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NetMap Project The - www.netmap.ie
The
NetMap
Project
Research
Report
Exploring Opportunities to
Create Value from Waste
Fishing Nets in Ireland

www.netmap.ie
NetMap Project The - www.netmap.ie
Table of Contents
Executive Summary

Introduction

Section One - The Challenge of Marine Plastics & Fishing Gear

      1.       Overview
      1.1      Fishing Gear
      1.2      The Impacts of Lost & Discarded Fishing Gear
      1.3      Marine Plastic Pollution in Ireland
      1.4      Conclusion

      2.       Relevant International & National Policy
      2.1      International Policy
      2.2      National Policy
      2.3      Conclusion

      3.       Management of Fishing Nets at Irish Ports
      3.1      Introduction
      3.2      Cork Port Findings
      3.3      National Port Findings
      3.4      Aquaculture
      3.5      Conclusion

Section Two - Looking Towards Potential Solutions for Ireland

      4.       Social Enterprise
      4.1      Introduction
      4.2      The Role of Social Enterprise & the Environment
      4.3      European & National Policy supporting Social Enterprise
      4.4      Funding & Operational Supports
      4.5      Could a Social Enterprise help manage waste Fishing Nets in Ireland?
      4.6      Opportunities & Considerations in the establishment of a Social Enterprise.
      4.7      Conclusion

      5.       Concrete Trials
      5.1      Introduction
      5.2      Trial Methodology
      5.3      Trials
      5.4      Conclusion

Appendices

      1.       Relevant National Port Policy - Documents Reviewed
      2.       SFPA Port Stats 2015
      3.       Concrete Trial Specification
      4.       Concrete Trial One Record Sheet Results - Gannon Eco
      5.       Concrete Trial Two Record Sheet Results - Inland & Coastal

                                                                                     The Netmap Project   2
NetMap Project The - www.netmap.ie
Executive Summary
It is clear that marine litter and in particular plastic      Polyethylene, a lower value material, is more complex
pollution continues to ascend on the global agenda,           to recycle. There appears to be an absence of recycling
as the realities of the harmful effects of plastic debris     companies in Ireland that have a desire or are capable
and microplastic become apparent. Likewise, the               of reprocessing discarded fishing nets. Due to the volume
problem of lost and abandoned fishing gear is now             and weight of end of life nets, they are costly to transport
receiving attention on a global, European and                 to any recycling facilities in Europe that may be able to
national level, with policymakers, governmental               reprocess the material. Some ports are then faced with
and non-governmental organisation lobbying for                the accumulation of waste fishing nets on ports over
and implementing strategies to improve management             a period of time, eventually causing a health and safety
of fishing nets, increasing recyclability and in the          hazard and then needing to be removed by a waste
longer term protecting our environment.                       management company. However, BIM, in recent times,
                                                              have engaged with a number of ports to trial a recycling
The first section of this report introduces the Challenge     programme for Polyethylene nets which be expanded
of Marine Plastics and Fishing Gear, exploring the relevant   upon in the future.
International & National Policy governing the management
of end of life fishing nets and exploring the current         Section Two examines potential solutions for waste fishing
situation as regards management of waste fishing              nets in Ireland, centring around the potential for a Social
nets at Irish ports.                                          Enterprise to obtain value from the waste stream and
                                                              then more specifically at potential applications within
In a national context, it appears evident that the specific   the concrete industry. The number of enterprises and
management of waste fishing nets has not been provided        organisations tackling waste fishing gear globally and
for in legislation or policy within the Irish statues nor     their proven success, demonstrates the possibilities for
directly expressed in any of the port waste management        such a venture in Ireland. It is clear that there are multiple
plans or in the bye-laws reviewed as part of this research.   opportunities for Social Enterprise in collecting,
However reference has been made in the Fishing                re-processing or reusing net materials for new products
Harbours Centres business strategy that the need for          on a small scale local level. However the challenges
fishing net storage, repair and waste management should       in the management of fishing nets as a waste material
be addressed. Ireland’s National Seafood Agency,              should be also be acknowledged by groups or
Bord Iascaigh Mhara (BIM) have been working with              organisations interested in embarking on a Social
a number of ports across the country to improve               Enterprise in this area.
management of waste fishing gear, through various
schemes and projects, including the successful "Fishing       Trials undertaken with the construction sector as regards
for Litter” initiative. Recent developments at EU level,      the potential applications for waste fishing net materials
including the potentially transformative Plastics Strategy    in concrete suggest comparative benefits on mortar
2018, coupled with specific measures on Port Reception        strength when using waste fishnet fibres. However, it is
Facilities, Gear Marking and Producer Responsibility          evident, that if a market was to emerge for waste fishing
Schemes are set to bring considerable positive change         net fibres in the construction industry, investment would
in how waste fishing nets are managed, potentially            be required to establish facilities suitable for re-processing
streamlining routes for re-processing, recycling and          fishing net materials in Ireland.
reuse, allowing a wider 2nd life market for these
valuable materials.                                           This report will serve as a useful starting point for both
                                                              social and commercial enterprises wishing to further
Discussions with management at Irish ports revealed that      explore the potential for the reuse, the recycling and
the primary types of fishing nets used in Ireland include     the reprocessing of waste fishing nets in an Irish context.
polyethylene and nylon netting. The latter does not
appear to be a problem when they come to end of life
due to robust recycling schemes in place coupled with
demand in Europe for this higher value nylon material.

                                                                                         The Netmap Project              3
NetMap Project The - www.netmap.ie
Introduction
Current research estimates approximately 8 million              treatment, 3D printing and the construction sector, as well
tonnes of plastic enter our oceans each year, with the          as providing expert guidance to SME’s on sustainable
Ellen McArthur Foundation citing there is likely to be more     business. Through the Circular Ocean project, Macroom E
plastic than fish in our seas by 2050. The issue of marine      gained substantial knowledge on the scale of the problem
plastics is of ever increasing international concern and        and the intricacies surrounding management of end of life
is particularly pertinent to Ireland. As an island nation we    fishing gear on an international level. It became apparent
have a marine area that is ten times the size of its land       there was an opportunity to explore this further in an Irish
area above the sea, with the majority of our population         context, specifically:
living within 50km of the ocean. The issues surrounding
marine plastic pollution continue to rise to the top of         •       How this waste stream is currently managed in
the environmental agenda both on the international and                  Irish ports, with a focus on the Cork region
national stage, most recently with the launch of the first      •       Would it be possible to gather data on the
ever EU Plastics Strategy in January 2018.                              volumes of waste fishing gear materials in Ireland
                                                                •       Could we identify potential sustainable
Background to The NetMap Project                                        applications for waste net materials, so that
The idea for this project emerged from the SMILE                        they can benefit coastal communities in which
Resource Exchange programme. A FREE service for                         they emerge, with a particular focus on the
businesses, SMILE encourages the exchanging of                          applications of waste fishing net fibres in the
resources between its members in order to save money,                   construction industry
reduce waste going to landfill and to develop new               •       Examine the potential of a Social Enterprise
business opportunities. Potential synergies are identified              model to provide a community based solution,
through an online platform www.smileexchange.ie,                        which could potentially reap employment and
through the programme hotline or through facilitated                    economic advantages to rural communities,
technical assistance. SMILE is project managed by                       while addressing an environmental challenge
Macroom E (a wholly owned subsidiary of Cork County
Council) and is funded through a partnership between the        Following a successful application to the EPA Green
Environmental Protection Agency, Cork County & Council,         Enterprise Funding Call in 2016, research began on
the Southern Waste region and Local Enterprise Offices.         the “NetMap” project in January 2017.
Through discussions with SMILE members, the significant
problem posed by waste fishing nets in Ireland
and internationally was highlighted as an area that
warranted further research.

Macroom E subsequently initiated an application to the
ERDF Interreg VB Northern Periphery and Arctic (NPA)
Programme for the Circular Ocean project, in conjunction
with University partners at the Environmental Research
Institute at North Highland College (Scotland), The Centre
for Sustainable Design (UK), The Arctic Technology Centre
(Greenland) and The Norwegian University of Science &           The Seafood Industry in Ireland
Technology (Norway). The focus of the three year (2015-         According to “Harnessing Our Ocean Wealth - An
2018) Circular Ocean project is to seek opportunities for       Integrated Marine Plan for Ireland” (July 2012) “Taking our
recovery and reuse of waste Fishing Nets & Rope (FNR’s),        seabed area into account, Ireland is one of the largest EU
with a view to benefiting local economies.                      states; with sovereign or exclusive rights over one of the
                                                                largest sea to land ratios (over 10:1) of any EU State. Our
Macroom E is the sole Irish partner and has responsibility      ocean is a national asset, supporting a diverse economy,
for the Communications activities surrounding the project.      with vast potential to tap into the global marine market for
Circular Ocean’s communications strategy centres around         seafood, tourism, energy and new applications for health,
creating awareness of the detrimental environmental             medicine and technology.
impacts of end of life fishing nets and rope, while inspiring
communities to divert waste fishing gear materials from         The Marine Institute explain that “the waters around
our oceans and landfills for reuse, recycling and new           Ireland contain some of the most productive fishing
product development. Circular Ocean will produce                grounds and biologically sensitive areas in the EU.
progressive new data on the environmental impact of lost        The main fish species caught are mackerel, horse
and abandoned FNR’s, lifecycle analysis and a barrier           mackerel, boarfish, blue whiting, herring, cod, whiting,
assessment on mechanisms for better management.                 haddock, saithe, hake, megrim, anglerfish, plaice,
Partners are also investigating the potential applications      sole and nephrops.”
of end of life fishing nets in areas such as wastewater

                                                                                          The Netmap Project               4
NetMap Project The - www.netmap.ie
According to the 2016 BIM Business of Seafood Report:

•            Ireland’s Seafood Industry contributes
             €1 billion in GDP to the overall economy and
             represents 70% of the overall Blue Economy,                              •           6 Fishery Harbour Centres
             valued at €1.4 billion                                                   •           Managed by the Department for Agriculture,
•            The industry employs an estimated 8,500                                              Fisheries & the Marine
             people in full and part-time roles, rising to                            •           Strong network of collaboration
             11,000 when ancillary employment is included
•            In 2015, sea fisheries landings (both Irish and
             Foreign) into Ireland were valued at €344 million,
             while aquaculture production was valued at
             €148 million
                                                                                      •           50 Ports under management across 13
Ireland’s six major Fishery Harbour Centres (FHCs) are                                            Local Authorities
run by the Department of Agriculture, Food & the Marine.                              •           Follow individual Local Authority
From our research, it appears there is an established                                             Waste Regulations
culture of networking and knowledge exchange amongst
harbourmasters in the FHC’s, as well as seemingly more
robust systems and structures for waste management.

There are an additional 40 secondary ports in the
Republic of Ireland, run by either local authorities or
a semi-state port companies. The number of smaller                                    •           12 Commercial semi-state companies based in
harbours used by the inshore fleet is probably in excess                                          ports with a commercial freight aspect
of 100, however, many of these are grouped together for                               •           Some also manage smaller neighbouring
statistical purposes (e.g. in Cork, Skibbereen is an official                                     fishing ports
landing port that encompasses a number of smaller piers).                             •           Independent structure and waste
Most of these smaller harbours are only used over the                                             management strategy
summer months by seasonal, usually pot fisheries. Most
of the larger vessels (in excess of 15m length) operate
from the Fishery Harbour Centres. However, some of the
non-fishery harbour ports account for increasingly larger
volumes of fish landings. The 2016 annual report by the
Licensing Authority for Sea Fishing Boats puts the number
of Irish Fishing vessels at 1,991 across all sectors.
The first section of this report introduces The Challenge
of Marine Plastics and Fishing Gear, exploring the relevant
International & National Policy governing the management
of end of life fishing nets and exploring the current
situation as regards management of waste fishing nets at
Irish ports. Section Two examines potential solutions for
waste fishing nets in Ireland, centring around the potential
for a Social Enterprise to obtain value from the waste
stream and then more specifically at potential applications
within the concrete industry.

References

•            Harnessing Our Ocean Wealth – An Integrated Marine Plan for Ireland (July 2012) https://www.ouroceanwealth.ie/about-plan
•            The Marine Institute – Areas of Activity – Fisheries & Ecosystems https://www.marine.ie/Home/site-area/areas-activity/fisheries-ecosystems/
             fisheries-ecosystems
•            “The Business of Seafood 2016 – A Snapshot of Ireland’s Seafood Sector” – BIM (2016) http://www.bim.ie/media/bim/content/pub lications/corporate-other-
             publications/BIM-the-business-of-seafood-2016.pdf
•            Licensing Authority for Sea Fishing Boats Annual Report (2016) https://www.agriculture.gov.ie/media/migration/seafood/seafisheries/fishboatlicencing/
             AnnualReportEnglish190717.pdf

                                                                                                                          The Netmap Project                           5
NetMap Project The - www.netmap.ie
1
Section

The Challenge of Marine
Plastics & Fishing Gear
NetMap Project The - www.netmap.ie
1. Overview

1.1		 Fishing Gear
1.2		 The Impacts of Lost & Discarded Fishing Gear
1.3		 Marine Plastic Pollution in Ireland
NetMap Project The - www.netmap.ie
1.        Overview
Marine pollution is a major concern on a global scale,        recycling. Due to it’s characteristically expansive size
with reports of millions of tonnes of litter ending up in     and weight, fishing nets also prove to be a difficult
our oceans worldwide. Jambek et. Al estimate that more        material to store and re-process mechanically.
than 150 million tonnes of plastics have accumulated          Fishing gear proves a particular threat to our marine
in the world’s oceans, while 4.6-12.7 million tonnes are      environments when lost or abandoned at sea, commonly
added every year. This scourge of plastic pollution on our    referred to as “Ghost Gear”. Ghost Gear refers to any
coastlines is causing significant harm to our environment,    fishing equipment or fishing-related litter that has been
our health and our economies, causing ever increasing         abandoned, lost or otherwise discarded; also referred
concern and demand for action.                                to as ‘derelict fishing gear’ and/or ‘fishing litter’.

                                                              According to a 2018 report by World Animation Protection
                                                              “Ghost gears capacity to entangle, injure and kill hundreds
                                                              of species of marine animals on a large scale makes
                                                              it a serious concern requiring urgent action. Globally,
                                                              ghost gear hotspots differ in the types of gear they
                                                              contain, the original target species to be fished and the
                                                              currents that carry them, but is estimated to represent
                                                              10% of all marine debris.”

                                                                  Case Study: Global Ghost Gear Initiative
                                                                  A multi-stakeholder alliance committed to driving
                                                                  solutions to the problem of lost and abandoned
                                                                  fishing gear worldwide, the Global Ghost Gear
                                                                  Initiative (GGGI) aims to improve the health of marine
                                                                  ecosystems, protect marine animals from harm,
                                                                  and safeguard human health and livelihoods.
                                                                  Founded by World Animal Protection on the best
                                                                  available science and technology, the GGGI is the
                                                                  first initiative dedicated to tackling the problem of
                                                                  ghost fishing gear at a global scale. The GGGI’s
                                                                  strength lies in the diversity of its participants
Source: www.circularocean.eu                                      including the fishing industry, the private sector,
                                                                  academia, governments, intergovernmental and
As policymakers work to introduce legislation around              non-governmental organisations. Every participant
the manufacture and use of certain single use plastic             has a critical role to play to mitigate ghost gear
products, the focus has also been placed on the fishing           locally, regionally and globally. The Global Ghost
gear, primarily produced from plastic materials but as of         Gear Initiative have published a series of guidance
                                                                  documents including a “Best Practice Framework for
yet, not widely recycled. Fishing gear can be particularly
                                                                  Fishing Gear Management” and “Approaches to the
detrimental to our marine environmental when lost or              Collection and Recycling of End-of-Life Fishing Gear”
abandoned at sea, left to continue to entangle and                designed to assist those wishing to participate in
poison marine life for hundreds of years.                         ghost gear related projects.

In order to provide a basis for our research, this section        Source: www.ghostgear.org

will provide an introduction to some of the problems
associated with the prevalence of waste fishing gear.
                                                              A 2016 Report from UNEP (United Nations Environment
                                                              Programme) reveals that “Due to the continued expansion
                                                              of the Aquaculture industry, the effects of the associated
1.1 Fishing Gear                                              gear must also be considered in the context of marine
                                                              plastic pollution. Aquaculture structures are either
Due to its many advantages over more natural fibres,          suspended from the sea surface or placed in intertidal
plastic has been the material of choice for most fishing      and shallow subtidal zones directly on the bottom. The
gear within the commercial fisheries sector over the past     majority of activities use lines, cages or nets suspended
number of decades. Undeniably resilient, plastic fishing      from buoyant structures, often consisting of plastics (air-
nets may then be equipped with ancillary gear such as         filled buoys), and EPS (expanded polystyrene). Aquaculture
lead weights, plastic buoys or combination rope, resulting    structures are lost due to wear and tear of anchor ropes,
in a multi-material item which can be difficult to separate   because of storms, and due to accidents/conflicts with
into individual materials/polymers for the purposes of        other maritime users. Severe weather conditions can cause
                                                              widespread damage to aquaculture structures, at times
                                                              generating large quantities of marine debris.”

                                                                                              The Netmap Project           8
NetMap Project The - www.netmap.ie
1.2 The Impacts of Lost
& Discarded Fishing Gear
Environment
According to research by Wilcox et al., “the entanglement
of marine animals in marine debris, especially derelict nets
and other abandoned fishing gear is widely recognised
as a major source of mortality. The findings of a report on
the impacts of pollution on marine wildlife, showed the                                             8 MILLION TONNES
single greatest impact from any item was predicted to
                                                                                                    OF PLASTICS
                                                                                                    GO INTO THE SEA EACH YEAR,
be entanglement of birds by fishing line and rope, with                                             AMONG WHICH A LARGE
                                                                                                    AMOUNT OF FISHING GEAR
expected lethal impacts on 25-50% of animals. Given
that fishing gear is intentionally designed to ensnare and                         IN FACT                                             HOW DOES
capture fishing, it is expected that loss of intentionally                                                                             THAT HAPPEN?
discarded gear would continue to ensnare both fish and                             46%
                                                                                   OF THE GREAT
                                                                                                                                       • ABRASION (broken plastics
                                                                                                                                        bits get lost in the water)

other marine taxa, with considerable risk of death by                              GARBAGE PATCH
                                                                                   IS FISHING NETS
                                                                                                                                       • VOLUNTARY ABANDONMENT
                                                                                                                                       • ACCIDENTS
exhaustion or suffocation.” The report goes on to state
“when compared with other consumer items discarded                                 20%        OF EU FISHING GEAR
                                                                                              IS LOST OR DISCARDED
                                                                                   AT SEA, WORLDWIDE THAT’S
in the ocean, fishing gear clearly poses the greatest                              640 000 TONNES
ecological threat.”
                                                                                   EACH YEAR

                                                                                   27   % OF   ALL
                                                                                            BEACH LITTER
                                                                                   COMES FROM FISHING GEAR
                                                                                                                                       ONLY
                                                                                                                                       1.5%
                                                                                                                                                        OF WORN OUT
                                                                                                                                                        FISHING GEAR
                                                                                                                                                        GET RECYCLED
Research undertaken by The Circular Ocean Project
state that “The desirable properties of plastics (low cost,
light weight, durable) are those that contribute to it being
problematic in the marine environment. Owing to its low                                                THE IMPACT
density, a large proportion of plastic floats, increasing the         THE                                                  ANIMAL
number of species that may interact with it, with potentially         ENVIRONMENT                                          WELFARE
                                                                      SEAFLOORS ARE POLLUTED
negative consequences. Furthermore, it does not                       AND BIODIVERSITY DECREASES
                                                                                                                           GHOST FISHING
                                                                                                                           Marine life gets
                                                                                                                                                           CHEMICAL
                                                                                                                                                           CONTAMINATION
biodegrade, but instead breaks up into smaller fragments              GLOBAL COST
                                                                      OF MARINE LITTER
                                                                                                                           trapped in lost
                                                                                                                           fishing gear
                                                                                                                                                           has disruptive effects
                                                                                                                                                           on species
that remain in the environment.”                                      TO MARINE ECOSYSTEMS
                                                                      €10.7 billion
There are two main ways that plastic pollution                        HUMAN
effects marine species:                                               HEALTH
                                                                      Marine litter is a vehicle
                                                                      for diseases and bacteria

•         Entanglement – species become entangled in                  TOXICITY IN THE
                                                                      FOOD CHAIN
          lost for discarded fishing nets or other single
          use plastics. Seabirds may also collect plastic             THE
                                                                      ECONOMY
          as nesting building materials, often causing                LESS                        € 630                    1 TO 5%      € 30
          entanglement of chicks and adults, resulting                TOURISM
                                                                      due to dirty
                                                                                                  MILLION
                                                                                                  cost for
                                                                                                                           TOTAL        MILLION
                                                                                                                           REVENUE LOSS cost for the navigation
          in injury or death.                                         beaches and
                                                                      waters
                                                                                                  cleaning up all
                                                                                                  EU coasts
                                                                                                                           for the fisheries    sector (damaged
                                                                                                                           & aquaculture sector equipment, accidents, etc.)

•         Ingestion – individuals mistakenly consume
          plastic debris, with potentially lethal side effects.                                         EU ACTION
Recent estimates by Gall & Thompson (2015) indicate that               EXISTING ACTION                                      EXTENDED
                                                                       The EU has already started
                                                                                                                            PRODUCER
over 690 marine species globally have been affected by                 addressing the problem
                                                                                                                            RESPONSIBILITY
marine debris, including cetaceans, pinnipeds, seabirds,               target to
                                                                       REDUCE
                                                                                                                            By making producers responsible for managing
                                                                                                                            plastic litter from fishing gear, we will:
turtles, fish and crustaceans, with the majority                       MARINE
                                                                       LITTER BY                  UPDATED                   INTERNALISE
                                                                                                  RULES ON PORT
involving plastic.                                                     30%                        RECEPTION
                                                                                                                            THE ENVIRONMENTAL
                                                                                                                            COST OF MARINE LITTER
                                                                                                  FACILITIES
                                                                                                                            ATTRACT
                                                                                    € 53 MILLION                            INNOVATION FOR
                                                                                    FUNDING                                 MORE SUSTAINABLE
                                                                                    through the European                    MATERIALS
                                                                                    Maritime and Fisheries Fund
                                                                                    (2014-2020)                             STIMULATE
                                                                                                                            THE RECYCLING
                                                                       MANDATORY                  MANDATORY                 MARKET
                                                                       MARKING                    RETRIEVAL
                                                                       OF FISHING                 OR REPORTING              HELP OUR
                                                                       GEAR                       OF LOST                   FISHERMEN
                                                                                                  FISHING GEAR
                                                                                                                            CHERISH THE
                                                                                                                            RESOURCES OF
                                                                                                                            OUR OCEAN

                                                                                                                    maritime affairs
                                                                                                                    & fisheries

Source: RSPB Cymru            Source: Claire Fackler, NOAA        Source: https://ec.europa.eu/fisheries/new-proposal-will-tackle-
                              National Marine Sanctuaries         marine-litter-and-%E2%80%9Cghost-fishing%E2%80%9D_en

                                                                                                                               The Netmap Project                                   9
NetMap Project The - www.netmap.ie
Economy
In addition to the environmental impacts, lost or
abandoned fishing gear can have a significant negative
impact on the fishing industry. Continued “ghost fishing”
continually causes mortality of target species, ultimately
reducing the fishing stocks available to fisherman.
Lost and abandoned gear on or beneath the surface
of the water often become entangled in engines or
propellers, with fisherman incurring substantial repair
costs and loss of fishing time. UNEP estimate “The total
cost of marine litter to the EU fishing fleet has been
estimated to be nearly €61.7 million (Annex VII; Mouat
et al. 2010, Arcadis 2014).”

Tourism continues to play a vital role in Ireland’s
economy, with figures from the Irish Tourism Industry
Confederation showing the industry was worth an
estimated €8.7 billion in 2017. With Failte Ireland’s 2016
Tourism Review revealing that”overseas tourists listing
beautiful scenery and natural unspoilt environment as the
leading attractions to visit Ireland”, it is imperative that
our coastlines and marine environments are protected
against plastic pollution. Stockpiles of discarded fishing
nets at fishing ports can blemish picturesque coastlines,
diminishing the potential economic gain of tourism in
our coastal towns and villages. With recent international
publicity surrounding the level of microplastic in seafood
globally, Ireland maintains a reputation for premium quality   A 2017 report on Seabirds & Marine Plastic Debris in
seafood, which is an added attraction to our shores for        Ireland undertaken under the Circular Ocean project
culinary enthusiasts.                                          reported that “The presence of plastics, particularly
                                                               micro-plastic is widespread in the North-eastern Atlantic
1.3 Marine Plastic                                             with a mean of 2.46 particles m-3 There is no baseline
                                                               data for the levels of marine plastic in the seas around
Pollution in Ireland                                           Ireland, however recent monitoring in the Celtic Sea
                                                               revealed that 57% of trawl samples contained litter, with
In the 2017 Coastwatch Survey, the most widely                 84% comprising of plastic. Between 2012 and 2016, 93%
distributed litter item after plastic bottles was rope/        of 14 beached fulmars collected in Ireland were found
string, reported from 72% survey sites, while fishing and      to contain ingested plastic, all exceeding OSPAR’s 0.1g
aquaculture waste was recorded in 42.8 % of survey units.      EcoQO Level (Ecological Quality Objectives indicator).
When this figure was broken down, nets were seen in 148        It was noted that 69 seabird species were identified as
survey sites, aquaculture and angling gear in 67 and traps     commonly occurring breeding species or migrants in
in 58. Results were obtained from 538 shore sections or        Ireland, of these 17 species had been examined, with
‘survey units’ across the Republic of Ireland and checked      13 showing evidence of plastic ingestion. A further four
by Coastwatch volunteers at low water.                         species that had been studied showed no evidence of
                                                               plastic ingestion. For species where multiple samples
                                                               were available, the highest prevalence of plastic ingestion
                                                               occurred in the Northern Fulmar, consistent with other
                                                               studies which highlight that as surface feeders they are
                                                               highly susceptible to ingesting plastic fragments.”

                                                                                        The Netmap Project              10
Source: www.circularocean.eu

A 2018 study led by the National University of Ireland in
                                                               1.4 Conclusion
Galway to quantify microplastic ingestion by mesopelagic       While awareness of the issues surrounding marine plastics
(part of the pelagic zone that extends from a depth of         has grown, so too has the scale of the problem, due to
200 to 1000 meters below the ocean surface) fish in the        continued economic growth, particularly as the global
Northwest Atlantic, found that 73% of all fish contained       demand for seafood continues to escalate. As many
plastics in their gut contents. Overall, the study found a     organisations, groups and individuals continue working
much higher occurrence of microplastic fragments, mainly       to explore systems to better manage end of life fishing
polyethylene fibres, in the gut contents of mesopelagic        gear, it is essential to unearth the materials potential
fish than previously reported. Stomach fullness, species       value as a resource for new products.
and the depth at which fish were caught at, were found
to have no effect on the amount of micro-plastics found
in the gut contents.

The international Ghost Fishing foundation in
collaboration with Ghost Fishing UK announced their
first Irish project in early 2018. The partnership with
Whale Watch West Cork and South West Technical Diving
will retrieve abandoned or lost fishing nets, fishing gear
and other marine debris from local wrecks and reefs,
while creating awareness of the problem by sharing
photos and films of the clean-up project. Subject to a
successful funding campaign, Phase One of the ghost
gear removal project was scheduled to take place in May
2018, whereby two divers will perform a reconnaissance
mission to identify specific target areas and pinpoint ghost
gear in preparation of the main team who will
start removing the gear later in the summer.

                                                                                       The Netmap Project            11
References
•          “Plastic Waste Inputs from Land into the Ocean” - Jenna R. Jambeck et al (2015) http://science.sciencemag.org/content/347/6223/768
•          “Ghost Beneath the Waves – Ghost gears catastrophic impact on our oceans and the urgent action needed from industry” - World Animal Protection (2018)
           https://www.worldanimalprotection.org.uk/campaigns/animals-wild/sea-change/ghosts-beneath-waves
•          Global Ghost Gear Initiative https://www.worldanimalprotection.org/our-work/animals-wild/sea-change/our-work/gggi
•          “Marine plastic debris and micro-plastics – Global lessons and research to inspire action and guide policy change” – UNEP (United Nations Environment
           Programme), Nairobi (2016) https://europa.eu/capacity4dev/unep/document/marine-plastic-debris-and-microplastics-global-lessons-and-research-inspire-action-
           and-guid
•          “Using expert elicitation to estimate the impacts of plastic pollution on marine wildlife” - Wilcox et Al (2015) https://www.sciencedirect.com/science/article/pii/
           S0308597X15002985
•          “Seabirds & Marine Plastic Debris in Ireland: A synthesis and recommendations for monitoring” – N O’Hanlon, NA. James, E. Masden & AL. Bond (2017)
           http://www.circularocean.eu/research/
•          “The Impact of Marine Debris on Marine Life” - Gall & Thompson 2015 https://www.sciencedirect.com/science/article/pii/S0025326X14008571
•          Irish Tourism Industry Confederation Year End Review (2017) http://www.itic.ie/YE17/index.html
•          Failte Ireland Tourism Facts 2016 http://www.failteireland.ie/FailteIreland/media/WebsiteStructure/Documents/3_Research_Insights/2_Regional_
           SurveysReports/Tourism-Facts-2016-Revised-March-2018.pdf?ext=.pdf
•          Coastwatch Survey Results (2017) http://coastwatch.org/europe/wp-content/uploads/2017/12/Summary-results-2017-Coastwatch-Final.pdf
•          “Frequency of Microplastics in Mesopelagic Fishes from the Northwest Atlantic” – Wieczorek, Alina M.; Morrison, Liam; Croot, Peter L.; Allcock,
           A. Louise; MacLoughlin, Eoin; Savard, Olivier; Brownlow, Hannah; Doyle, Thomas K. (2018) https://www.frontiersin.org/articles/10.3389/fmars.2018.00039/full

                                                                                                                              The Netmap Project                           12
2. Relevant International
& National Policy

2.1		 International Policy
2.2		 National Policy
2.1 International Policy
The following section outlines some of the international     The effectiveness of ships to comply with the discharge
legislation that may directly or indirectly regulate         requirements of MARPOL depends largely upon
management of end of life Fishing Nets, Ropes &              the availability of adequate port reception facilities,
Components (FNRC’s). In some cases, the policy is            especially within special areas. Hence, the Annex
categorised under the subject of marine pollution            also obliges Governments to ensure the provision of
or ocean plastics, but ultimately encompasses FNRC           adequate reception facilities at ports and terminals for
materials, which are predominantly plastic based.            the reception of garbage without causing undue delay to
                                                             ships, and according to the needs of the ships using them.
UN Sustainable Development Goals                             However, according to MARPOL, vessels smaller than 100
Launched in 2015, the UN’s 17 Sustainable Development        gross tons and carrying fewer than 15 persons are exempt
Goals (SDG’s) were designed to shape the global              from a number of regulations. This exemption means that
agenda on sustainable development until 2030.                a large proportion of fishing boats are exempt from many
Goal 14 “Life Below Water” is particularly pertinent to      of MARPOL’s stringent waste handling regulations.
management of end of life gear and was implemented
“to conserve and sustainably use the oceans, seas and        FAO Voluntary Guidelines
marine resources for sustainable development.” SDG           on Marking Fishing Gear
14.1 requires a significant reduction of marine debris by    In February 2018, the Food & Agricultural Organisation
2025, citing “Careful management of this essential global    (FAO) of the United Nations announced a draft set of
resource is a key feature of a sustainable future.”          Voluntary Guidelines on Marking Fishing Gear.
                                                             The guidelines will “help countries to develop effective
While SDG 12 aims to “Ensure sustainable consumption         systems for marking fishing gear so that it can be traced
and production patterns”, stating that by 2030 overall       back to its original owner. Doing so will support efforts
waste generation must be significantly reduced through       to reduce marine debris and its harmful impacts on the
prevention, reduction, recycling and reuse.                  marine environment, fish stocks, and safe navigation.
                                                             It will also allow local authorities to monitor how
                                                             fishing gear is being used in their waters and who is
                                                             using it, which makes them an efficient tool in the fight
                                                             against illegal, unreported and unregulated (IUU) fishing.”
                                                             Considering the worldwide scale of the problem of
                                                             lost and abandoned fishing gear in our oceans, “the
                                                             Guidelines are global in scope, but countries recognize
                                                             that making them work for small-scale fisheries in
                                                             developing countries will require additional support
                                                             to meet the new standards.” It is expected that the
                                                             guidelines will receive final endorsement by FAO’s
                                                             Committee on Fisheries in July 2018.
Source: www.un.org
                                                             UNEP (UN Environment)
MARPOL 73/78                                                 Regional Sea Programme
The International Maritime Organization (IMO) developed      The objective of the UNEP Regional Seas Programme
the MARPOL 73/78 Annex V as a major international            is “to address the accelerating degradation of the
instrument that addresses ocean-based litter pollution       world’s oceans and coastal areas through a “shared
from ships. Overall, this instrument bans discharge of all   seas” approach, by engaging neighbouring countries
garbage from ships at sea with the exception of only a few   in comprehensive and specific actions to protect their
defined circumstances. A recently revised Annex V sets       common marine environment.” More than 143 countries
a framework for managing garbage generated by ships.         have joined 18 Regional Seas Conventions and Action
Ships >100 GT or ships certified to carry >15 passengers     Plans for the sustainable management and use of the
are required to provide a Garbage Record Book (GRB),         marine and coastal environment. In most cases,
which is meant to record all discharge of garbage made       the Action Plan “is underpinned by a strong legal
at both sea and reception facility. MARPOL Annex V also      framework in the form of a regional Convention and
requires vessels to log the loss of any fishing gear by      associated Protocols on specific problems.” Ireland
recording where the gear was lost, the characteristics       is a contracted party of the North East Atlantic
of the lost items and which precautions were taken to        programme, under the OSPAR Commission.
prevent the loss.

                                                                                       The Netmap Project              14
OSPAR Convention                                                 for Prevention of Pollution from Ships (MARPOL 73/78)
OSPAR is the mechanism by which 15 Governments                   and associated regulations. In addition, the application of
(including Ireland) & the EU cooperate to protect the            the Code of Conduct for Responsible Fisheries, support of
marine environment of the North-East Atlantic.                   the Responsible Irish Fish initiative, and implementation of
The objective of OSPAR objective in respect of marine            the Fishing for Litter scheme, are measures engaging the
pollution is “to substantially reduce marine litter in the       fishing industry in tackling marine litter.”
OSPAR maritime area to levels where properties and
quantities do not cause harm to the marine environment”          EC Directive on Port Reception Facilities
by 2020. In order to achieve this, the North East                for the Delivery of Waste from Ships
Atlantic Environment Strategy also commits to “develop           Directive 2000/59/EC on port reception facilities for ship
appropriate programmes and measures to reduce                    generated waste and cargo residues aligns EU law with
amounts of litter in the marine environment and to               the international obligations provided in the MARPOL
stop litter entering the marine environment, both                Convention. The Directive’s main aim is “to reduce the
from sea-based and land-based sources”.                          discharges of ship-generated waste and cargo residues
                                                                 into the sea, thereby enhancing the protection of the
To fulfil this objective OSPAR agreed a Regional Action          marine environment. As such, the Directive is a key
Plan for Marine Litter for the period 2014-2021. The plan        instrument for achieving a Greener Maritime Transport,
contains “55 collective and national actions which aim to        as set out in the Commission’s Communication ‘Strategic
address both land based and sea based sources, as well           goals and recommendations for the EU’s maritime
as education and outreach and removal actions. The key           transport policy until 2018’, which includes among its
action areas relating to waste fishing gear include Port         recommendations a long term objective of ‘zero-waste,
Reception Facilities, waste from fishing industry, fines for     zero-emissions’. The Directive is also the main EU
littering at sea, the Fishing for Litter initiative, abandoned   legal instrument for reducing marine litter from sea-
and lost fishing gear and improved waste management.”            based sources in line with the 7th Environmental Action
                                                                 Programme and international commitments made by the
EU Marine Strategy Framework Directive                           EU and its Member States.”
The Marine Strategy Framework Directive requires
European member states to “reach good environmental              The PRF Directive requires ports to meet the following
status (GES) in the marine environment by the year               requirements: ports must develop and implement a waste
2020 at the latest”. Good environmental status in the            reception and management plan, require waste deliveries,
marine environment means that the seas are clean,                implement a type of cost-recovery system and establish
healthy and productive and that human use of the marine          a system for enforcement. Ship owners are required to
environment is kept at a sustainable level. Under the            notify ports of waste deliveries in advance. Member states
directive, marine waters must be assessed against an             are to ensure that costs of waste handling at ports are
agreed set of standards across a number of important             recovered through fees charged to the ships. All ships
environmental areas.”                                            calling at an EU port must pay a fee irrespective of their
                                                                 actual use of the facilities. This is called an “indirect fee”
Ireland has been working on the implementation of                versus a “direct fee” where payment is based directly
the MSFD and development of a strategy for Ireland’s             on use/services. These indirect fees should provide a
marine waters since the Directive was transposed into            “significant” part of the port’s waste handling fees. This
Irish Law in 2011. “The first steps in the implementation        “significant” amount has been defined as at least 30% of
of the MSFD in Ireland was the undertaking of an Initial         the total cost of ship waste handling. Some fishing and
Assessment of Ireland’s marine waters, the definition            recreational vessels are exempt depending on the size.
of the characteristics of GES for each of the eleven
descriptors and the establishment of a comprehensive             Member States are relying increasingly on the MARPOL
set of environmental Targets and Indicators to guide             framework, making implementing and enforcing the
progress towards achieving GES. This step was followed           Directive problematic. In addition, Member States apply
by the establishment and implementation of coordinated           different interpretations of the Directive’s main concepts,
monitoring programmes for the on-going assessment                creating confusion among ships, ports and operators.
of the environmental status of marine waters.”                   Consequently, a 2018 proposal for revision of the directive
                                                                 aims to achieve a higher level of protection of the marine
According to a summary report released by the                    environment by reducing waste discharges at sea, as well
Department of Environment, Community and Local                   as improved efficiency of maritime operations in port by
Government in 2016 “For sea-based sources of litter              reducing the administrative burden and by updating the
Ireland’s marine strategy focuses on the implementation          regulatory framework.
of measures through existing legislation and international
agreements and industry based initiatives. Marine
litter-related measures are included in the Foreshore
and Dumping at Sea (Amendment) Act (2009), EC Port
Reception Facilities Directive, the International Convention

                                                                                            The Netmap Project               15
EU Control Regulation                                           EU Plastics Strategy 2018
Article 8 of the EU Control Regulation (EEC) (no. 2847/93)      The first ever Europe-wide strategy on plastics was
provides detailed rules for fishermen to mark and               announced in January 2018, is a part of the transition
identify their fishing vessels and gear. These rules came       towards a more circular economy. It will protect the
into force in 2005 and apply to passive gear such as            environment from plastic pollution whilst fostering growth
gillnets, entangling nets, trammel nets, drifting gillnets      and innovation, turning a challenge into a positive agenda
and longlines. These detailed regulations require gillnet       for the Future of Europe. There is a strong business
fishermen to mark each piece of gear and also use               case for transforming the way products are designed,
intermediary buoys.                                             produced, used and recycled in the EU and by taking
                                                                the lead in this transition, we will create new investment
EU Action Plan for the Circular Economy                         opportunities and jobs. Under the new plans, all plastic
The EU Circular Economy package includes legislative            packaging on the EU market will be recyclable by 2030,
proposals on waste, with long-term targets to reduce            the consumption of single-use plastics will be reduced
landfilling and increase recycling and reuse. The targets       and the intentional use of micro-plastics will be restricted.
should lead Member States gradually to converge on best
practice levels and encourage the requisite investment in       To reduce discharges of waste by ships, the Commission
waste management. Further measures are proposed to              is presenting together with this strategy a legislative
make implementation clear and simple, promote economic          proposal on port reception facilities. This presents
incentives and improve extended producer responsibility         measures to ensure that waste generated on ships
schemes. This action plan will be instrumental in reaching      or gathered at sea is delivered on land and adequately
the Sustainable Development Goals (SDGs) by 2030, in            managed. Building on this, the Commission will also
particular Goal 12 of ensuring sustainable consumption          develop targeted measures for reducing the loss or
and production patterns. By stimulating sustainable             abandonment of fishing gear at sea. Possible options
activity in key sectors and new business opportunities,         to be examined include deposit schemes, Extended
the plan will help to unlock the growth and jobs potential      Producers Responsibility schemes, recycling targets
of the circular economy.                                        and incentive schemes for the collection of discarded
                                                                fishing gear. The Commission will also further study
To raise levels of high-quality recycling, the plan seeks       the contribution of aquaculture to marine litter and
harness improvements in waste collection and sorting.           examine a range of measures to minimise plastic loss
Collection and sorting systems are often financed in            from aquaculture.
part by extended producer responsibility schemes, in
which manufacturers contribute to product collection            The commission will continue its work to improve
and treatment costs. In order to make these schemes             understanding and measurement of marine litter,
more effective, the Commission is proposing minimum             an essential but often neglected way to support effective
conditions on transparency and cost-efficiency. Member          prevention and recovery measures. The strategy will
States and regions can also use these schemes for               support member states on the implementation of their
additional waste streams. In order to achieve high levels       programmes under the Marine Strategy Framework
of material recovery, the plan aims to send long-term           Directive, including the link with their waste/litter
signals to public authorities, businesses and investors,        management plans under the Waste Framework Directive.
and to establish the right enabling conditions at EU level,
including consistent enforcement of existing obligations.       In order to harness action on a global scale, the strategy
                                                                includes actions in support of multilateral initiatives on
A number of sectors face specific challenges in the             plastic, such as renewed engagement on plastics and
context of the circular economy, because of the                 marine litter on for a such as the UN, G7, G20,
specificities of their products or value-chains,                the MARPOL convention and regional sea conventions,
their environmental footprint or dependency on material         include the development of practical tools and specific
from outside Europe. These sectors need to be addressed         action on fishing and aquaculture.
in a targeted way, to ensure that the interactions between
the various phases of the cycle are fully taken into account    Europe has examples of successful commercial
along the whole value chain. Increasing plastic recycling       partnerships between producers and plastics recyclers
is essential for the transition to a circular economy. The      (e.g. in the automotive sectors), showing that quantity
use of plastics in the EU has grown steadily, but less than     and quality issues can be overcome if the necessary
25% of collected plastic waste is recycled and about 50%        investments are made. To help tackle these barriers, and
goes to landfill. Large quantities of plastics also end up      before considering regulatory action, the Commission is
in the oceans, and the 2030 Sustainable Development             launching an EU-wide pledging campaign to ensure that
Goals include a target to prevent and significantly reduce      by 2025, ten million tonnes of recycled plastics find their
marine pollution of all kinds, including marine litter.         way into new products on the EU market. To achieve swift,
Smarter separate collection and certification schemes           tangible results, this exercise is addressed to both private
for collectors and sorters are critical to divert recyclable    and public actors, inviting them to come forward with
plastics away from landfills and incineration into recycling.   substantive pledges by June 2018.

                                                                                          The Netmap Project                 16
The Commission is committed to working with the
European Committee for Standardisation and the industry
to develop quality standards for sorted plastic waste and
recycled plastics. These standards will help combat the
misgivings of many product brands and manufacturers,
who fear that recycled plastics will not meet their needs
for a reliable, high-volume supply of materials with
constant quality specifications.

Awareness Campaigns, measures to prevent marine
littering and projects to clean up beaches can be set up
by public authorities and receive support from EU Funds.

May 2018 – European Commission Proposal
will tackle marine litter and “ghost fishing”
A further directive was proposed in May 2018 to target
the reduction of the impact of certain plastic products
on the environment. The directive sets specified
targeted actions for member states in respect of the
10 single-use plastic products most often found on
Europe’s beaches and seas, notably the directive also
includes lost and abandoned fishing gear. With its
proposal, the Commission will encourage all actors
involved to get a maximum of derelict gear back to
shore and include it in the waste and recycling streams.
In particular, producers of plastic fishing gear will be
required to cover the costs of waste collection from
port reception facilities and its transport and treatment,
as well as the cost of awareness-raising measures.

This new measure builds on existing rules such as the
Marine Strategy Framework Directive and complements
other actions taken against marine pollution, such as
under the Port Reception Facilities Directive.
Up to now, ports have been able to charge fishermen
for bringing retrieved abandoned, lost or disposed of
fishing gear ashore over and above their normal fee.
The Commission’s proposal to revise the Port Reception
Facilities Directive removes this disincentive. However,
ports’ costs for expanding facilities and running them
could find their way back into the port fee; thus
increasing the overall cost for fishers.

This proposal aims to close the loop by adding
Extended Producer Responsibility (EPR) schemes to
the existing measures. This will ensure that managing
fishing gear plastic litter, once it has arrived on shore, is
the responsibility of the producers. Thereby reducing port
costs for fisherman, particularly in small fishing ports, and
it will accelerate the development of a dedicated waste
stream for fishing gear waste. The proposal will now go
to the European Parliament and Council for adoption.

See Image on Page 18

                                                                The Netmap Project   17
Source: https://ec.europa.eu/fisheries/new-proposal-will-tackle-marine-litter-and-%E2%80%9Cghost-fishing%E2%80%9D_en

                                                                                                             The Netmap Project   18
2.2 National Policy
This section summarises the Irish waste legislation             The SPA Act requires all ships to have adequate storage
relevant to harbours authorities managing marine waste,         facilities on the vessels to store oil, harmful substances,
with particular focus on any legal provisions or guidance       swage and garbage on board, so as to prevent
for the management of waste fishing nets and fishing gear       unauthorised disposal into the sea. This is inspected
in Irish harbours.                                              by Harbour officers, and inadequate storage facilities
                                                                on the vessel are an offence under the Act.
There are varying management structures in Irish
harbours including Port Company managed harbours,               Whilst there are clear definitions in the Act relating to
Local Authority Harbours and Fishery Harbour Centres.           discharge and garbage, fishing nets and fishing gear are
Reference to waste management in relation to general            not specifically mentioned, nor does the Act set out an
waste and specifically to the management of waste               exception in terms of size or capacity of the vessel.
fishing gear and nets across these harbour categories
was investigated.                                               The Dumping at Sea Act, No.14 of
                                                                1996 to 2016, (as amended)
The information presented in this section was attained          The Dumping at Sea Act, 1996 gives effect in Ireland to
by carrying out desk research across relevant websites          the OSPAR Convention, which sets out applications for
including the Irish Statute Book                                permits to allow certain controlled dumping at sea, (i.e.
http://www.irishstatutebook.ie/; the Department of              dredging materials). The Act does not directly mention
Transport, Tourism and Sport website, which includes            fishing nets or fishing gear, however makes clear under
Irish Maritime Administration, (http://www.dttas.ie/maritime)   Clause 2 that where any vessel, substance or material is
as well as Local Authority and Port Harbour websites.           dumped in a maritime area , shall be guilty of an offence
Contact was made with stakeholders in the maritime              under the Act. There are specific permits that can be
sector and conversations with representatives of the            granted for dumping but do not include vessel garbage.
waste management sector were taken into account.                The amendment Act 2009 provides for certain functions
                                                                of permitting to be managed by the Environmental
Sea Pollution Act, No 27                                        Protection Agency.
1991 to 2006 (as amended)
In Ireland, MARPOL 73/78 (as detailed in previous               The Waste Management Acts
section) has been enacted by the Sea Pollution Act 1991         1996 to 2017 (as amended)
(No.27 of 1991), (“SPA”) which has been amended several         The Waste Management Acts 1996 to 2017 (“WMA”)
times up to 2006. To give full effect to the purpose of         define waste as any substance or object which the holder
the Act, the Minister for Transport, Tourism and Sport,         discards or intends to discard or is required to discard.
with responsibility for Maritime Administration, has the
power to make Regulations under this Act to prohibit            Materials meeting the requirements of By-products are no
and regulate the discharge of garbage at sea from Irish         longer classed as waste and the decision when waste can
registered vessels and within Irish waters. This includes       cease to be waste, having undergone a recovery process,
the sea disposal of fishing nets and fishing gear. Anyone       has been clarified.
found contravening such Regulations shall be guilty of
an offence under the Act. (Relevant Regulations made            There are certain categories of waste which involve
under this Act include S.I. No. 372/2012 - Sea Pollution        additional duties or controls, including hazardous waste,
(Prevention of Pollution by Garbage from Ships) Regs            waste oils, bio-waste, batteries, tyres, end-of-life vehicles
2012. – see below for details).                                 and waste electrical and electronic equipment (“WEEE”).

The SPA Act does not specify any exemptions, so the             Storage of Waste
Regulations enacted under this Act may relate to ships          Certain waste can be stored on a temporary basis for up
generally or to any class of ship, to substances generally      to six months, provided that a certificate of registration
or any description of substance, and be made subject            is obtained. The original waste producer or other waste
to such conditions and such exemptions as may be                holder must be authorised to dispose of waste and must
prescribed in the Regulations.                                  carry out the treatment of the waste in accordance with
                                                                the waste hierarchy and so as not to cause or facilitate
If facilities for disposal of waste are inadequate in a         the abandonment or dumping of waste or the transport,
harbour the Minister for Transport, Tourism and Sport,          recovery or disposal of that waste in a manner that causes
with responsibility for Maritime Administration,                or is likely to cause environmental pollution.
may, by Regulation, make provision for such discharge
or disposal options to be made available.

                                                                                           The Netmap Project               19
Transfer of Waste                                             The Regulations place requirements on harbour
The WMA places a duty on a waste producer/holder to           authorities and persons having control of a harbour to
only transfer waste to an “appropriate person”, which is      provide adequate facilities at ports and terminals for the
a person authorised to undertake the collection, recovery     reception of garbage. The Minister for Transport, Tourism
or disposal of the class of waste in question. After the      and Sport, with responsibility for Maritime Administration,
waste is transferred, the person who has taken possession     can notify the International Maritime Organisation where
of the waste becomes the waste holder and takes on the        facilities provided under the regulations are alleged
liability for that waste.                                     to be inadequate. Schedule 1 of the regulations provide
                                                              a format for reporting alleged inadequacies of port
The Act does not apply to the dumping of waste at sea, as     reception facilities.
defined within the Dumping at Sea Act 1981 (No. 8 of 1981)
which was repealed and incorporated into the Dumping at       The regulations specify that:
Sea Act 1996-2016 (as amended).                               All vessels of 12 meters and longer shall display placards
                                                              and notify the crew & passengers of requirements under
S.I. No. 372/2012 - Sea Pollution (Prevention of              the S.4 (General Prohibition to dispose Garbage at Sea)
Pollution by Garbage from Ships) Regs 2012                    S.5 (Animal Carcasses or food waste may be disposed
These Irish Regulations enacted under the Sea Pollution       of more than 12 nautical miles from the coast) and S.6
Act 1991 (No 27 of 1991) give effect in Ireland to Annex V    (food waste may be disposed more than 3 nautical miles
to the MARPOL Convention (as detailed in previous             from land and 500 m from other floating platforms if
section). Annex V means the revised Annex V to the            ground-up to less than 25mm particles), and S.7 (stricter
MARPOL Convention as set out in Resolution MEPC.201           conditions for discharge of food waste and residues in
(62) of the Marine Environment Protection Committee of        seas designated as Special Areas).
the International Maritime Organization. These Regulations
revoked the Sea Pollution (Prevention of Pollution by         All vessels above 100 tons gross tonnage or carrying
Garbage from Ships) Regulations 1994 (S.I. No. 45 of 1994);   15 persons or more shall comply with the regulations
Amendment Regulations 1997 (S.I. No. 516 of 1997); and        by carrying a Garbage Management Plan, which
Amendment Regulations 2006 (S.I. No. 239 of 2006).            specifies procedures for storing, processing and
                                                              disposing of garbage.
The Regulations apply to all Irish ships regardless of
location on National or International waters, and to all      The ships above 400 tons gross tonnage or with 15
other ships when they are in the territorial seas and         or more persons shall also maintain a Garbage Record
inland waters of the Irish State.                             Book in which every garbage disposal or completed
                                                              incineration is logged.
The purpose of the Regulations is to prohibit and control
the disposal of garbage into the sea in accordance with       The Regulations:
specific requirements for different types of garbage for
disposal (i.e. food waste) and the geographical location      •       Sets out definition for “Fishing Gear”- means
of the ship (distance to shore). They also provide for the            any physical device or part thereof or combination
requirement of availability of adequate waste facilities              of items that may be placed on or in the water or
at ports and terminals for the reception of garbage.                  on the sea-bed with the intended purpose of
In addition, the Regulations include requirements for                 capturing, or controlling for subsequent capture
certain ships to have Garbage Management Plans                        or harvesting, marine or fresh water organisms;
and to carry Garbage Record Books.                            •       Definition of “Garbage” includes waste fishing
                                                                      gear and all plastics -further defined as all
These Regulations apply to all ships which are defined as;            garbage that consists of or includes plastic in any
                                                                      form, including synthetic ropes, synthetic fishing
•       A vessel of any type whatsoever operating in                  nets, plastic garbage bags and incinerator ashes
        the marine environment and includes hydrofoil                 from plastic products
        boats, aircushion vehicles, submersibles, floating    •       Includes fishing gear in plastic waste to be
        craft and fixed or floating platforms and includes            disposed of
        fixtures, fittings and equipment                      •       S. 4. General Prohibition of disposal of garbage
                                                                      at sea includes fishing gear–
The Regulations make provision for the prohibition            •       Accidental loss of fishing gear at sea that poses
of the discharge of all garbage into the sea, there are               a significant risk to the marine environment
some exceptions in relation to food wastes. It prohibits              must be reported to authorities
the discharge into the sea of all plastics, including but     •       The Garbage Book requirements includes waste
not limited to synthetic ropes, synthetic fishing nets,               fishing gear as item ‘I’.
plastic garbage bags and incinerator ashes from plastic
products is prohibited.                                       The discharge into the sea of all plastics, including but
                                                              not limited to synthetic ropes, synthetic fishing nets,
                                                              plastic garbage bags and incinerator ashes from plastic
                                                              products is prohibited.
                                                                                        The Netmap Project                20
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