M/T Rasi: Nine Deaths at a Certified Ship Recycling Yard in Bangladesh

[Chattogram Coastal Road Photo by Samina Khondkar - Own work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=148921351]

On the morning of August 14, workers at the Ferdous Steel yard in Sitakunda, Bangladesh, were cutting an opening in the bottom of a ballast tank aboard a beached LNG carrier. Hydrogen sulphide escaped. Two men died where they stood. Seven more died in hospital.

Among the dead was Motiur Rahaman, aged 17. Another was Abdul Alim Sujon, a safety officer who went into the tank to pull his colleagues out and did not come back.

The yard where this happened is certified as compliant with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. Certificates were issued by the Indian Register of Shipping in May 2025 and by ClassNK in April of this year. One month before the deaths, Bangladesh's Department of Inspection for Factories and Establishments had taken legal action against the same yard following repeated occupational safety failures.

For shipowners approaching an end-of-life decision, this casualty is worth studying carefully, because it demonstrates that the certification most owners now rely on to demonstrate responsible recycling did not prevent nine deaths at a facility with a documented safety record and active enforcement proceedings against it.

The Vessel

The ship was the M/T Rasi, IMO 9176008. A 280 meter LNG carrier built in 2000, beached at Chattogram in July 2025 and dismantled over the following year.

Her paper trail is the part owners should read closely.

She was previously the HL Ras Laffan, sailing under the South Korean flag and owned by H-Line Shipping. Shipping databases link her disposal to the cash buyer GMS. She was reflagged to Saint Kitts and Nevis. By the time she went up the beach at Sitakunda, the name, the flag, and the registered owner had all changed.

The NGO Shipbreaking Platform had specifically warned in March 2025 that H-Line was preparing to retire the vessel.

How Distance Gets Created

The sequence above is not unusual. It is the standard structure of an end-of-life sale, and understanding it is the foundation of understanding where responsibility actually sits.

An owner rarely sells directly to a recycling yard. The vessel is sold to a cash buyer, a specialist intermediary that purchases end-of-life tonnage outright, takes title, and resells to a yard. The cash buyer pays cash on delivery, assumes the risk of the final voyage, and handles the transaction with the facility.

What follows the sale is a set of changes that are individually explicable and collectively significant. The vessel is renamed, frequently to something short and unfamiliar. She is reflagged, typically to a registry that specializes in last voyages. Saint Kitts and Nevis, Comoros, Palau, and similar flags appear repeatedly in this role. The registered owner becomes a single-purpose entity.

By the time the vessel beaches, nothing on her stern connects her to the company that operated her for twenty years.

That distance is the product the cash buyer sells. It is not incidental to the transaction. It is a substantial part of what the owner is paying for, and owners should be honest with themselves about that when assessing their own exposure.

What the Hong Kong Convention Actually Requires

The Hong Kong Convention entered into force on June 26, 2025. It was the framework the industry pointed to for fifteen years as the answer to South Asian shipbreaking, and its arrival was treated as a resolution.

Its core requirements are real. Ships must carry an Inventory of Hazardous Materials, verified and maintained through the vessel's life and finalized before recycling. Recycling facilities must be authorized by their competent authority and must produce a Ship Recycling Facility Plan. Each vessel requires a ship-specific Ship Recycling Plan prepared by the facility. There are certification and reporting requirements and an enforcement mechanism.

What the Convention does not do is prohibit beaching. Vessels may be dismantled directly on tidal beaches provided the facility holds authorization, and the certification regime has been applied to beaching yards.

That is the structural criticism, and the Rasi deaths gave it a concrete illustration. The Bangladesh Environmental Lawyers Association put it directly, noting that shipbreakers had argued the Convention's entry into force removed the need for the controls they had faced under the Basel Convention, while compliance with what BELA characterized as the weaker instrument had done little to improve occupational health and safety.

Certification Is Not Condition

The numbers behind the argument are worth stating.

Between the Convention's entry into force on June 26, 2025 and the Rasi casualty on August 14, 2026, the Bangladesh Institute of Labour Studies recorded 84 accidents at Bangladeshi ship recycling facilities, causing 15 deaths and 81 injuries. Of 31 functioning yards, 23 have been certified as green and eight are in trial operation, per the Bangladesh Ship Breakers and Recyclers Association.

At Ferdous Steel specifically, the YPSA database records at least seven worker deaths in separate incidents since 2015. Across the Sitakunda yards, YPSA has counted at least 62 deaths since 2019.

Muhammad Ali Shahin of YPSA, who has monitored the industry for years, described the Rasi incident as unprecedented in scale, saying he had never seen such casualties at a single yard.

Relatives of the dead alleged that workers had not been given adequate protective equipment, and that they had been called in on a weekly holiday.

The point for an owner is narrow and important. A certificate from a recognized organization confirms that a facility met an audited standard on the date of audit. It does not confirm operational condition on the day your vessel is being cut, and in this case both certificates were current while enforcement proceedings were live and a fatal accident history was already on record.

Three Frameworks, Not One

Owners frequently treat ship recycling as governed by a single regime. It is governed by three, and they do not agree.

The Hong Kong Convention sets the international standard described above and permits beaching at authorized facilities.

The Basel Convention treats end-of-life vessels containing hazardous materials as hazardous waste subject to transboundary movement controls. The Basel Ban Amendment prohibits export of hazardous waste from OECD to non-OECD states. On that analysis, sending a vessel from an OECD country to a South Asian beach is a prohibited waste export rather than a commercial vessel sale, and the fact that she sailed there under her own power does not change the character of the transaction.

The EU Ship Recycling Regulation requires vessels flying the flag of an EU member state to be recycled only at facilities on the European List. Beaching yards have historically not appeared on that list, though the European Commission is now considering approving facilities that dismantle directly on beaches, a prospect the Rasi deaths have sharpened.

The tension between these instruments is not academic. It determines whether a sale is a straightforward commercial disposal or a regulated waste movement, and the answer varies with the flag, the owner's domicile, and where the decision to sell was made.

Where Owner Liability Actually Attaches

For an owner planning a disposal, the practical question is what exposure survives the sale to the cash buyer.

Regulatory Exposure Under Waste Shipment Law: European jurisdictions have prosecuted shipowners for illegal waste export where vessels were sold for beaching, on the reasoning that the decision to dispose was taken within the jurisdiction and the reflagging and resale were steps in a transaction whose end point was known. The cash buyer structure has not consistently defeated those prosecutions. An owner domiciled in a jurisdiction that applies the Basel framework should take specific legal advice before assuming the intermediary breaks the chain.

Flag State Exposure: EU-flagged vessels are directly caught by the Ship Recycling Regulation. Reflagging before the final voyage is precisely the practice the Regulation's anti-circumvention provisions were written to address, and the timing of a flag change relative to the sale decision is evidentially significant.

Financing and Charter Covenants: Banks subscribing to responsible ship recycling standards impose contractual obligations on borrowers regarding disposal. Charterers, cargo interests, and cargo owners increasingly ask. A disposal that breaches a financing covenant is a default, and that is a commercial consequence with no regulatory element at all.

Reputational Exposure: The NGO Shipbreaking Platform publishes the ownership chain. It did so for the Rasi, naming H-Line and identifying GMS, and it had flagged the vessel more than a year before she beached. The distance the cash buyer sells is not distance from public attribution.

Insurance: An owner's P&I entry ends with the sale. What does not end is liability arising from the owner's own decision, and that is not a P&I risk in any conventional sense. Directors and officers cover and legal expenses cover are the relevant lines if a regulatory proceeding follows, and both should be reviewed against the specific exposure before a disposal rather than after.

The Reason This Keeps Happening

Any honest treatment of ship recycling has to state the commercial fact underneath it.

Beaching yards in South Asia pay substantially more per light displacement ton than European or Turkish facilities. On a large vessel the difference runs to millions of dollars. That gap is the entire explanation for why the practice persists despite fifteen years of conventions, regulations, and campaigning.

An owner choosing a South Asian beach over an approved facility is making a decision worth a specific amount of money, and the honest framing of the choice is that the price difference is the value the market places on the difference in working conditions.

Owners are entitled to make commercial decisions. What is harder to sustain is the position that the choice is a neutral one because an intermediary handled it.

What Owners Should Actually Do

Decide the recycling destination as a board-level matter, not a broker-level one. The commercial upside of a beaching sale is quantifiable. So is the regulatory, financing, and reputational exposure. That comparison belongs in front of whoever is accountable for it.

Contract for the destination. BIMCO's RECYCLECON provides a framework for sale for recycling that allows the owner to specify the facility and impose obligations on the buyer. A sale that gives the cash buyer unrestricted discretion over destination is a decision to not know, which is not the same as not being responsible.

Exercise due diligence on the specific yard, not the certificate. Ferdous Steel held current certification from two recognized organizations while facing enforcement action and carrying a fatal accident history. Ask for the enforcement record, the accident history, and the date of the last physical audit. That information exists and NGOs publish much of it.

Prepare the Inventory of Hazardous Materials properly and early. The IHM is the document that tells the yard what is aboard. On the Rasi, workers cutting into a ballast tank encountered hydrogen sulphide. Whatever the investigation concludes, the general point stands that accurate hazard information is the difference between a controlled operation and a confined space fatality.

Review your D&O and legal expenses position before the sale. If a regulatory proceeding follows a disposal, the exposure sits with the company and its officers rather than with a marine policy that ended when title transferred.

Watch the European List decision. If the Commission approves beaching facilities for the European List, the compliance position for EU-flagged tonnage changes materially. If it does not, the divergence between the Hong Kong and EU regimes widens.

The Bottom Line

Nine men died in a ballast tank on a certified vessel at a certified yard operating under a convention the industry spent fifteen years describing as the solution.

The owner who operated that ship for most of her life sold her to an intermediary. The intermediary renamed her, reflagged her, and delivered her to a beach. Every step was ordinary and the whole sequence is standard practice.

For owners approaching disposal decisions, the useful lesson is not that the Hong Kong Convention failed, though that argument will now be made forcefully. It is that certification is evidence rather than assurance, that the cash buyer structure creates commercial distance rather than legal insulation, and that the choice of destination remains the owner's choice regardless of how many parties are inserted between the decision and the beach.