The Floating Storage and Offloading (FSO) tanker J. NAT has been beached on the shipbreaking shores of Gadani, Pakistan despite clear warnings by Interpol and international civil society groups that the vessel contains high levels of toxins.
For more than a year, the vessel has been under the spotlight of enforcement agencies and public watchdogs for its illegal export from Indonesia and the multiple attempts to illegally scrap it in South Asia. In Bangladesh and India, local authorities banned its entry due to the dangerous presence of hazardous substances in its steel structures, ballast waters, oil slops and oil sludges following alerts by NGOs. In an attempt to conceal the ship’s identity, its name was changed several times, from J. NAT to RADIANT to CHERISH, and its real-time location concealed. After several months off the radar, the vessel recently reappeared in Mumbai before initiating its final voyage towards Pakistan.
Despite the risks linked to the presence of hazardous substances onboard the vessel, workers were instructed to initiate its scrapping at Plot 60 on the Gadani shipbreaking beach. Local media reports that mercury-contaminated oil sludge was removed from the ship and filled in drums for sale, with workers complaining of severe burning, rushes on their hands and face, and breathing difficulties. It is further likely that the vessel’s steel is contaminated by mercury, which will release extremely toxic vapours when heated by, for example, torch-blowers . Exposure to mercury, even at low levels, has been linked to central nervous system damage, kidney and liver impairment, reproductive and developmental disorders, defects in foetuses and learning deficits.
Dismantling operations of the J. NAT have now been halted by local authorities, and an investigation has been launched. It is not the first time the yard owner, Dewan Rizwan, a former Chairman of the Gadani Shipbreaking Owners Association, has exposed workers to serious risk. At least five workers died in a fire onboard a ship at his yard in January 2017.
The NGO Shipbreaking Platform, Basel Action Network (BAN), European Environmental Bureau (EEB), Nexus3 Foundation, and Zero Mercury Working Group are now urging Pakistani authorities to keep the yard sealed, and call on Indonesian authorities to take back the waste in line with international law. 
“This case is a shocking example of how companies make profits on the backs of vulnerable workers and coastal environments. It is an environmental crime to dodge international laws that ban the trade of hazardous wastes, and the shipping industry has a duty of care to ensure human rights due diligence when selling their obsolete assets,” says Ingvild Jenssen, Executive Director and Founder of the NGO Shipbreaking Platform.
The harsh working conditions at Gadani became widely known after the explosion on 1 November 2016, the worst tragedy in the history of shipbreaking. At least 29 workers were then killed and more than 60 workers were reported injured, many of them suffering severe burn wounds. Fires, explosions, falls from great height and falling steel blocks kill numerous workers each year at the South Asian shipbreaking yards.
IndustriAll-affiliated Pakistan National Trade Union Federation (NTUF) has voiced strong concerns related to systemic breaches of basic labour rights and occupational health and safety. Most of the shipbreaking workers are migrant workers from the poorest parts of Pakistan, including Khyber Pakhtunkhwa. They leave their families behind as there is no appropriate housing or schooling available in Gadani. Workers lack contractual arrangements with the yard management and have to work very long hours without extra pay, no paid holidays or social benefits, such as social security and pension.
As in Chattogram and Alang-Sosiya, the shipbreaking yards operate on a tidal beach, causing pollution to both soil and water. The area is void of hazardous waste disposal facilities, so toxins are simply dumped in the sea or outside the shipbreaking plots. A recent study shows elevated concentrations of mercury and methylmercury in the Gadani shipbreaking area. Local activists have filed a complaint under the Balochistan Environmental Protection Act demanding that shipbreaking activities must operate in line with the Basel Convention. So far, the government has not initiated the necessary changes to ensure a move of the industry to proper facilities and investments in capacity for downstream waste management.
Since the explosion of 1 November 2016, there has been increased awareness, nationally and internationally, of the dangers faced by the workers in the shipbreaking yards in Pakistan. This led to a moratorium on the import and cutting of tankers in Gadani. The ban has since been lifted, but without concrete measures in place to prevent the recurrence of these tragedies. Berge Bulk, Eurotankers, Petrobras, Polaris Shipping and Sinokor are amongst the shipping companies that have selected dirty and dangerous scrapping in Gadani in the last twelve months.
The Platform documents the scrapping of floating oil and gas units, including drill ships, floating platforms, jack-up rigs and FPSOs/FSOs. An increasing number are beached in South Asia, including units owned by Diamond Offshore, Maersk, Odebrecht, SAIPEM, SBM Offshore and Transocean. As the J. NAT, SBM’s mercury-laden tanker YETAGUN was illegally exported from Indonesia. Its scrapping on the Indian beach of Alang was investigated by Dutch media Zembla and revealed that workers were unknowingly exposed to mercury contamination.
 Mercury will remain as a thin invisible coating of metal structures used in the oil and gas processing sector. High concentrations of mercury were documented to have accumulated on and in the steel of the tanks of another unit that operated in the same geographical area, the FSO YETAGUN. Mercury is typically absorbed into the surface of the carbon steel tank walls, piping and pumps. When heated up by simple methods such as sand blasting, water blasting, grinding and gas axing (oxy-acetylene cutting torch) extremely toxic mercury vapor is released in high concentrations which will bypass most commercial personal protection equipment (PPE).
 Pakistan and Indonesia are both signatories to the Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal. Under this Convention, the trade in mercury and several other hazardous wastes that are contained within the structure of the FSO J. NAT is strictly controlled. The import of the vessel requires that there is prior informed consent (PIC) between Indonesian and Pakistani authorities and that the declarations of hazardous materials left on board must reflect actual conditions. Moreover, the Convention requires that no export be made if there is reason to believe that the recycling or waste management facilities employed for the materials will not constitute environmentally sound management under the Convention. The shipbreaking yards that operate on the tidal beach of Gadani are well-known for their dangerous and polluting practices.
Indonesia and Pakistan are also parties to the Minamata Convention. The oil and gas sector is an important source of mercury emissions and its floating storage, production and offloading units will be contaminated. Measures should be taken by the oil and gas sector to ensure the safe removal, storage and disposal of this highly toxic substance.