Post Waste Plan

The Port of Inverness is a thriving commercial enterprise, situated at the mouth of the River Ness. The Port handles approximately three quarters of a million tonnes of cargo per annum. The number of commercial vessels using the Port remains steady at approximately 340 per annum, but the general size of vessel has increased significantly over the last few years, and cargo tonnages have therefore shown a steady increase. The Port is tidal, and can handle vessels up to 5000 DWT.

The major import is of various grades of fuel oils, virtually all from UK based refineries. Other significant imports are processed timber, salt, grains, coal, animal feed and general cargo, from around the European area. Exports include sterling board, grains, wood chips and general, to European ports. Exports have on occasion gone to the USA, and cargo continues to be exported to Turkey.

Inverness Harbour Trust has had an operational Port Waste Management Plan, authorised by the MCA, since October 1998. The requirement to do so was initially stipulated under the Merchant Shipping (Port Waste Reception Facilities Regulations) 1997. Subsequent legislation has modified the requirements on the Port, and the customers who use it. Amendments to the original plan were made by way of addendums by the MCA, and the plan itself periodically locally reviewed to ensure its relevance and effectiveness.

From mid 2007 to present, a ten hectare extension has been constructed at the mouth of the river. This has created additional lay-down areas, a new 150 metre quay called “North Longman”, and a new 150 berth Marina. The previous 22 berth marina facility was closed and in-filled during October 2007.

The opportunity has been taken to completely re-issue the Plan to reflect these changes.

The new Marina operation is a joint venture between Inverness Harbour Trust and Caley Marina, and the company formed to run it is called Inverness Marina Ltd. Their waste streams are totally separate to that of the Harbour, and they hold their own Waste Plan. Contact details for Inverness Marina Ltd are on page 11.

Responsibility for implementation of the Waste Management Plan rests with the Harbourmaster, as directed by Inverness Harbour Trust.

Contact;

Captain Ken Maclean

Harbourmaster

Inverness Harbour Trust

Harbour Office,

Longman Drive

Inverness

IV1 1SU

Tel 01463 715715

Fax 01463 715705

E-mail hm@invernessharbour.co.uk

2. Legislation

2.1

MARPOL Regulations 1973/78 - The International Convention for the Prevention

of Pollution from Ships (Known as MARPOL 73/78) provides an international framework on

how pollution from shipping should be regulated. MARPOL applies to all UK ships and all ships in UK

Territorial waters, including fishing vessels, passenger ferries, small craft and yachts, harbour

authorities and terminal operators. It simply requires states to ensure that the provision of waste

reception facilities are ‘adequate’ and do not cause ‘undue delay’ to the ships using them.

‘Adequate means capable of receiving the types and quantities of prescribed wastes from ships

normally using that harbour or terminal taking into account the operational needs of the users of the

harbour or terminal, its size and geographical location, the types of ships calling there and any

exemption provided’.

MARPOL covers five specific areas. These are enumerated as follows:

ANNEX 1 - Regulations for the Prevention of Pollution by Oil.

ANNEX 2 - Regulations for the Prevention of Pollution by Noxious Liquid Substances.

ANNEX 3 - Regulations for the Prevention of Pollution by Harmful Substances in Packaged Forms.

ANNEX 4 - Regulations for the Prevention of Pollution by Sewage.

ANNEX 5 - Regulations for the Prevention of Pollution by Garbage.

The United Kingdom is a signatory to Annexes 1, 2, 3, 4 & 5

This plan will be amended when the Annex 4 of MARPOL has been incorporated into UK legislation.

MARPOL 73/78 is implemented in the UK through the following regulations.

The Merchant Shipping and Fishing Vessels (Port Waste Reception Facilities)

Regulations 2003 SI. 1809 – implements EC Directive 2000/59/EC on port reception facilities

for ship-generated waste and cargo residues. They provide a mechanism for landing waste shipping

for appropriate disposal and prevent it from being disposed of at sea. This legislation controls the

landing of waste from and the provision of appropriate facilities.

Environmental Protection Act 1990 (EPA 90) (as amended) & The

Environmental Protection (Duty of Care) Regulations 1991 - The EPA 90 provides a

framework for the Waste Management legislation, and defines waste. Part II defines any waste from

industrial, commercial or domestic sources as controlled waste.

The Duty of Care Regs - Section 34 establishes the Duty of Care was established on anyone who

produces, imports, carries, keeps, treats or disposes of controlled waste. This does not apply to

householders. Within The Duty of Care is a system for transferring the waste to a receiver of the

waste. A Waste Disposal Transfer Note is used with written descriptions and details of the controlled

waste, and records of these transfers are kept for a minimum of 2 years.

Special Waste Regulations 1996 (as amended) – Implement the European Hazardous Waste Directive 91/689/EEC. These regulations provide an effective system of control which ensures that special wastes are managed correctly from the moment they are produced until they reach their final disposal or recovery site. The transferring of wastes under these regulations is performed using a Special Consignment Note with written descriptions and details, and records must be kept for a minimum of four years.

Special Waste Amendment (Scotland) Regulations 2004 - The Special Waste Regulations 1996 transposed the requirements of the Hazardous Waste Directive. However they did not fully transpose all of the Directives requirements, nor did they take into account possible amendments to, and expansions of the European Waste Catalogue, and the list of hazardous wastes. The Special Waste Amendment (Scotland) Regulations 2004 addresses these issues.

Regulation (EC) No 1774/2002 of the European Parliament and of the Council -

This regulation sets out Community requirements for the control, importation and disposal of animal by-products.

Under the Regulation International Catering Waste is Category 1 material and must be

disposed of accordingly.

This material is one of the means by which exotic notifiable diseases could be introduced into the UK,

particularly if farmed or feral animals are able to come into contact with it. The relevant legislation is

therefore designed to minimise the risk of this happening.

International Catering Waste means foods, which are, or contain, or have been in contact with products of animal origin intended for consumption by the crew and/or passengers. It also includes such items as packaging material, or disposable cutlery or plates.

Other waste that is mixed with a quantity of International Catering Waste, must be disposed of as if it were ICW.

Catering waste from means of transport operating from within the European Union (EU) is not the subject of these notes. It should be handled in the same ways as UK catering waste.

Products of Animal Origin (Third Country) (Scotland) Regulations 2007

This Regulation covers the definition, and method of disposal of, International Catering Waste received into Scotland.

The Landfill (Scotland) Regulations 2003 –

The Landfill Regulations also introduce the concept of pre-treatment of waste. This requires that with immediate effect, any landfill that has been granted its license or permit since July 2001 must only take waste that is pre-treated. From July 2004, all hazardous sites must only take waste that is pre-treated. From the 30th of October 2007, all other sites will only be able to accept waste that has been pre-treated.

2.2

Other relevant legislation is;

SI 1984 No 862 The Prevention of Pollution (Reception Facilities) Order 1984

SI 1988 No 2293 The Merchant Shipping (Reception Facilities for Garbage) Regulations 1988

SI 1994 No 1056 The Waste Management Licensing Regulations 1994

SI 1996 No 972 The Special Waste Regulations 1996

SI 2003 No 1809 The MS & Fishing Vessel (Port Waste Reception Facilities) Regulations 2003

Merchant Shipping Notices

MSN 1678 The Special Waste Regulations 1996

MSN 1720 The MS (Prevention of Pollution by Garbage) Regulations 1998

Merchant Guidance Notes

MGN 253 Port Waste Reception Facilities Regulations 2003

MGN 259 Exemptions to the Port Waste Reception Facilities Regulations 2003

MIN 326 Port Waste Facilities – Reporting Form (revised).

MIN 358 CERS Port Waste Infringements Reporting requirements.

Marine Information Notes

MIN 284 Port Waste Reception Facilities: Re-Cycling & Segregated Wastes

Objectives of the Plan

To bring to the attention of Port users their responsibilities as a result of legislation.

To inform Port users of the facilities available to them for the disposal of waste, at the Port.

To ensure facilities provided comply with the regulations and meet the needs of Port users.

Waste types and quantities

4.1 Introduction

It is a requirement of the Merchant Shipping and Fishing Vessels (Port Waste Reception Facilities) Regulations 2003, that the responsible Port Authority carries out an assessment of the types and quantities of waste expected. This assessment will then be compared with the quantities actually received. This is done annually in January and statutory reports forwarded to the MCA.

Vessel Categorisation

Coastal tankers importing various grades of fuel oils make up the biggest group of vessels calling at the Port.

These short sea vessels discharge their cargoes to a facility in the upper part of the Port, with the vessels taking river water for ballast prior to sailing. There is therefore no requirement for them to dispose of dirty ballast water, this being dealt with at Grangemouth, where the majority of the tankers are loaded.

Short sea bulk and general cargo vessels are the next largest group using the Port. These cargoes are both imported and exported, and the Longman quay, at the lower part of the Port is the area where the vast majority of these vessels are handled. Along with the normal ship generated waste, a significant amount of operational cargo waste is generated. This comprises dunnage, slings, battens, steel banding and polythene sheeting.

Other producers of waste

A new 150 berth yacht facility has been constructed as part of the Longman Quay extension project.

The Harbour Office is used by the Port Authority on the upper floor, and offices downstairs are leased out to the Maritime & Coastguard Agency, and also to a Port user company operating at the Port. Normal office rubbish is gathered nightly and disposed of in the same covered skips as are provided for commercial ship use.

Plain paper is collected in dedicated office bins, and sent for confidential disposal then recycling.

There are two small companies who lease operational space at the upper harbour, from the Port Authority. These companies make their own arrangements for the collection and disposal of their own generated daily office waste, and such waste is disposed of outwith the Port facilities.

Facilities

The Port Authority provides three covered skips, blue in colour, for the reception of ship garbage (non-recyleable), within the Port. These are provided through a local contractor, Shanks, at present. One of these is situated at the downriver end of Longman quay, one is on Citadel quay close to the tanker berth, and the other is situated at North Longman quay. The skips are being appropriately signed and worded. A daily check is kept on how quickly the skips are filling, and they are emptied appropriately. The cost of these skips is borne by the Port Authority. (See annex for schematic of location.)

These skips are for commercial vessel use only, visiting yachts must use the facilities provided for them within the Marina.

Disposal of very large amounts of garbage, requiring more than one skip, must be arranged through the Agent, and paid for accordingly.

“Segregated Waste”. There are limited segregated facilities for the reception of different types of ships garbage for recycling. These are located immediately adjacent to the three locations of the covered/blue skips detailed above.

Two separate appropriately signed Euro-carts are provided for mixed paper and cardboard only. This is on a trial basis initially.

As part of the review of this Plan, the feasibility of providing separate facilities compatible with onwards disposal for recycling, of glass/bottles/cans/mixed paper and cardboard was investigated. It has proved unpractical and not cost effective to provide facilities for glass/bottles or cans.

The Port Authority also has a small 1200 litre oil reception tank/pump, mounted on a trailer. This tank is for receiving small quantities of waste oil and bilges, from Coastguard vessels, operational craft, and from servicing port vehicles.

This service is provided free of charge and the cost is borne by the Port Authority.

A very small amount of waste oil in 25 litre drums is disposed of by the Port, on behalf of Port users.

The Port maintains a separate Waste Oil Register for recording such quantities received.

Commercial vessels wishing to land 205 litre drums, either empty or part filled, must arrange their disposal directly through the ships Agent. Under no circumstance are they to be left beside garbage skips, or on the quayside.

The Port does not provide skips for reception of cargo wastes. The main company operating on the dry goods side at the port is Scotline. This company makes their own arrangements, through Finnies, for the adequate provision of open skips for the reception of dunnage, slings, battens, steel banding and polythene sheeting. The costs of these are borne by Scotline directly.

There are no dedicated facilities at the Port for the reception of tank washings, oily mixtures containing oils in bulk, sludge, scale, or sewage. Should a vessel of any type require to land this material, then it can be facilitated by the use of a road tanker, from an approved waste disposal contractor, arranged directly through the ships agent. Twenty-four hours notice is usually required for this facility.

Approved contractors will normally invoice ships Agents for payments for disposals, but Masters should obtain receipts for quantities. (Details should be entered in ships record book for future inspection by Port State Inspectors).

Each year, the Port Authority will check with the individual shipping Agents as to how many such road tankers have been employed. It is usually three, or less.

Yachts wishing to pump out sewage holding tanks or the emptying of chemical toilets, have dedicated facilities provided for them within the Marina, operated by Inverness Marina Ltd, IML.

“Special waste”, and waste from “Harmful Substances in Packaged Form”, from a vessel must be disposed of via an approved waste disposal contractor, arranged directly through the ships Agent.

Special waste includes; lead acid batteries, fluorescent light tubes, tyres, television/computer monitors, aerosols, asbestos, solvents, and any other item listed in MSN 1678.

Redundant fridges/freezers or washing machines must not be left adjacent to skips. Arrange disposal through your ships Agent.

The above items must never be added to a normal harbour quayside skip, which would then have to be classed as Special waste in its entirety, causing greatly increased costs. Should this occur, then the Harbour reserves the right to charge the ships Agent acting on behalf of the vessel for the recovery of all costs incurred in disposing of any such contaminated skip.

“International Catering Waste” may on occasion be received at the Port. Given that this is only for food waste from non-EU countries that qualifies, and that the type of short sea shipping operating in and out of the Port is generally only trading with other EU countries, a dedicated facility has not been put in place. However the Port has had numerous contacts with the approved waste contractors as to the likely costs involved of receiving and disposing of such waste, along with the costs of subsequent disinfection of containment used.

It is the responsibility of the Master of a vessel arriving from a non-EU country, to liaise with his ships Agent for the collection of any ICW held aboard.

Given that the quantity is likely to be small and that ICW has to be transported out of the Highlands for disposal at licensed landfill, the best cost effective option for the vessel may be to retain it aboard for disposal at a larger, southern port. If however it must be landed, then it must be received it into an appropriate sized containment arranged through the ships Agent.

ICW must never be added to a normal harbour quayside skip, which would then have to be classed as ICW in its entirety, causing greatly increased costs. Should this occur, then the Harbour reserves the right to charge the ships Agent acting on behalf of the vessel for the recovery of all costs incurred in disposing of any such contaminated skip.

Consultation

As with the previous Port Waste Plan, Inverness Harbour Trust is required to consult with all Port users and other organisations having a reasonable interest in the proper disposal of waste arising from shipping and Port activities. The simplest way of ensuring that reception facilities meet the needs of Port users and complying with the requirements of the regulations, is to talk to those who need to make use of them

This Plan is intended to be a “live” document and as such users are encouraged to notify the Port Authority of amendments and/or improvements as they occur, rather than waiting for planned review meetings, which will be held at intervals not exceeding three years. The effectiveness of the Plan will be subject to constant monitoring with any subsequent proposed changes being subject to full consultation with the users.

The consultation exercise for this Plan has included representation from Port users, ships agents, waste management contractors, the local Maritime & Coastguard Agency, Port Health Authority, members of the yachting community, and operational staff.

The following are some of those consulted;

Mr AGM Catto Scotline

Mr J Christie Highland Stevedoring Ltd

Mr Scott Gair Moray Firth Cruises

Mr S Catto Highland Haulage

Mr A Cook BP Oil Ltd

Mr A McLarty Babcocks

Mr A Rendle Maritime & Coastguard Agency

Mr L Seaton Sureclean Ltd

Mr G Henderson Shanks Ltd

Mr S Finnie Finnies Ltd

Mr A McNab Veterinary Officer, Scottish Executive

Mr J Lee Highland Council Environmental Health

Mr C Craig Scottish Environmental Protection Agency

Charging Structure

Under the “polluter pays” principle, ships should bear the cost of providing reception, treatment and disposal of waste, but the cost of using port waste reception facilities should not be so high that it encourages disposal of waste at sea.

All ships must pay the Port a mandatory charge, which makes a significant contribution to the cost of port waste reception facilities, irrespective of the actual use of the facilities.

The policy of Inverness Harbour Trust is to consolidate the mandatory charge within the port dues. This is done by incorporating an additional charge of 1 penny per gross tonne, within the overall charge for berthing dues, applicable to all commercial vessels calling at the port.

The cost of the Waste facility provision, against that received from the vessels, is checked on an annual basis.

At present there is a 100% recovery of costs.

Prior notification

At least twenty-four hours prior to arrival in port, the Master of a vessel is required to inform the Port authority, by e-mail or fax, of the type and quantity of waste to be delivered to the waste reception facility. This does not apply to fishing vessels or to pleasure craft authorised to carry no more than twelve passengers.

It is the responsibility of the Master of a vessel arriving from a non-EU country, to liaise with his ships Agent for the collection of any ICW held aboard.

Virtually all commercial craft now have their own version of the pre-notification form required, but should a vessel not have one, then on contacting their Agent, or the Port Authority, a pro-forma can be either faxed or e-mailed to the vessel, for their use.

An example of this pro-forma is attached within the annex to this plan.

E-mail address hm@invernessharbour.co.uk

Fax 01463 715705.

The notification forms are retained on file for the current year, plus twelve months.

Data from the notification forms are retained on monthly summary sheets, and used for compiling the annual notifications to the MCA

Delivery of Waste

The Master of a vessel calling at the Port of Inverness shall ensure that before the vessel leaves the port, all vessel-generated waste is delivered to a waste reception facility, unless sufficient dedicated storage capacity is available to store the waste until the next port of call, and the correct notification procedure has been followed.

Non-Compliance

The responsibility for ensuring that the quantity and type of waste landed, is as stated on the pre-notification to the port, lies solely with the ships Master. Port staff may make random spot checks on the waste being landed.

Non-Compliance will be reported to the MCA via the Central European Reporting System (CERS) website. (Ref MGN 358). Such vessels may then be made a target by the MCA for inspection, who may inform other ports/terminals of their non-compliance. Vessels that fail to comply with the requirements shall be guilty of an offence and liable on summary conviction to a fine.

Exemptions

Vessels can apply for an exemption from some of the requirements of the Port Waste Reception Regulations. Ships so entitled should apply to the MCA in accordance with MGN 259, who will then advise Inverness Harbour Trust, if such a vessel has received an exemption.

Workboats, pilot boats and other similar vessels that operate within the Ports area of jurisdiction, and do not normally leave the area, fall outside of the scope of the requirement to notify, deliver or pay charges.

Deficiency reporting

Given that the large majority of vessels trading to the Port, are regularly returning throughout the year, and that the type of wastes being landed is fairly mundane, it has not been the policy of the Port Authority to issue a form for reporting deficiencies to each and every vessel attending the port. Feedback is obtained verbally from the port users, and regular vessel Masters, if there is any issue arising.

Masters should in the first instance contact the Harbour Master, to allow the complaint to be investigated, and to rectify the deficiency. (A copy of the MCA form from MIN 326 is attached to this form.)

For the vessels that have not been to the Port before, a General Information sheet on the Port is given to vessel Masters by the Pilot, on boarding the vessel on arrival. This form has the plan of the harbour, giving the garbage skip locations, printed on the reverse.

At the same time any issues to do with the provision of waste facilities, and their locations may be discussed.

(A copy of the Information sheet is annexed to this plan.)

Contractor Lists

Sureclean Ltd 10 River Drive, Alness Tel 01349 884480

Shanks Waste Services Ltd Evanton Industrial Estate, Dingwall Tel 01349 830852

Finnies Skip Hire 32 Longman Drive, Inverness Tel 01463 713637

MSIS Admiralty Base, Shore Rd, Invergordon Tel 01349 854454

Northburn Industrial Services Blackdog Industrial Centre, Aberdeen Tel 01224 825448

Baillie Brothers Ltd Linkwood Industrial Estate, Elgin Tel 01343 555312

Moray, IV30 1HZ

Viridor 5 Dalhousie Business Park Tel 0131 663 1061

Carrington Road, Bonnyrigg

EH19 3HY

Useful contacts list

Inverness Harbour Trust Harbour Office, Longman Drive Tel 01463 715715

Inverness, IV1 1SU

MCA East SCOTNI, Aberdeen Marine Office Tel 01224 597900

(Thomas S Robinson) Marine House, Blaikies Quay

Area Operations Manager Aberdeen AB11 5EZ
thomas.robinson@mcga.gov.uk

Inverness Marina Ltd c/o Scotline Office, Longman Drive Tel 01463 220501

Inverness, IV1 1SU Mob 07526 446348

SEPA Graesser House, Fodderty Way Tel 01349 862021

(Mr Colin Craig) Dingwall, IV15 9XB

State Veterinary Service Longman House, Tel 01463 728800

(Scottish Executive) 28 Longman Road,

(Mr A McNab) Inverness, IV1 1SF

Highland Council Environmental 21 Church Street, Inverness Tel 01463 703968

(Mr John Lee)

Highland Council Waste TEC Services, Ross House Tel 01349868614

Services High Street, Dingwall

(Mr Andy Hume) IV15 9RY

Review

Review of the Port Waste Management Plan will be carried out at least every three years, and will involve consultation with representatives of the Port users, regulatory authorities, and other concerned bodies.

MCA Annual Reporting Forms

There are two sets of information that must be submitted on an annual basis to the local Marine Office by the plan holder. In both cases the information should be submitted by the end of April each year, and should take the form of a written or electronic return.

There is a continuing requirement under MARPOL 73/78 for the UK to provide information to the international Maritime Organisation (IMO), as to the type, capacity, and notice required to use reception facilities for oily wastes, noxious liquid substances, tank washings and slops. A copy of this form is annexed to the Plan.

The UK Regulations and EC Directive require information on amounts of waste landed, and totals for the amounts retained onboard vessels, to be collated by the Plan holder, and returned to the MCA. This return should break down the amounts of waste into the format found in the notification form (Schedule 2 of the Regulations), and should additionally provide an update on the Ports mandatory charge for the provision of port waste reception facilities, if there have been changes made that year. A copy of this second form is also annexed to this plan.

Appendices (1 to 6)

HARBOUR MAP 4.pdf

Information for Masters Rev3 2008Appendice 2.doc

Port Waste Reception Notification Blank Appendice 3.doc

Annual report IMO requirements blank.doc

Annual report EU requirements blank Appendice 5.doc

Inadequacies of Port Reception Facilities Appendice 6.doc