TT Talk - Cargo packing matters

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The biennial cycle of maritime Dangerous Goods regulations, the next Amendment of which enters mandatory application on 1 January 2024, provides a valuable opportunity to consider the trajectory of  changes or improvements in safety for the freight supply chain.

The provisions relating to the transport of Dangerous Goods are revised regularly. While the overall governance of the regulations and the Dangerous Goods List is centred in Geneva and housed in the United Nations Recommendations on the Transport of Dangerous Goods, commonly known as the UN Model Regulations, the IMO, domiciled in London, has responsibility for the implementation of these regulations in the maritime mode.

The next version of the International Maritime Dangerous Goods Code (IMDG code), being Amendment 41-22, will shortly enter mandatory application. Consequently, TT has, in conjunction with UKP&I, updated the well-established ‘Book it right, pack it tight’ publication to provide general assistance and route map to the industry in these important matters.


While there have inevitably been numerous changes embedded in this IMDG Amendment, a number of consequential debates remain underway at this inter-governmental level. IMO committees are, for example, currently seeking to reach finalisation on how to fashion a revised safety framework regarding the transport by sea of Charcoal / Carbon (UN 1361). This vexed issue, frequently resulting in fires while in the supply chain, has encountered protracted debate. As previously reported, the concerns relate essentially to lump charcoal that is intended for burning on barbecues and the like – sometimes having been treated with accelerants to boot.

the concerns relate essentially to lump charcoal that is intended for burning

While tests and research are ongoing to determine certain particular hazards, it appears that there is agreement over key safety measures that may be adopted. These will, however, only become mandatorily applicable from 1 January 2026 in Amendment 42-24. There remain some concerns relating to the differentiation between this cargo and Activated Carbon (UN 1362), which is produced from the raw material. Further, there are non-lump forms of Charcoal, such as produced for artists materials, that have quite distinct burning, cooling and packaging processes; deft handling of such issues will be required by regulators, carriers and enforcement agencies.

Lithium-ion batteries

The topic arguably giving rise to most debate in the transport and logistics industry – lithium ion batteries, in their various forms – has yet to reach centre-stage at regulatory level. It is, however, almost a year ago that TT published the joint whitepaper on this, raising a number of calls to action. Subsequent papers, such as the guidance produced by CINS or the best practices from IUMI, have demonstrated both developing safety thinking and the need for further robust research.

The global need for decarbonisation and related demand for effective battery storage drive research towards power output and speed of recharge, but not necessarily enough towards safety through the supply chain and end-to-end life cycle. TT continues to lobby for engagement between manufacturers and the transport industry to reach a common understanding of the hazards presented and how these can best be controlled. In part, this requires thorough independent scientific research – as much for the existing and legacy chemistries as for what is emergent, since the former will continue in circulation for many years, including in increasing states of degradation.

there must surely be opportunity to get ahead and… implement safety innovations to protect seafarers, broader workforce, assets and the environment

Incident investigations – such as following the serious fire aboard ‘Freemantle Highway’ – will doubtless shape diverse regulatory change, but there must surely be opportunity to get ahead and in the meantime implement safety innovations to protect seafarers, broader workforce, assets and the environment.

What is changing?

The UN agencies are necessarily constrained by the submissions that are raised, either by member states or affiliated organisations. Relevant here are the container inspection findings that are reported to IMO annually. Those lodged for 2022 continue to be too sparse to guide decision-making (and well below the annual average count over the last decade), while demonstrating continuing concerns in key safety issues such as placarding (the external alert) and effective packing.

It is heartening that the National Cargo Bureau (NCB) are repeating a broad-based inspection initiative to shed more light on general container packing safety. Indeed, the work of the Cargo Integrity Group, where TT was a founding partner, continues to be highly important in promoting safe packing practices, linking to the IMO/ILO/UNECE CTU Code.

Perhaps a ground-breaking initiative is the Cargo Safety Program recently announced by World Shipping Council that seeks to standardise cargo screening across the liner shipping industry, combining this with container inspections and creating a machine learning powered feedback loop, linking also to a ‘Verified Shipper Database’. There are a number of technology providers who deliver parts of such a matrix, but combining all elements has the potential not just to tackle non- or mis-declaration, but also beneficially segregate and reward those actors who habitually adopt good practice.

the potential not just to tackle non- or mis-declaration, but also beneficially segregate and reward those actors who habitually adopt good practice


It is in everybody’s interest to improve certainty of outcome; innovations and initiatives such as these have the potential to deliver far beyond regulatory change.

TT regularly focuses on regulatory compliance and the adoption of sound safety practices. In this regard, we would remind all actors of the judgment statement in ‘MSC Flaminia’ that regulations set the baseline for safety. In other words, it is insufficient merely to comply where you have reason to believe that other factors need to be taken into account. Using a simple universal analogy: traffic speed restrictions are not intended to urge the driver to adopt a given speed. Good driving practice requires that all hazards are continually and fully assessed, and appropriate actions taken accordingly.


If you would like further information, or have any comments, please email us, or take this opportunity to forward to any others who you may feel would be interested.

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Peregrine Storrs-Fox

Risk Management Director