Launched in September 2023, the overall objective of the SENSREC-DW (SENSREC-Decent Work) project is to enhance the capacity of the Government of Pakistan and its ship recycling industry to promote a just transition and put in place sound and effective measures that improve the standards of health, safety and environmental compliance at ship recycling yards, as required by the Hong Kong Convention, as well as the capacity for environmentally sound waste management of the hazardous and other materials that are generated from the process of ship breaking. From a labour perspective, the project will advocate for the promotion of decent working conditions including labour and social protection of workers.

SENSREC-DW is a direct collaboration between IMO and ILO. Both UN agencies will work hand in hand to implement the project with a view to tackle issue in a more holistic manner. 

Project work is divided into four components covering legal and institutional refinement; capacity building for health, safety and environmental compliance; planning for management of hazardous materials and wastes with an outline design of a facility for downstream treatment, storage and disposal of waste; and supporting industry upgrade. Delivery of these components will consist of international and local inputs and coordination.  

Considering the relatively short timeframe for the SENSREC-DW project in Pakistan, it is focused on producing a clear and comprehensive identification all the factors that need to be addressed in order to successfully deliver improvements in ship recycling standards in Pakistan. Thus, the expected outcome will be the endorsement by Pakistan of a detailed roadmap and action plan for legal and institutional reform to support the effective implementation of the Hong Kong Convention and other related international instruments and best practices for ship recycling and hazardous waste management.

Subject to availability of funding, the project described in this document could be interpreted as a first phase of a more ambitious programme that provides support for the full implementation of the roadmap and action plan.

This phase of the project will not cover the development of capital-intensive schemes such as waste treatment facilities.  These could be the focus of a second phase, with support from funding partners.  This current phase will investigate, evaluate and produce information from which the infrastructure requirement can be identified and selected and will generate outline designs for costing purposes that can be used to initiate detailed design specification to assist in informing funding partners and for implementation of a future second phase.

Current scenario in Pakistan

While Pakistan acceded to the HKC in 2023, its ship breaking industry faces regulatory gaps and enforcement challenges in addressing environmental degradation and occupational health and safety issues. Urgent action is needed by the government, in partnership with industry and civil society, to bring the sector in line with international standards and norms. The entry into force of HKC will demand significant upgrades to the industry in Pakistan if it wants to remain competitive. 

On the legal front, Pakistan has certain regulations in place to deal with various matters related to ship breaking, such as environmental protection, safety and security of the workforce. However, legislation needs to be reviewed to identify any aspects that may need to be updated or reinforced to ensure the shipbreaking industry operates in a more safe and environmentally responsible manner in line with Pakistan’s international obligations under the Hong Kong Convention. 

The “Ship-Breaking Industry (Special Procedure) Rules, 1997” cover sales tax liabilities, record-keeping, and determination of scrap and product percentages for shipbreaking. These rules set time limits for clearing sales tax liabilities and specify the required documentation and procedures. 

In relation to hazardous waste and environmental protection, the Hazardous Substances Rules, 2003, under the Pakistan Environmental Protection Act, 1997, as well as the Balochistan Environmental Protection Act 2012, apply. It is also pertinent to mention that Pakistan is a party to the Basel Convention, and has taken significant steps to improve hazardous waste management through new regulations and policies, such as the National Hazardous Waste Management Policy, 2022. In its efforts to ensure compliance with the Basel Convention, domestic law of Pakistan provisions:

• Fulfilling obligations under the Basel Convention on transboundary movements of hazardous waste;
• Emphasizing a life-cycle approach from generation to disposal;
• Measures for controlling transboundary waste movements, managing contaminated sites, capacity building, monitoring, and sustainable financing; and
• Strengthening coordination between federal and provincial governments.

In January 2024, the Pakistan Environmental Protection Agency published draft Hazardous Substances Rules. Key provisions include:

• Licensing requirements for manufacturing, importing, transporting, handling, storing or disposing hazardous substances;
• Detailed application requirements including Environmental Impact Assessments for imports;
• Packaging and labelling standards for hazardous substances;
• Safety precautions for workers including protective equipment, training, and medical check-ups; and
• Record-keeping and reporting requirements for license holders.

The draft rules cover a wide range of hazardous substances including persistent organic pollutants, heavy metals, and industrial chemicals. While Pakistan still faces challenges in enforcement and implementation, these new regulations and policies demonstrate a commitment to strengthening the regulatory framework for hazardous waste management in line with international standards. 

There are multiple laws governing OSH of workers and laborers at workplace in Pakistan, such as Workmen Compensation Act of 1923, the Labourers Act of 1934, Factories Act of 1934, the West Pakistan Hazardous Occupations Rules of 1963, the Provincial Employees Social Security (Occupational Diseases) Regulations of 1967, and the Labour Laws (Amendment) Ordinance of 1972. Although these legislative instruments provide for safety and security of labour, Pakistan intends to frame more comprehensive and robust legislation for the purposes of providing more safe, secure and protected environment to ship breaking industry owing to it being dangerous and highly labour-intensive industry.