TT Talk - Vigilance in carriage of Dangerous Goods by air
The Hong Kong Civil Aviation Department (HK CAD) have issued a Dangerous Goods Advisory Circular following instances of undeclared mercury (UN 2809) being carried by air and found to be leaking on arrival. Since mercury is classified as Class 8 corrosive substance, leakage presents a significant hazard to an aircraft when it is not properly packaged, marked, declared and handled.
The HK CAD circular advised that the shipments concerned were consigned as general cargo, with descriptions such as 'Jewellery', 'Metal chains', 'Metal iron' and 'mould'. None were declared as dangerous goods in accordance with the ICAO Technical Instructions and related IATA Dangerous Goods Regulations.
The TT Club would fully endorse the advice from the circular for carriers and freight forwarders to be alert to the potential that cargo is being mis-described. Experience would suggest that unscrupulous shippers can be extremely creative - as these descriptions of mercury evidence. Furthermore, beware that inner packaging may be adequately and appropriately marked, but this fact masked by the shipper using outer packaging bearing no hazard marking of any kind. Being alert to likely weight and cube for particular cargo may help - for example, for mercury the regulations do not simply prescribe packaging and marking, but also maximum allowable volume.
For any operator in the international supply chain there is simply no alternative to ensuring that you know your shipper. Even in these economically constrained times, there is every reason to take simple but effective steps to be reasonably satisfied that things are as they should be - the entire system relies on trust and that means trusting each party in the chain to act professionally.
Here's a non-exhaustive list of things to consider:
New customer due diligence
- Validate the physical address – web mapping will show not only that it exists but also that it’s where you would expect it to be.
- Check the nature of the enterprise – does any website give a thorough understanding of the scope of activities? Is the entity listed in any related directories?
- Enterprises are people – is it clear who owns and manages the entity? Are there company registration details?
- Be wise on the trade – take care not to breach, for example, sanctions in terms of cargo types or routing.
Existing customer vigilance
- Reconcile documents – do all documents match each other and what you would expect from that shipper?
- Be alert to warning signs – is there a change in any pattern of the relationship, nature of cargo or shipping instructions? If you challenge information, is the response credible, eg. is the MSDS consistent in every way?
- Carry out random checking – inspect randomly across your customer base (to avoid needlessly upsetting any one), keeping photographic evidence of any packages that are opened for physical examination. Any suspicions between documents and packages should be followed up or the shipment returned to the shipper.
In many jurisdictions the penalties are stiff, particularly relating to carriage by air; the TT Club would welcome if every jurisdiction took robust and summary action against those who consign mis-declared, undeclared or forbidden dangerous goods by whatever mode. Whatever the motivation of those who do it, the practice is simply wrong and unacceptable. To boot, it puts lives (and property) at risk unnecessarily.
Read the full alert from theHong Kong Civil Aviation Department
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In a week during which yet another cargo-related containership fire took place, it is timely to draw attention to on-going industry developments to improve controls in the carriage of dangerous goods by sea.