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2011

DISHONORABLE DISPOSAL

Ocean Disposal Practices Adopted

Throughout the twenty years leading up to the ban on exports, the Navy and MARAD have looked increasingly favorably toward ocean disposal to meet fleet reduction goals at least cost to the government. While the U.S. government once externalized costs to foreign shipbreaking yards by exporting vessels, the U.S. government now externalizes costs to the ocean for much the same reason.

Ocean disposal of obsolete vessels via artificial reefing and sinking exercises (SINKEX) are deemed cost-effective disposal strategies by the Federal government and are permitted by a

series of exemptions from existing environmental laws, by ignoring obligations under international law and by neglecting to account for externalized costs. While the EPA acknowledges that these vessels are sunk still

containing

toxic

materials

within

their

composition,

including

asbestos,

polychlorinated biphenyls (PCBs), iron, lead paint and antifouling paint, the EPA allows exemptions to various ocean dumping laws that would normally forbid the ocean disposal of such contaminants, purely on the basis of accounting that indicates reduced costs to the government.

Ocean Disposal Violates U.S. and International Ocean Dumping Regulations

SINKEX and artificial reefing operations violate U.S. and International ocean dumping regulations including the Marine Protection, Research and Sanctuaries Act (MPRSA); Toxic

Simply stated, the EPA permits the ocean disposal of hazardous waste, even when it is illegal under ordinary circumstances, while also

acknowledging

that

some

of these

toxic

London

Protocol; and the

Convention.

This has been

London

(TSCA);

Act

Substances Convention; Stockholm

Control

accomplished

through

application

of

exemptions,

inappropriate wavers and

discretion from U.S. and international laws.

materials, such as PCBs, leach into the marine environment from sunken vessels and accumulate in the bodies of fish and other marine organisms. They have justified this by claiming that the risks to human health and the environment are acceptable risks. Recent evidence however belies this assertion.

Navy Studies Claimed No Harm

While the EPA has permitted SINKEX under the MPRSA and provided full exemption from the Toxic Substances Control Act (TSCA), this general permit and TSCA exemption granted in 1999 by EPA Administrator Carol Browner, was based on a limited body of scientific research that was conducted primarily by the Navy itself,

the agency seeking the exemption. The EPA has justified its exemptions based on these Navy led studies. These studies have gone unchecked for more than a decade and have been used to justify the ocean dumping of approximately 95 naval vessels.

BASEL ACTION NETWORK

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