ICHCA calls for more awareness, better enforcement and less complexity to improve safety in containerised dangerous goods

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While many good initiatives are now underway to ensure the safe transport of dangerous cargoes along the container supply chain, much more still needs to be done to raise awareness of the risks, enforce the rules, simplify guidance documents and ensure better dissemination of good practice from first to last mile. This was the consensus among members of industry, legislators, policy makers and enforcing authorities who gathered in London on 6 March at ICHCA International’s Packaged Dangerous Goods seminar, the latest in a series of high-level safety events organised by the global cargo handling NGO.

With dangerous goods (DG) now making up an estimated 10-12% of global container trade - accounting for potentially up to 6 million or more shipments per annum - the seminar, sponsored by international insurer TT Club, brought together industry and institutional stakeholders to explore how to tackle injuries, fatalities, damage and loss during DG transport and handling on land and at sea.
Bingbing Song, Technical Officer - IMDG Code at the International Maritime Organization (IMO) gave delegates a thorough overview of the current regulatory framework, emphasising the mandatory nature of the IMDG Codes and distinguishing them from the newer Code of Practice for Safe Packing of Cargo Transport Units (CTU Code), which remains non-mandatory. While the IMDG Code has been adopted by 172 countries, attendees heard that non-compliance feedback to the IMO is astonishingly low, with only 5 reports submitted last year. Competent authorities are urged to address this poor state of affairs, as non-compliance reports are crucial to identifying and addressing the major safety risks worldwide.

TT Club Risk Management Director, Peregrine Storrs-Fox emphasised that dangerous goods are of fundamental concern to the insurer. Among other initiatives, he called on industry and regulators to explore how new ‘big data’ technology can be leveraged to generate deeper insights that can drive improved safety. He highlighted that fires and poor packing feature predominantly in DG related incidents. TT Club analysis shows that historically these two causes consistently appear in the top five that account for two thirds of the claims over the last five years; it is estimated that the supply chain industry loses US$500 million per year related to packing failures alone. He noted in addition that in each of the last two years there have been at least 20 major ship or shore-based fires, a high proportion of which were related to dangerous goods.

The malice of misdeclared cargoes
Ken Rohlmann, Senior Director Cargo Service / Dangerous Goods at Hapag-Lloyd and Vice Chairman of CINS, the container shipping industry’s ‘Cargo Incident Notification System’, said that misdeclaration, whether from fraud or miscommunication, is among the key risk factors. “Known dangerous goods transports are well-planned, checked and executed by experts. The real risk we are exposed to is the risk we cannot see: dangerous goods or other sensitive commodities that are not properly declared to shipping lines,” he observed.
Ken Rohlmann, Senior Director Cargo Service / Dangerous Goods at Hapag-Lloyd and Vice Chairman of CINS
Ken Rohlmann, Senior Director Cargo Service / Dangerous Goods at Hapag-Lloyd and Vice Chairman of CINS
Mr Rohlmann outlined how Hapag-Lloyd’s new search engine, ‘Cargo Patrol’, has been designed to scan the booking environment in real-time to pick up potentially undeclared DG or other suspicious cargo, using known keywords and synonyms. The system reports approximately 1250 potential hits per day and will be made available for use by other container lines in future through IBM. “With this tool in place we have reduced the risk to our crews, vessels, customers’ cargo and the environment through early detection,” he said.
Captain John Leach, Risk Manager at Britannia P+I added that in the specific case of calcium hypochlorite – a DG responsible for a number of significant incidents – all fires in the last 15 years have been as a result of misdeclaration. New technologies for the container booking environment will help to improve visibility, control and accountability, said James Douglas, Director at Exis Technologies, who explained how the company is helping to build a shared online database portal for managing DG shipment data – critical in the current alliance and vessel/slot sharing environment where cargo may be booked with one carrier but moved by another.

Enforcement imperative
“We need more enforcement of the rules”, asserted Alex Kemp, Senior Associate at Holman Fenwick Willan (HFW). From his extensive experience working on “a large number of container ship casualties caused by dangerous cargo, including lithium batteries, charcoal, ‘blowing agent’, and of course, calcium hypochlorite”, Mr Kemp argued that fraud is widespread and that shippers need to be brought to account to prevent misdeclared cargo from finding its way into the supply chain. “Casualties from dangerous goods far outweigh casualties caused by overweight containers in terms of volume, severity and financial cost,” he observed.
Keith Bradley, Technical Adviser on IMDG issues and former Hazardous Cargoes Adviser at the UK Maritime and Coastguard Agency, echoed this sentiment. He told delegates the industry needs a holistic approach to look at all cargoes and suggested that parties could ask to check the training records of other parties in the supply chain before accepting goods.
More pressure on the regulators themselves is needed, agreed Craig Neame, Partner at HFW. Discussing lessons from the Tianjin Port disaster of August 2015, Mr. Neame said that “we have to look at enforcement as much as the legislation itself.” He also called on shippers, carriers and ports to share more information, adding: “We need more events like this to mobilise all participants in the maritime supply chain.” Conor Feighan, Policy Advisor for the Federation of European Private Port Operators (FEPORT), said that DG guidance itself could also be improved, noting that in some cases useful information is not communicated to port operators and guidelines are sometimes too general and unworkable, for example in the case of landside planning.

Ports: learning from Tianjin
Wouter de Gier, Global Head of Safety, Environment and Performance Management at APM Terminals, explained how the global container port operator has developed its approach to DG management over the past several years. A major incident at its Mumbai CFS in 2011, leaving two dead and 13 injured, spurred the introduction of global minimum safety requirements, followed in 2014 by the ‘Fatal 5’ programme. The Tianjin tragedy in August 2015 was a “wake-up call” for the whole industry, he said, prompting APM Terminals to conduct a baseline review of DG risks across the globe, including a joint supply chain assessment with sister companies Maersk Line and Damco. The exercise revealed “big differences” between facilities and also showed that 45% of responding terminals were within 2km of a DG storage facility – the nexus of the Tianjin disaster. Subsequent work led APM Terminals to the release of a global dangerous goods operating standard in 2016.
Mr de Gier nonethless acknowledged that there was still much more to be done to improve everyday practice, including stopping the current perverse financial incentive for terminals and shipping lines to keep boxes in depots for years at a time. Long-standing DG containers are “our blind spot,” he said.

Culture change critical
Cultural change within the freight forwarding community is desperately needed, said Captain Terry Frith, Technical Manager of the non-profit Chemical Distribution Institute (CDI). He pointed out that stakeholders in the chemical tank community understand the risks involved; an appreciation he says that is fundamentally missing within the dry cargo industry. General lack of awareness was cited also by Jim Robertson, Dangerous Goods Safety Adviser at securing technology provider Cordstrap, as a major cause of incorrectly packed cargo. When dangerous goods are rejected, “we need to be telling the packers what they have done wrong with reference to the CTU Code”, he argued. It is not enough to simply reject cargo, concurred seminar attendees: each of the stakeholders has a role to play in bringing awareness and training to improve the packing of dangerous goods.

Feedback for future improvement
In order to get the CTU Code achieving its purpose, legislators desperately need feedback from industry, urged Francesco Dionori, Chief of Transport Networks & Logistics Section Sustainable Transport Division at UNECE. He told delegates that there is a lack of data concerning how the CTU Code is being used. In fact, it was the first time he had seen a number for how many incidents were caused by badly packed cargo, he revealed, referring to TT Club’s figure of 14.2%. A survey designed for this very purpose has recently been launched jointly by ICHCA International, World Shipping Council, Global Shippers Forum and TT Club. One idea proposed at the seminar in order to improve safe packing was to make the training element of CTU Code mandatory.
The London seminar is just one element of a continuous effort by ICHCA and other organisations to create a greater awareness and understanding of the risks involved in the transport of packaged dangerous goods. “This is our call to arms,” said Captain Richard Brough, Technical Advisor to ICHCA International “We need to harness the Tianjin moment to bring far greater awareness of the very real risks involved in the transport of packaged dangerous goods. We are hindered by complexity throughout the supply chain and from the regulations. The industry has today called for a ‘dummy’s guide’ to the IMDG Code to cut complexity and communicate it in simple terms to the people who need to know it. I believe that ICHCA is best placed within the industry to respond to this challenge so we will be looking at how to produce this much needed guidance in the coming months.”

ICHCA International


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