TT Talk - Do your container fleets meet the latest safety standards?
The safety of containers was initially addressed when there were tens of thousands of units. Now, some 45 years later, there are tens of millions in circulation. The International Maritime Organization (IMO) has been reviewing the processes associated with the Convention for Safe Containers - are you ready for the changes?
The IMO’s review process, particularly during the last decade, represents a number of incremental steps, each initiated by an incident or a concern raised by a member Government. It started with the introduction of the ‘Serious Structural Deficiencies’, a short list of the key components and the maximum permitted damage, after which designated officers can stop or restrict international movement. This is now being further amended to bring clarity to safety levels.
Then, an accident in Canada prompted a review of the Continuous Examination Programme regime, under which the majority of the world’s 31 million TEU are maintained. This prompted a review of the Supplement to the Convention, the requirement by Contracting Parties to audit approved programmes and development of a new guide for preparing maintenance schemes.
Another accident involving swaps bodies collapsing on board ‘Annabella’ in the Baltic stimulated a detailed and through discussion on some of the basic principles of the Convention, particularly relating to stacking strength. As a result, the IMO have prepared instructions for marking containers with reduced stacking capabilities.
So are you prepared?
Currently the Convention for Safe Containers requires that all containers are marked in accordance with the current version of ‘ISO 6346 – freight containers, coding, identification and marking’ with regard to containers built with an allowable stack mass (1.8g) less than 192,000 kg. An amendment to this standard will be shortly published, revising the table for the final character in the size/type code, essentially changing the numeral to a letter. In most instances changes to an ISO standard are only applicable from the date the standard is published; not in this case. IMO requires that all containers used for international maritime transport are marked, whether they are newly built or 20 year old units. That means the majority of the swap bodies and many regional containers will require to be re-marked immediately the standard is published, A proposal to the next Maritime Safety Committee will permit owners and operators some respite – to carry out re-marking when the container is thoroughly inspected or examined as part of the maintenance programme. However, all changes must still be completed by 1 July 2015.
With the introduction of the guidelines for preparing continuous examination programmes, Contracting Parties (the authority that approves your programme and issues the ACEP reference) will know what will be expected of the periodic audits. That will mean that a representative could shortly visit your offices to check the process of maintaining your containers, including record keeping and adherence to the written scheme or programme. Do you know when and where every one of your owned or operated containers was last thoroughly examined and what proof have you that the examination was carried out?
In addition to the audit of the scheme, the Contracting Party also has to review all the schemes under their jurisdiction every ten years to confirm that they are still in operation. Failing to provide requested details may result in ACEP approval being revoked. There are also detailed provisions relating to the transfer of responsibility between lessor and lessee of a container; be warned!
We all know the importance of the CSC Safety Approval Plate – its presence along with an ACEP reference or next examination date permits the container to be used in international maritime transport. Marked on the plate are a number of important references – the first is the Approval Reference, generally issued by a classification company on behalf of the Contracting Party, this reference links the design with the manufacturer and the classification society. The second reference – the Identification number – is essential in tracing the container back to the original manufacturer. You should note that it is no longer permitted to use the container serial number for this identification.
And once in service, what changes can affect you?
Designated control officers can issue the container operator with instructions which restrict their movement or placement within stacks if they feel that the damages found on a container exceed the new safety levels. This may prevent lifting the unit using certain methods, or stacking except on or near the top slots. Bearing in mind the work that is going on with regard to the prevention of containers being lost overboard, it may not be useful to have a heavily loaded container with a top stack instruction!
We gratefully acknowledge the assistance in the preparation of this edition of Bill Brassington of ETS Consulting, who is a member of the ISO Technical Committee 104 on Containers.