“This [guidance] was clearly not written for either the ship recycling industry in the United States or the work force in the ship recycling industry,” Polly Parks of Southern Recycling told EHS Today.

OSHA released the online guidance document in early April. Southern Recycling requested its withdrawal based on three main concerns:

1. Lack of input from industry. According to Parks, OSHA did not collaborate with the ship recycling/metal recycling industry to create this document. “If they want to have a guidance for how to do safe ship recycling in this country, they should be working with the industry that is doing safe ship recycling in this country,” she said.

2. Inaccurate production process and regulatory information. “They suggest a more complicated process for planning on how to dismantle a vessel according to U.S. regulatory standards than what is done in the industry,” Parks explained. “What they think is happening with ship recycling is a deconstruction of the vessel, which is a different industrial process – you are deconstructing a vessel, but it’s not the same as putting a vessel together.”

Parks also cited regulatory inaccuracies in the guidance, including the stipulation that booms must be placed around vessels, but this is not required as part of a ship recycling facility’s spill response plan. The guidance also states that toxic coatings must be stripped from surfaces prior to heat application, while 29 CRF 1915.33(d) specifies that either the toxic coatings must be stripped or respiratory protection must be worn.

3. Misleading fatality information. The guidance cites statistics from the U.S. Bureau of Labor Statistics that 46 workers have died in the shipbreaking industry since 1997. Parks noted, however, that OSHA used NAICS code 48833, Navigational Services to Shipping and Salvage, which is not limited to shipbreaking. Parks said that 86 percent of the establishments covered by 48833 include tugboat, towing and piloting services.

In her letter to OSHA requesting the document’s withdrawal, Parks wrote, “The publication gives the reader the impression that ship recycling in the United States is a dangerous and fatal occupation with a fatality rate to rival the beaches of Turkey, Pakistan, India, Bangladesh, Indonesia and China. This is not acceptable.”

Finally, Parks raised concerns that document isn’t applicable to the industry and “does not address the way ship recycling is being done in this country.”

“I think part of the problem for OSHA is that their shipbreaking regulations are in with ship building and ship repair. In fact, these facilities are metal recycling facilities,” she said. “So there’s sort of a cultural difference of how you look at things.”

Parks stressed that if there is a problem within the industry, such as a work practice leading to high levels of injury, Southern Recycling and the industry at large should be made aware of it.

“If OSHA wants to do something for the ship recycling industry, we would like them to do what we have been asking them do to – provide their materials in languages other than English,” Parks said. “We would like materials and assistance that could actually help us.”

The guidance document is not a standard or regulatory action. OSHA released the document “to help protect shipbreaking workers from injury or death.”

EHS Today was unable to reach OSHA for additional comment.