Protecting life below water is about maintaining biodiversity and safeguarding the ecosystems in the ocean. Through its ocean operations, WWL has a risk of impacting life below water through activities relating to ballast water, hull fouling, ship generated waste and vessel recycling.
The company takes its responsibility for protecting life below water seriously through strict adherence to all applicable rules and regulations. Additionally, it actively engages 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 their 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.
Long established and strictly enforced regulation addresses the need for all vessels to be adequately prepared for environmental emergencies. In addition, the potential negative consequences of being ill-prepared in an emergency make it an especially important issue.
Environmentally harmful oil spills are not something any of the company’s stakeholders, including customers, investors and employees would want to be associated with. Association with a company which is unprepared when a spill occurs is something they want even less.
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 varous ship management companies who in turn work with individual vessels.
The focus of preparation on every vessel owned by WWL are SOPEP/OPA 90 drills. Regulation demands these drills are conducted at least bi-annually. They are organised by the ship managers who are also responsible for ensuring that sufficient and effective tools and materials are maintained on-board each vessel to respond to oil spills of various kinds, for example whether on the deck of a vessel or to the sea.
If an environmental emergency does occur the company’s Emergency Response Reporting Routines Policy is enacted to minimise damage to enable the company to respond quickly and effectively to minimise environmental damage. The policy includes immediate notification from the vessel to the Marine Operations Management team who are responsible for the group’s emergency response.
Evaluation of results
During 2017 there was one case of environmental regulation non-compliance from ocean operations. It regarded an oil spill in Zeebrugge of over 20 litres, which is generally regarded as the threshold of ‘significance’ in the industry. No sanction was levied by the authorities. The standard oil spill response procedures were effectuated to minimise the impact of the spill. The total quantity of the oil spill was estimated to be 40-50 litres and it occurred while discharging oil sludge from the vessel to a receiving barge. The reason for the spill was due to miscommunication over whether a flanged connection was ready for transfer to commence. The details of the case have been shared with relevant stakeholders.
In 2017 355 SOPEP / OPA 90 drills were conducted across the owned fleet, giving an average of in excess of 4.5 per vessel – well in excess of the regulatory minimum. WWL believes that the attention created by the drill frequency is what helps avoid environmental emergencies occurring in the first place.
Ambitions and next steps
The current approach to emergency preparedness is functioning well and so the existing approach will be continued for 2018.
Environmental issues in ship recycling
One of the environmental issues of shipping is how vessels are broken up and recycled once they reach the end of their service lives. Too often there is a significant negative environmental impact from ship breaking. WWL ‘green recycles’ vessels that it owns and has direct influence over whether the approach taken is environmentally responsible. The process is supervised on site by a specialist Ship Management team and overseen by Marine Operations Management.
Those communities who live near to where recycling of the company’s vessels takes place clearly have a material interest in the environmental aspects of how the vessels are recycled. The Norwegian State Pension Fund’s decision to divest its stake in several shipping companies with poor environmental performance on vessel recycling, shows growing investor awareness and interest too. As a stock listed company that also means the issue is very relevant for WWL. Additionally, the forebears of the company have been ‘green recycling’ vessels in an environmentally responsible way for many years and hence it is important to the company’s employees that the practice should continue.
Ensuring process control
WWL is firmly committed to green recycling of vessels to industry-leading environmental and social standards. Maintaining control over the process, which is essential to achieving such standards, is done in three ways. First, before any recycling process begins with candidate facilities / yards being vetted by one of a competent and known surveyor. Such yards must have proper safety management, craned berths or floating docks and handling and storage of all materials. Secondly, the vessel is 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. Also, the payment structure for the yard is set up such that they are incentivised to achieve particular safety and environmental performance results.
During the vetting process the yard must be able demonstrate it has a proper environmental management system in place to contain and manage all materials and substances, including all kinds of oils, arising from the recycling process. Prior to 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 they are concerned that environmental protection measures are inadequate.
Evaluation of results
WWL did not recycle any vessels in 2017 because no vessel in the group’s ownded fleet had reached end-of-life status.
Ambitions and next steps
During the course of 2018 the company will formalise its long-standing green approach to vessel recycling in a green recycling policy. That policy, which will be published on the company website, will include reference to environmental aspects of ship recycling. Additionally, a contract term will be drafted for all future long-term vessel charters that will stipulate the vessel, if redelivered close to the end of its service life, must be recycled in a manner consistent with WWL’s green recycling policy. The company also has an ambition to have the clause inserted in existing long-term charter parties. The proportion of vessels in the group’s fleet that are on long term charter is approximately 20%. Finally, in the interests of transparency, the company will publish details of how its owned vessels have been green recycled since 2000 on its website.
Ballast water
Ships require ballast water for several purposes including stability, trim and manoeuvring. Vessels in the WWL fleet have a ballast capacity of several thousand tonnes. Ballast water is a known vector for the transport of invasive species and hence regulation requires measures to be taken to mitigate the risk of organisms being transferred by ballast water. The regulation applies to all vessels everywhere and all the time.
Protection of marine ecosystems is important for environmental and economic reasons, which makes the issue material for many coastal communities. For WWL it is a compliance issue and part of its commitment to be a responsible logistics provider.
How the topic is managed
Selection and installation of the ballast water treatment system for owned vessels is overseen by the company’s Marine Operations management team, while ongoing compliance with the regulation for those vessels is the task of the ship management companies.
Most WWL vessels currently comply through ballast water exchange, however the proportion of the fleet complying with ballast water treatment systems will grow as those systems are installed.
It is the policy of the company to install only systems that have received Type Approval from the United States Coast Guard (USCG) as well as the International Maritime Organisation (IMO), as those are considered to have been most rigorously tested. It is also the intention of the company to select as few different treatment system vendors as possible because a unified standard across the fleet makes training more straightforward and mitigates the risk of non-compliance through human error.
Evaluation of results
WWL has been fully compliant with ballast water regulation throughout 2017. It is also in the final stages of an exhaustive process to select the optimal ballast treatment system vendor for the owned fleet.
Ambitions and next steps
Once the company selects a vendor, installation of the first ballast treatment systems will commence. The goal is to have two systems installed during 2018 and to monitor their performance closely to make any necessary adjustments to the programme at an early stage. By 2025 all vessels in the fleet will have been retrofitted with ballast water treatment systems.
Hull fouling
One of the most impactful and least discussed aspects of vessel performance is hull fouling. In the same way as it is difficult to swim fully clothed, it requires significantly more power to propel a vessel at a constant speed as the level of hull fouling increases. That means hull fouling has a direct relationship to atmospheric emissions of all kinds. Moreover, the organisms that can grow on the hulls of ships can present an invasive species risk with negative environmental and economic consequences.
WWL buys its own fuel and that fuel is the big single item in its cost base. Hull fouling can quickly account for several percent of over consumption, making it a key focus area for the company. Moreover, there is an increasing body of regulation governing management of hull fouling, so it is a compliance issue too. For its commercial and investor stakeholders the compliance aspect makes the topic material. For coastal communities near ports the invasive species risk can be very significant due to the threat of ecosystem disruption, which in turn can have negative economic consequences.
Hull fouling management
Hull fouling management is overseen by the Marine Operations Management team.
All WWL’s 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 main stakeholders are the Marine Operations Management team of the company, and its ship management companies. Where possible, the company uses hull cleaning vendors that operate ‘clean and capture’ systems, that collect all the material removed from the hull so that it can be disposed of in a controlled manner that eliminates the invasive species risk.
Evaluation of results
An empirical hull fouling scale has been adopted as part of a fouling management programme. The fouling factor of a vessel is scored on a scale of one (good) to 10. The scale takes account of the type, amount and coverage of full fouling. Implementation across the owned and long-term charter fleet began in 2017 and continues still. The average for the 75% of the owned fleet that were assessed in 2017 was 4. The first year for complete owned fleet results will be 2018.
WWL has also been working to establish a hull fouling management platform online to record all inspection and cleaning quick and convenient review by port state authorities and the company itself. At present 30 vessels in the owned fleet have been registered on the platform.
Ambitions and next steps
In 2018 the hull fouling management programme will be extended to entire owned fleet. Long term charter vessels will also be monitored under the same. Vessels with severe fouling will be the vessel owner’s responsibility under the terms of the charter party, while vessels with more moderate fouling will be addressed on a case by case basis.
During 2018, all owned vessels will be logged on online biofouling management platform.
Ship generated waste
The routine operation of a vessel generates waste. Major sub-categories of waste include dunnage, packaging, fuel sludge and food waste. Monitoring the quantities of each waste type generated and disposal methods is the focus of this indicator. For most of the categories mentioned, it makes sense to strive for zero waste, however dunnage is the exception; insufficient dunnage can quickly lead to safety issues.
WWL strives to reduce the production of waste to the greatest extent possible due to the cost and complexity of disposal. That, and the fact that discharge of waste is governed by regulation, make it a material topic for the company. Environmental damage arising from the irresponsible disposal of waste assigns importance to the issue for society in general and port state control authorities in particular.
Managing on-board waste
It is 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 managing the issue of waste generation on the owned fleet, while the company’s ship managers ensure that the policies and requirements set by WWL are followed on individual vessels.
Management of waste onboard the owned fleet is built around well established and understood 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, must be discharged to an authorised reception facility.
A sizeable number of WWL’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 landbased 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 amount of garbage landed to shore reception facilities during 2017 from owned fleet was 4915cmb, giving a vessel average of 59.2cbm. Food waste discharged to sea was 210cbm. This was the first full year data, so year on year comparison is not possible. In addition, such a comparison may not be a reliable performance indicator as a lot of the waste, like dunnage, is driven by operations and cannot and should not be reduced to zero. However, the average amount of waste produced per vessel should track downward over an extended period of time.
Ambitions and next steps
During 2018 an initiative will be undertaken to generate a comprehensive overview of on-board waste handling facilities across the owned fleet. Further, new waste management performance metrics will be devised based on the findings of the study. The study’s findings will also be used to inform the drafting of a formal WWL garbage handling procedure to be implemented across the fleet.
Finally, 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.