount of market shares Bangladesh has been upholding this
industry locally over decades. However, the conditions of the shipbreaking yards
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pushed the regulators to intervene in the industry. The Bangladesh government
recently undertook various initiatives to enhance safe and environmentally sound
manners of recycling of ships. In August 2011, high level Bangladeshi delegates
accompanied by industry representatives and other stakeholders visited other
shipbreaking nations such as China, India and Turkey. They gathered information
and ideas prior to formulating a pragmatic rule for this industry.
“Since we’re newcomers in the global market, we prefer to share ideas and
experiences with leading shipbreaking nations to put the shipbreaking industry on a
firm footing,” We want to move forward in a transparent way, and won’t compromise
with anything that might pose threat to environment” Mr. Dilip Barua, Hon’ble
Minister for MOI, BD, (AKM Moinuddin, 2011)
This move demonstrated the commitment of government and showed the breaking
industry about the new possibilities towards green and safer recycling.
”We are moving in the right directions, just wait and see. Bangladesh shipbreaking
industry will soon be recognized as global example for its environment- friendly
growth and expansion. We will take a pragmatic as well as an environment and
workers friendly policy to ensure the sector’s sustainability which is a must for the
country’s economic development” Mr. Dilip Barua, Hon’ble Minister for MOI,BD (
The Daily Star, 2011)
The above statement from the government gives a clear indication of how the
industry should look in the future. Subsequently, SBRR was framed and enforced
from December 2011. Coincidentally SBRR has been formulated just after the
adoption of the Hong Kong Convention, 2009 (HKC). Interestingly, though
Bangladesh did not ratify HKC but most of the requirements for ‘safe and
environmentally sound recycling of ships’ under HKC was reflected in Bangladesh
Rule ‘SBRR, 2011’ (Government Gazzete, 2011).
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Since the implementation of the SBRR regulations, the industry is showing positive
transformation towards green recycling which is more visible in the recent past. The
changes may not be established overnight but may require some time.
Moreover, the process has to be promoted and continued in order to cope with the
future demand and requirements of the regulators, industry and its clients.
It could be steps to the beginning towards green recycling. The future trend might
also demand further modernization under local circumstances and conditions. It is
evident that many local players are also proponent to further mechanization and
modernization of this industry for an accident and pollution free environment.
However, the technologies and resources are lacking locally. Therefore, innovative
technologies and ideas have to be explored and shared in order to support the
industry acknowledging the local conditions.
Bangladesh shipbreaking industry has both challenges and opportunities with
numbers of advantageous parameters specially abundance of cheap laborers,
technical know-how, shipping experience and expertise, local steel demand and
second hand market utility. With such potentials for better sustainability, the industry
needs logical support both internally and externally in various aspects such as
technical, human oriented, organizational and financial.
Ship recycling should be looked into with an international perspective. Much needed
international co-operation with transfer of technology and information and sharing of
responsibilities from various stakeholders is equally important with ongoing local
efforts.
In addition to a global ship breaking policy in Bangladesh, local initiatives have to be
promoted and particularly those aiming to improve the working conditions in the
breaking yards by training the workers.
Bangladesh has shipping experience and good expertise in Maritime Education and
Training. For example the Bangladesh Marine Academy, a center for maritime
103
excellence has long 50 years of reputation in the maritime training field where they
can support the enhancement of the industry through the training in collaboration
with existing SBRI training facilities in a joint venture project.
104
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108
Appendix A
Details of research conducted in Chittagong
Qualitative Interview of 35 different workers on random basis from various working
groups as below:
08 from cutter group.
02 from winch group,
12 from general working group/helper,
02 from foreman group,
01 yard supervisor,01 yard manager,
01 office manager,
02 from sorting/grading group,
01 safety officer,
02 from wire group,
02 from security guard,
01 from oil group.
A set of questionnaire on the above qualitative research can be found in Annex 1.
Author also conducted a Quantitative interview of 100 workers from different
working groups randomly selected within yards, training institute & outside yard in
local tea stalls. (Ref. Annex 2)
In addition to workers:
Interviewed two yard owners, one in Agrabad and one in Khatunganj
location (Ref. Annex 3).
Interviewed a technical representative from BSBA, at his office located in
Sk. Mujib road (Ref Annex 4).
109
Interviewed Chief training coordinator and one instructor from Training
institute located at Kadamrasul, Bhatiary (Ref Annex 5).
Data collection and conducting survey was not easy as the industries are very
restricted for general entry. However Author managed to convince BSBA
representative, some of the leading yard owners who extend their help in this regard.
Training provider was kind enough to take me to some of the yards while conducting
on job training helped author to understand the real life scenario. Since there is no
central data base of this industry some of the data collected from various print media,
NGO reports, and private and government organizations.
110
Appendix B
List of Hazards identified by ILO in “Safety and Health in Shipbreaking, Guidelines
for Asian countries and Turkey”
111
Appendix C
An example of soil contamination found in sites in Bangladesh and
estimated Accumulated hazards.
(Source: World Bank report, 2010)
112
Appendix D
Amount of hazardous materials per million GT on merchant and
navy vessels
Source: World Bank Report’2010, page 29.
113
Annexes (1 to 5)
Details of sample questionnaires used for interviews with different
stakeholders.
Annex 1
A set of questionnaire to the workers group as a qualitative approach:
1. What is your age? ————————————
2. Which part of Bangladesh you are from? ——————————————–
3. What formal level of education you have in the past? —————————–
4. How long you are working in this industry and under what capacity? ———-
5. Are you employed directly or by contractor? ————————————
6. Are you aware of the hazards associated with this industry?
7. Have you witnessed any accident before (follow up Questions)?
8. Do you have any background knowledge about the industry?
9. Have you undergone any form of training?
10. Do you think the training you have undertaken is understandable to you?
11. .Who pays for your training and how much? ——————
12. To your opinion how the overall safety situation may be improved. ————

Thank you very much
114
Annex 2
A set of questionnaire to the workers group as a quantitative
approach:
1. What is your age?
2. Marital Status?
3. How long and under what capacity you are working this industry?———————-
4. What level of formal education you
have:
5. Have you received any form of
training so far?
6. Was the training understandable to
you? Yes/No/No comment
7. Do you think the training you received is sufficient? Yes/No/No opinion
8. Have you any idea about the associated work hazards? Yes/No/Not at all
9. Have you witnessed any accident before? Yes/No
10. What kind of accident you witnessed ………………………
11. Are you provided with your protective gears? Yes/No/I don’t know
12. To your opinion how the overall safety situation can be improved:
Thank you very much
No Edu Primary SSC HSC&
above
Proper
training
Drills Knowledge
Sharing
Forming
Association
Others
20-29 Years 30-39 Years 40 years & above
Married Unmarried
YES NO
115
Annex 3
A set of questionnaire for the Employer/Yard Owners as a
qualitative approach
1. You are owner of how many yards?
2. Do you realize the importance of ship recycling industry in Bangladesh?
Yes/No
3. What makes the industry stop and re-open over the past? ……………………..
4. Do you recognize this industry has declined in the recent times due to poor
working conditions and of environmental issues? Yes/No
5. Do you recognize the organizational safety mostly depends upon Decent
working cond.?
Yes/No
6. Do you realize the capacity building through proper Education and Training will bring
more productivity and efficiency for the industry? Yes/No
7. Do you face any challenges to educate your peoples? Yes/No
8. Do you feel the training providers are adequately equipped to offer suitable
training? Yes/No
9. With your experience and ideas what form of training would be most suitable
for the workers? ……………..
10. How do you employ your workers? By direct employment/ via contractor?
11. Do you feel to set up a safety management system by bridging your workers
and staffs?
Thank you very much
116
Annex 4
A set of Questionnaire for the representative of Bangladesh Ship
Breakers Association
1. Over the past this industry has played an important role in global context,
why currently it is suffering from frequent stop and re-opens?
2. Do you think that the yard owners, managers and the officials do recognize
these issues?
3. You being in the lobby with Government and other international bodies, with
your opinion what best possible approach can be made to mitigate the
issues?…………………………
4. With your opinion how this industry can be made a future viable
industry………………….
5. With your opinion how the OHS and other labor related issues can be
addressed……………..
6. Understandably most of the labors are migrant workers, with your opinion
how they can contribute to the organizational
safety……………………………………..
7. Do you realize that among other factors capacity building through appropriate
education and training can play a significant importance in the safety aspects?
8. To your opinion considering the workers level of education and work
experience which form of training could be most suitable for them?
9. Do you think the current training providers are well equipped for this
purpose?
10. In line with HKC, How the industry is looking forward to face the future
challenges? ………..

Thank you very much
117
Annex 5
A set of questionnaire for the training institute as a qualitative
approach
1. As a training provider are you been approved by SBSRB? Yes/No/In process
2. Is there any qualification criteria set out for the training provider? Yes/No
3. Do you have a dedicated training institute? Yes/No/Rental basis
4. Is there any guideline to develop a training curriculum? Yes/No
5. What form of training guidelines you are currently following? ———————–
6. Understandably most of the workers are illiterate, what methodology and training
tools you are using pertaining to their Education and Training.
7. Do you think you have appropriate teaching materials? Yes/No/May be
8. Are they understandable to the workers? Yes/No/May be
9. Do you have any Assessment criteria prior issuing any certificate? Yes/No
10. Are you facing any challenges in providing Education and training? —————
11. With your opinion how the training could be improved? ——————-
12. Do you feel any external resources/investment could make the program more
sustainable? Yes/No
13. Do you feel the industry has all the expertise and technical ability to handle
Asbestos, PCB’s, POP’s etc? Yes/No
14. Is there any particular course for the peoples dealing with the special hazardous
waste management? Yes/No
15. Do you recognize the training package should comprise of all the aspects of
occupational safety and health, environmental and other human rights related
issues? Yes/No
16. Is your training program is supervised by any Govt. Authority? Yes/No
Thank you very much
Class Room On job Trng Other method
118
Annex 6
Employment generation in shipbreaking linkage domain.
SL ORGANIZATION
NUMBER
OF FIRM /
INDUSTRY
MATERIALS
SUPPLIED
WORKERS
EMPLOYED FINISH PRODUCTS
1 RE-ROLLING
MILLS 525 MS PLATES &
GIRDERS 2,62,500 RODS,ANGLE,FLAT BAR
2 STEEL MILLS 15 MELTING
SCRAP 21,000 ROD/BAR ANGLES
3 SHIP REPAIRER 70
PLATES,
GIRDER,
CABLE,
ENGINE
4,000 SHIP REPAIR
4 FURNITURE
INDUSTRY 2300 CARDBOARD,
DOORS 2,30,000 OFFICE & HOUSEHOLD
FURNITURE
5 ELECTRIC &
CABLE 575
COMPUTER,
FRIDGE,
ELECTRIC
CABLE ETC.
28,750 OFFICE & HOUSEHOLD
EQUIPMENTS
6 DOCK YARD 69
PLATE,
GIRDER,
CABLES,
EQUIPMENT,
ENGINE ETC
40,000 INLAND SHIP BUILDING &
REPAIR
7 TRANSPORT
ORGANIZATION 300 9000 CARRIAGE OF GOODS
8 TRANSPORTS 4000 12,000 TRUCK, COVER VAN, PICKUP
ETC
9
ACTIVE SHIP
BREAKING
YARDS
80
SHIP
DISMANTLING
& RECYCLING
1,60,000 ACTIVE
10
UPCOMINGSHIP
BREAKING
YARDS
39 7800 UNDER DEVELOPMENT
11 ROD SALER 3000 1,50,000 BUY/SALE
12 FOUNDRY &
MOLDING SHOP 2100 CUST IRON 2,10,000 TUBEWELL, MANHOLE
COVERS
13 ROPE SHOP 230 ROPES 2300 FISHING NETS &
HOUSEHOLD CRAFT
119
14 HARDWARE
SHOP 1500 MACHINERY
& TOOLS 2,25,000 INDUSTRIES, HOUSEHOLD,
SHOPING MALLS ETC
15 WORKSHOP 2000
LATHE,
WELDING
MACHINE
40,000 EQUIPMENT MAKING &
FABRICATION
16
ALUMINIUM &
COPPER
FACTORIES
1020 ALUMINIUM &
COPPER 1,02,000 COOKING UTENSILS
17 PIPE SHOP 203
MULTI
DIMENSIONA
L PIPES
10,150 EQUIPMENT MAKING &
FABRICATION
18 BRONZE/COPPE
R SALER 160 ALLOY
PROPELLOR 800 EARN FORIEIGN CURENCY
BY EXPORT
19 BLACKSMITH 20,000 SUPPLY OF
IRON BAR 1,00,000 KNIVES, CHOPPER, SICKLE
20 OXYGEN
FACTORY 35 3000 OXYGEN SUPPLY FOR SHIP
BREAKING
21 EQUIPMENT
TRADERS 345 GENERAL/MA
RINE PARTS 34,500
GENERATORS SUPPLIED TO
GARMENTS, FISHERIES,
HATCHARY, FILLING
STATION &
ELECTRIFICATION OF
ISLANDS
22 IRON DEPO 2500 CAST IRON 2,50,000 RAW MATERIAL FOR
REROLLING & STEEL MILLS
23 PLASTIC
FACTORY 880 RUBBER &
PVC 79,200
BALLPEN,BATHROOM
FITTINGS,HOUSE HOLD
PLASTIC MATERIALS
24 COMMISSION
BUSINESSMEN 2500 12,500 SALE/PURCHASE
NEGOTIATION
25 BOILER
BUSINESSMEN 100 BIOLER
SUPPLY 500
TEA,TEXTILE,DYEING,PAPE
R,OIL REFINERY
INDUSTRIES
26 YARD OFFICE
STUFFS 80 1,600
27 SECURITY
GUARDS 80 3,600
28 BOATMEN 80 800
29 LIGHT
ENGINEERING 7000 LEATHE,
WELDING 4,4O,000 EQUIPMENT MAKING &
fabrication
Total 2,441,000
(Source: FBCCI/MOI,BD, Courtesy: BSBA)
120
Annex 7
Showing the market share of five major shipbreaking nations in
%age GT & DWT
Year Bangladesh China India Pakistan Others
2000 20 21 49 6 4
2001 35 18 33 12 2
2002 30 19 41 6 4
2003 18 35 37 5 5
2004 47 21 23 3 7
2005 56 4 30 1 9
2006 63 6 19 4 9
2007 44 8 32 9 6
2008 51 11 30 3 5
2009 38 15 36 10 1
Data By: Lloyds Fairplay
Year Bangladesh China India Pakistan Others
2000 22 28 39 6 5
2001 32 22 28 15 3
2002 28 25 38 5 3
2003 17 37 34 4 8
2004 53 20 16 2 9
2005 54 7 19 1 19
2006 68 4 21 2 5
2007 47 8 27 11 7
2008 54 12 28 3 4
2009 38 15 36 10 1
Data By: EA Gibson
(Courtesy: Captain Anam Chowdhury, BSBA)
121
Annex 8
Table showing the analysis from the quantitative research on 100
workers.
Age
group
Work
experience
Education
level
Training
status
Was training
understandable
Was the
training
sufficient
Do they
know
all
hazards
Whether
provided
with
PPE
Comments on
improvement:
(One worker
had multiple
comments)
10% in
age
group
18-20
12% less
than 6
months
28% no
education
36%
obtained
training
34% said
understandable
46% said
yes
38% said
knows
23% said
provided
80% comments
both with proper
training and
practical drills
40% in
age
group
21-30
24%
between 1-
2yrs
44%
primary
52% no
training
51% said not
understandable
42% said
no
46% said
partly
knows
52% said
not
provided
60% said
information
exchange/sharing
36% in
age
group
31-40
32%
between 2-
5yrs
20%
Secondary
school
12%
under
training
15% had no
comment
12% no
comment
16% not
at all
25% said
partly
provided
60% said
formation of
association
14%
above
40
32% above
5yrs
8% above
SSC
20% said by
other measures
(Source: Authors’ Own Research)
122
Annex 9(A)
Pictures showing various equipment and machineries usability in the local
market (pictures taken by the author between 17 May to 7 June 2012)
Pix (left) showing scrap plates in a vendor shop. Pix (right) pipes collected from scrap ship on sell.
Pix (left), ship’s furniture shop beside highway. Pix (right), ship’s electrical panel board refurbished.
Pix (left) Ships motors in vendor shop Pix (right) ships electric cable and rope shop
123
Pix (left) ships woods piled up for sell Pix (right), ships kitchen utensils in vendor shop
Pix (left) ships electric machineries in vendor shop Pix (right) ships generators stock pile by vendor
Pix (left) paint and chemical shop beside highway. Pix (right) most wasted metals for melting shop
124
Pix (left),ships valves overhaul and on sell Pix (right),ships bathroom fittings and kitchen cutleries
Pix (left), ships ladder shop Pix (right), ships lifeboat stock for sell
Pix (left), LSA and FFA items’ shop Pix (right), Souvenirs and antique shop.
125
Annex 9(B)
Picture gallery of the current yard infrastructure developments
Main approaches to the Yards:
Picture above showing main approach to the yards with security arrangement.
126
Lay out plan of a yard, Security check and entry procedure,
Board of Emergency Telephone numbers Safety Warmnings
Safety Poster
127
Yard site office:
Daily workers list with spot of job (Top) in local language and yard site office (Bottom)
128
Annex 9(C)
General Overview of a Yard and yard structures with current
working practices:
A front view of a yard (left) and a back view (right)
Generator and workshop Room
129
Real Life Scenario in the yard:
Above pictures shows the current working practices in the yards,
130
Workers accommodation, recreation, mess room and welfare facilities:
Pictures showing workers living complex.
Inside view of dormitory/workers living space.
Workers mess room with cooking facilities Workers recreation room
131
Drinking water facility for workers
A designated prayer room on top of living complex Barber shop inside a yard

Medical Facilities:
A first Aid room inside a yard, with medical Helpant. A First aid room under construction
132
BSBA Hospital outside the yards with indoor and outdoor facilities.
General housekeeping:
Above pictures showing some form of housekeeping within the yards.
133
HAZMAT Handling Facilities:
An Asbestos storage negative pressure chamber (left) and various other hazmat storage room (right).
Oil and Oily sludge storage well
134
Firefighting facilities:
Mechanization of the yards:
Above pictures showing the transformation of mechanization in the yards
135
Annex 9(D)
Training infrastructure development
Showing BSBA training center set up at JUBA Bhaban, Halishahar in April’2011, (pix courtesy from training
center).
Training center renamed as ASTI from March’2012, Relocated at KdamRasulpur,( A batch under class room
training, pix by author june’12)
136
Teaching Aids currently used by Training Institute:
Above pictures showing various safety methods in different working conditions. Same are currently used as
teaching aids and supplemented with lectures.
137
Annex 9(E)
Qualitative and Quantitative Interview by Author
Qualitative interview with cutters, shift in charge and safety officer (left).Qualitative interview with welder and
fitter (Right),
Picture showing quantitative interview with workers (left) and qualitative interview with cutter foremen (right).

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