TT Talk - Harnessing the regulation of Maritime Dangerous Goods
Engaging with governments globally, TT Club and ICHCA have drawn attention to the state of packing in the intermodal supply chain and the need for greater rigour by all stakeholders to improve safety.
At the recent meeting of the International Maritime Organization’s (IMO) Sub-Committee on the Carriage of Cargoes and Containers (CCC), ICHCA and TT Club made a submission concerning the inspection programmes for Cargo Transport Units (CTUs) implemented by national governments.
Analysing the reports submitted to IMO in previous years, TT Club established that the number of member states reporting, in comparison with those in membership of IMO, has always been less than 10% and currently stands at about 2.5%. Further, the number of inspections performed has never exceeded 80,000, and currently represents something less than 4 per 100,000 packed containers moved.
The submission drew out two key concerns from the deficiencies found in this small sample. First, there is an apparently deteriorating trend for ‘Placarding and Marking’ failures, which is the key visual risk alert for all supply chain stakeholders. Wrongly placarded units can create a major hazard, as exemplified at a terminal facility in Vancouver in 2015 when a container packed with dangerous goods caught fire, as well as fundamentally undermine the handling of the numerous incidents on board ship.
Perhaps more importantly, ‘Stowage and Securing’ deficiencies, which TT Club has repeatedly reported to be causative in many cargo related incidents, average in excess of 20%.
At ICHCA’s seminar in April 2017 on dangerous goods, hosted by TT Club, reports were given of widespread disregard of dangerous goods regulations, with one shipping line revealing that many shippers use alternative terms for dangerous goods (DG) to avoid surcharges and having to comply with additional measures, including any ship or port restrictions, as well as the regulations themselves.
Calculating the actual number of dangerous goods shipments is complex, but some estimates are that declared volumes comprise up to 10% of all container movements. UNCTAD calculates in its Review of Maritime Transport 2016 that there were approximately 180 million TEU movements in 2016. Assuming 60% of 180 million TEU equates to actual CTUs, 50% of those are laden, of which 10% contain declared dangerous goods, then approximately 5.4 million units annually are packed with dangerous goods.
The state for non-DG…?
It might also be assumed that more care and attention is given to consignments of declared dangerous goods; it may be expected that deficiencies would be more prevalent where more detailed regulations are not deemed to apply. Thus, the findings reinforce experience that packing and securing remains an enormous issue in the unit load industry.
“The findings reinforce experience that packing and securing remains an enormous issue in the unit load industry”
Whilst the International Maritime Dangerous Goods (IMDG) Code is mandatory, the CTU Code is not, albeit it is referenced from the IMDG Code and International Convention for the Safety of Life at Sea (SOLAS). The evidence from recent events is that awareness of the CTU Code is very low and therefore compliance with good practice will be poor.
Cargo Integrity Campaign
It is for this reason that TT Club has teamed with Global Shippers Forum , ICHCA and World Shipping Council to promote the importance of the CTU Code. This ‘Cargo Integrity’ campaign started at European Shipping Week earlier this year, which the IMO Secretary General and Senior Deputy Director attended, and continued during the CCC sub-committee meetings and most recently at the ICHCA 65th Anniversary Conference in Las Palmas. In each instance, the key messages are aligned to the stakeholders in the audience – whether governments, shippers, terminals or carriers – identifying key responsibilities that they can discharge to improve safety in the intermodal supply chain.
“The level of national government reporting is insufficient to draw concrete conclusions by which to steer IMO’s work, improve compliance or increase safety”
In response to a number of suggestions made in the submission to CCC, the sub-committee recognised that the level of reporting is insufficient to draw concrete conclusions by which to steer its work, improve compliance or increase safety, albeit that the absence of reporting should not necessarily lead to the conclusion that inspections are not being carried out. At least one Maritime Administration, which had not reported in recent years, committed to make the CTU inspection regime more robust, as well as to submit a report to the next meeting of CCC in September 2018.
Strengthening compliance culture
CCC also noted the analysis provided by TT Club and ICHCA, inviting governments to provide information on the experience and lessons learned from the application of national CTU inspection programmes. Further, concern was expressed about the high rate of deficiencies and the lack of adherence to the provisions of the IMDG Code.
The TT Club/ICHCA submission also suggested that consideration be given to advances in scanning technologies that may permit improved and risk-based inspections to be carried out more effectively. While not specifically debated, there was general encouragement for the industry and governments to develop more specific ideas for consideration.
In the meantime, the IMO Secretariat committed to improve the ease of reporting, utilising its GISIS methodology, together with recognising that Maritime Administrations could link up the findings of industry inspections that are carried out to the same standard. It is to be hoped that inspection programmes will be ramped up in the coming months in order that more credible data can be shared, as well as engendering an improved culture of compliance globally.
“It is to be hoped that inspection programmes will be ramped up in order that more credible data can be shared, as well as engendering an improved culture of compliance globally”
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.
Risk Management Director, TT Club