The important issue of protecting life below water includes maintaining biodiversity and safeguarding the ecosystems in the ocean. Wallenius Wilhelmsen’s activities relating to ballast water, hull fouling, ship generated waste, and vessel recycling all represent a potential risk to life below water. This is why the company takes its responsibility for protecting life below water very seriously. To ensure this, the company strictly adheres to all applicable rules and regulations, as well as actively engaging in the development and support of novel solutions that act to mitigate the environmental impact of its operations.
Environmental emergency preparedness of ships
With a large fleet in global operation, environmental emergencies may arise for reasons both within and outside of the control of the company. By nature, it is not possible to predict when and where they may occur, or what they concern, but it is possible to make preparations to ensure an optimal emergency response. That is the focus of this material topic which has two indicators; the number of significant spills and the number of oil prevention drills conducted.
Ensuring emergency preparedness
The Marine Operations Management team has the overall responsibility for ensuring the emergency preparedness of the fleet. In practice this is done indirectly through close collaboration with the fleet’s various ship management companies who are responsible for the spill response readiness of the individual vessels.
The focus of preparation for all vessels owned by Wallenius Wilhelmsen is on IMO Shipboard Oil Pollution Emergency Plans and Oil Pollution Act 90 drills. Furthermore, there is a focus on ensuring that adequate supplies of effective tools and materials are maintained onboard each vessel to respond to oil spills of various kinds. The regulations stipulate that drills are conducted at least bi-annually. They are organised by the ship managers who are also responsible for the provision of adequate response tools and materials.
If an environmental emergency does occur, the company’s Emergency Response Reporting Routines Policy is enacted to enable the company to respond quickly and effectively to minimise environmental impact. The policy includes immediate notification from the vessel to the Marine Operations Management team who are responsible for the company’s emergency response. To complement the Emergency Response Policy, group-wide cloud-based emergency response handling systems were set up during 2018 for both landbased and ocean operations as well as IT.
Evaluation of results
During 2018 there were no cases of non-compliance relating to environmental emergencies from ocean operations. Furthermore, there were no significant oil spills, which are generally regarded in the industry to be spills of 20 litres or more. Both were acceptable results and represent an improvement on the single spill event that occurred during 2017.
In 2018 660 SOPEP / OPA 90 drills were conducted across the owned fleet, giving an average of 10 per vessel, which meets the requirement of the regulations. The regulations stipulate that each year there must be at least four notification drills which must be reported to local authorities, four scheduled spill drills, one unannounced spill drill, and one Vessel General Permit drill. Last year’s report did not include all categories of drills, hence the average number of drills per vessels was lower. Wallenius Wilhelmsen believes that the attention created by the drill frequency, variety, and authenticity are effective for maintaining crew readiness, and have been central to avoiding environmental emergencies.
Ambitions and next steps
The current approach to emergency preparedness onboard vessels continues to function well and so the existing approach will be not be modified during 2019. Emergency drills using the emergency response system InCaseIT will be run twice during the year to ensure that the relevant processes, tasks and systems provide the desired effect.
Environmental issues in ship recycling
The way a vessel is recycled at the end of its service life can greatly impact the local environment where the recycling takes place. In too many cases, water and/or land is contaminated by oily discharges or toxic materials. Wallenius Wilhelmsen has direct influence over how its vessels are recycled and has for many years taken a responsible ‘green recycling’ approach.
Ensuring process control
Wallenius Wilhelmsen’s Marine Operations Management team is responsible for overseeing how vessels are recycled. Maintaining control over the process, which is essential to achieving such standards, is done by closely following the company’s Vessel Recycling Policy. The main points of the policy include appointing an independent surveyor to assess any candidate facilities. Such yards must have proper safety management, craned berths or floating docks, and the correct handling and storage of all materials. Their measures and experience should also be taken into account.
The second point of the policy states that the vessel should be sold through cash buyers to a specific yard to be recycled to specific standards and within a specified timeframe. There is no possibility for the vessel to be recycled other than as Wallenius Wilhelmsen intends.
Thirdly, the actual recycling is supervised by a qualified partner who has the right to halt work on safety or environmental grounds. The payment structure for the yard should be set up so that they are incentivised to achieve particular safety and environmental performance results.
During the vetting process the yard must be able to demonstrate that employees have the necessary qualifications, and that working hours and payment regulations are being adhered to. Prior to the commencement of recycling, the Inventory of Hazardous Materials (IHM), which is important in guiding and planning the safe dismantling of a vessel, is updated. During recycling the ship manager’s site superintendent has the right to halt activities if working conditions or processes are deemed to be unhealthy or unsafe, or if Personal Protective Equipment (PPE) is inadequate. Towards the end of the process items from the vessel that can be reused or recycled, such as furniture, domestic appliances, and computers must be offered to the local community.
Evaluation of results
The Wallenius Wilhelmsen group did not recycle any vessels in 2018 because no vessels had reached their end-of-life. During 2018 the company formalised its long-standing green approach to vessel recycling in a Vessel Recycling Policy, which has been published on the Wallenius Wilhelmsen website. The policy includes references to the human and labour rights aspects of ship recycling.
Wallenius Wilhelmsen was a founding member of a major industry initiative, the Ship Recycling Transparency Initiative (SRTI, www.shiprecyclingtransparency.org), launched in 2018. SRTI is an online platform for the disclosure of all the relevant policies and practices for shipowners in relation to vessel recycling. It is a response to the lack of transparency that has long-existed in the area, which in turn has been a key factor in enabling irresponsible practices to continue. Apart from the obvious negative social and environmental impacts, poor recycling practices put companies taking a responsible approach at a financial disadvantage.
The information disclosed on SRTI is available to any interested party and it is hoped that it will enable industry stakeholders including customers, lenders, and investors to make informed and responsible decisions in relation to vessel recycling. Wallenius Wilhelmsen is a steering committee member of SRTI and has been actively working to raise its profile and urge other companies to become SRTI members. Some of the world’s most prominent shippers have started to become signatories, thereby showing their support for the need for transparency in vessel recycling.
There were plans to develop a contract term during 2018 for long-term vessel charters – this would require a charter vessel that was being redelivered close to the end of its service life to be recycled in a manner consistent with Wallenius Wilhelmsen’s Vessel Recycling Policy. The clause was not developed because no long-term charter agreements were made for vessels that would be approaching recycling age at the time of redelivery.
Ambitions and next steps
To complement the detailed information already disclosed on the Ship Recycling Transparency Initiative’s platform, Wallenius Wilhelmsen will publish details of how its own vessels have been green recycled since 2000. Although initially planned for publication during 2018, this information will be part of the new corporate website in 2019.
During 2019 the company will ensure any existing long-term charter vessels that are redelivered at or close to recycling age are responsibly recycled. Similarly, if entering into any long-term charter agreements where redelivery would be at or close to the point of recycling, a contract term will be included to ensure the vessel is recycled in a manner consistent with the company’s Vessel Recycling Policy.
Ships require ballast water for several purposes including stability, trim, and manoeuvring. Vessels in the Wallenius Wilhelmsen fleet each have a ballast capacity of several thousand tonnes. Ballast water is a known vector for the transportation of invasive species and therefore regulation is required to mitigate the risk of organisms being transferred from one ecosystem to another.
Protection of marine ecosystems is important for environmental and economic reasons, which makes the issue important for many coastal communities. For Wallenius Wilhelmsen it is a compliance issue and is therefore a minimum requirement to trade. It is also part of its commitment to be a responsible logistics provider.
How ballast water is managed
The selection and installation of the ballast water treatment system for owned vessels is overseen by the Wallenius Wilhelmsen’s Marine Operations Management team. Ongoing compliance for those vessels is the task of the ship management companies.
The Wallenius Wilhelmsen fleet complies with the regulation through the installation of ballast water treatment systems. The regulation specifies that the installation deadline for a particular vessel is linked to its dry-docking schedule. While awaiting the installation of the ballast water treatment system, vessels in the fleet maintain compliance through deep sea ballast water exchange.
The company’s policy is to only install systems that have received Type Approval from the United States Coast Guard (USCG), in addition to IMO, as only those may be used in United States waters. The company has only chosen a select number of treatment system vendors in order to make training, operations, and maintenance as straightforward as possible, and to mitigate the risk of non-compliance through human error.
Evaluation of results
Wallenius Wilhelmsen has been fully compliant with ballast water regulation throughout 2018, continuing the level of performance from 2017. During the year the company concluded an exhaustive process to select the ballast treatment system vendors for the owned fleet. Two systems were installed in 2018, meeting the target for the year.
Ambitions and next steps
The plan for 2019 is to retrofit ballast water treatment systems on the seventeen owned vessels that are scheduled to dry dock this year.
One of the most impactful yet least discussed aspects of vessel performance is hull fouling. Significantly more power is required to propel a vessel at a constant speed as the level of hull fouling increases. That means the increased levels of hull fouling increase emissions to air of all kinds. Moreover, the organisms that grow on the hulls of ships can present an invasive species risk with negative environmental and economic consequences.
Hull fouling management
Hull fouling management and policies are overseen by the Marine Operations Management team, while ongoing compliance with regulations and implementation of company policies for the owned fleet is the responsibility of the ship management companies.
All Wallenius Wilhelmsen owned and long-term charted vessels must conform to its Underwater Hull Maintenance Policy. The policy describes the roles, responsibilities, objectives, and norms to be followed in relation to hull fouling. The company only uses hull cleaning vendors that operate ‘clean and capture’ systems. These systems collect all the material removed from the hull so that it can be disposed of in a controlled manner that eliminates the risk of invasive species, or of paint flecks entering the water column. The only exception is for charter vessels departing from a port where a ‘clean and capture’ system is not available. This is especially the case with vessels bound for New Zealand, where vessels must be cleaned prior to arrival unless it can be documented that their hull is free from fouling.
Evaluation of results
In accordance with the target set for 2018, all the owned fleet have been enrolled in hull fouling management programmes. An empirical hull fouling scale is used as part of the programme. The fouling factor of a vessel is scored on a scale of one (good) to 10. The scale takes into account the type, amount, and coverage of hull fouling. The scale is used across the owned fleet and the implementation in long-term charter vessels is ongoing. The average score for the owned fleet in 2018 was four, which remains unchanged from 2017. The 2018 result includes more vessels than in 2017 and some of these have failed anti-fouling coatings. For that reason, a number of vessels will be docked earlier than scheduled to have new coatings applied that meet the company’s coating quality standards.
Wallenius Wilhelmsen has also been working closely with a vendor and former Orcelle Award winner to establish an online hull fouling management platform. This will enable the company to record all inspections and cleaning activities, with reviewing made quick and convenient for port state authorities and the company itself. The trial phase platform is being re-engineered to provide more versatile access and upload rights. Except for owned vessels in Asia and the Americas that are regional trades, all owned vessels that undergo cleaning or inspection are registered on the platform. Access to the platform has been given to certain authorities to enable them to assess the hull condition and maintenance activities before a vessel even arrives in a port.
Ambitions and next steps
During 2019 the hull fouling management programme, which includes inspection and cleaning routines, will be extended to all long-term charter vessels. If there are vessels with severe fouling, it will be the vessel owner’s responsibility to take appropriate measures.
Ship generated waste
The routine operation of a vessel normally generates waste. Major sub-categories of waste include dunnage, packaging from vessel supplies, fuel sludge, and food waste. Monitoring the quantities of key types of waste generated at the fleet and vessel levels are the focus of this indicator. For most of the categories mentioned, it makes sense to strive for zero waste. Dunnage – the timber and other materials used to support and stabilise cargo – is an exception to this. If there is insufficient dunnage, it can quickly lead to safety issues in the vessel.
Managing on-board waste
It is within the company’s mandate to effect changes in the amount of waste produced and how it is handled for vessels in the owned fleet. The group’s Marine Operations Management team are responsible for the overall policies, processes and management of waste generation on the owned fleet, while the company’s ship managers ensure that the policies and requirements set by Wallenius Wilhelmsen are followed on individual vessels.
Management of waste onboard the owned fleet is built around well-established and clearly communicated procedures and the company’s steadfast commitment to compliance with all applicable regulations. Some regulatory requirements, such as the Garbage Record Book and Oil Record Book are actively used to add structure to the process. The correct means of disposal of waste varies by type. For instance, overboard discharge of food waste is permitted under certain conditions, whereas more environmentally hazardous waste, like oil sludge, can only be discharged to an authorised reception facility.
A sizeable number of the company’s owned vessels have incinerators installed, however the company is gradually phasing out their use and they have not been installed on the latest new-build series. Due to their small size they are less efficient than land-based incinerators. Also, improvements in the capability to compact and store waste on-board along with the more widespread availability of proper waste reception facilities in port, have reduced the dependency on incineration.
Evaluation of results
The total amount of garbage landed to shore reception facilities during 2018 from the owned fleet of 83 vessels, was 6362 cbm , with an average per vessel of 76.7 cbm. That represented a decrease of 11% compared to the 2017 average of 86.2cbm for the 57 vessels of the WW Ocean owned fleet. Note that the average reported in 2017 is restated to 86.2 cbm (from 59.2 cbm) because it was incorrectly based on the entire owned fleet, rather than just WW Ocean owned fleet. Similarly, the 2017 total of 4915 cbm was for the WW Ocean fleet only. The decrease is believed to be linked to the focus on avoiding waste generation by reducing the unnecessary packaging left onboard during deliveries to the vessels, as described in the ‘Show Me The Plastic’ initiative below. In general, comparison between two years may not be a reliable performance indicator as a lot of the waste, like dunnage, is driven by specific operational or cargo needs and should not be reduced to zero. However, the average amount of waste produced per vessel should track downward over an extended period.
Food waste discharged to sea was 440 cbm, giving an average of 5.3 cbm for the 83 vessels in the owned fleet. The corresponding number for 2017 was 3.7 cbm. That figure was based on the 57 vessels of the WW Ocean owned fleet. Similar to the results for garbage, the 2017 result is restated to 210 cbm for the WW Ocean owned fleet, rather than the entire owned fleet. Superficially, it may seem that the average discharge to sea of food waste has increased, however it must be noted that there are differences in exposure to MARPOL Annex V Special Areas between the WW Ocean, EUKOR and ARC fleets. In the Special Areas food wastes may only be discharged when a vessel is as far as practicable from the nearest land, and in any event no less than 12 nautical miles from the coast. Special Areas include the Mediterranean, Baltic, Black, Red and North Sea as well the Wider Caribbean region, including the Gulf of Mexico and the Caribbean Sea. The EUKOR and ARC fleets have a higher exposure to these areas than the WW Ocean fleet. In short, it is not possible to reliably deduce anything about performance by comparing the average result for part of the owned fleet from 2017 with the average result for the entire owned fleet for 2018.
During 2018, an initiative called ‘Show Me The Plastic’ was taken to form a comprehensive overview of the plastic waste value chain across our global operations, including onboard vessels and at shore-based handling facilities. The main study findings concerned the optimal packaging sizes for delivers of food and beverages, the opportunity to make more use of non-plastic refuse bags onboard, opportunities to limit single-use plastic onboard and to measures to limit the amount of waste plastic water bottles. Further, the study’s findings have been communicated to all owned vessels and it is the responsibility of the ship managers to follow up on the findings and report the results to the company at the end of 2019.
Ambitions and next steps
During 2019, a supplier initiative to reduce the amount of packaging waste left onboard will be developed and applied with greatest focus on suppliers that contribute most to the problem.