TT Talk - Identify dangerous goods accurately

The shipping industry has been horrified to hear of the tragic incident that occurred in Tianjin. The cause of the original fire and subsequent explosions remain uncertain, but seem to reflect a usual chain of events that start with economic opportunity, misunderstandings and compromised standards, undermining measures for control or prevention.

There is no need to rehearse the known details of the fires and explosions centred in the Binhai economic zone, near the perimeter of the port area of Tianjin, which ranks 10th for container throughput. Although the initial incident took place at the end of the evening on 12 August, further fires have continued during the ensuing weeks and there is a large exclusion zone that has been put in place by the authorities.

It is sad to see the loss of life from this incident. The financial consequences – particularly swollen by the property and automobile exposures – are being likened to the costs related to ‘Costa Concordia’. From aerial photographs, the central explosions appear to have formed a crater approximately 66m x 54m. It might be imagined that a similar level of loss would have been incurred should the incident have occurred aboard a container ship… Indeed, since fires on deck can only currently be fought with sea water, it is worrying to see Reuters report: ‘Fire crews were criticized for using water to douse flames in the initial fire, which may have contributed to the blasts, given the volatile nature of the chemicals involved'.

Mis-declaration metrics: each one presents unacceptable risk
In November 2011, TT Club reported that there was a long line of incidents over decades evidencing the potentially disastrous impact of the carriage of dangerous goods that are not properly produced, packed, marked or declared through the supply chain. That article particularly focused on one such cargo reported to be a regular cause of fires: calcium hypochlorite. Container lines have made strenuous efforts to eliminate the problems arising from mis-declaration of this cargo, but it has been implicated in too many ship fires in recent months. While historically the ports of loading were in China, shipments emanating from Indonesia and India have also been implicated.

Concerns over mis-declaration of cargo have continued, both in relation to actual incidents and also cargo management screening processes that have been implemented, such as Hapag-Lloyd’s ‘watchdog’ system. During 2014, this system provided alerts on more than 162,000 shipments, from which the cargo management experts identified 2,620 cases of dangerous goods that had been incorrectly declared. As Hapag-Lloyd neatly described, ‘dangerous goods that are declared imprecisely, incorrectly or not at all have the potential to pose a major risk to crews, ships, the environment and other cargo on board’ – and on land.

“dangerous goods declared imprecisely, incorrectly or not at all have the potential to pose a major risk”

The CINS (Cargo Incident Notification System) Organisation, established by container carriers to share information on all cargo related incidents, continues to collate information in order to identify problems and trends. Membership has grown to 14 operators, comprising 64% of container slot capacity. The finding that about 25% of reported cases are related to mis-declaration underlines the concerns – perhaps more so for carriers that have yet to engage with CINS, since a proportion of shipments are simply cancelled and (in all probability) re-booked with another carrier.

However, ship-board fires continue to be reported, with charcoal proving to be a problem alongside calcium hypochlorite. It is estimated that some 10% of cargo carried by sea is declared as dangerous – and what should be declared but is not, of course, increases that proportion. And it is not just the maritime mode that is exposed: for air carriage, the International Civil Aviation Organization (ICAO) Dangerous Goods Panel agreed that as of 1 January 2015 the carriage of lithium metal batteries when shipped by themselves on passenger aircraft is prohibited. The US Postal Service has also placed a total ban on their carriage.

Federal Aviation Administration (FAA) tests found overheating batteries could cause major fires.  In its tests, the FAA filled a cargo container with 5,000 lithium-ion batteries and a cartridge heater, which was added to simulate a single battery overheating. The heat from the cartridge triggered a chain reaction in other batteries, with temperatures reaching about 600°C. This was followed by an explosion, which blew open the container door and set the cargo box on fire. A second test, some months later, produced similar results, despite the addition of a fire-suppression agent.

The safety chain – beginning, middle and end
The IMO/ILO/UNECE Code of practice for packing cargo transport units (CTU Code) states: ‘Although the carrier generally, in a contract of carriage, is responsible under that contract to deliver the cargo in the same condition as received, it is the shipper who should deliver a cargo which is safe and suitable for transport…Within this chain of responsibilities, each party in the chain should comply with their individual responsibilities and in doing so increase safety and reduce the risk of injury to persons involved in the supply chain’. 

“the shipper is responsible to ensure that an accurate description of the cargo is communicated to the carrier”

It is the shipper’s responsibility to ensure that an accurate description of the cargo is communicated to the carrier. Declaring ‘calcium hypochlorite’ as ‘calcium hydroxide’, ‘lithium-ion’ or ‘lithium metal’ batteries as ‘rechargeable batteries’, or scrap engines destined for a recycling facility as ‘car parts’ all place people at serious risk.



We hope that you have found the above interesting. If you would like further information, or have any comments, please email us, or take this opportunity to forward to any colleagues who you may feel would be interested.
We look forward to hearing from you.

Peregrine Storrs-Fox
Risk Management Director, TT Club

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+44 7000 882582

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