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ELEMENTS OF AN IMPLEMENTATION STRATEGY 101 obtain such a certificate would be considered a violation of Annex V. (Apart from providing some international control over shipboard garbage management, the certificate approach also could be a mechanism for confirming whether a ship has a comprehensive capability to manage all its Annex V garbage and APHIS wastes on board. Such a capability could exempt a ship from any requirement to off-load garbage at U.S. ports [an option discussed in Chapter 5].) The Animal and Plant Health Inspection Service exerts fairly tight control over cargo ships. Inspectors board many arriving vessels; for violations of APHIS disposal regulations, penalties may be assessed and fines must be paid within 72 hours. A "blacklist" is maintained of vessels with recent violations, and these vessels are monitored closely. During boardings, in addition to checking for compliance with quarantine regulations, APHIS inspectors also ask four questions concerning Annex V.7 However, any Annex V violations discovered must be referred to the Coast Guard, and a decision may not be rendered for months. Shoreside garbage disposal can be a problem for cargo ship operators, because disposal costs often are perceived as too high (see Chapter 5) and port reception facilities may be inconveniently located or their use may be denied. The Coast Guard exerts some control over U.S. public ports and operators of large private terminals through the COA program, but cost and convenience levels are not regulated. Some cargo ships, such as bulk carriers and chemical tankers, never call at a public port; instead, they go directly to the private waterfront terminals of the cargo owner. Some private terminals have been reported to turn cargo ships away when they attempt to off-load garbage, while other facilities, notably refineries, are so remote that it is difficult to arrange for services, such as off-loading of food-contaminated plastics and other garbage that must be quarantined. Analysis of Interventions Table 4-3 outlines possible interventions to improve Annex V implementation in the cargo ship sector. Due to the international profile of this sector, the most useful options are those that can improve compliance by foreign-flag as well as U.S.-flag ships. Technological innovations can be adopted by any ship operator. But it is clear that experts outside the merchant marineâdesigners, vendors, engineersâ 7 The four questions, all requiring "yes" or "no" responses, are included as items 23-26 on APHIS Form 288, Ship Inspection Report. They are: (23) Plastic materials requiring disposal are used aboard the vessel. (24) There are waste plastics in the vessel's trash for disposal ashore. (25) There is a functional incinerator or other disposal method aboard. (26)(a) Responsible vessel operator was requested to show garbage pickup receipt or other evidence of lawful disposal of plastics ashore. (b) Responsible vessel operator produced garbage pickup receipt or other evidence of lawful disposal of plastics ashore.
ELEMENTS OF AN IMPLEMENTATION STRATEGY 102 TABLE 4-3 Applying the Hazard Evolution and Intervention Model to Cargo Ships and Their Itinerary Ports Hazard Evolution Model Behavior that Encourages On-board Generation of Generating Garbage Garbage Intervention Model Modify Behavior that Reduce Garbage Encourages Generating Generation during Garbage Voyage Technological Reduce use of discardable packaging. Design packaging techniques and storage systems that minimize need for plastic wrappings and bindings as well as packing materials. Organizational and Assure that Use only vendors Operational organizational culture committed to packaging encourages commitment and storage techniques to proper garbage that minimize waste. management at all levels, Sort garbage at the site using TQM methods and of generation. expediting implementation of ISM. Educational (Target Modify crews' comfort Inform management Population/Content) expectations and attitudes about packaging about waste alternatives. Encourage management. Encourage vendors to develop acceptance of need to alternate packaging. avoid individually Encourage packaging packaged items. Train manufacturers to shoreside personnel develop affordable, vessel operators, and reusable containers. crews in TQM/ISM principles. Train regulatory authorities at federal, state, and port levels in TQM principles to break down barriers and achieve regulatory synergy.
ELEMENTS OF AN IMPLEMENTATION STRATEGY 103 Hazard Evolution Breakdown in Discharge of Exposure to Model Compliance Garbage into Sea Discharged Garbage Intervention Prevent Block Discharge Block Model Breakdown in of Garbage into Exposure to Compliance Sea Discharged Garbage Technological Design garbage Develop and Promote storage space into install appropriate affordable ships. Keep garbage handling compactors shipboard systems equipment, such that create non- well maintained. as efficient, safe buoyant waste Establish. system incinerators and slugs (with no for garbage pickup reliable shredders plastics). at ports that meets and compactors. Annex V and APHIS requirements. Organizational Establish internal Establish clear and Operational company penalties policies and for procedures for a noncompliance. comprehensive Encourage garbage commitment to management garbage system. management at the Standardize port level of the disposal services. individual. Educational Provide constant Inform crews of (Target reminders via compliance Population/ posters and requirements and Content) placards aboard methods and the ships. Educate harm caused by vessel operators improper and crews about discharges. the types of Inform managers garbage subject to of compliance Annex V versus methods, both APHIS organizational regulations. and technological. Require crew Inform regulators education for entry about ways to into U.S. waters or improve ports. integration of Annex V and quarantine regimes. Develop recycling programs for items (cans) often discarded overboard.
ELEMENTS OF AN IMPLEMENTATION STRATEGY 104 Hazard Evolution Model Behavior that Encourages On-board Generation Generating Garbage of Garbage Intervention Model Modify Behavior that Reduce Garbage Encourages Generating Generation during Garbage Voyage Government or Private Change regulatory balance Restrict use of certain Regulation and to emphasize cooperation materials on ships. Enforcement rather than control. Clarify Annex V roles and relationships of federal, state, and port agencies. Coordinate efforts at ship/ port interface. Economic (Market Include environmental Develop reusable Forces) impacts in cost-benefit packaging that is more analyses of garbage cost effective than management systems traditional materials or (typically rated on has a life-cycle cost profitability and benefit. efficiency). Establish cost benefits for all possible solutions (i.e., conduct impact analysis); identify optimal solution from cost benefit standpoint. are essential to technological advancement in this sector. For example, alternative packaging and storage systems need to be developed that minimize use of plastics. Appropriate garbage treatment equipment needs to be designed into new ships and, where necessary and feasible, purchased or developed and retrofitted on existing ships. Because this is an industrial community, organizational interventions are important. Garbage management strategies must be integrated into standard and emerging industrial practices, such as Total Quality Management (TQM) and the International Safety Management (ISM) Code adopted recently by the Interna-
ELEMENTS OF AN IMPLEMENTATION STRATEGY 105 Hazard Evolution Breakdown in Discharge of Exposure to Model Compliance Garbage into Sea Discharged Garbage Intervention Prevent Block Discharge Block Exposure Model Breakdown in of Garbage into to Discharged Compliance Sea Garbage Government or Audit practices to Require logs of Private ensure full waste handling Regulation and compliance. transactions. Enforcement Tighten Tighten port state inspection of port controls and reception inspections, facilities. Require Require off- flag states to issue loading of Annex waste V (and APHIS) management garbage at port certificates. calls. Economic Bounty provision Make on-board (Market Forces) in U.S. law may waste treatment encourage peer equipment and surveillance and use of port discourage reception violators. Return facilities monies from affordable. recycling to Incorporate vessel crew for disposal costs their discretionary into port user use. fees/tariffs. Spread cost across entire port user base. tional Maritime Organization (1993). The ISM lays the foundation for a new organizational and cultural framework for ship management, requiring that policies and actions be consistent within an organization and focusing attention on human factors. Shipping company operators can establish an organizational culture that supports proper garbage management by using only vendors that minimize waste, establishing clear and effective policies and procedures, and imposing internal penalties for infractions of the rules. Educational interventions must target not only vessel crews but also shipping