626 



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mechanism to address the legality of seabed disposal under the 

 Convention. That Resolution called for IMO to sponsor an 

 intersessional ad hoc legal expert meeting, with the findings and 

 report of that meeting forwarded to the Eighth Consultative 

 Meeting (February 1984) for further appropriate action. That 

 intersessional meeting has since been scheduled for 12-14 

 December 1983. 



In my role as counsel for Greenpeace International, which 

 has been accredited as a non-governmental observer at meetings 

 held under the London Dumping Convention, I will participate in 

 the December intersessional legal experts meeting. It is 

 Greenpeace's view that seabed disposal of high-level radioactive 

 wastes is covered by the Convention, and therefore prohibited. 



Several reasons support this position. Summarily stated, 

 protection of the marine environment is the foundation of the 

 London Dumping Convention — its object and purpose. In its 

 preamble, articles and annexes, the Convention repeatedly 

 emphasizes this concern as its driving force. As one response to 

 that mandate, the Convention prohibits the dumping of certain 

 wastes, including high-level radioactive wastes. In the 

 Convention's definition of dumping, the phrase, "disposal at 

 sea", could be interpreted narrowly to mean the final resting 

 place of wastes — with seabed disposal excluded from coverage 

 because those wastes, if properly buried, are not in direct 

 contact with "marine v/aters". Given the Convention's object and 

 purpose, though, the only reasonable interpretation is that which 

 defines "disposal at sea" to mean the place where dumping 



