Assessment of the Port of Abidjan

Transcription

1 Evaluation Report Assessment of the Port of Abidjan December 2009 A report by the United Nations Environment Programme and the International Maritime Organization in cooperation with the Secretariat for the Basel Convention on Transboundary Movements of Hazardous Wastes and their Disposal and with the support of the Government of Côte d Ivoire

2 Published in December 2009 by the United Nations Environment Programme 2009, United Nations Environment Programme United Nations Environment Programme 11-13, Chemin des Anémones CH-1219 Châtelaine, Geneva, Switzerland Tel. : +41 (0) Fax: +41 (0) postconflict@unep.org Website: This publication may be reproduced in whole or in part and in any form for educational or non-profit purposes without special permission from the copyright holder provided acknowledgment of the source is made. UNEP would appreciate receiving a copy of any publication that uses this publication as a source. No use of this publication may be made for resale or for any other commercial purpose whatsoever without prior permission in writing from UNEP. The designation of geographical entities in this report, and the presentation of the material herein, do not imply the expression of any opinion whatsoever on the part of the publisher or the participating organisations concerning the legal status of any country, territory or area, or of its authorities, or concerning the delimitation of its frontiers or boundaries. Editor: Maliza van Eeden Layout: Nikki Meith Cover photo: UNEP

3 Index Glossary i Introduction ii Context and objective of the Port Assessment iii Constraints and limitations iv Summary of main findings and recommendations v Linkages with draft Hazardous Waste Management Plan Institutional and legal context Institutional arrangements Autonomous Port of Abidjan Other institutional stakeholders Legal background International law National legislation Port control procedures Port control procedures International practice Notification of ship waste (incl. cargo residues) Verification Alleged inadequacies Global Integrated Shipping Information System (GISIS) Fee systems for ship-generated waste International practice Control procedures and fee system Port of Abidjan Hazardous waste management and treatment Port of Abidjan Hydrocarbon contaminated liquid waste (MARPOL Annex I) Noxious liquid substances (MARPOL Annex II) Dangerous substances in packaged form or in freight containers (MARPOL Annex III) Sewage (MARPOL Annex IV) Garbage / municipal waste (MARPOL Annex V) Waste generated at the PAA Assessment findings Legal context Institutional context Port control procedures Infrastructure and equipment MARPOL Annex I facility Storage of hazardous goods Municipal waste generated in the port area Intermediate storage of waste oil and hydrocarbon contaminated waste at fishing port MARPOL Annex V waste collection from ships Other issues Recommendations Legal framework Capacity building / training Infrastructure, reception facilities and equipment MARPOL Annex I treatment facility Storage facilities Health and safety Communication procedures and protocols Fee system Dredged sediments Annex I Stakeholders met during assessment mission Annex II Administrative structure of the PAA Evaluation Report: Assessment of the Port of Abidjan 1

4 Glossary ANDE BOO BOT CIAPOL DGAMP DPEC DQE EIA GISIS HWMP IMDG IMO ISM MARPOL MEPC MinEEF MT MVSU OHSAS PAA PRF PRFD SIIC SOLAS UNEP Agence Nationale de l Environnement (National Environment Agency) Build Operate Own Build Operate Transfer Centre Ivoirien Antipollution (Ivorian Pollution Control Centre) Direction Générale des Affaires Maritimes et Portuaires General Directorate of Maritime and Portuary Affairs Direction de la Politique Environnementale et de la Coopération Directorate of Environmental Policy and Cooperation Direction de la Qualité de l Environnement Directorate of Environmental Quality Environmental Impact Assessment Global Integrated Shipping Information System Hazardous Waste Management Plan International Maritime Dangerous Goods (Code) International Maritime Organization International Safety Management (Code) International Convention for the Prevention of Pollution from Ships Marine Environment Protection Committee (IMO) Ministère de l Environnement, des Eaux et des Forêts Ministry of Environment, Water and Forest Ministère du Transport Ministry of Transport Ministère de la Ville et de la Salubrité Urbaine Ministry of the City and of Urban Hygiene International Occupational Health and Safety Standard Port Autonome d Abidjan Autonomous Port of Abidjan Port reception facility Port reception facility database Service d Inspection des Installations Classées (Service for Inspection of Classified Installations) International Convention for Safety of Life at Sea United Nations Environment Programme 2 Evaluation Report: Assessment of the Port of Abidjan

5 i. Introduction The United Nations Environment Programme (UNEP) s Post-Conflict and Disaster Management Branch, in cooperation with the Secretariat for the Basel Convention (SBC) and the International Maritime Organisation (IMO), is implementing a project to strengthen capacity for hazardous waste management in Côte d Ivoire. The project stems from the dumping of hazardous waste in Abidjan in August 2006, which highlighted the urgent need for improvement in the management of hazardous waste in Côte d Ivoire and control and monitoring of transboundary movement of hazardous waste. The main objectives of the project are to: 1. Ensure the environmentally acceptable management of hazardous waste in Abidjan through the development of a Hazardous Waste Management Plan for the District of Abidjan; and 2. Strengthen capacities, within Côte d Ivoire and Africa to monitor and control the trans-boundary movement of hazardous waste. In the context of this project, an assessment was conducted of the Port of Abidjan to evaluate strengths and identify weaknesses in the capacity of national stakeholders to manage the movement of hazardous waste and apply the provisions of relevant Multilateral Environmental Agreements. (documentation and communication) and practical aspects (reception facilities, internal movement, health and safety of staff involved, analyses and follow-up); 2. Control procedures over ships in Port, preventing unauthorized offloading of waste; 3. Institutional division of responsibility between various agencies involved in monitoring and handling of the waste / residues received from ships, effectiveness of cooperation and capacities; 4. Facilities for treatment and disposal of the hazardous waste / residues entering the Port. The mission team consisted of: Maliza van Eeden, Project Coordinator, UNEP Post-Conflict & Disaster Management Branch; Peter Van den Dries, Port Waste Management Expert on behalf of IMO; Eva Röben, Hazardous Waste Management Expert on behalf of UNEP and with expertise on the Basel Convention. Meetings were held with the main stakeholders dealing with hazardous waste / residues within the Port of Abidjan, as follows: ii. Context and objective of the port assessment The assessment was conducted UNEP and IMO, in cooperation with SBC and with the support of the Government of Côte d Ivoire from 26 to 28 May The application of the provisions of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (Basel Convention) and the International Convention for the Prevention of Pollution from Ships, 1973 as modified by the Protocol of 1978 (MARPOL), were of particular interest. The assessment considered the following: 1. Existing practices within the Port of Abidjan for receiving waste from ships both procedural Table 1: Summary of meetings held Stakeholder met Ministry of Environment, Water & Forests (Directorate of Environmental Quality) General Directorate of Customs Centre Ivorian Anti-Pollution (CIAPOL, an agency under the auspices of the Ministry of Environment, Water & Forests) Autonomous Port of Abidjan (including Harbour Master s office) Directorate General of Maritime & Port Affairs Representative organisation of port waste management companies Ministry of Environment, Water & Forests (Focal Point for the Basel Convention) Date 26 & 28 May May May May May May May 2009 Evaluation Report: Assessment of the Port of Abidjan 3

6 In addition, the following site visits were conducted: Documents prepared in the context of the PAA s ISO and OSHAS certification; Site visited Date Register of garbage collected by the port waste collection companies; Autonomous Port of Abidjan 27 May 2009 Treatment facilities of ITI (company contracted to treat hydrocarbon contaminated sands and slops from offshore installations and certain refineries) A complete list of individual stakeholders met are included in Annex I. iii. Constraints and limitations 28 May 2009 Meetings were sought, but could not be obtained, with: The Ministry of the City and Urban Hygiene (Ministère de la Ville et de la Salubrité Urbaine) and its agency ANASUR (Agence Nationale de la Salubrité Urbaine), which is responsible for non-hazardous waste management; Ministry of Economic Infrastructure (Ministère des Infrastructures Economiques), which has oversight over Ivorian ports; CARENA (a private ship repair company). Within the timeframe for the mission, it was not possible to: Observe the offloading of waste from ships; Examine the intermediary storage area for MARPOL Annex I waste in the fishing port. The following documents were not available for inspection: Draft feasibility study for a liquid waste reception facility at the PAA; Environmental profile developed by the PAA; Complete set of legislation related to maritime affairs and waste/ water management; Customs / Harbour Master s register of goods entering the port; Data on the types and quantities of ship-generated waste and cargo residues discharged from vessels; Data on the capacity of MARPOL Annex V port reception facilities operating in the port of Abidjan. The above constraints did not affect the assessment s findings and conclusions, although some of the above documents could have assisted with further refining recommendations. iv. Summary of main findings and recommendations The following is a summary of the main findings and recommendations from the assessment. For further detail, please refer to Chapter MARPOL Annex I and IV reception facilities: The lack of operational reception facilities for residues falling under MARPOL Annexes I (oily residues and mixtures) and Annex IV (sewage) is a major challenge for the Port of Abidjan, since Côte d Ivoire has an obligation in terms of the MARPOL Convention to provide Annex I, Annex II, Annex IV and Annex V facilities. A feasibility study proposing various options is in progress. More concrete recommendations could be made once the study becomes available for review. 2. Training on hazardous waste / goods: Training is needed for most stakeholders in the port waste management cycle on the identification and 1 Port States have an obligation to provide adequate reception facilities for waste discharged by ships normally visiting their ports. 4 Evaluation Report: Assessment of the Port of Abidjan

7 handling of hazardous waste and dangerous goods, including response to accidents and spills. Training should target the Autonomous Port Authority, the DG of Customs, DG of Maritime and Port Affairs and CIAPOL on one hand, and workers and managers of port waste collection companies on the other. 3. Storage areas: As a temporary measure, it is recommended that a shelter be constructed to keep containers with imported hazardous goods (mostly raw materials for industries) protected from direct sunlight. In the longer term, the security measures, design and equipment of these secure storage areas should be assessed and improved. 4. Development of legislative provisions: Framework legislation on environmental management and maritime affairs is already in place. In addition, Côte d Ivoire has ratified the MARPOL and Basel Conventions and has promulgated several environmental laws (Environment Law, Water Law, etc.), however, detailed application decrees and procedures should still be developed. A review and further elaboration of legislation is recommended, particularly related to waste discharge and control. 5. Training on legal framework: All stakeholders would benefit from a better knowledge and understanding of the provisions of relevant international conventions, particularly the Basel and MARPOL Conventions. General knowledge of relevant national environmental legislation should also be increased. fee systems should be studied in more detail to determine the system best suited to local conditions, taking into account the potential impact on port traffic. Training on international best practices in port waste management, including fee systems, handling of ship generated waste and cargo residues, the development of waste reception and management plans, notification systems and enforcement is recommended. v. Linkages with Hazardous Waste Management Plan The UNEP and SBC hazardous waste management capacity building project, under which this port assessment was conducted, has as one of its components the development of a Hazardous Waste Management Plan (HWMP) for the District of Abidjan. The Plan has gone through a series of consultations and was validated at a multi-stakeholder workshop in October The findings and recommendations of this port assessment have been taken into account in the HWMP. All recommendations relating to training needs and capacity building have been integrated in the detailed project proposals, which have been developed with the aim of implementing the HWMP. In particular, the recommendations on collection, use, evaluation and exchange of information, as well as transparency and institutional communication have been incorporated. The HWMP also addresses the legal issues identified relating to specific norms and standards. 6. Information exchange / management: The hazardous waste management in Abidjan (including in the Port) would benefit from a more systematic collection and exchange of information, as well as improved systems for communication between stakeholders. 7. Best practices on port waste management: The adoption of an appropriate fee system is likely to increase the revenue available for the development and expansion of an environmentally sound reception system for ship-generated waste and cargo residues. This could also alleviate the problem of lack of personal protective equipment among workers. Different types of Evaluation Report: Assessment of the Port of Abidjan 5

8 Chapter 1 Institutional and legal context 1.1 Institutional arrangements Autonomous Port of Abidjan (PAA) The Autonomous Port of Abidjan is a state owned enterprise. It covers an area of 1000 ha on the Ebrié lagoon and 800 ha on land, and started operating in The port can be accessed via the Vridi channel, an artificial connection between the Ebrié lagoon and the sea, with a length of m, width of 370 m and depth of 13,5 m. Mooring posts at the PAA have a depth of between 10 and 15 m. The PAA is a landlord port, which lets concessions to 98 industrial enterprises operating in the port area. These enterprises employ a total of workers and represent 60% of Ivorian industrial production. 2 The PAA operates three quays. The North Quay has 5 mooring posts (with a total length of 775 m) and 5 storage facilities with an area of m². The West Quay has 10 landing posts (with a total length of m) and 10 storage buildings with an area of m². The South Quay has 5 landing posts (with a total length of 800 m) and 4 storage buildings with an area of m². The PAA also operates several specialised terminals: A modern container terminal covering 27 ha, with 5 mooring posts, a total quay length of 960 m and 4 container winches; Figure 1 : Map of the PAA 3 2 Source: Extracts from draft feasibility study for a treatment centre for wastewater coming from ships and from port industry in Côte d Ivoire, Eurotrans Consultants, 16 January Source: PAA website 6 Evaluation Report: Assessment of the Port of Abidjan

9 A fruit terminal; A wood terminal; Offshore landing posts for petrol tanks, including: 3 loading/unloading terminals connected via pipeline to the Societé Ivorienne de Raffinage (SIR) and United Meridien International Corporation (UMIC), 3 mooring posts for vessels between and tonnes and 5 mooring posts on the eastern side of the Vridi channel; A fishing port with m of quays, a reception hall of m² and maintenance area of m². 4 A new master plan for further extension of the port is in progress. The division of responsibilities for waste management within the PAA is fairly complex, with different port directorates involved at different levels of environmental management (please see Annex II for an organigram of the Port Authority). The Environmental Department under the Directorate of Heritage and Environment is responsible for environmental management at operational level. This department has a staff of 12, of which 11 are qualified technical experts. Duties and responsibilities are well defined and clearly assigned. The Department is also involved in the elaboration of an integrated Environmental Strategy, the approval of which depends on the Directorate General. An environmental profile of the PAA has been prepared, but was not available for review Other institutional stakeholders The responsibilities of all government institutions are attributed by the Decree no of 20 April The most important institutional stakeholders in the context of port waste management are: The Ministry of Environment, Water and Forests (MinEEF) with its agency Centre Ivorien Antipollution (CIAPOL) and the Service for the Inspection of Classified Installations (SIIC) (a sub-entity of CIAPOL). MinEEF is responsible for the elaboration of environmental policies, strategies and legislation, and for the implementation of the Environmental Law (Code de l Environnement) and the national waste management strategy. MinEEF is also the focal point for most international environmental conventions, including the Basel, Stockholm and Rotterdam Conventions. It has the mandate to prepare legislation on hazardous waste management and to ensure the monitoring and control of industrial waste. SIIC is responsible for the control of classified industries and its National Environmental Agency (ANDE) is responsible for the terms of reference and subsequent evaluation of environmental impact assessments. CIAPOL has two laboratories for waste and effluent analysis and is the main control mechanism in respect of waste discharged at the PAA. The environmental police, UNIPOL, is a sub-entity of CIAPOL and is responsible for controlling the location and manner of waste discharge. The Ministry of Transport and its General Directorate of Maritime and Port Affairs (DGAMP) (Direction Général des Affaires Maritimes et Portuaires). DGAMP is the supervisory authority for ports and ensures port security. DGAMP also certifies (and has the power to withdraw the certification of) private companies operating within the port s boundaries. DGAMP represents Côte d Ivoire at the IMO and is the national-level focal point for the MARPOL Convention. Ministry of Economic Infrastructure (Ministère des Infrastructures Economiques), under whose oversight the Autonomous Port of Abidjan falls. The Ministry is in charge of all public works for transport infrastructure, including ports, their operation, maintenance and relevant regulations. Ministry of Economy and Finances, with its General Directorate of Customs. The Ministry is responsible for the preparation of economic laws and strategies, the economic administration of all public institutions and partly or totally state owned enterprises. It is also responsible for tax and customs services. Ministry of Mines and Energy, which oversees the two most important petrol processing companies of Côte d Ivoire, SIR (Société 4 Source: Evaluation Report: Assessment of the Port of Abidjan 7

10 Ivoirienne de Raffinage) and PETROCI (Société National d Opérations Pétrolières de la Côte d Ivoire), as well as several distribution enterprises such as Shell Côte d Ivoire and Total Fina Elf Côte d Ivoire. These companies are important actors at PAA level and operate their own quays and infrastructure. The Ministry is responsible for energy and hydrocarbon supply security and transformation of raw hydrocarbons to semifinalised and end products. Ministry of Construction, Urbanisation and Habitat, which is responsible for the elaboration of urban development master plans (including potential further development of the PAA), urban planning legislation and the planning and control of sanitation infrastructure. The Ministry of the City and Urban Hygiene (Ministère de la Ville et de la Salubrité Urbaine) and its agency ANASUR (Agence Nationale de la Salubrité Urbaine, which is responsible for public works, approval and monitoring of urban waste management (industrial and domestic), preparation of legislation in respect of industrial and domestic waste, and prevention and control of urban pollution. ANASUR is responsible for coordinating the activities of the waste collection companies operating at the port and for the management of the Akouédo landfill site. 1.2 Legal background The major legal texts governing port waste management are the following: International conventions on maritime affairs, movement of hazardous waste and the environment; Laws on maritime affairs, environment and economic/ financial affairs; Decrees; Stakeholders internal rules and procedures International law The United Nations Convention on the Law of the Seas, 1982 (UNCLOS), the Basel Convention, MARPOL Convention and the International Convention on the Safety of Life at Sea, 1974 (SOLAS) are the most significant international conventions on environmental / maritime affairs. Côte d Ivoire has ratified all four. UNCLOS and the MARPOL Convention establish a framework of rights and duties: While vessels may discharge at sea (provided MARPOL s requirements are met), states have the right to impose an outright prohibition on polluting discharges from foreign and domestic shipping in their coastal zones. States have a duty to ensure the provision of adequate reception facilities for ships waste in their ports. This duty is explicit in MARPOL, while it is implicit in UNCLOS that each right also entails a duty. The MARPOL Convention is a framework convention with six annexes containing detailed regulations regarding permissible discharges, equipment on board ships, etc. The annexes cover the following topics: Annex I Annex II Annex III Annex IV Annex V Annex VI Discharge of oil or oily residues Discharge of noxious liquid substances in bulk Discharge of harmful substances transported in packed form Sewage discharge Discharge of garbage (household waste and other solid waste, including cargo related waste) Discharge of air pollutants from ships Parties to the MARPOL Convention undertake to ensure the provision of adequate waste reception facilities in their ports. Most member states delegate this duty to their port authority or to other public or private bodies, but states retain the ultimate responsibility for ensuring that the obligation is fulfilled. The global provision of adequate port waste reception facilities will contribute towards the elimination of intentional pollution of the marine environment from maritime activities. To achieve this objective of the MARPOL Convention, the means to dispose of ships waste ashore must be provided. The conditions of use of such facilities should not deter vessels from using them, either for practical or economic reasons. 8 Evaluation Report: Assessment of the Port of Abidjan

11 MARPOL covers ships generated waste and cargo residues, but the Convention presently does not directly define either term. However, IMO s guidelines for the implementation of Annex V to MARPOL 73/78 define cargo residues. Reference can therefore be made to the definitions adopted by the EU 5, which are consistent with MARPOL: Cargo residues means the remnants of any cargo material on board in cargo holds or tanks, which remain after unloading procedures and cleaning operations are completed, and includes loading/unloading excesses and spillage. Ship-generated waste means all waste, including sewage, and residues other than cargo residues, which are generated during the service of a ship and fall under the scope of Annexes I, IV and V of the MARPOL Convention and cargo-associated waste as defined in the Guidelines for the implementation of Annex V to MARPOL 73/78. To achieve and maintain high standards of environmental protection by all those involved in maritime operations, IMO has adopted the International Safety Management (ISM) Code to develop a culture of safety and environmental consciousness, both ashore and on board ships. The ISM Code imposes a duty on flag states to confirm, by means of auditing, that both the shore-side management systems and operational standards on board ships comply with the Code. Amongst other things, the ISM Code provides that every shipping company should: develop a safety and environmental protection policy; provide instructions and procedures for the safe operation of ships and protection of the environment in compliance with relevant international and flag state legislation; and ensure that all personnel on assignments related to safety and protection of the environment are proper familiarised with their duties. In terms of the Code, all personnel involved in the collection, handling and disposal of ships wastes should be aware of the State s national legislation and waste management policies and should receive appropriate training. Trained personnel involved in the collection or handling of noxious and harmful substances may be able to minimize the threat of accidental injury or the potential spread of disease, purely by being aware of the potential risk that they and the local environment face. SOLAS is concerned with the safety of merchant ships, including the carriage of cargoes, hazardous goods and safety management. In addition to the requirements of UNCLOS, MARPOL and SOLAS, the ISM Code provides a link between the need for compliance with international treaty obligations and the associated responsibilities of the maritime industry. This dual approach by governments and industry for the provision of adequate facilities is intended to complement other measures taken by the IMO to protect the marine environment. The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, 1992, has 172 Parties and aims to protect human health and the environment against the adverse effects resulting from the generation, management, transboundary movements and disposal of hazardous and other waste. The Basel Convention contains, in Annex I, categories of hazardous waste to be controlled, unless any of these wastes do not display one of the characteristics contained in Annex III. Annex II, categories of waste requiring special treatment, mainly refers to household waste. Both Annex I and Annex II wastes are subject to the provisions of the Convention. Waste derived from the normal operations of a ship, the discharge of which is covered by the MARPOL Convention, is excluded from the scope of the Basel Convention 6. The Convention firstly regulates the trans-boundary movements of hazardous and other waste applying the Prior Informed Consent procedure (shipments made without consent are illegal). Secondly, the 5 EU Directive 2000/59/EC on port reception facilities for ship generated waste and cargo residues 6 Art. 1, para 4: Wastes which derive from the normal operations of a ship, the discharge of which is covered by another international instrument, are excluded from the scope of this Convention. Evaluation Report: Assessment of the Port of Abidjan 9

12 Convention obliges its Parties to ensure that hazardous and other waste is managed and disposed of in an environmentally sound manner (ESM). Strong controls must be applied from the moment of generation of hazardous waste through its storage, transport, treatment, reuse, recycling, recovery and final disposal. To make this system work, the Convention requires Parties to designate official points of contact to ensure that information is communicated to the appropriate person/officials. These official points of contact are referred to as Competent Authorities or Focal Points, depending on their functions. Both contact points play key roles in the implementation of the Basel Convention and is responsible for receiving and transmitting information from other Parties and the Secretariat. Under the Basel Convention the exporting country desiring to export hazardous waste abroad should first secure the prior written consent of the country of import, as well as those of the countries through which the wastes will transit. The exporting country must send a notification containing sufficient information to enable the importing and transit countries to make informed decisions on whether to allow the proposed movements of wastes. The Competent Authority is responsible for receiving and responding to these notifications. The Competent Authorities of the importing and transit countries should reach a decision on whether to allow the proposed movement of waste. The Government of the Côte d Ivoire officially designated both a Focal Point and a Competent Authority for the implementation of the Basel Convention. The Bamako Convention, which came into force in 1998, was concluded by African nations to prohibit the import of hazardous and radioactive waste into Africa and to minimise and control the trans-boundary movement of such waste within Africa. Côte d Ivoire has ratified the Bamako Convention. Côte d Ivoire has a monistic legal system concerning international conventions (as per Article 87 of the Constitution of 2000), which means that conventions that have been ratified by Côte d Ivoire have the status of national legislation, without the need for transposition into national law National legislation For a summary of the most significant maritime affairs related conventions and national legislation in Côte d Ivoire, please refer to Table 2 opposite. The importation of hazardous waste into Côte d Ivoire is prohibited by law No of 7 July 1988 and framework law No of 3 October 1996, making the unauthorized importation of hazardous waste and noxious substances a criminal offence. The Ivorien authorities are aware of the need for more concrete and specific legal texts on environmental matters. A number of texts are under development, and the government is prepared to take on additional international commitments. The assessment mission was informed of the following legislative texts, which are currently under preparation (Table 3). Table 3: Legislative text under preparation Type Subject Area Responsible institution Ratification of international conventions in progress International Convention On Oil Pollution Preparedness Response & Co- Operation, London 1990 Maritime affairs/ environment Government Polluter pays decree Environment MinEEF Decrees Decree governing the transport of dangerous goods by sea, river and lagoon Maritime affairs/ industry/ environment Ministries of Transport, Economic Infrastructures, Environment Regulations Regulations on emission standards (adopting EC limitations) Environment MinEEF 10 Evaluation Report: Assessment of the Port of Abidjan

13 Table 2: Conventions and legislation related to maritime affairs Legislative instrument International conventions National laws National decrees National regulations Name and date Convention of 1965 on International Maritime Traffic, ratified by Decree no , 08 September 1966 International Convention on Civil Responsibility for Damages due to Hydrocarbon Pollution, Brussels 1969, ratified by Decree no , 21 December 1972 UN Convention on the Law of the Sea (Montego Bay Convention) of 10 December 1982, ratified by Decree no of 15 February 1984 International Convention for the Safety of Life at Sea (SOLAS Convention) of 1974 and its Protocol of 1978, ratified by Decree no , 27 July 1987 Convention on the Prevention of Marine Pollution by Dumping of Wastes, London 1972, ratified by Decree no , 28 July 1987 International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL), ratified by decree no , 28 July 1987 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, Basel 1989 Convention for Co-operation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region and Protocol, Abidjan 1984, ratified on 5 August 1984 Convention on Maritime Polluting Resulting from Immersion of Waste, London/ Mexico 1972, ratified on 16 July 1986 Bamako Convention on the Ban on the Import into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes within Africa, Bamako 1991, ratified on 9 June 1994 Stockholm Convention on Persistent Organic Pollutants (POPs), ratified on 20 January 2004 Law no of 09 November 1961 on the Merchant Marine Law no of 17 November 1977 determining Limits of the Marine Zones placed under Jurisdiction of Côte d Ivoire Law no of 07 July 1988 on Protection of the Environment against Impact of Hazardous and Nuclear Waste and Noxious Substances Law no on 23 December 1998, Water Law Law no of 07 July 1988 on the Protection of Public Health and the Environment Law no of 3 October 1996, Environment Law Law no of 15 April 2004 ; Finance Law and its application in 2004 Decree no of 20 April 2007 on mandates of government members Decree no of 08 May 2007 on the organisation of the Ministry of Transport Decree no of 21 April 1999 on regulations for the police of the Autonomous Port of Abidjan Decree no of 06 October 1991 on creation of CIAPOL Decree no of 12 September 1985 related to the organisation of an emergency plan for combating marine pollution caused by accidents ( Plan Pollumar ) Decree no of 28 January 1998 on classified installations Decree no of 08 November 1996 on EIA Decree no of 03 December 1997 protecting the marine and lagoon environment Regulation no of 28 October 2007 on the creation of an environmental police Regulation no. 46/MEMT/DGAMP of 14 March 2005 on organisation and mandates of the General Directorate of Maritime and Port Affairs (DGAMP) Regulation no. 82 of 05 May 1999 on the operation of the Autonomous Port of Abidjan Regulation no on obligatory authorisation for collection of waste from ships Regulation no. 09/MINIMAR/CAB/SGM/DNAMN of 04 May 1982 concerning the security of offshore platforms and other installations Regulation no. 11/MDIE-ET/MLCVE of 30 January 1998 concerning the conditions of immerging stranded goods/ wrecks in the sea Regulation no. 74/MT/CAB of 12 March 2003 concerning technical security visits to passenger ships Sector Maritime affairs Environment Maritime affairs Maritime affairs Maritime affairs/ Environment Maritime affairs/ Environment Environment Environment Maritime affairs/ Environment Environment Environment Maritime affairs Maritime affairs Environment Environment Environment Environment Finances Institutional Institutional Institutional Institutional/environmental Maritime affairs/ environment Industry/ environment Environment Environment Institutional/ environmental Institutional Institutional Maritime affairs/ environment Industry Maritime affairs Maritime affairs Regulation no on permits for import and export of waste Environment Ordinances Ordinance no of 18 December 2008 for the state budget to be executed Finances Decisions Procedures Decision no. 127/MT/DGAMP/DAPDP of 24 April 2007 on security directives concerning the entry and sojourn of vessels in Ivorian ports Service note No. 07/MT/DGAMP/DAPDP of 15 March 2007 concerning special modalities for discharge of liquid residues in Ivorian ports Maritime affairs Maritime affairs/ environment Evaluation Report: Assessment of the Port of Abidjan 11

14 Chapter 2 Port Control Procedures 2.1 Port control procedures International practice In some ports the providers of waste reception facilities require vessels to give advance notification of their intention to use the facilities. This tends to increase the effectiveness of port reception facilities and can make relevant information available more timely. In cases where the port authority plays an active role in the discharge of ship-generated waste, good communication between the port reception facility and the port authority provides port state control officers with the information they need to check on the amount of ship-generated waste actually discharged. (This is particularly important when a fee charging system is in operation.) Notification of ship waste (incl. cargo residues) It is up to the government of the port state to decide whether notification by vessels should be made to the port authority, the port reception facility, port state control officers or other institutions. The different types of notification are briefly discussed below. Vessel to port authority: A standardized form for the advanced notification of ship-generated waste and cargo residues has been developed by IMO s Flag State Implementation Sub-Committee (see MEPC.1/Circ.644). This notification form provides details on the ship, such as its IMO number, the previous and next ports of call, the types and amounts of ship-generated waste and cargo residues on board when entering the port, and the types and amounts of ship-generated waste and cargo residues to be discharged at a port reception facility. In EU ports the master of a ship (other than a fishing vessel or recreational craft authorised to carry no more than 12 passengers) and bound for a port located in the EU must accurately complete the notification form and provide this information to the authority / body designated for this purpose by the Member State in which that port is located: (a) at least 24 hours prior to arrival, if the port of call is known; or (b) as soon as the port of call is known, if this information is available less than 24 hours prior to arrival; or (c) at the latest upon departure from the previous port, if the duration of the voyage is less than 24 hours. Vessel to reception facility / waste collector: For logistical reasons and to improve the efficiency of port reception facilities, the providers of waste reception facilities may require advance notification from a ship of its intention to use the facilities. Waste collector to port authority / port state control: Where the port authority has implemented a fee system that includes the cost of discharge of ship-generated waste, the port authority must receive feedback on the actual amounts of waste discharged by the vessel. The use of an international standardized waste delivery receipt, as developed by IMO s Flag State Implementation Sub-Committee, can be useful in this regard (see MEPC.1/Circ.645). The waste delivery receipt contains the same information as the advance notification form, but includes a confirmation of the amounts actually discharged Verification Information provided in advance notification forms and waste delivery receipts should be crosschecked to ensure the traceability of waste streams. These checks can be done by the port authority or port state control officers. It may include an administrative data control procedure or random physical checks at port reception facilities and/or on board ships Alleged inadequacies Flag and port states should be able to demonstrate that they fulfil the requirements of the MARPOL Convention. In terms of IMO s Marine Environment 12 Evaluation Report: Assessment of the Port of Abidjan

15 Protection Committee (MEPC) Circular 349, the MEPC agreed that a report should be filed whenever ship owners or masters identify an inherent inadequacy of reception facilities (see MEPC.1/ Circ.469/Rev.1). The procedure for using the Alleged Inadequacy Reporting Form is as follows: a) Where the flag state and port state are not the same, the flag state should inform the port state, as well as the IMO Secretariat, of the alleged inadequacy. Notification should be made as soon as possible following completion of the form. b) Where the flag state and the port state are the same, the maritime administration should take the matter of the alleged inadequacy up directly with the port or terminal concerned. The flag state is required to notify IMO of any case where facilities are alleged to be inadequate. c) The port state is required to investigate the alleged inadequacy and respond to the flag state, with copy to IMO. d) The IMO Secretariat logs the report of the alleged inadequacy and any reply from the port state in the GISIS web based database (see below) Global Integrated Shipping Information System (GISIS) IMO has developed an internet-based port reception facility database (PRFD) as a module of the IMO Global Integrated Shipping Information System (GISIS), to facilitate global access to information on port reception facilities and promote the exchange and accuracy of data. By facilitating global access to the PRFD, the use of these facilities is encouraged 7. The PRFD provides information on available port reception facilities for the delivery of the following categories of ship-generated waste: Oily waste oily bilge water, oily residues (sludge), oily tank washings (slops), dirty ballast water, scale and sludge from tank cleaning and oily mixtures containing chemicals; Noxious Liquid Substances; Garbage; Sewage; Ozone-depleting substances and equipment containing such substances; and Exhaust gas cleaning residues. The PRFD also contains information on: The procedure for reporting alleged inadequacies of port reception facilities, including a copy of The consolidated reporting format (MEPC/ Circ.469/Rev.1); The contact details of the national authorities responsible for reports on alleged inadequacies of reception facilities, including their addresses; and Cases of alleged inadequacies of port reception facilities reported to IMO and the response by the relevant port states. The PRFD was designed to enable competent authorities to update the database by introducing new entries, editing or deleting records pertaining to port facilities under their jurisdiction. Access to this interactive function of the database is strictly via password provided to Member States. The PRFD is available to the general public through the GISIS web-page on a view-only basis for 24 hours a day with the possibility of searching the database and retrieving information on the available reception facilities per country, port and specific type of waste ( - click on Port Reception Facilities and note that new users need to register first). 2.2 Fee systems for ship-generated waste International practice Regulations 38 of Annex I, 18 of Annex II, 12 of Annex IV, 7 of Annex V and 17 of Annex VI of the MARPOL Convention require member states to ensure the provision of adequate reception facilities. However, 7 Information on the GISIS system, including the Manual for Member States Administrations, was communicated by IMO to Member States by means of circular letters No.2683 dated 30 November 2005 and No.2892 dated 24 June Evaluation Report: Assessment of the Port of Abidjan 13

16 in many ports reception facilities are not sufficient to ensure the environmentally sound discharge of waste in a way that discourages illegal dumping at sea. In terms of the polluter pays principle, the costs of port reception facilities, including the treatment and disposal of ship-generated waste, should be covered by ships. The establishment by ports of cost recovery systems to encourage the delivery of waste on land has indeed, when effectively implemented, been found to be effective in discouraging dumping at sea. Although no specific or generic system for charging is recommended, the IMO s Comprehensive Manual on Port Reception Facilities (chapter 11) contains a number of options for ports to consider as a means of recovering the cost of adequate facilities. The fees charged should not, however, serve as a disincentive to use discharge facilities. Two of the most common types of fee systems used by European ports are: No special fee systems, whereby a fee is imposed for the reception and handling of ship-generated waste on all ships entering a port (irrespective of their intention to discharge waste). Vessels are then allowed to discharge a certain amount of waste, at no additional cost. By including such a standard waste charge in port use fees, the economic incentive to discharge illegally at sea is removed. Open market systems, whereby ships pay a basic waste fee to the port authority, but are still required to pay the port reception facility for use of its facilities. The port authorities use the collected waste fee to subsidize actual discharge of waste, meaning that ships may be entitled to a refund on the fees they pay for the use of reception facilities. These types of systems, which exist in various forms, are generally applied regionally, allowing ships to choose between several authorized port reception facilities. In the European Union, a system whereby the costs of port reception facilities for ship-generated waste (including the treatment and disposal of the waste), is covered through the collection of a fee from ships 8, has been effective in encouraging the delivery of waste on land and discouraging dumping at sea. Fees covering the cost of the reception, handling and final disposal of shipgenerated waste are included in the harbour fee or otherwise charged to the ship, irrespective of whether any waste is actually delivered. In this way, all ships calling at an EU port bear a significant part of the cost of the reception facility (at least 30%). These cost recovery systems have a built-in, fixed element and in some cases a variable element, depending on the amount and type of waste actually discharged. Because of the variety of cargo residues and the differences in their final treatment, a standard approach to these types of waste is not practically possible. A distinction can therefore be made between fees for ship-generated waste and fees for cargo residues respectively. To ensure that fees are fair, transparent, non-discriminatory and reflect the cost of the facilities and services, the fees and the basis on which they are calculated should be freely available to port users. This increases the competitiveness of the port. Fee systems for ship-generated waste should be described in the port s waste reception and handling plans and should be authorized by the competent environmental and/or maritime authority. For discharge of garbage, various types of systems are possible with ships either paying the waste collection company directly, or a charge being imposed on vessels indirectly through port use fees. To avoid placing an undue burden on ships, vessels engaged in scheduled traffic with frequent and regular port calls may be exempted from certain obligations, when there is sufficient evidence that arrangements are in place for the delivery of waste. 2.3 Control procedures and fee system Port of Abidjan Turning now to control procedures in the Port of Abidjan, it should be noted that only MARPOL Annex V waste (garbage) is currently accepted, due to the suspension of activities of the company (ITE) that 8 In terms of Directive 2000/59/EU on port reception facilities for ship-generated waste and cargo residue 14 Evaluation Report: Assessment of the Port of Abidjan

17 previously operated a facility for treatment of MAR- POL Annex I waste. This is discussed in more detail in sub-chapter 3.1. In terms of current procedures, the ship s captain informs the shipping agent of the quantity of shipgenerated waste and cargo residues on board the vessel. The shipping agent contacts an authorised port waste collection company directly and negotiates a fee for the waste collection assignment. No verification or cross-checking on the quality of the data provided in the notification is done by the port authority, port state control or other government body. No fee system for ship-generated waste or cargo residues is in operation in the Port of Abidjan. When ITE still functioned, the fees for the collection and treatment of Annex I waste was paid by the shipping agent directly to ITE. Fees depended on the amount of waste discharged. According to the service note on discharge of liquid waste, CIAPOL is responsible for controlling, sampling and analysing liquid waste to be discharged from ships, before discharge is authorised. Port reception facilities such as the now closed ITE, as well as ITI (which treats waste / residues from offshore platforms) or any new treatment station that may come into existence, constitute classified installations and as such are subject to an EIA procedure and regular inspection by SIIC. With the cessation of ITE s activities, no discharge is authorised anymore, except as mentioned for oily waste from offshore platforms, which are treated by ITI. The final posttreatment residues are monitored by CIAPOL. list. The PAA does not interfere in the transactions between the agents and the port waste collection companies, so that waste discharge assignments are generally awarded to the lowest bidder. Since no minimum fee exists, this often leads to offloading taking place in conditions adverse to the health and safety of workers. The control of environmental compliance by port waste collection companies should be done by UNIPOL (CIAPOL s police service), but in practice controls are seldom executed. Concerning hazardous waste falsely declared as merchandise, the responsibility for inspection and identification lies with Customs. Customs officers are not, however, trained on the identification and handling of hazardous waste. Import permits for dangerous goods are issued by the ministry in charge of the industry importing the goods in question, for example Ministry of Agriculture for pesticides, Ministry of Health for health care goods, etc. No harmonised standards exist for the approval of imports. For dangerous goods in intermediate storage at the PAA, basic procedures and safety rules are set out in the Port Regulation. It is expected that the PAA will elaborate more detailed health and safety procedures during the ongoing ISO and OHSAS certification process. No control procedures are currently in place regarding the discharge of municipal solid waste. Solid waste declared as garbage is offloaded from vessels by port waste collection companies, which are authorised by MinEEF on an annual basis. There are no prescriptions regarding how offloading should be conducted. Ships should complete a declaration indicating the amount and nature of garbage, but the veracity of these statements is not controlled and no central register of declarations exists. Fees and conditions for discharge of municipal solid waste (garbage) are imposed by the shipping agents, who select a waste management company for a specific assignment from the authorised Evaluation Report: Assessment of the Port of Abidjan 15

18 Chapter 3 Hazardous Waste Management and Treatment Port of Abidjan Waste reception at the PAA is currently very limited, due to the lack of treatment facilities for hazardous waste and effluents in Abidjan. For an overview of the types of waste received or produced at the Port of Abidjan, as well as the methods of collection and disposal, please refer to Table 4a at the end of this chapter. 3.1 Hydrocarbon contaminated liquid waste (MARPOL Annex I) The PAA is obliged to accept hydrocarbon contaminated liquid waste in terms of Annex I of the MARPOL Convention. To comply with this obligation, the private enterprise ITE was founded in the eighties. ITE had a capacity to accept 1000 tonnes of residues per month (although data provided for the last year of ITE s operation shows that only t/ year were delivered). In the second half of 2008, the authorities stopped ITE s operations due to nuisance complaints from ITE s residential neighbours. At the date of writing, the company has not initiated EIA procedures in respect of a new site. The lack of appropriate reception facilities for Annex I waste is sorely felt by the PAA, which is forced to turn down discharge requests from ships. This is negatively affecting the competitiveness of the PAA. At the date of writing, however, MinEEF, the PAA and DGAM have confirmed that no formal inadequacy complaints had been transmitted to IMO. The government is currently considering a number of options to replace the ITE plant: A feasibility study by the PAA on new Annex I waste reception facilities is nearing completion. Potential services would include treatment of hydrocarbon waste and waste oil generated by industries operating in the PAA territory. The study seeks private companies to invest in this infrastructure. At the time of writing it appeared as if at least one foreign private company was interested in an investment of this nature. If no private investment solution is found, the Government of Côte d Ivoire could consider making the investment on its own, given the importance of the PAA for the Ivorian economy. This would obviously be subject to government funding being available. The state-owned company PETROCI has started the design of a proposed new, large-scale refinery, which would include a wastewater treatment plant for hydrocarbon polluted water, with an anticipated capacity considerably higher than that of ITE. The facility would be capable of accepting all Annex I and probably also Annex II waste from the PAA. This facility is, however, planned to be operational only in The PAA currently still accepts Annex I waste from local fishing boats, which do not have any other legal alternative to discharge hydrocarbon polluted waste. This waste is stored in an intermediate storage area in the Port. Some hydrocarbon contaminated waste from offshore platforms is treated by the specialised treatment company ITI. Polluted sands and sludge are produced during offshore platform operations. From the platforms the product, sands and sludge is pumped to super-tankers. From there, the sludge and sands are loaded onto ITI boats, brought to the PETROCI quay and loaded onto trucks for transport to the ITI treatment facility. Approximately 100 m³ of polluted sands is treated at the ITI site per month. ITI also treats waste from SIR and Shell. Treatment is conducted in two phases: First, solids and liquids are separated by sedimentation. Thereafter the hydrocarbons are separated from water by centrifugation. The sands are spread out on a cement foundation and treated with quicklime, yielding more stable chemical compounds. The lime reacts with the hydrocarbons to form a sand-like substance and the concentration of hydrocarbons is reduced from 40-60% to 5% or less. CIAPOL analyses both incoming sludge and the final residue. Observations at the site showed that basic environmental precautions had been taken, such as spreading the polluted sands on concrete to avoid contamination through percolation. The centrifuge operation could not be seen and no information was given about its efficiency. 16 Evaluation Report: Assessment of the Port of Abidjan

19 The quicklime method is a recognised pre-treatment for hydrocarbon contaminated soil, which allows a considerable decrease in hydrocarbon content, but does not completely eliminate hydrocarbons from the soil. ITI is currently considering an additional investment in microbiological remediation or incineration. 3.2 Noxious liquid substances (MARPOL Annex II) The import of hazardous waste is prohibited by the Basel Convention and the environmental legislation of Côte d Ivoire, while treatment capacity for hazardous waste is very limited in Côte d Ivoire. Currently only one small incinerator (without advanced stack gas treatment) exists for pesticide waste. Two investment projects for sanitary landfills are in the planning/ permitting phase. One of these includes a separate cell for hazardous waste and might also include a medium-size modern incinerator. These facilities will, however, not be operational in the next few years. No specialised facilities exist for toxic liquid waste. As a consequence, no hazardous liquid waste falling under Annex II of the MARPOL Convention is currently accepted and no change of procedure is expected. 3.3 Dangerous substances in packaged form or in freight containers (MARPOL Annex III) During a site visit of the PAA it was observed that containers carrying dangerous goods are marked correctly and that PAA personnel are well informed about the handling of these goods. Dangerous goods are generally imported raw material destined for Ivorian industries. If the delivery of a container to the enterprise concerned cannot be made immediately, the goods are stored in secure, restricted access areas equipped with fire extinguishers. However, no additional security and prevention measures (protection against heat and leakage, separation into categories of goods, etc.) seem to be taken 9. The Directorate General of Customs is responsible for controlling incoming goods and identifying hazardous waste shipped illegally to Côte d Ivoire or falsely declared as second hand goods. However, customs officers tend to focus on the detection of smuggled / counterfeit goods, narcotics and evasion of customs duty. They do not have the knowledge and training to implement effective environmental controls. Some goods condemned by Customs are regularly burnt at the Akouédo landfill, but no information is available concerning the characteristics and hazard criteria of this waste. Pollution through spills or accidents may occur during transport and during offloading / handling at the PAA. Spilled substances that mix with dust and sand are to be considered hazardous waste. PAA technical personnel indicated that they do not have sufficient information on and experience with this type of waste, and it is currently handled together with other garbage. For clean-up operations, PAA personnel request technical assistance from specialised companies, such as SIR in case of hydrocarbon spills or STEPC-CI (phytochemical industry) for chemicals spills. PAA officials advised that an accident took place recently, when containers with hazardous materials were severely damaged. The PAA does not have adequate personal protective equipment to deal with such cases. Cleaning of containers and packaging is often conducted on PAA premises without the necessary environmental safeguards Sewage (MARPOL Annex IV) Sewage from ships was previously collected and treated by ITE, but after the suspension of its activities, this type of waste is no longer accepted by the PAA. 3.5 Garbage / municipal waste (MARPOL Annex V) The only waste currently accepted from ships is waste with household characteristics. So-called quarantine waste (i.e. waste with potential to bring contagious diseases to the country due to contact with human body fluids) is not identified or treated separately. Garbage is collected by 24 9 According to visual observations; the mission time was not sufficient to discuss security and emergency plans within the PAA 10 Hazardous waste inventory District of Abidjan, UNEP 2009 Evaluation Report: Assessment of the Port of Abidjan 17

20 small enterprises (between 3-20 employees), which are authorised annually by MinEEF for this purpose. Most do not have adequate personal protective equipment for its workers and waste is collected manually under rather unsafe conditions. Shipping agents select a company for a specific waste collection assignment from the list of MinEEF authorised companies. Since the PAA does not interfere in the agreements between the collection companies and the shipping agents and competition is high, prices and work conditions are practically imposed by the shipping agents. As a consequence, the revenues do not allow the small to medium-sized companies to purchase personnel protective equipment for workers, who are often directly exposed to the waste they offload. Offloading from vessels is done manually. No control or inspection of the waste is done, as CIAPOL s control and analysis cover only liquid waste. Workers usually do not have the training to recognise hazardous waste. If a collection company suspects certain waste of containing dangerous substances, the company has to request and assume the cost of CIAPOL s analysis. As a result, CIAPOL analysis is almost never requested. Port waste collection companies report that hazardous waste from ships is frequently illegally mixed with domestic waste. Lubricant sludge is frequently included in the domestic waste, but discharge of chemicals or other unknown material has also been encountered. The collection companies generally do not object out of fear of losing business. Injuries due to exposure to hazardous waste do occur, but again are not officially reported. Waste collection companies must register the quantities and types of waste offloaded from ships as declared by the ship s captain and should provide copies to the PAA, which in turn must report to MinEEF. In practice, Table 4a: Overview of waste types, collection, treatment and disposal (MARPOL classification) Type of waste from ships Hydrocarbon contaminated water (slops, bilge water, ballast, motor oils and lubricants); hydrocarbon contaminated sands Noxious liquid substances Harmful substances in packaged form or from freight containers MARPOL classification Annex I Annex II Annex III Recipient Quantity Treatment Disposal Waste from oil platforms: Transported by commuter vessels to the shore, then transported by ITI tank trucks to ITI facilities Waste from ships: Formerly received by ITE, transported by ITE to its facilities. Since suspension of ITE s activities in 2008, this type of waste is no longer accepted. Waste from local fishing boats: Received and stored in an intermediate storage area until treatment. Not accepted due to lack of treatment facilities Dangerous goods: Unloaded by dock workers under supervision of PAA; stored in closed security area until delivery to end user. Hazardous waste: Official import prohibited by Basel Convention and national law, but not always identified. Offloading of small quantities together with garbage is reported by port waste collection companies. Sewage Annex IV Currently not accepted (previously received by ITE). Municipal waste/ garbage Annex V 24 small to medium size waste collection enterprises 100 t/month Separation of solids and liquids by sedimentation; treatment of oily sands with lime and centrifuge separation of water and hydrocarbons Sludge: 7,27 m3/day Bilge water: 155,8 m3/day Slops: 150 m3/day Waste oil: 0,44 m3/day Solvents: 5 m3/day Unknown Filtration to separate solid matter and centrifugation to separate hydrocarbons from water Intermediate storage until treatment/ disposal Purified water: Discharged to the sea Hydrocarbons: Sold as fuel Sand residues: Sold as filling material Solid waste: Discharged to Akouédo landfill site Hydrocarbons: Sold as fuel Purified water: Discharged to the sea Unknown None used by importer Unknown Discharge at Akuédo landfill site, illegal dump sites or urban waste containers Unknown Previously: Discharged into sea Unknown None, except sales of plastic bottles for recycling Discharged at Akuédo landfill site, illegal dump sites or urban waste containers 18 Evaluation Report: Assessment of the Port of Abidjan