Shipyard Waste Management during Dry Dock
Waste management in dry dock links each job to an identified stream, collected separately and followed through to its documented destination. Ship and yard agree responsibilities, containment and delivery evidence before work starts.
Operational Explanation
Following a waste stream means knowing which job produced it, where it is collected and to whom it is delivered. The initial list of streams supports the arrangement of containers, collection routes and documents: it prevents different materials from losing their identity as work progresses.
Docking can generate coating and abrasive residues, wash water, oils, structural materials and other streams. Classification, segregation, transport and destination depend on verified composition and the law of the yard jurisdiction. Residues containing controlled biocides require particular containment, but not every blasting residue automatically has the same classification.
Operational ship waste delivered to a reception facility must be distinguished from waste generated by yard processes. Responsibilities and documents should be assigned in the contract and applicable waste plan.
| Stage | What to link to the stream |
|---|---|
| Identification | Job and original materials, verified composition and information still to be checked. |
| Collection and custody | Identified container, separation from other streams, storage location and responsible party. |
| Delivery | Quantity, operator receiving the waste, transport and destination facility. |
| Closeout | Quantities produced, delivered and still present, with documents explaining their destination. |
AFS.3/Circ.6, §§3.1–3.7, 4.3 and 5.2–5.7.
Regulatory Reference
Environmental law of the yard jurisdiction; AFS Convention and AFS.3/Circ.6 for removal of antifouling coatings, including organotin and cybutryne; MARPOL Annex I/38 and V/8 for reception facilities; Basel Convention only where it applies to transboundary movement of hazardous or other covered waste.
IMO’s 2024 guidance distinguishes paint particles, contaminated abrasives and biocides dissolved in water. Settling removes solids but does not by itself establish that water can be discharged: the supernatant requires treatment and discharge under the applicable permit. Do not treat the guidance’s example parameters as universal limits. IMO AFS.3/Circ.6, 2.3 and 5.3–5.5.
Provide impermeable surfaces and collection of dust, residues and water; keep contaminated water separate from other liquids and collect waste types separately. Record quantities, containers, transfers and destinations for each stream so that environmental closeout can be verified. IMO AFS.3/Circ.6, 3.7, 4.2 and 5.2.
For operational ship waste, plan delivery to the reception facility and retain delivery evidence: the waste’s origin determines which documentary chain to follow. For yard processes, the plan identifies who manages classification, collection, storage, transport and treatment under local rules. MEPC.1/Circ.834/Rev.1, §§23–40 and appendix 3.
Scope of Application
Work generating residues, dust or process water. The plan should identify origin, properties, contaminants, responsible party, storage, treatment, transport and records for each stream.
Procedure / How to Complete It
- Inventory coatings and removed materials using specifications, SDS and available history.
- Agree the responsible party, collection point, containers and documents to be received from the yard for each stream.
- Define containment, collection and sampling under law and work method.
- Classify each stream from composition and local criteria.
- Keep streams identified and separate during collection and storage; link containers and transfers to the job that produced them.
- Check carrier and facility authorizations and retain manifests.
- Reconcile quantities, destinations and responsibilities at completion.
Practical Example
Before antifouling removal, owner and yard check the system specification and history, define containment and residue characterization, and document transport and destination at authorized facilities.
Removal produces contaminated abrasive and wash water: the two streams have separate containers and records. The responsible person compares collected quantities with those delivered and any material still in storage; for water, they check treatment and permitted discharge. Closeout links each stream to its delivery document or to the destination still to be completed.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Classification by name | Wrong code and destination | Use composition, characterization and local criteria |
| No documentary chain | Destination cannot be evidenced | Retain authorizations, weights and manifests |
What the PSCO Checks
Operational Tips
- Put responsibility and close-out documents in the repair specification.
- Do not mix streams before classification.
- Trace residues containing controlled AFS substances.
Preparation checklist
- Materials and coatings identified
- Containment defined
- Streams characterized
- Authorized operators checked
- Quantity and destination reconciled
FAQ
Related Topics
Certified substantive revision: 13 October 2026 · page fingerprint e1c4b58f3211