Cargo is the cause of container fires

GET IT RIGHT

CONTAINER FIRES • ADDRESSING THE SCOURGE OF FIRES ABOARD CONTAINERSHIPS MEANS FOCUSING ON THE CARGO, SAID A RECENT WEBINAR FROM THE TT CLUB AND UK P&I CLUB

THESE PAGES HAVE, over many years, spoken about the problem of fires aboard container vessels, which happen with depressing regularity and cause massive financial losses as well as the death of many seafarers. Moreover, while there have been many attempts to stem the tide, those efforts have so far failed to eliminate those incidents.

The TT Club has often been at the forefront of those efforts and it is continuing to raise awareness of the issues involved. In concert with the UK P&I Club, it is running three webinars on the subject, the first of which took place on 13 January and focused on the importance of getting the cargo right. If dangerous goods are properly declared, packed and stowed, the problem can be removed – but there are well documented reasons why that still does not happen.

The webinar was moderated by Stuart Edmonston, loss prevention director at the UK P&I Club, who noted that it is not just fires aboard ships that is the problem: not a week goes by without a fire in a container somewhere, whether before loading, after discharge or on a ship, and each has the potential to cause a major tragedy, with loss of life and property damage.

SHAPE OF THE PROBLEM Welcoming the more than 250 people who had signed up to view the webinar, Edmonston handed over to Peregrine Storrs-Fox, risk management director at the TT Club, who echoed the introduction, highlighting the massive explosions at Beirut and Tianjin as also being caused by the improper handling and storage of dangerous goods that had arrived by ship in containers. “The risks are there throughout the supply chain,” he said. But, looking at ship losses in particular, onboard fires present a severe challenge both to ships’ crews and to responders.

While the errors found in packing and shipping dangerous goods may often be related to ignorance and simple errors, it is believed that many are the result of fraud. Storrs-Fox mentioned that it is generally thought that around 10 per cent of all containers include dangerous goods but it is also thought that perhaps as many as 5 per cent more contain undeclared dangerous goods.

It is also acknowledged that the regulations are extremely complex, requiring expertise and diligence if compliance is to be achieved. But, Storrs-Fox reminded his audience, the judgment in the MSC Flaminia case made it clear that the International Maritime Dangerous Goods (IMDG) Code should be seen as a baseline and that shippers must consider all risks inherent in their consignments, not just those covered by the rules.

The regulations are not only complex but also differ from other rules that need to be complied with. For instance, the UN numbering system for dangerous goods does not match the coding system used in trade and customs rules. If these were aligned, it would ease compliance, Storrs-Fox said. Furthermore, there are multiple tracks of data involved in each shipment – bills of lading, safety data sheets, dangerous goods declarations (which are particularly relevant to stowage) and others. Managing all these different data flows is a big task.

There are guides to help shippers navigate the regulations, such as those provided by TT Club and its partners, but these are no substitute for having the expertise – especially scientific expertise – available to properly interpret the requirements, Storrs-Fox said.

There are a lot of stakeholders involved and plenty of opportunity for mistakes to arise leading to mis-classification or mis-declaration. Others in the industry have noted that there is an increasing lack of expertise available within the supply chain, as older professionals retire or are released.

A ROLE FOR EVERYONE Furthermore, Storrs-Fox continued, the fragmented stakeholder environment makes risk control very difficult. The fundamental requirements are trust, truth and transparency, something that is hard to achieve with so many “moving parts”. But mechanisms are available: the crucial thing for carriers is to “know your customer”, although he admitted that this is complicated by the use of sub-suppliers, freight forwarders and consolidators. Automated cargo screening is now getting more sophisticated, while dangerous goods compliance software can ensure the correct declaration and segregation – when used correctly.

Aside from these, x-ray scanning is in its infancy but could be useful at node points in the supply chain; automated data loggers and telematics units have a role to play, but mainly in identifying a problem once its has happened. But, Storrs-Fox stressed, enforcement is critically important. Governments and authorities must step up and help all those in the supply chain to work collectively.

So, Storrs-Fox concluded, work is underway, but change is needed. There are many entities trying to make a difference, he said, highlighting the Cargo Integrity initiative, which covers a range of issues involved in container shipping and promotes greater awareness of the Code of Practice for Packing of Cargo Transport Units (CTU Code) as well as broader dangerous goods issues.

Just how that change is to be affected was one focus of the webinar’s second presentation, by Uffe Ernst-Frederiksen, head of cargo management at Maersk Line and chairman of the Container Owners Association (COA). He began by explaining the Risk Zone-based model for dangerous goods storage, initially developed and implemented in-house by Maersk but now being used more widely. This initiative was introduced in September 2018 in response to what Maersk saw as an increasing number of container fires, with the aim of reducing the risk to the crew and the vessel itself in the event of such a fire.

CONTAIN THE RISK Explaining the rationale for the initiative, Ernst-Frederiksen said that, while the regulations are there, fires are still happening. Vessel operators need to do more to reduce the risks to cargo and humans. The number one priority is to reduce the risk to the crew, so dangerous goods should not be stowed on the ship close to the accommodation area. Secondly, it is vital to secure the power and propulsion of the vessel in the event of a fire, so dangerous goods should not be stowed near the engine room. Thirdly, the integrity of the vessel needs to be protected; high-risk dangerous goods should not be stowed midships or under deck but rather at either end, where an explosion would not affect the ship’s stability. The Risk Zone model also takes into account the stowage of substances that respond to carbon dioxide fire extinguishing systems.

Since the introduction of the Risk Zone model, Maersk has been working with a range of stakeholders, including classification societies, other carriers, TT Club, maritime authorities and the National Cargo Bureau (NCB) and its subsidiary Exis Technologies. This work led to the publication in November 2019 by the Cargo Incident Notification System (CINS) of a white paper, Safety Considerations for Ship Operators Related to Risk-Based Stowage of Dangerous Goods on Containerships, which is available for download from the CINS website, www.cinsnet.com.

The white paper provides detailed stowage recommendations, based on different designs of vessel. It is supported by Exis Technologies, which has developed and is maintaining a database to support CINS’ stowage guidelines, categorising specific UN numbers according to the appropriate Risk Zone. That database is freely available through the Hazcheck Systems website, https://hazcheck.existec.com.

THE MSC FLAMINIA CASE (ABOVE) HIGHLIGHTED SOME

ISSUES BUT AS CONTAINERSHIPS ARE GETTING EVER

LARGER SO ARE THE FINANCIAL RISKS AND THE

MOVE IT ABOUT As a carrier, is it easier to “just say no” to dangerous goods? That is always a temptation but, Ernst-Frederiksen said, it just shifts the risk, either to another carrier or, worse, into the unknown depths of non-declaration. In any case, the complex web of vessel sharing arrangements, the raft of local, national and international restrictions and additional seasonal or event-based restrictions means it is difficult to know just which cargoes to refuse.

“Rejecting cargo raises the risk for others,” Ernst-Frederiksen said. The solution is to have accurate and executable processes in place for cargo validation, together with quality control of manufacturers and other shippers – this may involve inspections or audits but, he added, the important thing is to “know your client” and engage with shippers over the long term.

Ernst-Frederiksen said he would also like to see more systematic inspections being undertaken by authorities, something that is mandated by the International Maritime Organisation (IMO) but, outside of the US, widely ignored. Recent inspection programmes have shown non-compliance rates of more than 50 per cent, either involving the IMDG Code or the CTU Code.

Ernst-Frederiksen’s message was that the industry needs a change of mindset; it needs to identify what he called “rogue shippers” and share that information widely across the container shipping sphere. Unfortunately, this might be difficult under current legislation. But individual carriers can help themselves, by a proper onboarding of new customers and by fostering relationships with existing clients. This is a local, frontline activity and needs to be nurtured.

QUESTIONS, ANSWERS The organisers had asked attendees to supply the questions they wanted answering beforehand, though more came along during the webinar, and the event lasted longer than scheduled to give Storrs-Fox and Ernst-Frederiksen the opportunity to address some of them and, in passing, to summarise their message.

Ernst-Frederiksen said that the best way to identify mis-declaration is to use a screening system. Unfortunately, many of the major container lines have developed their own system, meaning that a consignment that gets rejected by one could pass through the net of another and, through vessel sharing, end up transferring the risk. He mentioned that South Korea has been promoting the idea at IMO level of standardising these screening processes, with the support of customs and port authorities. But this will require a change of mindset and a change in the rules to allow carriers to share commercial information.

But, if those “rogue shippers” get caught, what penalties can be imposed? It is often difficult to pin the blame on one party, Ernst-Frederiksen said; a cargo that is shipped from a manufacturer may pass through the hands of several interests before it even gets on the ship, so identifying the party responsible for mis-declaration can be impossible. There have, though, been a few instances in Asia where shippers have been fined or imprisoned, so it can happen.

Storrs-Fox stressed the difference between fines, imposed by the relevant authorities as an enforcement action, and penalties under the contract of carriage, which are justifiable and useful, although perhaps often difficult to enforce. But, he said, it is vital that enforcement agencies follow through on criminal activity – which is what nondeclaration comes down to.

There was an intriguing question about whether a fundamental revision of the IMDG Code is needed and Storrs-Fox suspected there is. The Code has been built up over decades and has become increasingly complex; parts of it have not been subject to serious review for 40 years and, he said, some groups have been lobbying for just such a programme. However, it would be a massive task. Ernst-Frederiksen was not so sure, saying “I believe in the Code!” On the other hand, it needs to be more widely accessible and to be embraced by users.

TT Club and the UK P&I Club will continue the conversation in two further webinars scheduled for February and March. HCB will report back to readers on the outcome of those events.