NCB has ideas on container fires

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CONTAINERSHIPS • NCB HAS WEIGHED IN ON THE DEBATE OVER CONTAINERSHIP FIRES WITH SOME PERSUASIVE DATA AND RECOMMENDATIONS FOR A HOLISTIC APPROACH

AS CONTAINERSHIPS GET ever larger – the current record-holder is the newbuilding HMM Algeciras, which can carry almost 24,000 boxes – the risks posed by dangerous goods grow as well. Yet, while there have been many highprofile incidents over the years involving fires and explosions caused by dangerous goods, it has proved impossible to address the problem.

And the problem seems to be getting worse. TT Club has calculated that, on average, there is a major fire aboard a containership every 60 days, but in 2019 there were nine such incidents, indicating that their frequency is increasing. Such events inevitably result in damage to cargo and the vessels themselves but can also result in fatalities aboard the ships and damage to the marine environment.

It is generally reckoned that around 10 per cent of all containers moving by sea contain some form of dangerous goods but the risk is greatest when those dangerous goods have been declared wrongly or gone undeclared altogether, whether out of ignorance or wilful avoidance of the applicable regulations. There are also dangers from properly declared dangerous goods that have been poorly secured within the container or have been badly packed or stowed.

“The link between undeclared, misdeclared or poorly stowed dangerous cargoes and the increased incidence of catastrophic containership fires is hard to ignore,” says Ian J Lennard, president of the National Cargo Bureau (NCB). “The reasons for issues with dangerous cargoes are diverse and include a challenging regulatory environment; cargo prohibitions; more complex supply chains; and varied levels of understanding and processes. Because of this, it is important that the stakeholders work together and adopt a range of measures that will address all potential causes.”

READ THE PAPER With its long-standing experience as an authorised inspection body in the US, NCB recognises that these diverse factors will require a similarly diverse approach to resolving the problem. It has set down a number of recommendations in a white paper, A comprehensive holistic approach to enhance safety and address the carriage of undeclared, misdeclared and other non-compliant dangerous goods. The white paper details 12 recommendations as part of a holistic approach, ranging from embracing a safety culture for dangerous goods compliance to practical measures for container and vessel inspections and monitoring.

“Because of the clear and present risk predominantly to safety of life but also to ships, their cargoes and the environment, we are calling for all supply chain participants to work on a solution together,” says Lennard. NCB is, in the white paper, calling for urgent reform while offering a way forward for enhancing industry-wide compliance and safety. It recommends a comprehensive, holistic dangerous goods programme that sets a high, minimum bar for achieving regulatory compliance requiring a robust internal safety culture with strong management backing.

AS CONTAINERSHIPS GET EVER BIGGER,

SIZE OF THE THREAT As a measure of the problem, NCB reports that in 2019 it inspected 32,387 containers (dry and tank) with dangerous goods in the US; of those, 2,569 (7.9 per cent) were found to be noncompliant because of poor stowage/ securement, misdeclared cargo or other issues.

In addition, NCB recently spearheaded a Container Inspection Safety Initiative (CISI), that looked at 500 containers, including dangerous and non-dangerous import loads to the US from Latin America, Europe, Asia and the Middle East as well as US export loads involving shippers that had not previously been exposed to container inspections.

CISI aimed to quantify the level of danger that exists on every voyage caused by misdeclared or insufficiently secured cargoes. It found that 55 per cent of the containers inspected were non-compliant in some way, with poor securing of goods within the container in 43 per cent. Of those containing dangerous goods, 6.5 per cent had misdeclared cargo.

For export cargoes from the US, the overall failure rate was 38 per cent; NCB reports that its regular inspection activity finds an average failure rate of 7.9 per cent, and suspects that the much higher rate found during CISI indicates that shippers and consolidators are more likely to comply with applicable regulations if there is a reasonable chance their shipment will be inspected.

Over the past three years, NCB also conducted 3,286 dangerous goods compliance reviews on board container vessels on behalf of vessel operators. Of these, 24 per cent identified some type of stowage or segregation error, including those related to regulatory requirements and/or the vessel’s document of compliance. In addition, 71 per cent also uncovered discrepancies on the vessel’s dangerous cargo manifest such as missing stowage positions or emergency response information, incorrect proper shipping name or identification number, or missing signatures to signify that the dangerous cargo manifest had been reviewed and found correct.

“The levels of non-compliance observed indicate a system ripe for the type of disasters the industry has experienced over the last several years,” NCB says. “This will continue unless a comprehensive holistic approach is adopted by the industry to attack the root of the problem and minimise non-compliance by all supply chain participants.”

REASONS FOR NON-COMPLIANCE In order to reduce or eliminate non-compliance on this level, it is necessary first to understand why it is happening. NCB says that part of the problem is the sheer size and extent of global trade: demands for faster, just-in-time deliveries have created complex supply chains requiring more interdependency among participants and has resulted, in many cases, in a lack of visibility.

In this environment, many shippers are finding it challenging to keep pace with the regulations – especially those who view dangerous goods compliance as simply a regulatory mandate rather than an integral part of their safety culture. Many organisations offer insufficient training and, as a consequence, standards are low. The increasing adoption of e-commerce is also creating the potential for non-compliant dangerous goods as many of these new types of shipper have limited knowledge of the applicable regulations – or simply don’t realise the items they are moving are regulated as dangerous goods.

This complexity is being exacerbated by a lack of harmonisation between the various modal and national regulations, while many countries do not have the resources to effectively enforce compliance.

NCB also says that shipping lines themselves are amplifying the risk of misdeclarations when they ban or limit the carriage of certain dangerous goods, as has happened with, for example, calcium hypochlorite and fireworks. Calcium hypochlorite, an oxidising agent classified under Division 5.1 in the International Maritime Dangerous Goods (IMDG) Code, has been implicated in a number of major fires over the years and some carriers will no longer accept it. But global demand remains high and producers sometimes misdeclare it under names such as calcium chloride, bleaching powder, disinfectant, chloride of lime or chlorinated lime, purely in order to be able to ship it to their customers.

Port restrictions can have a similar effect. Many ports drastically tightened their dangerous goods guidelines after the Tianjin explosion in August 2015, with some even prohibiting dangerous goods altogether. One shipping line, using an algorithm to interrogate cargo bookings for undeclared dangerous goods, reported a surge in suspicious bookings in the aftermath of that incident.

INTERNAL AFFAIRS Other complications arise from the way that shipping lines organise their business. The proliferation of vessel sharing agreements

THE FIRE ABOARD MAERSK HONAM CONCENTRATED

means that it is almost inevitable that cargoes booked with one line will be carried by another at some point. While one carrier may have robust dangerous goods processes in place, the level of safety overall is established by the weakest link in the chain.

Furthermore, the increasing complexity of supply chains has encouraged some carriers to widen their offering to include full, in-house, door-to-door solutions comprising freight forwarding, warehousing, consolidation, intermodal, trucking and other logistics services in addition to ocean transport. This opens the possibility that the dangerous goods function will get lost in the mix.

Most, if not all, container vessel operators have developed processes and procedures for the review, approval, acceptance and carriage of dangerous goods. However, NCB says, management support, resources, tools, processes/procedures and training can vary greatly and may not be in line with industry best practice. Corporate structures may result in silos and a lack of clarity as to where the responsibility for dangerous goods compliance resides; the use of manual systems or legacy software may not be able to deliver accurate and reliable information; and undisciplined cut-off times can lead to issues with the verification of information.

TWELVE-STEP PROGRAMME Taking all these factors into account, and recognising that container shipping lines carry a disproportionate level of risk in the carriage of non-compliant dangerous goods, NCB’s white paper offers twelve recommendations to lines. 1.Key to establishing a robust culture is the creation of an awareness of the importance and responsibility for all employees to comply with applicable regulations and company policies. This requires company management’s commitment to dangerous goods regulatory compliance. A corporate dangerous goods policy should be developed that clearly delineates the functions and responsibilities of each business unit and employee roles related to the acceptance and handling of dangerous goods cargo, reinforcing best practices and fostering rigorous dangerous goods compliance and training. 2.Establish a dangerous goods department with full authority, and backing from senior management, on all matters concerning acceptance and transport of dangerous goods shipments. This dedicated department should receive thorough training in the requirements of IMDG Code Chapter 1.3 as well as all applicable local requirements, periodically supplemented with refresher training to take account of changes in regulations and practice. 3.Establish a compliant dangerous goods training programme that includes mandatory general awareness training for shore-based personnel throughout the company, where applicable, with function-specific training where necessary. This should go beyond just

‘checking the box’ and include training that ensures employees can apply the necessary regulatory knowledge to their specific job function. 4.Establish disciplined cut-off times for booking and acceptance of dangerous goods cargo for receipt of final, certified and signed shipping papers/declarations and for physical receipt of dangerous goods containers. This provides time to review documentation, resolve any discrepancies and carry out container inspections, proper planning and terminal staging for loading dangerous goods to assigned positions on the vessel. 5.Incorporate integrated digital tools that automate critical compliance functions. This would include a tool to screen initial booking data and subsequent documentation such as dangerous goods declarations and bill of lading shipping instructions for key words or phrases to detect undeclared or misdeclared dangerous goods before cargo is accepted; a tool to automatically check booking data for compliance with international regulatory requirements under the IMDG Code (and domestic or local requirements where applicable); as well as a centralised portal for validation of data elements against specific port restrictions, in-house restrictions and partner restrictions for vessel sharing agreements. There should also be a process in place to ensure that these tools are kept up to date with regulatory changes. 6.Establish a dangerous goods documentation process that requires certified and signed shipping papers to be in hand, reviewed for acceptance and validated against approved booking information before shipments are loaded on a vessel. This would include review of preliminary and final hazmat shipping papers or dangerous goods declarations for regulatory compliance and comparing Bill of

Lading or Shipping Instruction information against approved booking information and shipping papers to ensure consistency of information provided and to capture any misdeclared cargoes. 7.Establish a dangerous goods planning process that is strictly controlled. Planners should only plan and load shipments included

on a load list approved by the dangerous goods department. Any changes to the load list or stowage plan should be approved by the dangerous goods department. Dangerous goods stowage and segregation checks should be incorporated into an automated planning tool. However, these checks should not substitute for a properly trained planner’s knowledge to ensure all stowage and segregation requirements are accounted for in accordance with national and international regulations (where applicable) and the vessel’s Document of Compliance. 8.Adopt a risk-based strategy for stowage of dangerous goods that enhances safety on board containerships. This strategy would not replace the SOLAS and IMDG

Code requirements for stowage and segregation and should complement, but not substitute, ship operators’ existing measures for the carriage of properly declared dangerous goods. 9.Establish a receiving in-gate process for dangerous goods cargo that incorporates a centralised database to provide automatic display of correct container marking and placarding during inspection and review of dangerous goods cargo at the gate to avoid errors, increase compliance and speed of the in-gate process. In-gate process should include a physical external inspection of containers for damage, signs of leakage and proper placards and marks. Container placards and marks should be reviewed against booking information to ensure they match. Any container that does not match booking information and documentation or that does not pass physical external inspection should be placed on hold; responsible parties advised; and deficiencies rectified before cargo is accepted. 10.Establish a dangerous goods container inspection programme to validate integrity and ensure proper marking and placarding of the container; to ensure compatibility and proper securing of cargo stuffed in the container; and to check, where possible,

for proper package labelling and marks, the existence of damage, leaks or spills or potential undeclared cargo. 11.Establish a vessel inspection process for dangerous goods cargo that fosters good communications between vessel, terminal planners and assigned shipping line planner during loading operations. The stowage plan should be reviewed prior to commencement of operations and during loading to review for any updates and upon completion to ensure final stowage and segregation complies with applicable requirements. 12.Create one common, centralised dangerous goods database that the industry can access and update on an ongoing basis.

This database should include details that can be analysed to determine trends, improve standards and better target resources to address recurrent issues and their root causes.

THE RATIONALE NCB stresses that the incorporation of digital tools and centralised databases will be a critical component of any programme and should result in better detection of undeclared and misdeclared cargo before loading on to vessels; increased efficiencies and a reduction in unnecessary administrative functions and associated costs; a decrease in human error and faster turn time on dangerous goods booking approvals; and the production of valuable data to be used for analysis to determine trends and better target resources to address recurrent issues and bad actors in the supply chain.

Industry should also work together in order to address dangerous goods regulatory issues, NCB says. This may best be accomplished by establishing working relationships between relevant organisations to consider the way forward, engage with regulators as appropriate, and arrest the disturbing and costly trends in recent years involving the carriage of undeclared, misdeclared and other noncompliant dangerous goods.

The NCB white paper can be freely downloaded from its website at www.natcargo. org/Holistic-Approach-For-UndeclaredMisdeclared-And-Other-Non-compliantDangerous-Goods_White-Paper-by-NCB.pdf.

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