Submitted:
23 June 2026
Posted:
24 June 2026
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Abstract
Keywords:
1. Introduction
2. Literature Review
2.1. Risk Governance and Regulatory Regimes
- policy decisions at the governmental level shape regulatory constraints,
- regulatory priorities influence organizational trade-offs between safety and production, and
- frontline adaptations generate feedback that should inform higher-level governance.
- clearly defines and scopes the risk domain,
- allocates unambiguous roles and accountabilities,
- embeds the full risk-governance cycle (framing, assessment, evaluation, management, communication),
- ensures credible monitoring, enforcement, and learning functions, and
- remains adaptive as hazards and technologies evolve.
2.2. Robustness Versus Resilience in Safety Management
2.2.1. Conceptual Distinctions
- Resilience emphasizes adaptation, flexibility, and recovery. It is the ability to “bounce back” from disturbances.
- Robustness emphasizes strength, resistance, and maintenance of essential functions during disturbances.
2.2.2. Debates and Critiques
- Resilience discourse can over-emphasize short-term responses to acute shocks while neglecting chronic vulnerabilities [14].
- Organizational constraints like limited flexibility, opaque information flows, weak reporting cultures can make resilience a rhetorical aspiration, not a practical capacity [15].
- Resilience does not substitute for strong institutions and enforcement, especially where governance capacity is low [16]. Without strong regulation and enforcement, resilience risks becoming a rhetorical substitution for missing capacity.
2.2.3. Arguments for Robustness
- ex-ante safety design rather than post hoc recovery.
- redundant and engineered barriers that do not depend on individual initiative.
- codified safety functions and explicit accountabilities.
- transparent risk-acceptability criteria (RAC), to guide trade-offs.
- Independent oversight, monitoring, and verification
- Institutionalised learning embedded in regulatory cycles.
2.2.4. Operationalizing Robustness for Ship Recycling
- Legal recognition of ship recycling as a regulated industrial activity with defined safety obligations.
- Restriction or engineering control of inherently unsafe practices, such as uncontrolled beaching and hot work on afloat vessels.
- Mandatory interdisciplinary risk assessment, combining engineering analysis, human factors evaluation, and environmental appraisal.
- Clear national Risk Acceptance Criteria (RAC) with transparent thresholds, subject to independent review.
- Predictable, well-resourced enforcement, including frequent inspections and sanctions.
- Incident and near-miss reporting systems with sector-wide dissemination of lessons learned.
- Worker training, certification, and competency assurance as preconditions for performing hazardous tasks.
- Periodic regulatory review to ensure adaptability to technological and industry changes.
2.3. International Ship Recycling Regulatory Regimes: Structures, Variations, and What They Reveal About Robustness
2.3.1. South Asia (India, Bangladesh, Pakistan): Prescriptive Regulation with Weak Robustness
- under-resourced and overstretched inspectorates,
- inconsistent enforcement practices,
- extensive informal labour structures,
- limited reporting and data transparency, and
2.3.2. Turkey and the European Union: Performance-Based Regulation Under Robust Institutions
- performance-based elements (e.g., outcome obligations such as “no significant adverse environmental impact”),
- prescriptive technical standards (impermeable flooring, hazardous-material containment), and
- system-based requirements (safety management systems, certification, facility approval processes).
- frequent and independent inspections,
- publicly maintained facility approval lists (EU SRR Article 16),
- formalised reporting obligations and monitoring mechanisms,
- transparent documentation of accidents and non-compliance,
- professionalised workforce training and certification, and
- established channels for regulatory learning and periodic review.
2.3.3. Comparative Insights for Emerging Ship Recycling States
- Rule type alone does not determine safety outcomes.Prescriptive regimes struggle without enforcement capacity; performance-based regimes fail when monitoring is symbolic or under-resourced [27].
- Institutional robustness is the key differentiator.Countries with coherent legislation, resourced inspectorates, transparent data systems, and feedback mechanisms outperform those with fragmented or capacity-limited institutions, regardless of the nominal regulatory model [28].
- New entrants must build governance architecture, not just adopt standards.Simply transplanting HKC-style provisions without strengthening inspectorates, clarifying agency roles, institutionalising interdisciplinary assessment, and enabling transparent decision-making risks replicating the weaknesses seen in early-stage South Asian regimes.
2.4. Implication for the Nigerian Context
2.4.1. Safety Governance in Developing Contexts (with Focus on Nigeria)
2.5. Synthesis: Why Robustness Is the Appropriate Lens
3. Methodology
3.1. Research Design
3.2. Data Collection
- National legislation – e.g., Nigeria’s Factories Act (2004) and Labour Act (2004), which contain general occupational safety provisions.
- Maritime regulations and guidelines – e.g., the Nigerian Maritime Administration and Safety Agency (NIMASA) Act (2007), as well as NIMASA’s specific guidelines for Ship Scrapping Facility Permits (which outline requirements for yards seeking approval to operate).
- International standards and conventions – e.g., the IMO’s Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009) and relevant guidelines from the International Maritime Organization (IMO) and International Labour Organization (ILO) on ship recycling safety.
3.3. Data Analysis
3.4. Validity and Reliability
3.5. Ethical Considerations
4. Results
4.1. Current Risk Governance and Safety Practices in Nigeria’s Ship Recycling
4.1.1. Regulatory Framework Gaps
4.1.1.1. Absence of Legal Recognition and Fragmented Oversight
- NIMASA – maritime safety, permits, and guideline issuance.
- NESREA / environmental agencies – pollution control
- Federal Ministry of Labour – worker safety
- Port authorities – port access and local controls
- State governments – shoreline use and informal monitoring.
4.1.1.2. Permitting Requirements Exist on Paper but Lack Enforcement.
4.1.1.3. Existing Safety Laws Are Not Applied in Ship Recycling Contexts.
4.1.1.4. Limited Alignment with International Standards
| Criterion | Specific Element | Status in Current Regime |
| I. Scope of regulatory properties | Recognition of ship recycling as an official occupation/industrial activity in the national economy | No |
| Safety and health protection of personnel and facilities | Yes | |
| Environmental protection | Yes | |
| Employment standards and work environment | Yes | |
| Emergency planning | Yes | |
| Oil spill preparedness requirements | Limited | |
| Liability for accidents | Limited | |
| Management system requirements with clear responsibilities | Yes | |
| Division of authority | No (fragmented and overlapping) | |
| Regulatory approach (existence of any formal safety-regulatory model) | Yes, but largely prescriptive and generic rather than ship recycling–specific | |
| II. Features of integrative risk governance | Requirement for multiple actor-network involvement in risk framing | No |
| Incorporation of human and organisational factors into risk assessment | No | |
| Requirement for legitimisation of risk judgement (transparent risk-acceptability criteria) | No | |
| Requirement for safety culture and inclusiveness | No | |
| Inclusion of multiple actors in deliberation of risk issues | No | |
| III. Sustainability of regulatory functions | Assessment of regime sustainability over time (institutional capacity, stable funding, continuity) | No |
| IV. Regulatory adaptability to changed circumstances | Adaptability to emerging risks, technological change, industry evolution, and new standards | Limited |
| V. Continuous improvement | Mechanisms for continuous improvement (data collection, investigations, lessons-learned integration) | No |
| VI. Worker training and competency | Explicit requirements for worker training and competency in ship recycling | Limited in existing statutes and regulations |
4.1.2. On-the-Ground Safety Practices (Field Observations)
4.1.2.1. Nature of Facilities and Shoreline Use
4.1.2.2. Vessel Sourcing and Dismantling Processes
- Vessels are beached or brought alongside using tugs, with depth constraints around jetties managed informally.
- Initial cutting is performed in the water using oxy-acetylene torches.
- As the hull becomes lighter, winches gradually pull the vessel further ashore.
- Machinery and equipment are removed at various stages, driven by convenience and resale priorities.
- Large blocks fall into the water or onto the beach; smaller components are transported to secondary cutting zones on land.
4.1.2.3. Waste Handling and Hazardous Materials.
- Yard operators showed little or no awareness of hazardous materials such as asbestos, PCBs, and mercury.
- No designated storage areas for hazardous waste were observed.
- Waste piles at several sites (Figure 10) consisted of unsegregated scrap, contaminated residues, and evidence of open burning.
- Informal scavenging is widespread (Figure 11), with traders handling exposed cables, oily scrap, and pipes without protection.
- Cutting debris described by workers as “small rocks” or carbonised slag from oxy-acetylene cutting is routinely used to fill swampy land and stabilise yard floors (Figure 12).
4.1.2.4. Observed Unsafe Acts and Conditions
- Lack of PPE: workers cutting without gloves, helmets, hearing protection, or eye protection.
- Defective equipment: leaking gas hoses and visibly damaged cutting gear.
- Improper gas cylinder storage, including unsecured cylinders left in direct sunlight.
- Work under suspended loads, with workers standing or passing beneath lifted blocks.
- No effective fall protection for work at height; harnesses, where present, were often not properly latched.
- No oil-spill control; visible slicks and residues discharged into waterways.
- No accessible firefighting equipment near cutting zones.
4.1.2.5. Community and Environmental Exposure
- Children and adult scavengers present inside the dismantling zone (Figure 10).
- Fishermen reported declining fish stock, with nets torn by metal scrap drifting into waterways.
- Burning of oily waste was observed in two yards.
- Oil sheen, paint chips, and hull residues enter the surrounding ecosystem.
4.1.2.6. Productivity, Workforce, and Work Patterns
- Most yards process approximately 4–6 vessels per year.
- Tugboats may be dismantled within about 1-month, larger tankers in 4–5 months.
- A typical yard employs around 150 workers, many of whom are informal or casual labourers.
- Some facilities dismantle 2–3 vessels simultaneously to minimise waiting times.
- No evidence was found of formal training records, competency assessments, or routine safety drills.
- improvised, informal, and hazardous techniques;
- adaptive coping behaviour rather than structured safety controls;
- limited or no enforcement presence;
- no systemic learning, drills, or monitoring;
- no engineered containment or hazard segregation;
- high environmental and community exposure;
- untrained workers supervised by untrained foremen.
4.2. Stakeholder Perspectives on Risk Governance Challenges
4.2.1. Perceptions of the Regulatory Landscape
4.2.1.1. Fragmented Oversight and Lack of Clear Mandate
4.2.1.2. Permit System: Procedurally Heavy but Operationally Weak
4.2.2.1. Normalisation of Risk and Informal Adaptation
4.2.2.2. Awareness of Hazardous Materials: Low to Non-Existent
- insufficient in quality,
- inconsistently used,
- often purchased by workers themselves, and
- sometimes sold as scrap when damaged.
4.2.4.1. Productivity Pressures Drive Unsafe Practices
4.2.4.2. Informal Labour Market Effects
- Regulators asked for clearer mandates and more resources.
- Yard managers suggested tax relief or incentives to formalise operations.
- Workers requested training and stable employment.
- Experts highlighted the need for a “proper safety management system,” not just sporadic inspections.
5. Discussion
5.1. Interpreting the Findings Through Theoretical Lenses
5.1.1. Deviations from Renn’s Integrative Risk Governance Model
- Risk framing is narrow and dominated by yard managers and regulators, with no involvement of naval architects, classification societies, workers, communities, or environmental actors, deviating from the multi-actor inclusiveness central to integrative risk governance.
- Risk assessment is procedural rather than analytical. Firms treat it as a compliance formality. Critical engineering expertise (structural integrity, cutting sequence hazards, load-path risks, stability during beaching) is absent because naval architects and classification societies are not routinely part of the process.
- Risk evaluation lacks transparency or legitimacy. No national risk-acceptance criteria exist, and tolerability decisions are internal and subjective.
- Risk management and control are weak due to inconsistent inspections, under-resourced regulators, and absence of engineered containment; this confirms a breakdown in the monitoring/controlling function.
- Risk communication is minimal, with no reporting requirements for incidents or near-misses.
5.1.2. Rasmussen’s Socio-Technical Perspective and System Drift
- Policy level: No legal definition of ship recycling as an industry.
- Regulatory level: Fragmented mandates (NIMASA, NESREA, Labour), weak enforcement, dual role conflicts.
- Organisational level: Production pressure outweighs safety investments; informal labour predominates.
- Supervisory level: Minimal oversight; unsafe practices normalised.
- Worker level: Low training, informal improvisation, no hazard awareness.
5.1.3. Why Resilience Thinking Is Insufficient in This Context
- workers adapt to hazards,
- supervisors “make do,”
- yards adjust processes based on past incidents,
- regulators intervene mainly after something goes wrong.
5.2. A Robust Risk Governance Framework for Nigeria’s Ship Recycling Sector
5.2.1. Pillar 1 — Multi-Level Safety Oversight (Operational Safety Ecosystem)
- International: IMO, ILO, Basel Convention
- Government: Ministries of Transport, Environment, and Labour
- Regulators: NIMASA (safety), NESREA (environment), state authorities (shoreline and land use)
- Technical actors: Naval architects, marine engineers, classification societies (ABS, DNV, Lloyd’s Register, Bureau Veritas, RINA)
- Industry: Ship recycling operators and associations
- Supervisors: trained safety officers, foremen
- Workers: certified cutting, lifting, and hazardous-material teams
- Community: local leaders, fishermen’s associations
5.2.2. Pillar 2 — Integrative Risk Governance Process (Following Renn’s Model)
-
Inclusive risk framing
- ○
- mandatory involvement of technical experts (naval architects, class societies), worker representatives, and community stakeholders in hazard identification.
-
Interdisciplinary risk assessment
- ○
- structural and stability analyses by naval architects;
- ○
- verification of gas-freeing, hot-work, lifting plans, and cutting sequences by classification societies;
- ○
- integration of human factors and organisational risk assessment tools.
-
Transparent risk evaluation
- ○
- government-issued risk-acceptability criteria;
- ○
- publication of safety performance and inspection findings.
-
Robust risk management and control
- ○
- frequent inspections, mandatory safety audits, enforcement sanctions, and minimum technical standards (e.g., impermeable floors, cranes, waste-segregation zones).
-
Risk communication and learning.
- ○
- national incident and near-miss database;
- ○
- annual safety reports;
- ○
- regular safety dialogues between regulators, yards, and communities.
5.2.3. Pillar 3 — Enhanced Mitigation Strategies
- Enact a Ship Recycling Regulation or Act modelled on HKC.
- Establish a unified regulatory authority or inter-agency taskforce.
- Require licensing and safety certification of facilities.
- Mandatory Safety Management Systems (SMS) for ship recycling.
- Safety accountability at managerial level.
- Worker participation through safety committees.
- Gradual transition from beaching to safer methods (slipways, semi-dry docks).
- Investment in cranes, containment floors, and waste-management systems.
- Class-approved cutting and lifting plans.
- National curriculum for ship recycling safety training.
- Certification of cutters, riggers, rescue teams.
- Empower workers with legal right to refuse unsafe work.
5.2.4. From Diagnosis to Design: Gap-to-Framework Mapping and Implementation Phasing
5.3. Contributions to Theory
-
Empirical application of robustness theory in a developing-country context
- ○
- Few studies operationalise Hale’s and Renn’s principles in low-resource settings; this work fills that gap.
-
Demonstration of the limits of resilience in high-hazard, weak-institutional environments
- ○
- The Nigerian case provides evidence that resilience without robustness leads to chronic safety failures.
-
Integration of engineering actors into risk framing and governance
- ○
- We show why naval architects and classification societies must be embedded in the governance cycle. An aspect under-theorised in existing literature.
5.4. Contributions to Practice and Policy
- Formal recognition of ship recycling as an industry.
- Enactment of a national ship recycling regulation aligned with HKC.
- Creation of a national oversight body with clear mandates and stable funding.
- Independent inspections supported by classification societies.
- National reporting system for accidents and near-misses.
- Enforcement penalties for non-compliance and incentives for safer technologies.
- Adoption of SMS, structured training, and safer dismantling methods.
- Investments in infrastructure (cranes, containment, waste zones).
- Consultation, risk communication, and environmental protection measures.
5.5. Limitations and Future Research
- 4.
- The qualitative sample, while diverse, was small and may not fully capture informal worker perspectives.
- 5.
- Lack of reliable accident statistics limited quantitative benchmarking.
- 6.
- Regulatory documents may be incomplete or unpublished, making some interpretations tentative.
- Develop quantitative risk-acceptance criteria for Nigeria using expected-utility or risk-cost-benefit methods.
- Conduct comparative case studies with other African ship recycling nations (e.g., Ghana, Côte d’Ivoire).
- Evaluate implementation of the proposed framework longitudinally.
- Model the economic implications of transitioning from beaching to safer infrastructure.
6. Conclusion
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| Regulatory focus | Prescriptive regulation | System-based regulation | Performance-based regulation |
| Compliance basis | Detailed adherence to specified actions | Demonstration of effective management systems | Achievement of defined outcomes |
| Nature of rules | Technical, detailed requirements | Process-oriented standards | Goal- or results-oriented standards |
| Example sectors | US environmental regulation | Food safety, nuclear safety | EU air/water quality, energy efficiency |
| Criterion | Key Elements Assessed | Source(s) |
| Legislative and Administrative Framework |
|
Safety and health in shipbreaking: Guidelines for Asian countries and Turkey, International Labour Office, 2004 IMO GUIDELINES FOR SAFE AND ENVIRONMENTALLY SOUND SHIP RECYCLING. ANNEX 4 RESOLUTION MEPC.210(63), International Maritime Organization, 2012 |
| Integrative Risk Governance |
|
Risk Governance and Resilience: New Approaches to Cope with Uncertainty and Ambiguity, [36] |
| Sustainability of Regulatory Functions | Assessment of the sustainability of the regime's functionality over time | Advancing robust regulation: Reflections and lessons to be learned, [7] A conceptual framework for analysing adaptive capacity and multi-level learning processes in resource governance regimes, [37] |
| Regulatory Adaptability to Changed Circumstances | Assessment of how regulations are regularly reviewed to address:
|
Advancing robust regulation: Reflections and lessons to be learned, [7] |
| Continuous Improvement | Assessment of
|
Safety and health in shipbreaking: Guidelines for Asian countries and Turkey, International Labour Office, 2004 [25] IMO GUIDELINES FOR SAFE AND ENVIRONMENTALLY SOUND SHIP RECYCLING. ANNEX 4 RESOLUTION MEPC.210(63), International Maritime Organization, 2012 [20] Development of best practices for ship recycling processes [38] |
| Worker Training and Competency | Evaluation of worker training programs and verification of competency | IMO INTERNATIONAL CONVENTION FOR THE SAFE AND ENVIRONMENTALLY SOUND RECYCLING OF SHIPS. MEPC 58/23 [20] A study on evaluating the status of current occupational training in the ship recycling industry in Bangladesh, [39] |
| Instrument | Scope / Relevance | Limitations |
| Factories Act (2004) | General OHS requirements, lifting equipment rules | Not tailored to ship-breaking; weak enforcement |
| Labour Act (2004) | Employment conditions, worker protection | Limited application to informal labour force |
| Environmental Protection Act (1994) | Pollution control, waste management | No ship recycling-specific provisions |
| NIMASA Act (2007) | Maritime safety, regulatory powers | No explicit mandate for ship recycling coordination |
| NIMASA Ship Scrapping Facility Permit Guidelines | Permit requirements for recycling facilities | Weak implementation; no performance-based audits |
| Employees Compensation Act (2010) | Compensation for work-related injuries | Limited applicability in informal settings |
| Lifting and Allied Work Equipment (Safety) Regulations (2018) | Equipment inspection and safe use | Not enforced at ship breaking sites |
| Robustness dimension (Table 4) | Principal gap identified | Framework response | Pillar |
| I. Scope of regulatory properties | No legal recognition of ship recycling; fragmented division of authority; permits administrative rather than performance-based | Ship Recycling Act aligned with the HKC; unified regulatory authority or inter-agency taskforce; licensing and safety certification of facilities | 1, 3 |
| II. Integrative risk governance | No multi-actor risk framing, no human and organisational factors in assessment, no transparent risk-acceptance criteria, no stakeholder deliberation | Institutionalised five-step governance cycle: mandatory inclusive framing; interdisciplinary assessment involving naval architects and classification societies; government-issued national RAC; publication of inspection findings | 2 |
| III. Sustainability of regulatory functions | No assurance of institutional capacity, stable funding, or continuity | Statutorily mandated and ring-fenced resourcing of the oversight body; professionalised, adequately staffed inspectorates | 1, 3 |
| IV. Regulatory adaptability | Only limited capacity to absorb emerging risks, new technologies, and evolving international standards | Mandatory periodic regulatory review; structured alignment with HKC, ILO, and EU SRR benchmarks | 2, 3 |
| V. Continuous improvement | No mechanisms for incident data collection, investigation, or institutional learning | National incident and near-miss database; annual safety reports; regular safety dialogues between regulators, yards, and communities | 2 |
| VI. Worker training and competency | Training requirements only weakly present; no competency assessment or certification | National ship recycling safety curriculum; certification of cutters, riggers, and rescue teams; legal right to refuse unsafe work | 3 |
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