SCA and the U.S. EPA have worked together through the Sector Strategies Partnership for the past 10 years. The voluntary program aims to improve environmental performance and efficiency within the shipbuilding and repair sector by advancing strategies that enable new approaches, eliminate barriers, and drive change.
Sector Profile
Facilities in the Shipbuilding and Ship Repair sector build, repair, or alter ships, barges, and other large vessels for military and commercial clients. Most facilities that build ships can also repair them, but some smaller shipyards only perform ship repair work. Shipyards typically include dry docks, shipbuilding positions, berthing positions, piers, workshops, and warehouses. Most domestic shipbuilders make and repair ships for the U.S. Navy, U.S. Coast Guard, and other government agencies.
Programs and Resources
The Shipbuilding and Ship Repair Environmental Metrics Initiative
This ongoing program is designed to encourage and build capacity among shipyards to measure and report on key aspects of their environmental footprint in order to inform continuous improvement and support accountability and transparency in the sector. Fifteen shipyards, representing more than 90% of U.S. shipyard operations, have committed to reporting key environmental data on their environmental footprint to their trade associations on an annual basis.
Participating shipyards will report annually the following information to their respective trade associations:
Particulate matter emissions;
Greenhouse gas emissions;
Hazardous and non-hazardous waste generation;
Summary of stormwater BMPs in use during the reporting period; and
Whether or not an environmental management system (EMS) is in use, third party certified or under development.
The first year of reporting for the Environmental Metrics Initiative will be for 2008 data. The trade associations aggregated the information and the results are available HERE. The Environmental Metrics Reporting Sheet may be downloaded here.
The Environmental Metrics Initiative is a starting point for building broader and stronger environmental stewardship efforts throughout the shipbuilding and ship repair sector. Shipyards participating in the Environmental Metrics Initiative are committing to adding one new environmental metric per year to the initiative over the next few years.
Participants may download the Shipyard Metrics Initiative logo here.
If you are interesting in joining the initiative please contact Ian Bennitt at ibennitt@balljanik.com or (202)772-5577.
Atlantic Marine Holding Company (Jacksonville, FL)
Austal USA (Mobile, AL)
BAE Systems Ship Repair (Norfolk, VA)
BAE Systems Ship Repair (San Diego, CA)
Bath Iron Works (Bath, ME)
Bender Shipbuilding and Repair Co. (Mobile, AL)
Bollinger Shipyards, Inc.- Bollinger Shipyards Lockport, LLC (Lockport, LA)
Electric Boat (Groton, CT)
NASSCO (San Diego, CA)
Northrop Grumman Shipbuilding, Inc. – Avondale Facility (New Orleans, LA)
Northrop Grumman Shipbuilding, Inc. – Pascagoula Facility (Pascagoula, MS)
Northrop Grumman Shipbuilding, Inc. – Newport News (Newport News, VA)
Signal International, LLC (Pascagoula, MS)
Todd Pacific Shipyards (Seattle, WA)
Vigor Industrial LLC (Portland OR)
GHG Inventory Tool
The Shipyard Greenhouse Gas (GHG) Emissions Inventory Tool is designed to estimate GHG emissions for sources that occur in shipyards. The tool gives each shipyard a customized, credible way to measure its GHG emissions, based on emissions protocols developed by the World Resources Institute and the Intergovernmental Panel on Climate Change.
This is increasingly relevant as the EPA released finalized a rule to require facilities that emit 25,000 metric tons or more of carbon dioxide equivalent to report emissions. For those required, data collection is scheduled to begin January 1, 2010. The rule can be found HERE.
Lean Production and Environmental Management Systems
The purpose of Findings and Recommendations on Lean Production and Environmental Management Systems in the Shipbuilding and Ship Repair Sector (PDF) is to summarize research and findings on the relationship between lean production and environmental management systems in the shipbuilding and ship repair sector. Recognizing that lean production—a leading business model being applied in many sectors of the U.S. economy—and EMS both affect environmental performance, EPA initiated research to better understand the relationship between the lean model and EMS. The 2004 report, which is based on interviews with managers at five shipyards, concludes that the lean model and environmental management systems are compatible and synergistic approaches. The report also describes strategies that organizations have used and/or could use to improve their environmental performance and reduce costs by combining lean and environmental management practices.
EMS Implementation Guide
In summer 2003, the Sector Strategies Program released the final version of the EMS Implementation Guide for the Shipbuilding and Ship Repair Industry. Developed with ASA and SCA, the Guide describes an EMS that is based on the ISO 14001 standard and reflects an emphasis on sustained compliance, pollution prevention, and information sharing with the community. The Guide provides detailed information to shipyards interested in implementing an EMS and incorporates lessons learned and examples drawn from the experience of shipyards that participated in the Sectors Program pilot.
Vessel General Permit
The VGP came into effect on February 6, 2009. Regulated vessels of greater than or equal to 300 gross tons or having the capacity to hold or discharge more than eight (8) cubic meters of ballast water must submit an NOI to be in compliance. Permit details can be found here: http://cfpub.epa.gov/npdes/home.cfm?program_id=350
SCA’s Comments and Summary of EPA Responses - How will this affect you?
In comments submitted to EPA in August 2008, (see SCA’s comments HERE) SCA sought clarifications regarding VGP applicability to floating drydocks, vessels undergoing drydock repairs, and new construction.
--Discharges from vessels during the drydock period are not covered by the new VGP. Issues of who must obtain permits for such discharges are therefore also outside the scope of the VGP.
--Discharges resulting from construction activities are not covered by the VGP as they are incidental to vessel construction, not vessel operation.
--***Regarding floating drydocks***…
- With respect to ballast water or other incidental, non-industrial, discharges from a floating drydock that is moving between locations, such discharges are within the scope of the VGP as they would be incidental to the normal operation of a vessel operating in a capacity as a means of transportation.
- With respect to periods when the drydock is transitioning between its status as a means of transportation and becoming, in effect, a ship maintenance and repair facility, such as when discharging ballast water to accept into, or deliver vessels from, the drydock, the VGP would similarly cover its incidental, non-industrial, discharges.
- Once immobile and operating in an industrial capacity as a ship maintenance or repair facility, the drydock ceases to operate in a capacity as a means of transportation and thus its discharges are not covered by the VGP. NOTE: that similar logic would apply to other types of vessels that transition between transportation and non transportation modes of operation (for example, mobile drilling units or construction barges which cease moving to carry out their industrial, non-transportation functions).
Other Applicability and Exemptions
Commercial fishing vessels of any size and non-recreational vessels less than 79 feet in length are exempt from coverage under the VGP. This was due to legislative action late in the 110th Congress.