Local Consultancy Firm (LCF) Services for HKC Compliance
We act as a delegated Local Consultancy Firm (LCF) for ship recycling yards working toward, or maintaining, compliance with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (HKC) and the associated IMO MEPC Guidelines.
Under our delegated authority, we take a yard from its current operating condition to a documented, auditable, HKC-compliant facility — covering the physical infrastructure, the management system that governs it, and the people who run it day to day.
Scope of Our Delegated Authority
Our delegated scope as an LCF covers five defined areas.
Gap Analysis and Transition Plan
We begin with a structured Gap Analysis of the facility against every applicable HKC requirement and the relevant MEPC Guidelines — including MEPC.210(63) on safe and environmentally sound ship recycling and MEPC.211(63) on the authorization of ship recycling facilities.
The assessment covers:
- Yard layout, impermeable flooring, drainage and containment
- Cutting zones, primary and secondary cutting areas, and material flow
- Hazardous material handling, storage and downstream waste routes
- Emergency preparedness, fire safety and rescue capability
- Occupational health and safety arrangements and worker welfare facilities
- Existing documentation, records and management controls
The findings are then converted into a Transition Plan — a prioritised compliance roadmap that sequences every corrective action with a timeline, a responsible owner, an indicative investment requirement and a defined verification point. The Transition Plan is written so that it can be presented directly to the Competent Authority, to a Recognized Organization, and to shipowners performing their own yard due diligence.
Facility Development and Management System Creation
We support the physical development or upgradation of the yard and build the management system that keeps it compliant after the construction work ends.
This includes:
- Technical specification and design input for impermeable areas, containment, drainage and waste storage
- Layout planning for cutting, storage, decontamination and hazardous material zones
- Development of the facility’s documented management system — policies, procedures, work instructions, permit-to-work systems, checklists and record formats
- Establishment of an in-house training system, so that induction, refresher and job-specific training is delivered and recorded by the facility itself rather than depending permanently on outside providers
- Internal audit, monitoring and continual improvement mechanisms
- Alignment with recognised management standards where the facility wants that additional credibility
Capacity Building of Workers’ Skills and Knowledge
Compliance fails at the workface, not in the file. We build worker competence through structured, role-specific programmes covering:
- Safe cutting, gas cutting and hot work practices
- Working at height, confined space entry and lifting operations
- Identification, handling and safe removal of hazardous materials
- Correct selection and use of personal protective equipment
- Emergency response, fire fighting, first aid and rescue drills
- Supervisory competence, toolbox talks and incident reporting culture
Training is delivered in the working language of the yard, with practical demonstration, competence assessment and full training records suitable for audit.
SRFP and SRP Formulation Assistance
We assist facilities in preparing the two core HKC documents:
- The Ship Recycling Facility Plan (SRFP) — the yard’s own plan describing its scope, capability, safety and environmental controls, worker training, emergency arrangements and reporting systems, prepared to support the application for the Document of Authorization to conduct Ship Recycling (DASR)
- The Ship Recycling Plan (SRP) — the ship-specific plan prepared for each vessel, developed against the ship’s Inventory of Hazardous Materials (IHM) Part I, II and III and consistent with MEPC.196(62)
We prepare these documents so they withstand review by the Competent Authority, by Recognized Organizations and by the shipowner’s technical third party.
Other Essential Components
Compliance rarely stops at the checklist. We also support the additional elements a facility needs in practice — hazardous waste downstream traceability, subcontractor control, emergency and contingency planning, statutory liaison, record-keeping systems, and preparation for authorization, surveillance and renewal audits.
What You Receive
- Gap Analysis report with photographic evidence and requirement-by-requirement findings
- Transition Plan with prioritised actions, timelines and cost indications
- Complete management system documentation package
- In-house training framework, materials and records
- SRFP and SRP drafting support through to submission
- Ongoing advisory support through the authorization process
Who This Is For
Ship recycling yards preparing for HKC authorization, yards holding a Statement of Compliance seeking full DASR status, and facilities being assessed by shipowners, cash buyers or financiers against green recycling requirements.