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SMALL BUT DEADLY CONTAINERS • USING THE LIMITED QUANTITY PROVISIONS TO EFFECTIVELY HIDE DANGEROUS GOODS IN THE MARITIME CHAIN IS A DANGER, SAYS TT CLUB’S PEREGRINE STORRS-FOX TT CLUB, THE leading mutual insurer for the containerised maritime supply chain, has for many years been working hard to highlight
which vary depending on the limits specified in column 7a of the Dangerous Goods List. And those which show a ‘0’ in that column may
the hazards surrounding the transport of dangerous goods on containerships, after a seemingly endless litany of major fires, fatalities, property damage and environmental harm. These have often involved – or been strongly suspected as having involved – misdeclared or undeclared dangerous goods. A growing focus on the part of TT Club and container lines has sought to identify and remove such consignments from the chain before they cause harm, though incidents continue to plague the industry. It is apparent that, while there is some wilful misdeclaration of dangerous goods, a lot of the problems come down to expertise, knowledge and training. “Ignorance of the underpinning regulations and, for international shipments, how those regulations interact with one another has the potential to result in unintentional mis-declaration,” says Peregrine Storrs-Fox, risk management director at TT Club. Patterns in misdeclaration are varied, which makes policing the system very challenging. And there is always the get-out of using the limited quantity (LQ) provisions, which may in itself take the goods out of the relevant dangerous goods regulations and thus avoid or attract a lower surcharge from carriers. However, Storrs-Fox says, the LQ provisions are frequently misunderstood. The International Maritime Dangerous Goods (IMDG) Code is very specific, setting volume limits for both inner and outer packagings,
not be shipped at all as LQ.
DANGEROUS GOODS IN LIMITED QUANTITIES ARE STILL DANGEROUS GOODS AND MUST COMPLY WITH THE RULES
HCB MONTHLY | OCTOBER 2020
STILL IN SCOPE But use of the relief provided by the LQ provisions does not mean that compliance with the IMDG Code is no longer required. For example, training according to Chapter 1.3 of the IMDG Code is still required for all persons employed, including shippers and packers, whose duties concern the transport of dangerous goods, LQ or otherwise. Training shall include the requirements governing the transport of such goods appropriate to the person’s responsibilities and duties. Similarly, the cargo classification provisions remain applicable, as do requirements concerning appropriate packaging, filling provisions and leakproofness. Shipments by sea still require a container/vehicle packing certificate, which must specify among other requirements that the packages are correctly
segregated where appropriate, that the packages are not damaged or leaking and that the correct labels and marks are in place. “The LQ provisions are not a mechanism by which dangerous goods can simply be declared and placed into the supply chain as though they fall entirely outside of the scope of the applicable regulations,” Storrs-Fox says. In recognition of challenges faced by stakeholders in the supply chain, dangerous goods software platforms continue to be developed. One such platform is Exis Technologies’ Hazcheck Detect, a cargo screening solution that scans all booking details for keywords, validates against rules and highlights suspicious bookings to identify mis-declared and non-declared dangerous goods. As software applications become ever more sophisticated, while not themselves intelligent, they become vital tools in the armoury in safeguarding every aspect of the supply chain and delivery certainty of outcome. “Through good fortune, lack of effective identification and accountability, those who are motivated to mis-declare cargo when placing it into the supply chain may undoubtedly gain. Over time, the foundation of their respective business models and contracts become based on the cost savings derived from mis-declaration, undermining any safety culture. What may at the outset have been viewed as taking a risk becomes normal practice,” Storrs-Fox adds. www.ttclub.com
