Ichca journal issue 1 january 2014 pv ht by Rachael White

Issue 1 | January 2014

www.ichca.com container weighing

cargo unit packing

solid bulk cargoes

also inside

imo set to implement new

new International code

momentum gathers

accidents & incidents | p26

legislation on container

of practice due for

to tackle threats of

technical queries | p31

weight verification | p4

publication in 2014 | p9

liquefaction | p22

news & EVENTS | p36

THEICHCAJournal Co-ordinating the voices of global cargo handling

mandatory container weighing moves a step closer

What will it take to eliminate incidents like these?

ichca lobbies for tighter laws on inspection of ships lifting applicances

pack it in

thefirstword Welcome to the first issue of The ICHCA Journal. It has been some while since ICHCA International has published anything of this nature, so the first issue of The ICHCA Journal is a bumper one. Considerable focus has been given to two major international developments: impending IMO legislation on mandatory container weight verification and the new IMO/ ILO/UNECE Code of Practice on Packing of Cargo Transport Units. Alongside this are updates on the efforts ongoing to tackle the hazards posed by liquefaction of sold bulk cargoes, and by poorly maintained shipsâ&#x20AC;&#x2122; lifting appliances. ICHCA continues to be deeply involved in all of these issues both at the industry and regulatory level. In this edition, readers will also find an analysis of accident and incident reports received by ICHCA in recent months, details of some of the latest Technical Queries fielded by our Technical Director, and a news and events update. All of these will become regular features in future isues of the Journal, which will be published quarterly, with a supplementary e-newsletter every 2 months. As head of the new secretariat team for ICHCA International, it is a privilege to be part of such a respected organisation. While I have not been around quite as long as ICHCA, I have been fortunate to work in this sector since 1987 when, fresh out of university, I joined a container industry journal as a junior reporter and discovered a whole new world. Since then, the changes in our business have been immense. Back in 1987, few would have predicted the scale of global cargo handling and transport that we are dealing with today, nor its rapid spread to almost every part of the globe. One constant amid all the change, however, has been ICHCA. The globalisation of trade - and thereby cargo handling - has created tremendous opportunities for nations, enterprises and people. But it also brings real challenges. The job of fostering and disseminating good practice right around the world, not least in terms of safety, remains a major undertaking. In this regard, ICHCA today is equally, if not more, important and relevant than at any time in its 62-year history. As cargo chains continue to lengthen, diversify and grow more complex, ICHCA provides a unique platform to co-ordinate dialogue between many private and public sector stakeholders, build cross-party understanding, and shape and share best practice. I certainly hope that you enjoy this first issue. We heartily encourage your feedback (and your submissions!) to help us keep developing this and other ICHCA publications, and our member services in general. The final word must go to ICHCA Technical Director Captain Richard Brough, who has almost singlehanded written all the copy for this issue - a herculean task for which many thanks are due.

With best regards, Rachael White CEO, ICHCA International rachael.white@ichca.com Tel +44 203 3327 0576 www.linkedin.com/in/rachaelwhite

The ICHCA Journal ISSUE #1 January 2014

InTHISISSUE regulationroundups

NEWS&EVENTS

Mandatory weighing of containers moves a step closer to reality

Do you have the right IMDG Code?

36 IMSBC Code amendment 02-13

Interim report from Japan’s new Large Container Ship Safety Committee recommends container weight verification

International Code of Practice on packing of cargo transport units due out in 2014

ILO update

15 Challenges of turning (lots of) words into action highlighted at ICHCA CTU packing seminar

16 Why CTU packing is important

19 ICHCA supports calls for IMO to include inspections of all ships’ lifting appliances in SOLAS

22 IMO puts new regulations in place to counter the threat of bulk cargo liquefaction

regularfeatures

IMO MSC completes sub-committee restructure

37 38 IMO 2014 sessions and planned work

39 ICHCA ISP Panel update

40 ISO update and changes to SOLAS

40 Peel Ports to host ISP 72 meeting in Liverpool

41 Upcoming events

legaldetail

42 Extracts from DSC 18 WP3: Report of the Container Safety Working Group

Accidents & incidents

Annex 2 Draft MSC Circular: Guidelines regarding the verified gross mass of a container carrying cargo

Technical queries

premium members

www.ichca.com https://twitter.com/ICHCA2 www.linkedin.com/company/ichca-international https://www.facebook.com/ICHCAInternational

established expertise

The ICHCA Journal ISSUE #1 January 2014

regulationsroundup#1

Mandatory weighing of containers moves a step closer to reality ICHCA Technical Director Capt. Richard Brough reports on latest deliberations at IMO’s DSC 18 meeting last September on new legislation for mandatory verification of container weights and outlines the next steps Members will be well aware that proposed

In turn, as is normal in these cases, ICHCA established

new IMO (International Maritime Organization)

its own internal correspondence group (CG) to help

legislation on mandatory weighing of containers

advise the Technical Director and establish a “mandate”

loaded with cargo has been in development for

for ICHCA’s position when debating the issue at DSC.

a while and is due to reach its conclusion at the

ICHCA is extremely grateful to those members who

forthcoming 93rd meeting of the Maritime Safety

gave up valuable time to review the draft Guidelines and

Committee (MSC). MSC 93 takes place in London

send in their comments.

on 14-23 May this year. Members have been kept well up to date on the MSC’s sub-committee on Dangerous Goods, Solid

progress of this proposal in previous editions of Cargo

Cargoes and Containers (DSC) met for its 18th session

World Newsletter (the precursor to the new ICHCA

in September last year to debate the outcome of a

Journal) so this article just outines the very latest

formal IMO inter-sessional Correspondence Group that

position.

had been tasked by DSC 17. DSC 18: the debate DSC 17 agreed “in principal” to amend SOLAS,

Initial debate in the plenary session was presaged

the Safety of Life at Sea Convention, to include

by IMO Secretary General Koji Sekimizu, who urged

a requirement for mandatory container weighing.

delegations to support the draft amendment. He

However, it could not finally recommend the proposal

acknowledged that there would be significant impact

for adoption by its parent committee MSC, as there

on the container industry, but pointed out that once a

was a strong view from some nations’ delegations that

container was loaded there was very little the ship or

a significant piece of new legislation, with potentially far

master could do about it.

reaching consequences on the industry, could not be agreed without seeing its accompanying ‘Guidelines’.

Mr. Sekimizu added that accurate weights were of the utmost importance and the ship/port interface was key

Accordingly, the Correspondence Group, chaired by

to this. The loading process could contribute and ports

ICHCA ISP member Ken Smith of the US Coast Guard

had to be more responsible in this regard. He closed

(USCG) was established, with ICHCA Technical Director

his speech by emphasising that this was now the time

Capt. Richard Brough and Lars Kjaer of the World

to conclude and take action and urged the group to

Shipping Council (WSC) both co-chairing.

finalise the SOLAS amendment.

The ICHCA Journal ISSUE #1 January 2014

containerweighing

Ken Smith, USCG was then invited by the DSC

measure to help prevent loss of containers overboard

18 Chairman (China) to introduce the report of the

and that the other recommendations of the Maritime

Correspondence Group and he thanked the members

Research Institute of the Netherlands (MARIN) Lashing@

for their considerable contribution. ICHCA’s own internal

Sea report should be picked up.

CG also submitted a great many responses and many of these were incorporated into the final document. Ken

The Netherlands supported the proposal for two

added that there was overwhelming support for these

methods, added that stowing and stuffing was important

measures and the CG had come up with a “workable”

work and thanked ISO for complying with the IMO

solution.

request to look at ISO 3874, the current ISO standard for handling and securing of freight containers. The

The Netherlands delegation reminded DSC 18 (as

Netherlands delegation also asked DSC to consider

ICHCA had done at DSC 17) that this was only one

ICHCA’s previous paper on this matter. This was also

Interim report from Japan’s new Large Container Ship Safety Committee recommends container weight verification In its paper to DSC 18, ITF, the

of large container vessels. On 17

weight on the hull for large container

International Transport Workers

December, the new Committee

ships in the 8,000 TEU class and

Federation, referred to the June

issued its first interim report on

over in particular, cargo loading

2013 loss of the 8,000TEU

the MOL Comfort case, based

planning for actual voyages could

vessel MOL Comfort. Following

on the preliminary findings of a

frequently reach the maximum

the incident, Japan’s Ministry of

special Casualty Investigation Team,

permissible still water bending

Land, Infrastructure, Transport

established by MLIT in co-operation

moment (hogging condition). In

and Tourism (MLIT) - a member of

with Japanese ship classification

accordance with the deliberations at

ICHCA Japan - announced in late

society ClassNK.

the IMO related to the enforcement

August that it was establishing a

of container weight verification

new Committee on Large Container

Among other recommendations, the prior to loading, verification of

Ship Safety, with a brief to develop

interim report notes: “With regards

the actual weight of container

measures that will ensure the safety

to the proper management of cargo

cargoes provided by the shipper is recommended as a safety measure for large container ships.” A provisional English translation of the report can be found at: www. mlit.go.jp/common/001022353. pdf. MLIT promises a full English translation at a later date. With the full causes of the casualty not yet fully clarified and quantified, the investigation continues.

The ICHCA Journal ISSUE #1 January 2014

containerweighing

debated at the 70th meeting of ISP - ICHCA’s Technical

Belgium was concerned about the situation where

Panel in London during October and ICHCA will be

containers are booked well in advance of shipment and

preparing a paper for submission to the first meeting of

noted that the guidance needed to allow for changes to

MSC’s new Sub-Committee on Carriage of Cargoes and

the weight post-booking.

Containers (CCC) in due course. CCC is the successor

Bahamas wanted the responsibility placed firmly on

to DSC, following a restructure of the Maritime Safety

the shipper and further consideration given to control by

Committee announced by IMO last July.

Port States. Bahamas added that the shipper declaring the weight was not the same as actual “verification” and

The International Transport Workers Federation (ITF)

some of the wording was not strong enough.

spoke to its submission asking that “method 2” be

Chile felt that incorrect declarations needed to be

removed from the proposal, stating that that the optional approach would be open to abuse and would still rely on shippers’ “honesty”and therefore would essentially just preserve the status quo.

considered. Cook Islands pointed out that “overwhelming support” was not actually “consensus” and thanked ITF for its thought-provoking paper.

Several delegations then spoke out in favour of the

ICHCA also supported the proposal, but urged member

proposals as presented, i.e. with two alternative

states to enforce this in their national legislation or it

methods for weighing. These included WSC, Australia,

would be toothless and potentially lead to an imbalance

Belgium, Chile, China, Denmark, Germany, Japan,

in trade should some states not enforce the new rules,

Liberia, Nigeria, Russia, Singapore, UK, Vanuatu and

particularly when shippers were utilising “method 2”.

Venezuela. However, some of the supporters also raised

ICHCA re-iterated that it was grateful to be included in

issues for further consideration:

the CG and had consulted widely with many terminal

The capsized vessel mv DENEB in Algeciras, Spain

The ICHCA Journal ISSUE #1 January 2014

containerweighing

“

If the new rule on weighing containers is adopted at the IMO 94th MSC meeting this May, it will automatically enter into force 18 months later, becoming law in July 2016

operators and cargo interests. While understanding the

Annex 2 Guidelines under scrutiny

concerns raised by ITF, and appreciating that weighing

There were a number of delegations in the room who

of all containers was a ‘gold standard’, ICHCA did not

had not attended the WG at DSC 17, nor taken part in

believe that this could be achieved across the globe at

the CG. As a result, there was a degree of explanation

this moment. ICHCA also expressed its appreciation

as to why certain sections of the Guidelines were

that DSC was picking up on other measures as

presented as they were. There was considerable debate

recommended in the MARIN report.

on a number of the paragraph in the draft guidelines, which were amended after agreement, and the latest

Spain felt that the measures proposed did not go far

version is reproduced in full later in this issue (p44).

enough and added that the only viable option is at the port or “we can only place our trust in shippers”. The

Back in plenary session on the last day of DSC 18, WG

Spanish delegation felt that the proposed exemption

Chairman Ken Smith summarised the WG report and the

for ro-ro vessels on short international voyages was

DSC Chariman then opened the floor up to debate.

pointless and unworkable and queried the usage of the words “should” and “shall”. The Chairman summed up the debate thus far by stating that there was a good indication from plenary of majority support for the proposal as submitted and that delegations were looking for a practical approach. He therefore referred the outcome of the CG to the Working Group and said that DSC should conclude the issue at this session. He added that national enforcement, as reminded by ICHCA, would be important. The Chairman then established the Terms Of Reference

Spain said that it could not agree on the Guidelines as presented for three reasons:

• The proposed exemption for ro-ro vessels on short international voyages was not valid as there is no reference to this in the International Convention for Safe Containers (CSC) or SOLAS

• Concerns over Paragraph 10 (items delivered to Master) as it conflicts with ‘method 2’

• A strong belief that it is inappropriate and inconsistent to use conditional tense when stating how to apply the SOLAS Convention (this refers to use of the words ‘should’ or ‘shall’)

of the Working Group that would consider this and

Several delegations then weighed into the ro-ro debate,

other matters under the heading “Container Safety” and

which took some considerable time, with comments

appointed Ken Smith of USCG as its Chairman.

from Australia, Bahamas, Belgium, Canada, Denmark, Germany, Greece, ICHCA, Nautical Insitute (NI),

The various delegations to the Working Group that

Netherlands, UK and WSC, among others. At one point

met over the next few days outside of plenary debated

it was suggested that the exemption for ro-ro vessels be

elements of the CG report and agreed initially that there

widened out, but this was rejected.

should be no changes to the proposed wording of the SOLAS Chapter VI amendment itself. Debate then

Clarification on the difference between a road trailer

centred on the wording of Annex 2, “the Guidelines”.

stuffed with cargo and a container secured to the back The ICHCA Journal ISSUE #1 January 2014

containerweighing

“

ICHCA will now help its member organisations with guidance and practical solutions to implement the new container weight verification requirements

of a trailer in terms of ro-ro transport were sought. It

What happens next?

was agreed that they were essentially the same thing,

So DCS has finished its work on the proposed

which was why the exemption was there for short ro-ro

amendment to SOLAS to mandate weighing of

voyages.

containers by two methods. This recommendation now goes to DSC’s parent, the IMO Maritime Safety

It was finally agreed that the wording of the SOLAS

Committee (MSC) for approval, subject to agreeing the

amendment would be changed to embrace the

wording relating to ro-ro short voyage exemption, at the

comments of Spain and clarify the exemption status.

MSC 93 meeting in London on 12-23 May. According

Governments who could not accept this wording and

to SOLAS rules, the amendment will then be circulated

wanted to suggest alternatives should send a paper to

for 6 months and after this will be “adopted” by MSC at

the parent committee MSC at its next meeting.

its 94th meeting in November 2014. If the new rule is adopted at MSC 94, it will enter into force automatically

Bahamas queried the wording on ‘Port States’ and

18 months later,. This means that mandatory container

‘Flag States’, arguing that the latter could do little in

weighing will become law in July 2016 at the earliest.

respect to this amendment by way of enforcement. ICHCA will now help its member organisations with Once again, various delegations were split on this and

guidance and practical solutions to implement the new

after considerable debate Germany’s proposal to remove

requirements.

the word Flag was accepted. With a final clarification of the term ‘Shipping Company’ the work was completed

Turn to p38 for extracts from the DSC 18 Container

and the Chairman concluded the debate.

Safety WG report and full text of the Annex 2 Guidelines.

If any members have queries about the IMO SOLAS Convention Amendment or the associated Guidelines on mandatory container weighing, please contact: Capt. Richard Brough, Technical Director | richard.brough@ichca.com

The ICHCA Journal ISSUE #1 January 2014

regulationsroundup#2

Photo courtesy of TT Club

After almost three years in development, the new IMO/ILO/ UNECE Code of Practice for Packing of Cargo Transport Units has finally been completed. Richard Brough reports

International Code of Practice on packing of cargo transport units due out in 2014 The development of the new IMO/ILO/UNECE

The original guidance document, which forms part of the

Code of Practice for Packing of Cargo Transport

IMO’s IMDG (International Maritime Dangerous Goods)

Units (CTUs) is almost complete, having taken

Code, comprised several chapters on the basics of

nearly three years and ICHCA International has

packing and securing units. The guidelines covered all

been involved heavily throughout the process.

types of units, i.e. containers, swap bodies, rail cars and road trailers, used in the road, rail and sea transport of

Back in February 2011, the three UN organisations ILO

dry goods, refrigerated cargoes and liquids (hazardous

(International Labour Organization), IMO (International

and otherwise).

Maritime Organization) and UN ECE (United Nations Economic Commission for Europe) hosted a meeting

The group determined that because of the lack of

comprising representatives from governments,

penetration of the old Guidelines, their relative obscurity

employers organisations and employee representatives,

and the high number of incidents causing severe

to discuss the rationale for an update of the original

accidents and loss of life in road, rail and sea transport

Guidelines for Packing of Cargo Transport Units (CTUs),

that were reported each year, the document needed to

which was originally issued back in 1997.

be updated and made more widely available.

This so-called ‘Global Dialogue Forum’ also invited

Accordingly, the three UN bodies agreed to work

ICHCA to take part as a recognised body in consultative

together and fund a new Group of Experts who would

status by these three UN bodies.

meet to develop the updated document. A programme The ICHCA Journal ISSUE #1 January 2014

CTUpacking

“

The status of this version has been elevated to that of a non-mandatory code. While it is not binding, it is hoped that national authorities will refer to it in their own legislation

of meetings was scheduled at the UN’s Palais de Nations

UNECE pointed out that some chapters may need

in Geneva along with inter-sessional working groups, by

review, but hoped to overcome these issues in readiness

correspondence, to meet an approval deadline of 2014.

for the fourth meeting.

ICHCA’s Technical Director Capt. Richard Brough

Slovakia pointed out that there had been an enormous

attended all of the meetings in Geneva as a member

amount of work in developing the Code which now ran

of the Group of Experts. To augment the work of the

to 362 pages and should be reduced in length.

inter-sessional correspondence groups, ICHCA also established its own internal correspondence group

Belgium made some comments on North America’s

comprised of members of ISP - ICHCA’s Technical Panel,

usage of 4G accelerations for shunting operations

from across the globe.

and what would happen if, as the Code suggested, a container was refused for shipment. i.e., it should not be

Code vs Guidelines - what’s the difference?

‘sent back’ as the draft suggested.

The status of this new version has been elevated to that of a ‘non-mandatory code’. This means that it is

Netherlands agreed that it was a huge document

non-binding in itself, however it is hoped that national

and training would be key. The document had clear

authorities will refer to it in their own legislation.

illustrations and the sections on contamination and fumigation were good and should be kept (some nations

The IMO debated the draft at its Dangerous Goods,

calling for certain annexes to be removed).

Solid Cargoes and Containers (DSC) Sub-committee meeting in September 2013 and the details of those

Japan, Germany and UK supported the Code but had

discussions are outlined below. The meeting also

concerns over its size and usability. UK added that it

received some proposed changes to the document from

would be a very useful reference document, but must be

several delegations.

freely available.

In plenary session, the draft Code was introduced by the

International Chamber of Shipping (ICS) expressed

Chairman (China), who updated attendees on the work

concerns with some of the formulae that were based

of the Group of Experts (of which ICHCA is a member).

on static rather than dynamic container tests and asked

He noted that the Group was planning to meet again in

for analysis of some of the calculations, observing that

Geneva during November to finalise the Code, ready for

ISO may help with this. The Institute of International

approval by the IMO, ILO and UNECE governing bodies

Container Lessors (IICL) agreed.

in 2014, leading to publication. As such that meant this would be the last meeting of DSC to consider the draft.

ICHCA’s intervention called for pragmatism. Referring to the size of the document, ICHCA pointed out that the

The UNECE was represented at the meeting by Valerie

drafting consultant - Bill Brassington of ETS Consulting

Blanchard and ILO by ICHCA ISP member Frank Leys.

(an ISP Panel member) - had been asked to produce

The ICHCA Journal ISSUE #1 January 2014

ctupacking

a ‘definitive’ document in order to avoid the current situation where there was a plethora of other publications, making it difficult for packers to know which was the latest and authoritative version. ICHCA added that the task, once the new Code was published, was how to disseminate the information and promulgate its use. While the Code will be non-mandatory, ICHCA noted that it was urging nation states to adopt it into their legislation; otherwise, the high frequency of serious incidents throughout the CTU supply chain would not reduce. ICHCA also stressed that the Code should be available interactively on the web to help encourage take-up and facilitate ease of use by the different industry parties, and at the many different levels, required. The International Transport Workers Federation (ITF) supported ICHCA’s statement and added that it would be wrong for DSC to reduce the size of the document. World Shipping Council (WSC) urged the sub-committee to leave it to the ‘experts’ to sort out the difficulties with calculations for concentrated loads in CTUs and let ISO have a look first. WSC agreed that the Code should be freely available and on the web. It also supported ICHCA’s views, wanting to see a ‘cascade’ or modular principle so that the new Code reached the appropriate level in the industry. After several more interventions, the Chairman summed up by saying that the Code should be “user-friendly”, readable, controllable and easy for packers. Concern on the size and layout were valid and also how it will be accessed in the future.

Photos courtesy of ETS Consulting

The ICHCA Journal ISSUE #1 January 2014

CTUpacking

The Chairman added that it should be publically available

of Experts, scheduled for November 2013 in Geneva,

for all and that the three organisations should have

would be under considerable pressure to agree (or

a website for the Code. Training and Implementation

reject) all the changes submitted to DSC.

would be key and there were several areas for further examination by the Working Group, i.e., consideration of

As many delegations felt they had not had time to

accelerations, bedding calculations etc.

submit comments, UNECE agreed to receive further comments by the deadline of 8 October 2013, which

In the DSC Working Group sessions chaired by Ken

would then be considered by the Group. Subsequent

Smith of the US Coast Guard (USCG - ICHCA ISP panel

to DSC 18, ICHCA re-convened its own internal CG

member) this was one of the topics debated. The Group

and submitted collated comments to UNECE by the

spent considerable time discussing the structure of the

deadline.

Code and the process for getting the Code approved, given that this was the last meeting of DSC that could

The DSC Working Group decided not to analyse in detail

consider the text.

the comments submitted from several delegations, but to forward these to the Group of Experts to consider

There were calls for the Code to be delayed for another

along with all those that had been submitted to UNECE

year to give DSC a chance to review the text once more,

directly by the 8 October deadline.

but this was resisted and the Secretariat confirmed that this would be the final opportunity for IMO to debate it.

USA re-iterated that the Code referred to European standards in several places and these should not be

All of this meant that the final meeting of the Group

used. The Chairman also pointed out that comments from IMO should cover maritime aspects only as ILO and UNECE covered the other modes. The Working Group also met informally on Thursday under the Chairmanship of Chris Welsh, General Secretary of Global Shippers Forum (GSF - ICHCA member), who is also the Chair of the Group of Experts developing the new Code. ICHCA attended this meeting with a large delegation. The discussions centred on pre-arrangements for the November meeting in Geneva so that best use could be made of the time available to finalise the Code. There was also a great deal of discussion around the format of the Code and what it might finally look like. Earlier the IMO WG had recommended that the Code be “sectioned” with a Main Body, supporting Annexes and informative Appendices.

The original CTU packing guidelines, published back in 1997, never achieved industry-wide awareness 12

The ICHCA Journal ISSUE #1 January 2014

UK felt that the “core” Code was Chapters 1-4, especially the ‘do’s and don’ts’ in Chapter 3, which

ctupacking

could be seen as the first place to go, and that these bullet points could then cross-refer to the appropriate details contained elsewhere. This concept was fully supported by ICHCA.

by the numbers: what’s in the new code

CHAPTERS 1

Introduction

Definitions

Key requirements

Chains of responsibility and information

General transport conditions

CTU properties

Back in plenary session, there was some

CTU suitability

further debate, especially on how the Code

Arrival, checking and positioning of CTUs

would be promulgated and the sub-committee

Packing cargo into CTUs

endorsed the recommendations of the Working

10 Additional advice on the packing of dangerous goods

Group.

11 On completion of packing

UNECE confirmed that the Code would always be freely available from its website and that it had some resource to build a web version.

12 Advice on receipt and unpacking of CTUs ICHCA would like to thank the many members

13 Training in packing of CTUs

of its CTU Code CG who spent a lot of time

ANNEXES

poring through the text and lending their

Information flow

considerable experience to the comments, all

Safe handling of CTUs

of which were transmitted through to UNECE.

Prevention of condensation damages

Approval plates

Receiving CTUs

Minimizing the risk of recontamination

Packing and securing cargo into CTUs

Access to tank and bulk tops, working at height

Fumigation

Code gains seal of approval in November As noted above, the final Group of Experts meeting took place in Geneva during November, under the chairmanship of Chris Welsh, GSF and the ILO consultant contracted to develop the Code, Bill Brassington of ETS Consulting (ISP member). It was attended by representatives from national administrations

10 Topics for consideration in a training programme

APPENDICES 1

Packaging marks

Friction factors

and employer and employee representatives.

Practical methods for the determination of friction factor µ

At least 6 of the delegates at the meetings

Specific packing and securing calculations

were members of ICHCA’s ISP Technical

Practical inclination test for determination of the efficiency of cargo securing arrangements

Panel! ICHCA’s own delegation, headed up by Technical Director Richard Brough, was joined

Informative materials

by ISP members Peregrine Storrs-Fox, TT

Consequences of improper packing procedures

Club, and David Parrin, Cordstrap.

CTU types Quick lashing guides

The process of going through the draft Code line by line, and reviewing and considering all of the comments, corrections and additions submitted to the UNECE secretariat by many delegations (including ICHCA) took several days.

Intermodal load distribution Manual handling Transport of perishable cargo CTU seals Testing for hazardous gases

The ICHCA Journal ISSUE #1 January 2014

CTUpacking

“

At 300 pages, this is a very comprehensive document indeed. The challenge for 2014 onwards will be how to disseminate it out through the industry worldwide

Chapter 3: it all starts here

The main body of the Code will have 13 chapters.

Among other issues, the Group of Experts meeting

These will be supported by 10 annexes, 5 appendices

took on board the recommendations made in the

and the “informative materials” section.

Working Group at DSC 18 about the structure of the Code.

Chapter 3 is critical, as it lists the key requirements to consider when engaged in CTU packing and

With the Code having expanded from the original

securing and refers the reader to other chapters or

60 pages or so in the 1997 Guidelines to well over

to the Annexes and Appendices for further, detailed

300, with additional annexes containing essential

information.

information and appendices with “informative material”, concern had been widely been expressed that it had

The topics now classified as “informative materials”

become so big that it would be difficult for users to go

(see table p 13) do not comprise a formal part of the

straight to the right information for them.

Code, but were nevertheless seen by the Group of Experts as essential supporting information.

A separate working group was established in Geneva (which ICHCA attended) to look at the structure in

Following an exhaustive, and exhausting, meeting in

detail and make recommendations back to the main

Geneva, the final version of the Code was then re-

Group on what annexes should remain and what

circulated to the Group of Experts, and to the ICHCA

should be removed to the “informative materials”

internal correspondence group, to check for textual

section.

accuracy.

After more debate in the main group meeting,

The Code is now due to be approved by the three

consensus was finally reached on this issue and the

governing bodies - IMO, ILO and UNECE - for

results are shown in the table on the previous page.

publication later this year.

If any members have queries about the new Code of Practice on Packing of Cargo Transport Units, please contact: Capt. Richard Brough, Technical Director | richard.brough@ichca.com

The ICHCA Journal ISSUE #1 January 2014

ctupacking

Challenges of turning (lots of) words into action highlighted at ICHCA CTU packing seminar The new Code of Practice on CTU

latest developments, with some

As part of this effort, we will be

Packing is very comprehensive

of the industry’s most respected

offering members special rates for

document indeed and the challenge,

journalists attending. A number of

the new CTUpack e-learning course,

once it is available, is to disseminate

excellent reports followed. One such,

developed by Exis Technologies and

it out to the industry.

prepared for BIMCO by Michael

sponsored by the TT Club. Details

Grey, is reproduced in full overleaf.

will follow soon. For more information

This was one of the major discussion

see http://ctupack.existec.com

points at ICHCA’s well-attended and

ICHCA will have a very important

successful seminar “An introduction

role to play going forward, both in

We will also continue to be involved

to the IMO/ILO/UNECE new Code

continuing to raise awareness about

with future amendments/updates,

of Practice on Cargo Transport

the new Code, and giving advice and

although given the increasing

Unit Packing,” which took place in

information to the logistics supply

pressure on the budgets of the UN

London between the IMO’s DSC

chain on how to comply with its

organisations concerned this is not

meeting and the Geneva Group of

precepts.

expected for a few years - if not

Experts meeting.

decades. After all, this is the first update since 1997, some 26

During a day of speeches

years.

and lively debate between the various government and industry

It is hoped that the proposed

stakeholders, a key national

UNECE website will have an easy

administrator suggested that given

to use version with hyperlinks and

many nations’ reduction in budget

search facilities. What is not clear

and resources for pro-active

is how the Informative Material will

interventions, governments will

be viewed. Many organisations

look to industry to self-regulate as

have developed their own guides

much as possible.

to packing CTUs. This ‘new bible’ was meant to replace all of that

The simple fact that many of those

and guarantee to the end user

attending the ICHCA seminar had

that he or she is referencing the

not even seen the previous 1997

best source of information.

version gives a small indicator of the task now faced by legislators

There is already concern that

and industry alike.

those same organisations will

Our CTU Packing Seminar also offered a valuable chance to inform the media about the

Chris Welsh of the Global Shippers Forum, who chaired the Group of Experts on the new Code, seen here in dialogue with fellow speakers and delegates at the ICHCA CTU Packing seminar

develop their own ‘Guides to the Code’ and (re)introduce confusion. Only time will tell.

The ICHCA Journal ISSUE #1 January 2014

CTUpacking

Why CTU packing is important Michael Grey reports for BIMCO on discussions at ICHCA’s recent seminar on CTU packing It is a very long trail of destruction that can be

in which unsecured loads keep on going after the

traced back to badly packed cargo transport units

driver has braked, with awful consequences. In the rail

(CTUs). In the maritime world people point to

industry, whole freight trains have been derailed on

whole deck stacks that mysteriously collapse as

account of heavy loads breaking free, causing chaos

a result of the contents of just one container, or

and confusion. Safe and secure packing of CTUs is thus

accidents in ports which wreck lifting equipment

a “multi-modal” issue.

or kill and injure dock workers. Re-learning the knowledge But as much a worry are the accidents which take

Containers have been around for nearly half a century,

place on the roads, with ill-stowed containers and

but it is clear that the knowledge of their safe packing

unsecured contents falling off trailers on sharp bends or

is something that is required to be regularly re-learned.

roundabouts, crushing cars or pedestrians.

When containers first appeared, the first major consortia worked hard to ensure that those who had learned their

In the US alone, there is a terrible toll of truck accidents

The ICHCA Journal ISSUE #1 January 2014

skills in the general cargo/break bulk trades aboard ships

ctupacking

and in the docks were able to transmit their knowledge

recognised in the code, with its authors realising the lack

to people, perhaps miles from the sea, who would now

of awareness which is often responsible for accidents.

have to pack these new boxes. What perhaps was not realised is that this knowledge is something that requires

Bill Brassington, the safety consultant who chaired

regular refreshment to the newcomers in the business as

the code committee, suggests that much of the

the years progress.

available information is out of date and those who are doing the packing often have no appreciation of the

“If cargo is well stowed, it can resist most things”,

accelerations and decelerations to which CTU contents

commented Peregrine Storrs-Fox of the Through Transit

will be exposed during a sea voyage or even the trip to

Club (TT Club) at a recent seminar provided by ICHCA

the docks. There was a huge catalogue of avoidable

International. He employed - possibly even invented -

accidents, which ranged from the risks of people being

the word “adjacency” to describe the damage a single,

exposed to fumigants or dangerous atmospheres after

badly packed container could do to those around it in

opening a container, to being crushed by loose cargo.

a containership’s cells, or in the deck stacks. He also

Quarantine and the need for boxes to be clean and fit for

cited a worrying International Maritime Organization

use were issues sometimes overlooked.

(IMO) report which suggested that one in every three containers held cargo that had been incorrectly packed

The content of the new code, with its 13 chapters

and, worse still, this data had obstinately not changed

and annexes, was designed to be read by a large

over the past eight years.

number of people and aimed to be both simple and understandable. It provided the right information in an

Doing what is right

easily accessible form and provided the data at every

The correct packing and handling of containers, he

level, with an overview for management and information

pointed out, depended on a very large number of

for supervisors, along with the detailed packing

people and interests throughout the supply chain doing

procedures for operators and packers, working with

what was right, with the issue of trust paramount. But

every kind of CTU. It emphasised the importance of the

this chain also contained fragmented interests in an

packer, who would be required to assume responsibility,

uncontrolled community. And while there might be plenty

the full length of the logistics chain. And while the

of information issued by carriers, by larger shippers,

code was non-mandatory it was, said Mr. Brassington,

by clubs and other interest, there was no escaping the

available to become a model for international legislation.

pressures of speed and cost. Fundamental lack of expertise The seminar in London was to promote understanding

It was fundamentally a lack of expertise that was causing

on the new IMO/ILO/ UNECE Code of Practice for

so many accidents and incidents, said Chris Welsh of

Packing of CTUs, the final touches of which were being

the Global Shippers Forum and who had been chairman

made to its draft form and which it was hoped would

of the ILO/IMO/UNECE Group of Experts.

be deemed acceptable at IMO in 2014. It considered its impact upon the links in the logistics chain, the way in

Even big shippers, he maintained, lacked expertise,

which the contents could be disseminated widely and

with the ignorance extending throughout the supply

how the code, which was a non-mandatory document,

chain, with real experience long gone. Methods of

could be enforced.

disseminating information on correct packing were not working and something that was easier to use than the

The importance of knowledge and training has been fully

current advice was needed. The ICHCA Journal ISSUE #1 January 2014

CTUpacking

Mr. Welch called for clarity and simplicity, based on the

safety-driven. It was the translation of regulation or

“less is more” principle, with the information clarifying the

theory into practice which would ultimately make the

responsibilities of the shipper in the accuracy of weight

difference and improve safety. He suggested that

declarations, the avoidance of eccentric stowage and

there should be “no imperialism” in the implementation,

inadequate securing. There needed to be co-operation

with international organisations like BIMCO and the

between the parties, as the shipper may not have been

professional institutes, along with local associations, all

the packer.

co-operating to promulgate the lessons of the code and ensuring its effectiveness.

Shippers, he maintained, do not deliberately mis-stow as the customer wants it right, while the regulators

What about enforcement?

often fail to understand the supply chain. The key, said

How is the code to be enforced? A UK perspective

Mr. Welsh, was simplicity and accessibility; perhaps a

was given by the Maritime & Coastguard Agency’s

web-enhanced tool that gave the packer all the data he

Keith Bradley, who suggested that the aim should be

needed about the cargo he happened to be handling.

to change behaviour, and to have a more cohesive interpretation of safety, in which the common

Keep it simple and comprehensible

acceptance of the costs of badly packed CTUs would

Indeed, it was the need to get the necessary information

disappear. The industry would want a level playing field

to the individual packers that was crucial, said Frank

for enforcement, and being too prescriptive might be

Leys of the ILO. There were a range of options, from

self-defeating. Entities within the supply chain, said

pocket cards through posters to more advanced tools,

Mr. Bradley, needed to be reminded of their roles and

but it was crucial to make sure the information was

responsibilities, with a new attitude to “due diligence”

simple and comprehensible to those doing the packing

and more care about whom one was doing business.

- “translating” this to the appropriate level (as well as

There was also a need to make the supply chain more

the right language). Don Armour of the Freight Transport

“visible”. The regulators’ role might then be able to

Association suggested “chopping up the code” into

change to one of working with industry.

specific areas of interest, noting that publication of the document only marked the half-way point. There was

This was a well-organised, useful seminar which

also a lack of enforcement resources in many parts.

emphasised the importance of the Code and above all that its success would largely depend upon training and

So training was a crucial matter and modern systems of

disseminating the information the full length of the supply

eLearning, suggested Ken Burgess of Exis Technologies,

chain. The proof, of course, will be in its acceptance and

would provide the means to train large numbers of

ultimately upon the level of claims and damage to people

people simultaneously, targeting and tailoring the content

and goods.

as appropriate. It was a fact that the container industry was very fragmented, so there were training challenges to be overcome, but modern tools like apps could be very effective, flexible and delivered in line with industry standards. Other challenges, pointed out David Parrin of Cordstrap, which made securing devices, included the fact that presently the industry tended to be cost, rather than

The ICHCA Journal ISSUE #1 January 2014

Michael Grey is BIMCO’s Correspondent in London. He is a former Editor of Lloyd’s List and a frequent contributor to many maritime publications. This article was originally published in the BIMCO General Bulletin 108 and is reproduced in full here with BIMCO’s kind permission.

regulationsroundup#3

ICHCA supports calls for IMO to include inspections of all ships’ lifting appliances in SOLAS under classification surveys and it is estimated that only 3% of such equipment is currently covered in this way. ICHCA’s proposal, if adopted, would ensure that all such equipment is brought under ‘class’, thereby improving the quality and provision of surveys to help prevent further incidents. This topic has been backwards and forwards with IMO for a number of years now. The first such report was submitted some 7 years’ back by the Maritime Administration of New Zealand, based on a survey in its territorial waters over a period of 7 years, which identified 334 incidents involving ships’ lifting

The picture above shows the results of the failure of a ship’s cargo crane at the pedestal. There have been numerous such accidents, some leading to loss of life, and even one where the crane had only been inspected some three weeks earlier. ICHCA has asked IMO to consider including inspection of ships cranes in the SOLAS (Safety of Life at Sea) Convention. At the moment, ships cranes have to be

appliances, leading to 18 serious injuries and at least one fatality. Absence of inspection and maintenance procedures Post-incident analysis revealed that there was “in some cases an absence of rigorous procedures for inspection and maintenance of such equipment.” This report was submitted to IMO’s Maritime Safety Committee (MSC) at its 83rd meeting in 2007. At MSC 86, New Zealand reported on 11 more failures of ships’ lifting appliances. By MSC 89 in 2011, Japan reported on a serious failure of a heavy-lift ship’s crane which injured three people, one fatally, and caused a barge to sink.

inspected under various regimes and national or regional legislation, but it is clear to us that this is insufficient or

At the 56th meeting of the MSC sub-committee on Ship

there would not be so many incidents reported.

Design and Equipment (DE) in February 2012, ICHCA

Shipowners do not have to include such equipment

reported on incident frequency, based on information The ICHCA Journal ISSUE #1 January 2014

shipsliftingappliances

gathered by the International Group of P&I Clubs (IGP&I),

even questioning the frequency of incident data and

one of our corporate licensed members, from a survey

implying there was not really an issue that required IMO

of its member clubs. The IGP&I survey highlighted 126

action.

incidents over the survey period from P&I member clubs representing 13,000 vessels. Extrapolating this data

Nevertheless, IMO supported the proposal and

to the full number of vessels in the IGP&I member club

established an inter-sessional correspondence group

portfolio would equate to over 500 such incidents.

(CG) - appropriately chaired by New Zealand - to carry out further research and report back to DE 58 (now re-

The incidents reported in the IGP&I survey were varied,

designated as SSE 1 - the first meeting of the new Sub-

including failures to hoist wires, slewing rings, crane

committee on Ships Systems and Equipment following

jib structures, holding down bolts, brakes and other

the recent MSC sub-committee re-organisation).

structural failures. The CG has been tasked with: ILO Convention 152

•

Completing an analysis of incidents

The only truly ‘international standard’ for inspection of

•

Suggesting an appropriate SOLAS amendment

ship’s cranes and fittings is in the International Labour

•

Specifying the range of equipment that should be

Organization (ILO) Convention 152. However, only 26 nation states have ratified this Convention, so it is not universally applied. Furthermore, as the Maritime Administration of New Zealand points out, ILO Conventions - unlike SOLAS - do not contain a “no more favourable treatment” clause and this limits their effectiveness. ICHCA’s submission to DE 57 in March last year was well supported by many nations and other NGOs, although it has to be said it was not universally supported, with some organisations

The graph top right shows a synopsis of the cause of incidents with ships’ lifting applicances, collated by New Zealand from its own research and other members of the Correspondence Group. Bottom right, incidents shown by crane type

The ICHCA Journal ISSUE #1 January 2014

included - some are arguing for cargo cranes only,

shipsliftingappliances

while others (including ICHCA) would like to see ALL ships’ lifting equipment covered The Correspondence Group has also been tasked with looking at what standards and legislation exist that can be referred to, including ILO 152. It has also been suggested that ILO looks to amplify its guidance by including thorough examinations of slewing rings and holding down bolts. ICHCA will be supporting the paper that is submitted to SSE 1 and is grateful to all those ISP Technical Panel members and others who have taken part in the work of the correspondence group. ICHCA will keep members updated with progress at SSE 1, which we will be attending in March this year. New Zealand has already submitted its papers to IMO and ICHCA will be supporting this strongly.

In 2011 the UK P&I Club, in conjunction with crane manufacturers Liebherr and Macgregor, plus Lloyds Register, published “Survey and Examination of Ships’ Lifting Appliances”; which highlights key points for surveyors and ships’ crews to look for during examinations and inspections. Copies of this extremely useful guide are available to download free of charge at: www.ukpandi.com/knowledge/article/ survey-and-examination-of-ships-liftingappliances-3645

The ICHCA Journal ISSUE #1 January 2014

regulationsroundup#4

IMO puts new requirements in place to counter the dangers of bulk cargo liquefaction Pictured above, solid bulk cargo loading conditions that may be encountered in ports. ICHCA has argued to IMO that sampling in stockpile operations is flawed, as it is impossible to obtain an accurate representation of the whole cargo when a stockpile may be 15m high and the surveyor can only dig down a metre or so 22

The ICHCA Journal ISSUE #1 January 2014

bulkcargoliquefaction

Work has been ongoing at IMO for quite a while now in an effort to prevent further vessel casualties and the loss of many seafarers’ lives as a result of bulk cargoes liquefying during sea transport. ISP Technical Panel member Jim Chubb, a very experienced marine surveyor, currently employed by South Seas Management, has been extremely instrumental in working with IMO on behalf of ICHCA. In particular, Jim has led ICHCA’s response to the Inter-sessional Correspondence Group (CG) on the transportation of Iron Ore Fines (IOF). Established at the 16th meeting of IMO’s Dangerous Goods, Solid Cargoes and Containers (DSC) subcommittee in September 2011, and chaired by Dr Sam Ota of Japan, the CG was tasked with: •

Considering the adequacy of current methods for determining the transportable moisture limits (TML) for IOF and the possibility of new and/or amended existing methods to be included in appendix 2 of the IMSBC (International Maritime Safety of Bulk Cargoes) Code

•

Considering the evaluated and verified research into IOF

•

Taking into account the above, preparing draft invididual schedule(s) for IOF and any amendments required to appendix 2 and reviewing the existing iron ore schedule, as needed

associated research that has taken place with regard to sampling and vessel dynamics. ICHCA has been particularly concerned about sampling methodologies in ports, and submitted a paper on this topic - largely authored by Jim Chubb - to DSC, which was well received. The essence of this paper was to raise awareness about restrictions on the accuracy of cargo sampling in some stockpile configurations, and the lack of a robust international standard on this issue (notwithstanding the existence of ISO standard 3082). Can test not sufficient If the sample taken at port is not representative of the cargo being loaded into the vessel, then the Master cannot be certain that the declared TML is a good indicator of that cargo’s ability to withstand dynamic motions of the vessel. Some Masters had only the “can test” to rely upon, which involves shaking a small sample of cargo in a tin can and if moisture appears on the surface of the sample, then there could be a problem. So, much of the inter-sessional work has focused on cargo sampling and tests to establish the TML more accurately. There has also been substantial field research undertaken on-board vessels loaded with bulk cargoes. ICHCA maintained that sampling in some ports was flawed as it was impossible to obtain a representation of the whole cargo when a stockpile may be 15 metres high and the surveyor can only dig down a metre or so. Some terminals, of course, are able to sample from the conveyor as the vessel is loading.

This has turned out to be an extremely onerous task and the IMO is extremely grateful to Dr. Ota’ for his

A very comprehensive research report on this topic

splendid chairmanship of the group.

was submitted to DSC 18, which met last September. This work was undertaken by highly skilled specialists

Successive meetings of the IMO sub-committee on

from Brazil and Australia, representing the world’s three

Dangerous Goods, Solid Cargoes and Containers

largest mining groups, who came together in a formal

(DSC) have been updated on the progress of the

Technical Working Group (TWG) to research methods

CG’s findings and recommendations, along with the

for determining the TML of Iron Ore Fines using The ICHCA Journal ISSUE #1 January 2014

bulkcargoliquefaction

laboratory techniques, modelling tools and small scale

are included in these. There are two key changes which

physical and computerised numerical models.

relate to cargoes which may liquefy (Group A cargoes):

The work of the TWG was overseen by the International

A. Assessment of acceptability of consignments for

Group of P&I Clubs (an ICHCA International member)

safe shipment

together with Imperial College London and the University

The amendments to the IMSBC Code include a more

of Strathclyde.

robust assessment of acceptability of Group A cargoes for safe shipment. This is detailed in the new section

In addition, several bulk cargoes were monitored during

4.3.3 and involves extra approval from the competent

loading at port and during sea voyage on a range of

authority of the port of loading before Group A cargoes

vessels, to see how the cargo performed in dynamic

can be transported. It specifically applies as follows:

motion.

•

The shipper must establish procedures for sampling, testing and controlling the moisture content of the

Key findings from the TWG’s research included:

cargo to ensure that it is less than the transportable

•

moisture limit (TML) when it is on board the ship

The Proctor-Fagerberg Test Method D is the best determinant of TML

• •

•

The competent authority of the port of loading

Iron Ore Fines so tested at 80% saturation did not

must confirm that the procedures comply with the

liquefy, either in Capesize or handysize vessels

provisions of the IMSBC Code and the Guidelines

Iron Ore Fines have different mineral compositions

for Developing and Approving Procedures for

and in particular “goethite” content is relevant here.

Sampling, Testing and Controlling the Moisture

As well as “hematite”, these minerals govern the

Content for Solid Bulk Cargoes which may Liquefy

resistance to liquefaction

(MSC.1/Circ.1454) before granting approval

The safety margin in IOF sea transport is greater the

•

The competent authority of the port of loading must

larger the vessel

issue a document stating that the procedures have

Free surface water does not form in all cargoes

been approved. The document’s validity must not

and a “wet base” to the cargo loaded does not

exceed five years

necessarily lead to liquefaction A full copy of the TWG report can be downloaded at http://ironorefines-twg.com/wp-content/ uploads/2013/06/TWG-IOF_Proctor-Fagerberg_Test_ Report-Final.pdf There is still considerable work to be undertaken and

•

The procedures will be subject to initial, renewal and intermediate verification by the competent authority.

•

The competent authority of the port of loading must verify the implementation of the procedures

•

A copy of the document stating the procedures have been approved must be given to the Master or his representative

this was summed up by Jim Chubb in his paper to the

The IMO will disseminate the names of the relevant

recent ISP 70 meeting in London, October 2013. He

competent authorities through the GISIS database.

reported: B. New Nickel Ore schedule “At MSC 92 in June 2013, amendments to the IMSBC

The amendments also include a new schedule dedicated

Code that will enter into force on 1 January, 2015, and

to Nickel Ore, a Group A cargo which may liquefy if

may be implemented voluntarily from 1 January 2014,

shipped at a moisture content in excess of its TML, and

were agreed. The amendments proposed by ICHCA

a cargo associated with the loss of several bulk carriers,

The ICHCA Journal ISSUE #1 January 2014

bulkcargoliquefaction

most recently the Trans Summer on 14 August, 2013. The debate regarding Iron Ore Fines is still ongoing and a schedule for this cargo will not be mandatory under the IMSBC Code until 1st January 2017.” For further information on the amendments to the IMSBC Code, see Resolution MSC.354(92) For more information on voluntary implementation from January 2014, see MSC.1 / Circ.1452

In response to the sinking of four bulk carriers loaded with nickel ore in very short succession with the tragic loss of 66 seafarers’ lives, Intercargo , the International Association of Dry Cargo Shipowners, published the ‘Intercargo Guide for the Safe Safe Loading of Nickel Ore’ in February 2012. Copies of this very useful guide can be downloaded at no cost from the Intercargo website at: www.intercargo.org/cargoes/127-nickel-ore.html

The ICHCA Journal ISSUE #1 January 2014

accidents&incidents

ICHCA’s latest analysis of accident and incident reports reveals that collisions are still a worrying source of serious and fatal injuries in ports and terminals For the period covering March to September

This reveals that in the vast majority of cases, personnel

2013, ICHCA received 36 accident and incident

are being fatally injured by coming into contact with

reports. Analysis of these reports reveal that 28

various items of port equipment. This will be the topic of

dock workers were fatally injured and a further 17

a joint session between ICHCA’s ISP Technical Panel, TT

received serious injuries.

Club (premium member) and PEMA, the Port Equipment Manufacturers Association (corporate licensed member)

This of course is not scientific (or by any means

at ISP 71, taking place in Malaga, Spain during February.

complete) and highlights the fact that ICHCA tends to

Delegates and members will be looking at technological

receive reports of the more serious incidents or those

and other solutions for helping to prevent collisions

that are featured in the media. What is clear, however, is

between personnel and equipment, among other topics.

that there are still far too many such reports coming in from around the world.

One of the incidents referred to above was caught on camera and shown on YouTube. Not for the faint

Further analysis of the factors involved in these 36

hearted, the video footage clearly shows a reach stacker

reports showed:

reversing out of a container stack in the terminal area,

•

61% (22) involved plant/vehicles other than cranes

when the driver inadvertently catches the adjacent stack

•

36% (13) involved cranes and/or lifting equipment

as he manoeuvers out. The containers in this stack then

•

22% (8) involved container movements

topple over onto a van which is parked next to them. The driver is aware of the impending danger, jumps out

The female driver of the car in this incident in China was miraculously pulled from her vehicle apparently unhurt

The ICHCA Journal ISSUE #1 January 2014

accidents&incidents of the vehicle and tries to run away, but one of the higher containers falls on top of him, with obvious consequences. This tragic incident, which is not by any means rare,

Accident and incident reporting: A request to ICHCA members

highlights several issues, including: •

Location of stacks and manoeuvring space

•

Access and control of vehicles/pedestrians

•

Skill and ability of drivers

The location of the incidents reported was roughly 50:50 in terms of those taking place on-board a vessel or on the quayside. In previous periods, we had seen a high incidence of personnel falling, but this only occurred in three of the latest current reports. However that, of course, is still three too many. Three of the reports involved dock vehicles being driven by a port operative who ended up going over the quayside into the dock water and subsequently drowning before being able to be rescued. ISP has recently been discussing dock rescue situations, albeit with a focus on incidents involving mooring gangs. Dangers for mooring gangs While mooring activity may not be regarded by some as “cargo-handling”, many organisations have multiskilled staff who carry out cargo handling and mooring operations, so ICHCA indeed considers this topic to be highly relevant. An initial survey of ICHCA’s members found wide disparity in dock/harbour or sea rescue facilities and responses. Answers ranged from no facility or provision at all, or reliance on the emergency services, to full helicopter rescue capability. This is clearly an area of great concern and ISP is carrying out further work in this regard. This includes an update of ICHCA’s publication on personal protective equipment such as life jackets and

The ICHCA Secretariat regularly receives reports of accidents and incidents with respect to cargo handling and related activities, throughout the transport chain, from members and other sources all across the globe. These reports are discussed in detail at meetings of ISP - ICHCA’s Technical Panel, where any accident prevention message and or a review/update of ICHCA’s Technical Publications can be initiated as appropriate. In many cases, we only receive preliminary reports and there is not enough information to arrive at any meaningful conclusions. While we encourage all members to share such reports with us, we also urge you to send as much supporting information as possible. All information received is treated with absolute confidentiality.

Please continue sending your reports to: Richard Brough Technical Director richard.brough@ichca.com

buoyancy aids.

The ICHCA Journal ISSUE #1 January 2014

accidents&incidents

position of moorer

Steel beam

In this incident, a mooring operative was knocked into the water from a mooring dolphin when the mooring rope accidentally released from the automatic hook. He hit his head on the steel beam as he fell into the water

The picture above shows a mooring ‘dolphin’, where a

The ILO Code of Practice on Safety and Health in Ports,

mooring operative was knocked into the water when the

2005 Edition, can be downloaded in English, Spanish

mooring rope accidentally released from the automatic

and French at:

hook. He hit his head on the steel beam as he fell into

www.ilo.org/safework/info/standards-and-instruments/codes

the water. Fatal flatrack operations incident Several of the newspaper reports in this period cited “a

In the following report, risk assessments and safety

lack of technical or occupational safety”. If true, this is a

procedures would, on the face of it, certainly appear

sad state of affairs and totally unacceptable.

to be lacking. A dock worker was fatally injured and another seriously as they fell into the hold of a vessel.

In the absence of a port company’s own guidelines, or

The vessel was loading/discharging vehicles by use of a

national guidance on port

flatrack container. As the flatrack was being loaded back

safety, the comprehensive

onto the vessel, the two workers were standing or sitting

International Labour

on the flatrack itself.

Organization (ILO) Code of Practice on Safety and

Unfortunately, the crane driver managed to knock the

Health in Ports, 2005

container spreader holding the flatrack against the side

Edition, is readily available

of the hold. This resulted in the flatrack detaching from

and contains much useful

the spreader and the two men falling.

information on port and cargo handling safety.

Several incidents involved either incorrect cargo slinging

ICHCA was involved in its

or failure of the slings whilst bundles or setts of timber

revision, along with many of

and steel were being handled. In all reported cases, the

our ISP members.

cargo fell back into the hold and killed or injured dock workers who were unable to get out of the way.

The ICHCA Journal ISSUE #1 January 2014

accidents&incidents ISP members are working on new safety guidance on

were not watertight and therefore gases could be

handling of steel, as there has been a number of such

trapped inside. There was no means of mechanical

incidents reported, especially with the handling of steel

ventilation

pipes/tubes, which will be the primary focus of the new

•

guidelines.

over time • •

concerned safety professionals. Despite many years of campaigning and education, there are still far too many

O2 and CO2 meters should have been used before entry

Enclosed space entry: cargo hold death and injury The subject of enclosed space entry has long

A “low oxygen risk area” warning sign had faded

No-one should have been allowed in until it was declared safe to do so

•

people losing their lives in such incidents.

Proper ventilation of the trunking should have been carried out

•

The shipboard procedures had not been followed

While most would recognise a ballast tank or void space on a vessel as a “confined or enclosed space”,

Our thanks to corporate licensed member Port Skills

many do not regard cargo holds and the accesses

& Safety (PSS) for drawing this report to ICHCA’s

to them in the same way. However there is clear -

attention.

and painful - evidence of fatalities caused through asphyxiation, either brought about by chemicals in the

IMO has been debating at its DSC (Dangerous Goods,

space (such as leaking containers or fumigants) or the

Solid Cargoes and Containers) Sub-committee

cargo itself depleting the oxygen in the hold.

whether all cargo vessels should carry oxygen meters. Some want this to go much further and carry a variety

One such incident recently reported on formally by

of atmosphere testing equipment. Whatever, it is vital

the Hong Kong Marine Department involved a vessel

that all such spaces are declared safe for entry by a

carrying wood pellets.

responsible person before dock workers attempt to access them.

An ordinary seaman and bulldozer operator entered the vessel hold via an enclosed trunking, where they

Aluminium ingot loading fatality investigation results

were overcome quickly and collapsed inside the trunk.

Our final report this edition concerns the outcome of an

The seaman died and the bulldozer operator was

investigation into a fatal accident in Australia involving

seriously injured. Eleven personnel in the rescue team

bundles of aluminium ingots.

felt physically uncomfortable and were admitted to hospital.

On 23 September 2012, a stevedore working on board a general cargo ship died after being crushed under

The wood pellet cargo had oxidised and was also

packs of aluminium ingots, which toppled over during

giving off carbon monoxide. At the point when the hold

loading. Other stevedores raised the alarm and tried to

was opened,the oxygen level was 15%. In the trunking,

help the crushed man but he showed no signs of life.

the level of CO2 was 1000 ppm- i.e lethal!

Paramedics and police officers arrived on the scene shortly afterwards and confirmed that the stevedore

The investigation by the Hong Kong Marine

was dead.

Department’s Accident Investigation Section found several failings in procedures:

An investigation by the Australian Transport Safety

•

Bureau (ATSB) found that the stevedore was climbing

The enclosed stairway trunking access doors

The ICHCA Journal ISSUE #1 January 2014

accidents&incidents

down aluminium ingot packs to work on a lower tier of

to address the issue. The main action taken has been

the cargo when the packs toppled over. It was usual for

the addition of vertical straps to hold ingot stacks in a lift

some stevedores to climb up or down ingot packs to

together (one strap for each pair of adjacent stacks).

work on different cargo tiers instead of using the ladders provided.

The vessels manager has made toppling of cargo a specific agenda item at the daily meetings between

The ATSB investigation identified that the ingot cargo

senior staff on-board its ships and stevedores in all

units or lifts (multiple packs of ingots strapped together)

ports. It has also introduced a policy of rejecting ingot

were inherently unstable and prone to toppling over. The

lifts with broken pack, lifting or unitising straps for

stevedoring company’s procedure for loading aluminium

loading on any of its ships.

products did not adequately address the risk of the cargo toppling over and the implementation of basic

The ATSB has recommended that the stevedore

precautions, such as using ladders to climb between

companies additionally address the issue of stevedore

cargo tiers, was not effectively monitored or enforced.

fatigue.

The ATSB also found that stevedores often worked

It has also issued two safety advisory notices to all

extended hours, exposing the company’s operations to

stevedoring companies regarding issues with ingot

a level of fatigue-related risk that had not been assessed

loading and fatigue risk, with the aim of disseminating a

and treated.

broad safety message.

What’s been done as a result Immediately after the accident, the stevedoring company re-assessed the risks involved in loading aluminium ingots and revised its procedures for managing the risk of an ingot lift toppling. The primary measure was establishing an exclusion zone adjacent to a lift. This was included in a revised procedure for ingot loading with other measures such as the use of ladders. Steps to implement the procedure and ensure compliance included increased monitoring of loading operations. Other safety action taken included: •

An independent review of procedures

•

Retraining of senior grade stevedores in hazard management

•

Developing a process to reject hazardous lifts

•

Suggestions to improve ingot lift configurations

The company responsible for preparing ingot packs for loading has also taken steps to enhance the stability of ingot lifts and a review is ongoing to identify other ways

The ICHCA Journal ISSUE #1 January 2014

ATSB safety advisory message on ingot loading Individual stacks of aluminium ingots and other similar break-bulk cargoes (whether or not strapped together for carriage on ships) should always be considered unstable and prone to toppling over. No work should be undertaken in the vicinity of ingot stacks unless they have been secured to prevent toppling. The full ATSB report and recommendations on this incident are available at www.atsb.gov.au/publications/investigation_ reports/2012/mair/296-mo-2012-010/si-2. aspx

technicalqueries

Our regular report highlights some of the diverse Technical Queries that ICHCA has received and responded to in the past few months TQ1-1 What are the norms or standards for container eccentricities and do they depend on weight?

In all such cases, it is not sufficient for the unit to be supported just on its landing legs and there should be additional supports placed underneath the trailer at the front end, to give extra stability. A special trailer trestle

In general the industry works on a maximum of

or “horse” is preferred, but sometimes stacks of pallets

5% eccentricity. 10% is only permitted in certain

have been used.

circumstances. The ‘rule of thumb’, which is also

TQ1-2 One of our members recently had an incident where a reefer vehicle tipped onto its front end when being loaded. The reefer had been parked on its legs and had only been loaded with 2 pallets of frozen fish into its front end when it unbalanced and tipped.

TQ1-3 There are about 6 grain loading facilities in our country that load grain into containers. Some of our container terminals have stopped receiving the loaded containers at the terminal gate as they are loaded improperly and the containers bulge - usually at the doors - which causes leaking. This bulging also means the containers cannot be stored on deck as they will not fit into the allocated stowage slot and cannot be stored below as the leaking grain plays havoc with the ships bilges. The Australian Authorities have rules on container loading to stop these issues. Are there any in other countries?

This is a very common operation where standing trailers

After considerable research and requests to ISP for

are being loaded with cargo, sometimes with the use

further information it would appear that the Australian

of fork lift trucks being driven into the unit from a dock

Guidelines are the best here. As a general rule however,

loading bay or portable ramp.

no containers in this condition should be accepted for

included in the ISO standard and now the new CTU Packing Code (see p9), is for a maximum of 5% eccentricity when 60% or more of the load is contained in 50% or less of the container’s length or breadth. The same rule of thumb applies to other cargo transport units (i.e., road and rail trailers).

shipment. If grain leaks into the hold it can contaminate other cargoes, mould may develop and there could be consequential clean-up operations and potential claims. Many terminal operators have a policy of placing such containers in a ‘hospital’ or ‘quarantine’ area, well away from terminal stacking areas and seek instructions from the shipper or the shipping line on what to do next.

The ICHCA Journal ISSUE #1 January 2014

technicalqueries

Examples of leaking grain containers If any member wishes to view the Australian Rules then

bulkheads are installed, have a tendency to be

please contact the Technical Director.

uneven. This is frequently due to blowing the grain into the box, resulting in the stow being higher at the far end, which can give rise to lifting problems

There are also some further points to consider for grain shipments in containers:

•

During initial rail carriage, the uneven stow is unlikely to shift to any great extent. It is more likely to settle

•

Carriage of bulk materials of this nature is increasing, but the risk of damage to containers and of injuries is not sufficiently considered

•

Ports should handle containers loaded with grain with spreader equipment rather than centre-hook

The likelihood of damage to containers (bulging

slings, which are likely to stress the upper rails in

sidewalls, bent rails etc.) is increased where cargo

particular

is loaded only to around half the height, especially in 40ft units, due to load concentration at effectively the weakest point of the sidewall •

due to the prevalent dynamic movement on rail

•

The eccentric nature of cargo loading, together with the potential use of slings rather than spreaders for lifting operations, can cause distortion and racking

Use of half height, half width or no bulkheads

to the container structure. Both the eccentric load

increases the likelihood of cargo loss and,

and structural damage may also cause ship loading

particularly at discharge point, bodily injury on

problems, including snagging in the cell guides.The

opening the container doors

consequences of this type of problem can be varied,

•

Loading operations, even where suitable liners and

including damage to the handling equipment and

The ICHCA Journal ISSUE #1 January 2014

technicalqueries the ship, loss of cargo, damage to the container,

forgotten twistlock, that can easily become dislodged

clean-up costs and possibly injuries

and fall on the person below.

The introduction to the Annex on ‘Structural safety

In all cases where there is a potential hazard, a full risk

requirements and tests’ in IMO’s International

assessment should be carried out and formal safety

Convention for Safe Containers Code (CSC) states:

procedures written up, based on that risk assessment.

“In setting the requirements of this Annex, it is implicit

Those procedures should then be enforced effectively.

that in all phases of the operation of containers the forces as a result of motion, location, stacking and

While the picture below does not show an intermodal

weight of the loaded container and external forces will

rail terminal, this is a typical area where containers are

not exceed the design strength of the container. In

handled other than by container quay cranes. Even

particular, the following assumptions have been made:

in rail terminals there will be container movements by

a. The container will so be restrained that it is not subjected to forces in excess of those for which it has been designed; b. The container will have its cargo stowed in accordance with the recommended practices of the

overhead gantries, RTGs, RMGs, reach stackers or FLTs. In all such cases where this type of equipment is operating there is potential risk of something falling from a height and injuring those below, so safety helmets should be mandatory.

trade so that the cargo does not impose upon the container forces in excess of those for which it has been designed.” This is significant in relation to the later CSC sections about packing of containers and cargo securing. Only if containers are selected in accordance with the cargo to be carried and properly packed are they legally in compliance with the CSC.

TQ 1-4 What procedures and policies are in place with respect to the wearing of safety helmets in port rail terminals, particularly for container intermodal transfers? This question is not uncommon, but for the sake of a varied view the Technical Director asked ISP members

TQ1-5 Several terminals under our management are complaining about container vessels that are arriving with lashing bars and equipment dispersed on lashing bridges or crossways.

for a response. In the overwhelming majority of cases companies had policies of mandatory wearing of hard hats (approved safety helmets) wherever containers were being handled. While a safety helmet may not protect a worker if a container falls on him or her, there may be many other smaller objects on the top of the container, such as a

The equipment has not been properly stored by the previous port and the vessel crews have had no time to store all lashing equipment themselves between ports, especially in feedering voyages. In fact, we have had disputes with vessels over this issue. This is causing some real safety issues with risks of a fall from height, slips and trips for The ICHCA Journal ISSUE #1 January 2014

technicalqueries stevedores and also for vesselsâ&#x20AC;&#x2122; crew-members. Can you offer any advice on how this is handled in other terminals? The grainy pictures opposite - apologies for the poor quality but the problem can be clearly seen - were sent in by the member as an example of what the vessel looks like on arrival. This is an issue where, unfortunately, there is no definitive single answer. Much will come down to the commercial relationship between the shipping line and the stevedore and/or third party lashing gang provider. What is clear is that there is a duty on the Master of the vessel to keep walkways and working areas used by personnel free of obstructions, safe and well-lit. This situation has come about because of the productivity and time pressures placed upon ship and stevedore alike. Nevertheless, if there were to be an injury sustained by a stevedore or shipâ&#x20AC;&#x2122;s crew member then potentially there would be a claim for compensation on the vessel operator and/or the stevedoring company. In some ports the stevedores would refuse to work in such conditions and would stand by while the working area was cleared up and lashing gear stowed correctly. Vessel design, although it is unclear from these pictures, may also have a part to play and the new Annex 14 of the Cargo Stowage and Securing Code calls for lashing bar trays or racks to be conveniently located alongside the lashing area to facilitate safe stowage. This situation can only be resolved by looking at who actually has the task (under the commercial arrangements) to safely stow the equipment away and allowing sufficient time in port for the task to be carried out. If, for whatever reason, the vessel has to sail before this task is completed then it falls upon the vessel to complete the task before arrival in the next port.

The ICHCA Journal ISSUE #1 January 2014

technicalqueries

“

Having a strong global reference point for technical questions is very important. When new issues arise, there is a panel of technical experts who can research and report on the issue and lobby where necessary on a very high level (member feedback)

ICHCA’s Technical Query service: a valuable resource for members Technical Queries (TQs) are received from ICHCA members and associates throughout the year on a very wide range of topics, as can be seen from the summary report on the preceding pages. Queries are extensively researched using ICHCA’s own technical library and/ or in-house publications, along with comprehensive checking against relevant international legislation and guidance documents. The Technical Director also uses his own knowledge and experience to augment the response where appropriate. From time to time, ISP - ICHCA’s Technical Panel, is also asked to give its feedback so that a range of responses can be gathered. During 2014, the Secretariat will be compiling a comprehensive archive of previous TQs, which will be made available on the members’ area of the ICHCA website. Meanwhile, The ICHCA Journal will now carry regular reports on some of the queries received and responded to over the previous quarter. Any member who needs assistance with a similar query should contact the Technical Director, Richard Brough on richard.brough@ichca.com. All queries are treated in the strictest confidence.

The ICHCA Journal ISSUE #1 January 2014

news&events

Do you have the right IMDG Code? Amendment 36-12to the International Maritime Dangerous Goods (IMDG) Code became mandatory on 1 January 2014. Previous copies of the Code should now be destroyed as the information contained may be out of date. The various changes in the new edition have already been communicated in previous newsletters. ICHCA’s BP3 publication on the IMDG Code has now been completely revised and will be published in February. ICHCA safety cards IIL1 and IIL2, covering documentation requirements, labelling and placarding, are currently with sponsor TT Club for review and will be available shortly as downloadable PDFs. Copies of the two-volume Code are available to ICHCA members at a 15% discount on IMO’s published prices. The includes hard copy and e-versions. Contact the secretariat at support@ichca.com for more information. The third volume, which contains supplementary

information, is updated by ‘flyers’ available from the IMO website. The current version of the ‘Supplement’ is the 2010 edition. Following several complaints, IMO has now promised to replace any copies of the IMDG Code that have faulty binding at no cost to the purchaser. Work has already commenced on the next amendment, 37-14, on the continuing two year cycle IMO has also issued its latest “Errata and Corrigenda” for the 2012 Edition. While these do not contain any substantive changes, there are a number of important corrections to entries in the list of dangerous substances and several others related to packing and tank provisions, consignments procedures etc. Copies of the “Errata and Corrigenda” are freely available to download from the IMO website or from ICHCA’s Technical Director at richard.brough@ichca.com

International Maritime Solid Bulk Cargoes Code amendment 02-13 The newest edition of the International Maritime Solid Bulk Cargoes (IMSBC) Code is amendment 02-13, which may be applied on a voluntary basis from 1 January this year in place of the previous version, which became mandatory on 1 January 2011. Amendment 02-13 will itself become mandatory on 1 January 2015 and work has already commenced at IMO on amendment 03-15. 36

Discounted copies of the IMSBC Code are also available to ICHCA members. Email support@ichca.com for more information. If any members have concerns over the changes to either the IMDG or IMSBC Codes, please contact: Richard Brough Technical Director richard.brough@ichca.com

The ICHCA Journal ISSUE #1 January 2014

news&events

IMO MSC confirms sub-committee changes IMO’s Maritime Safety Committee (MSC) has restructured its sub-committees as part of a general review and reform process initiated by IMO Secretary General Koji Sekimizu. As a recognised non-governmental organisation (NGO) at IMO, ICHCA International has been involved mainly with MSC and, more particularly, with its subsidiary committees on Dangerous Goods, Solid Cargoes and Containers (DSC) and Ship Design and Equipment (DE). This is all now set to change, with MSC reducing the number of its sub-committees from nine to seven. Under the new system, DSC becomes CCC, the Subcommittee on Carriage of Cargoes and Containers. DE becomes SSE, the Sub-Committee on Ship Systems and Equipment. The ongoing work on mandatory weighing of containers and liquefaction of bulk cargoes will now be handled by CCC and that on ships’ lifting appliances by SSE. The other sub-committees, with which ICHCA generally has less input (depending on the agenda) have been announced as:

•

HTW: Human element, training and watch-keeping (formerly STW)

•

III: Implementation of IMO Instruments (formerly FSI)

•

NCSR: Navigation, Communications and Search and Rescue (formerly COMSAR and NAV)

•

PPR: Pollution Prevention and Response (formerly BLG)

•

SDC: Ship Design and Construction (formerly DE, FP and SLF)

The new CCC also has its own Editorial and Technical (E&T) Group which carries out further detailed work on legislation and amendments to the IMDG and IMSBC Codes. ICHCA normally attends these sessions as well. Sub-committees meet at the IMO building on London’s Albert Embankment, opposite the Houses of Parliament. Any ICHCA member wishing to contribute to the association’s work at IMO and other UN agencies is invited to contact Technical Director Richard Brough richard.brough@ichca.com. Please see p38 for a list of 2014 IMO sessions/activities.

ILO update ICHCA also has NGO status with the International Labour Organization (ILO) and the most important piece of work here in the past was the review of the Code of Practice on Safety and Health in Ports. It is understood that this work may be reviewed in the next ‘biennium’ agenda and members will be kept updated. More recently of course, the ‘Group of Experts’ in which ICHCA took part concluded its work on the new IMO/ILO/ UNECE Code of Practice for Packing Cargo Transport Units (see pp.9-18 for full reports). This work is expected to be approved by the three governing bodies of the sponsoring UN organisations and published later this year. The last body to approve will be the ILO itself at its meeting in November. ICHCA will be hosting a series of “roadshows” to help affected companies understand how to read the Code and implement its guidance. More information will be circulated on these as it becomes available. In the meantime, if any member wishes to see a copy of the draft Code then please contact the secretariat. Also now completed with ICHCA involvement and published last year is the ILO’s Guidelines on Training in the Port Sector, which is freely downloadable from the ILO website at: www.ilo.org/sector/Resources/codes-of-practice-and-guidelines/WCMS_175376/lang--en/index.htm

The ICHCA Journal ISSUE #1 January 2014

news&events

IMO sessions in 2014 SESSION/DATE

KEY BUSINESS ITEMS

SSE 1

•

10-14 MARCH

Debate on proposals to include examination and certification of all ships’ llfting appliances under SOLAS

CCC E&T 21

•

Amendments to the IMSBC Code and any other matters addressed to the E&TGroup by CCC

28 APR-2 MAY

•

There will also be another session of the E&T Group immediately following CCC 1 in September

msc 93

•

Approval of DSC amendment to SOLAS to mandate compulsory weighing of containers or

14-21 MAY

their contents •

Adoption/endorsement of recommendations by DSC 18, including: »»

Invitation to BIC to further develop the ACEP scheme database

»»

Decision to amend Chapter 7 of the IMDG Code with respect to counterfeit refrigerants (this work was initiated by a joint USA and ICHCA submission following serious incidents including fatalities)

»»

Decision to develop an IMO Model Course for the Safe Transport of Solid Bulk Cargoes

»»

DSC circular on early implementation of the draft amendments to the IMSBC Code relating to the draft schedule for iron ore fines

»»

New requirement for vessels to carry portable atmosphere testing equipment for enclosed spaces

CCC 1

•

BIC database for container ACEP schemes

8-12 SEP

•

Liquefaction of bulk cargoes

•

Container losses overboard - measures other than weighing

•

Code of Practice on Packing of Cargo Transport Units

•

Container refrigerants

•

Other matters concerning safe handling and carriage of containers, e.g. further development of amendments to the CSC (Convention for Safe Containers) 1972

•

Latest proposed amendments to IMDG (37-14) and IMSBC Codes (03-15)

•

Casualty and incident reports, including reports of discrepancies found in dangerous goods shipments

•

Bulk cargoes classified as HME (Harmful to the Marine Environment) as specified in MARPOL annex V

•

How to deal with old type IMO portable tanks and road tank vehicles for transport of dangerous goods

msc 94

•

SOLAS amendment for weighing of containers to be “adopted” if approved by MSC 93

17-21 NOV INTER SESSIONAL

ICHCA members are involved in the formal inter-sessional IMO Correspondence Groups dealing

WORK GROUPS

with the following topics: •

Liquefaction of Bulk Cargoes and Schedules for Iron Ore Fines

•

Proposals for SOLAS amendment to include examinations of Ships Lifting Appliances

•

Safety signs and walkways in Ports and Airports

•

HME (Harmful to the Marine Environment) substances within the IMSBC Code in relation to the revised MARPOL Annex V

•

Revision to the Guidance on the continued use of existing IMO type portable tanks and road tank vehicles for the transport of dangerous goods (DSC/Circ.12 and Corrigenda)

The ICHCA Journal ISSUE #1 January 2014

news&events

ISP - ICHCA’s Technical Panel Currently with over 70 members from around the world and all manner of sectors, ISP - ICHCA’s Technical Panel is flourishing and carrying out a wide range of activities on behalf of the membership and indeed the industry at large. Along with the Technical Director, Panel members have been involved in all of the recent legislative activity at the various UN bodies with which ICHCA has NGO status with. In fact at the last DSC meeting at IMO, where the debate focused on mandatory weighing of containers and the new CTU Packing Code, we had the largest contingent of delegates from an NGO, with over 15 members present. The Panel has also been busy contributing to the ICHCA internal Correspondence Groups that feed into our deliberations at the IMO and elsewhere. Three ISP meetings were held in 2013: one in the Port of Cork, Ireland and two in London. All three sessions were wellattended and there was much to debate, with several new initiatives on the table. Key topics currently under review include: • Lashing and securing of containers • Problems with corner castings • Rescuing personnel from the dock/harbour • Lifejackets and personal protective equipment • 2 x 20’ containers lifted by spreader in 40’ mode

authoring or reviewing and updating. There are some14 publications that have been through this process and will be published to the website member-only area for downloading over the next few months. We regret the length of time it has taken to bring these to conclusion; this unavoidable delay was due to the recent workload of the secretariat during transition to the new arrangements. However, normal service on publications will be restored very soon. The first such

reviewed publication - BP3on the IMDG Code - is due to be issued in February.

The meetings have seen a wide range of presentations which will be made available to all members on the website shortly.

A very busy meeting for ISP#71 is scheduled for Malaga in Spain from 10-12 February and the Panel is being kindly hosted by the Port of Malaga and new member Noatum Ports. As well as the busy agenda which will include interactive breakout sessions, there will be a joint session with PEMA (Port Equipment Manufacturers Association) on collision prevention in terminals - another new initiative for 2014.

The Panel is also the source of many of ICHCA’s publications and Panel members are involved in either

A report on ISP#71 and other Panel activities will be published in the next issue of The ICHCA Journal.

Are you interested in joining ISP? ISP membership is by invitation/approval, based on each individual member’s personal credentials, knowledge and experience in their particular field of expertise. If you are interested in taking part as a full or corresponding member, please contact the secretariat at support@ichca.com and we will forward your details to the Panel chair.

The ICHCA Journal ISSUE #1 January 2014

news&events

ISO update ICHCA is also recognised as an NGO by ISO, the International Organization for Standardization, and participates in a number of its working groups from time to time. In particular, we are concerned with those ISO groups involved in standards for containers and their lashing systems and equipment. We were therefore pleased to be represented at the last meeting of ISO/TC 104 SC 1: WG 2, which took place in Hamburg last October. (TC stands for Technical Committee and TC 104 is specifically related to Freight Containers. SC 1 is the Sub-committee related to General Purpose Containers.) Among other topics, the Working Group discussed: • • •

Working draft of ISO 17905 Revision of ISO 3874 (Series 1 Freight Containers Handling and securing) ISO/TR 15069 (Series 1 Freight Containers - Handling and Securing – rationale for ISO 3874 Annex A)

We were very grateful to Kirk Mandt of ICHCA ISP Panel member Robert Bock - German Lashing for attending this meeting on the Association’s behalf. The ISO review requested by IMO in response to ICHCA’s submission to DSC on other concerns raised in the MARIN report “lashing @sea” regarding losses of containers overboard is not yet completed and we will keep members updated as it progresses. The next meeting of ISP in Malaga this February will be debating this topic, among many others. There will also be a full update on latest revisions and changes to ISO standards that may affect members in the next edition of The ICHCA Journal.

Changes to SOLAS From 1 January 2014, SOLAS - IMO’s International Convention on the Safety of Life at Sea - has been modified in several areas. Of particular potential significance to ICHCA members is an amendment to Chapter VII, to replace Regulation 4 on documents covering transport information relating to the carriage of dangerous goods in packaged form and the container/vehicle packing certificate.

Peel Ports to host ISP 72 meeting in Liverpool UK port operator Peel Ports has kindly agreed to host the next meeting of ISP - ICHCA’s Technical Panel, in Liverpool. ISP 72 will take place on 7-8 October at the Maritime Centre, Peel Ports’ HQ in the Port of Liverpool. The meeting will include a tour of the Port of Liverpool, courtesy of Peel Ports, which among other investments is currently developing the Liverpool2 regional container hub port with the adoption of automated stacking cranes and other advanced technology. More details will be announced shortly; in the meantime, our thanks to Peel Ports for hosting what we are sure will be another productive ISP meeting. www.peelports.com

News and articles - we’d like to hear from you Members are enouraged to add ICHCA to your media mailing list and connect with us on twitter @ICHCA2, where you will now find a lively stream of industry updates published daily (also appearing on the ICHCA website homepage). Please also send us your suggestions and/or submissions for technical, regulatory or other articles that you would like see included in future editions of The ICHCA Journal. Contact the secretariat at support@ichca.com 40

The ICHCA Journal ISSUE #1 January 2014

news&events

Upcoming events Our listing focuses on events organised by ICHCA and its members, those where ICHCA representatives are attending and those where ICHCA is an official supporting organisation, usually with special rates available to members. Any member who would like to add to the listing, please contact the secretariat at support@ichca.com

DATE

VENUE

EVENT

for more details

11-12 February

Malaga, Spain

ISP 71 meeting Open to members of ISP - ICHCA’s Technical Panel; ICHCA members welcome as observers

Helen Coffey helen.coffey@ichca.com https: //www.etouches.com/ ichca-isp71

19 February

West Lakes, Australia

ICHCA Australia luncheon meeting With guest speaker Capt. Ian Ives, Director, Transhipping and New Business Development, CSL Australia Pty Ltd on “Transhipment: Getting ore to market through shallow ports”

Deb Warda deb.warda@ichca.com

19 February

West Lakes, Australia

ICHCA Australia agm Open to ICHCA Australia members

Ian Lovell ian.lovell@ichca.com

27-28 February

Melbourne, Australia

6th Intermodal Asia 2014 ICHCA South Australia Chairman Neil Murphy will speak on current container trade opportunities and risks. ICHCA member John Warda, Emerald Grain, will talk about managing grain operations through intermodal networks. ICHCA is an official supporting organisation for this event and members qualify for a 20% discount. Quote ICHCA when you register

www.transportevents.com

2-4 March

Cape Town, South Africa

3rd cool logistics africa 2014 ICHCA is an official supporting organisation for this event and members qualify for a 15% discount. Quote ICHCA2014 when you register

www.coollogisticsafrica.com

4 March

Brussels, Belgium

FERRMED conference on Efficient multimodal transport in Europe ICHCA Technical Director Richard Brough will attend on behalf of the association

www.ferrmed.com

19 March

London, UK

international salvage union associate members’ day ICHCA Technical Director Richard Brough will be attending and speaking

www.marine-salvage.com

27-28 March

Lago, Nigeria

12th intermodal africa north ICHCA is an official supporting organisation for this event and members qualify for a 20% discount. Quote ICHCA when you register

www.transportevents.com

23-24 April

Marrakech, Morocco

2nd med ports 2014 ICHCA is an official supporting organisation for this event and members qualify for a 20% discount. Quote ICHCA when you register

www.transportevents.com

29 Apr-1 May

Birmingham, UK

Multimodal 2014 ICHCA Technical Director Richard Brough will join a panel on container packing and weighing on 30 April. Registration for seminar sessions is free.

www.multimodal.org.uk

The ICHCA Journal ISSUE #1 January 2014

legaldetail

Extracts from DSC 18 WP3: Report of the Container Safety Working Group SUB-COMMITTEE ON DANGEROUS GOODS, SOLID CARGOES AND CONTAINERS 18th session Agenda items 5 and 8 DEVELOPMENT OF MEASURES TO PREVENT LOSS OF CONTAINERS REVISION OF THE GUIDELINES FOR PACKING OF CARGO TRANSPORT UNITS GENERAL 1. The Working Group on Container Safety met from 16 to 18 September 2013 under the chairmanship of Mr. K. Smith (United States). 2. The group was attended by delegations from the following Member Governments: BRAZIL, CHINA, CYPRUS, DENMARK, ESTONIA, FINLAND, FRANCE, GERMANY, GREECE, JAPAN, LIBERIA, MARSHALL ISLANDS, NETHERLANDS, NEW ZEALAND, NIGERIA, NORWAY, PANAMA, PERU, REPUBLIC OF KOREA, RUSSIAN FEDERATION, SLOVAKIA, SPAIN, SWEDEN, UNITED KINGDOM, UNITED STATES and the following Associate Member of IMO: HONG KONG, CHINA 3. The group was also attended by representatives from the following United Nations and specialized agencies: INTERNATIONAL LABOUR ORGANIZATION (ILO) UNITED NATIONS ECONOMIC COMMISSION FOR EUROPE (UNECE) and observers from the following non-governmental organizations in consultative status: INTERNATIONAL CHAMBER OF SHIPPING (ICS)

INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO) INTERNATIONAL ASSOCIATION OF PORTS AND HARBORS (IAPH) BIMCO ICHCA INTERNATIONAL LIMITED (ICHCA) EUROPEAN CHEMICAL INDUSTRY COUNCIL (CEFIC) INSTITUTE OF INTERNATIONAL CONTAINER LESSORS (IICL) INTERNATIONAL ASSOCIATION OF DRILLING CONTRACTORS (IADC) INTERNATIONAL GROUP OF PROTECTION AND INDEMNITY ASSOCIATIONS (P & I Clubs) INTERNATIONAL ROAD TRANSPORT UNION (IRU) THE INTERNATIONAL MARINE CONTRACTORS ASSOCIATION (IMCA) INTERNATIONAL TRANSPORT WORKERSâ&#x20AC;&#x2122; FEDERATION (ITF) WORLD SHIPPING COUNCIL (WSC) THE NAUTICAL INSTITUTE (NI) TERMS OF REFERENCE 4. Taking into account the comments and decisions made in plenary, the working group was instructed to: With regard to agenda item 5: .1 finalize the draft amendments to SOLAS regulation VI/2 and the draft Guidelines regarding verified gross mass of a container carrying cargo, based on document DSC 18/5; .2 further consider the matter related to preventing the use of counterfeit refrigerants, taking into account document DSC 18/5/5, and advise the Sub-Committee on how to deal with the matter of responsibility, related to the proposed modifications of the draft amendment to paragraph 7.3.7.2.4 of

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the IMDG Code to refer to E&T 20 for finalization; DEVELOPMENT OF MEASURES TO PREVENT LOSS OF CONTAINERS Draft amendments to SOLAS chapter VI: 5. As instructed by the Sub-Committee, the group considered the draft amendments to SOLAS chapter VI, regarding mandatory verification of gross weight of containers, based on Annex 1 to document DSC 18/5, and after an in-depth discussion of all the issues involved, the group finalized the draft amendments to SOLAS regulation VI/2, as set out in annex 1. Draft Guidelines regarding the verified gross mass of a container carrying cargo: 6. Having considered the draft Guidelines regarding the verified gross mass of a container carrying cargo (DSC 18/5, annex 2), the group took action as indicated hereunder. Scope of application 7. The group considered the comments from the delegation of Spain, made in plenary, regarding paragraph 4 of the draft Guidelines, concerning the scope of application and concluded that there is no contradiction, as the draft Guidelines apply to containers tendered by a shipper and not to single cargo items which are delivered to the ship and packed on board into a container. Methods for obtaining the verified gross mass of a packed container: 8. In considering comments from the delegation of Spain concerning paragraph 7.2.1 of the draft Guidelines,

legaldetail the group agreed that no additional amendments were necessary. Verified gross mass 9. The group considered the comments from the delegation of Belgium in plenary, that in the draft Guidelines, the mass should not be considered at the time of booking, but after the container is packed, and noted that it is recognized that it is commercial practice for the shipper to provide a gross mass to the carrier at the time of booking. However, in the draft amendments to SOLAS regulation VI/2.5 and paragraph 8 of the draft Guidelines regarding the verified gross mass of a container carrying cargo, as set out in annexes 1 and 2, respectively, it is specified that it is the verified gross mass which must be used on the documentation and as a condition for ship loading. If the gross mass is already verified at the time of booking it can be used for ship stowage purposes. Equipment 10. In considering section 11 (Equipment) of the draft Guidelines on whether accuracy standards should be defined in the draft Guidelines, as there may be different standards in various States, and noting that IMO guidelines cannot interfere with national regulations, the group decided to keep the draft text as prepared by the correspondence group. Master’s discretion 11. In response to the enquiry from the delegation of Greece about the meaning and scope of paragraph 20 of the draft Guidelines, the consensus view of the group was that the paragraph as drafted embodies and reaffirms the Master’s discretion to require an individual packed container to be weighed as condition for ship stowage if the Master has concerns about the validity of the verified gross mass provided in the shipping document.

As this already follows from the pertinent SOLAS provisions, the group also agreed that it is not necessary to amend the proposed amendments to SOLAS regulation VI/2 and/or paragraph 20 of the draft Guidelines further regarding the Master’s discretion to accept or deny shipments for ship stowage.

items, including the mass of pallets, dunnage and other securing material to be packed in the container and adding the tare mass of the container to the sum of the single masses, using a certified method approved by the competent authority of the State in which packing of the container was completed.

Enforcement

5. The shipper of a container shall ensure the verified gross mass is stated in the shipping document. The shipping document shall be: .1 signed by a person duly authorized by the shipper; and .2 submitted to the master or his representative and to the terminal representative sufficiently in advance, as required by the master or his representative, to be used in the preparation of the ship stowage plan‡

12. The group considered the comments from the delegation of the Bahamas, made in plenary, concerning enforcement and how obligation should be placed on port States to ensure shippers are acting responsibly. In this context, the group reviewed paragraphs 21 and 22 of the draft Guidelines and amended the draft text to reflect that it is a requirement of Contracting Parties to ensure SOLAS requirements are enforced. Draft Guidelines regarding the verified gross mass of a container carrying cargo: 13. After a lengthy discussion of all related matters, the group prepared the draft Guidelines regarding the verified gross mass of a container carrying cargo, as set out in annex 2 to this report ANNEX 1 DRAFT AMENDMENTS TO SOLAS CHAPTER VI Part A General Provisions Regulation 2 – Cargo information The new paragraphs 4, 5 and 6 are added after the existing paragraph 3, as follows: 4. In the case of cargo carried in a container, the gross mass according to paragraph 2.1 of this regulation shall be verified by the shipper, either by: .1 weighing the packed container using calibrated and certified equipment; or .2 weighing all packages and cargo

6. If the shipping document, with regard to a packed container, does not provide the verified gross mass and the master or his representative and the terminal representative have not obtained the verified gross mass of the packed container, it shall not be loaded on to the ship. The term “container” has the same meaning as that term is defined and applied in the International Convention for Safe Containers (CSC), 1972, as amended, taking into account the Guidelines for the approval of offshore containers handled in open seas (MSC.1/Circ.860) and the Revised Recommendations on harmonized interpretation and implementation of the International Convention for Safe Containers, 1972, as amended (CSC.1/ Circ.138/Rev.1). † Refer to the Guidelines regarding the verified gross mass of a container carrying cargo (MSC.1/Circ.[…]). ‡ This document may be presented by means of EDP or EDI transmission techniques. The signature may be electronic signature or may be replaced by the name in capitals of the person authorized to sign.

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Annex 2 Draft MSC Circular: Guidelines regarding the verified gross mass of a container carrying cargo 1. The Maritime Safety Committee, at its [ninety-third session (14 to 23 May 2014)], having considered the proposal by the Sub-Committee on Dangerous Goods, Solid Cargoes and Containers, at its eighteenth session (16 to 20 September 2013), approved the Guidelines regarding the verified gross mass of a container carrying cargo, as set out in the annex. 2 The Guidelines are intended to establish a common approach for the implementation and enforcement of the SOLAS requirements regarding the verification of the gross mass of packed containers. 3 Member Governments are invited to bring the annexed Guidelines to the attention of all parties concerned. GUIDELINES REGARDING THE VERIFIED GROSS MASS OF A CONTAINER CARRYING CARGO Introduction 1 To ensure the safety of the ship, the safety of workers both aboard ships and ashore, the safety of cargo and overall safety at sea, the International Convention for the Safety of Life at Sea (SOLAS), as amended, requires in chapter VI, part A, regulation 2 that packed containers’ gross mass are verified prior to stowage aboard ship. The shipper is responsible for the verification of the gross mass of a container carrying cargo (hereinafter “a packed container”). The shipper is also responsible for ensuring that the verified gross mass is communicated in the shipping documents sufficiently in advance to be used by the ship’s master or his representative and the terminal representative in the preparation of the ship stowage plan. In the absence of the shipper providing the verified gross mass

of the packed container, the container should not be loaded on to the ship unless the master or his representative and the terminal representative have obtained the verified gross mass through other means. 2 The purpose of these Guidelines is to establish a common approach for the implementation and enforcement of the SOLAS requirements regarding the verification of the gross mass of packed containers. The Guidelines provide recommendations on how to interpret and apply the provisions of the SOLAS requirements. They also identify issues that may arise from the application of these requirements and provide guidance for how such issues should be resolved. Adherence to these Guidelines will facilitate compliance with the SOLAS requirements by shippers of containerized shipments, and they will assist other parties in international containerized supply chains, including shipping companies and port terminal facilities and their employees, in understanding their respective roles in accomplishing the enhancement of the safe handling, stowage and transport of containers. Definitions 3 For the purpose of these Guidelines: Administration means the Government of the State whose flag the ship is entitled to fly. Calibrated and certified equipment means a scale, weighbridge, lifting equipment or any other device, capable of determining the actual gross mass of a packed container or of packages and cargo items, pallets, dunnage and other packing and securing material, that meets the accuracy standards and

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requirements of the State in which the equipment is being used. Cargo items has the same general meaning as the term “cargo” in the International Convention for Safe Containers, 1972, as amended (hereinafter referred to as “the CSC”), and means any goods, wares, merchandise, liquids, gases, solids and articles of every kind whatsoever carried in containers pursuant to a contract of carriage. However, ship’s equipment and ship’s supplies, including ship’s spare parts and stores, carried in containers are not regarded as cargo. (Refer to the revised Recommendations on the safe transport of dangerous cargoes and related activities in port areas (MSC.1/Circ.1216).) Container has the same meaning as the term “container” in the CSC and means an article of transport equipment: (a) of a permanent character and accordingly strong enough to be suitable for repeated use; (b) specially designed to facilitate the transport of goods, by one or more modes of transport, without intermediate reloading; (c) designed to be secured and/or readily handled, having corner fittings for these purposes; and (d) of a size such that the area enclosed by the four outer bottom corners is either: (i) at least 14 m (150 sq. ft.); or (ii) at least 7 m (75 sq. ft) if it is fitted with top corner fittings. The term container includes tankcontainers, flat-racks, bulk containers etc. Also included are containers carried on a chassis or a trailer except when such containers are driven on or off a ro-ro ship engaged in short international voyages

legaldetail (see definition of ship). Excluded from the definition is any type of vehicle. Also excluded from the definition are “offshore containers” to which the CSC, according to the Guidelines for the approval of offshore containers handled in open seas (MSC/Circ.860) and the Revised Recommendations on harmonized interpretation and implementation of the International Convention for Safe Containers, 1972, as amended (CSC.1/Circ.138/Rev.1), does not apply.

is any material within individual sealed packages to protect the cargo item(s) inside the package. Refer to the Revised Recommendations on harmonized interpretation and implementation of the International Convention for Safe Containers 1972, as amended (CSC.1/Circ.138/Rev.1). Securing material means all dunnage, lashing and other equipment used to block, brace, and secure packed cargo items in a container.

Contract of carriage means a contract in which a shipping company, against the payment of freight, undertakes to carry goods from one place to another. The contract may take the form of, or be evidenced by a document such as sea waybill, a bill of lading, or multi-modal transport document.

Ship means any vessel to which SOLAS chapter VI applies. Excluded from this definition are roll-on/roll-off (ro-ro) ships engaged on short international voyages where the containers are carried on a chassis or trailer and are loaded and unloaded by being driven on and off such a ship.

Gross mass means the combined mass of a container’s tare mass and the masses of all packages and cargo items, including pallets, dunnage and other packing material and securing materials packed into the container (See also “Verified gross mass”).

Shipper means a legal entity or person named on the bill of lading or sea waybill or equivalent multimodal transport document (e.g. “through” bill of lading) as shipper and/or who (or in whose name or on whose behalf) a contract of carriage has been concluded with a shipping company.

Package means one or more cargo items that are tied together, packed, wrapped, boxed or parcelled for transportation. Examples of packages include, but are not limited to, parcels, boxes, packets and cartons. Packed container means a container, as previously defined, loaded (“stuffed” or “filled”) with liquids, gases, solids, packages and cargo items, including pallets, dunnage, and other packing material and securing materials. Packing material means any material used or for use with packages and cargo items to prevent damage, including, but not limited to, crates, packing blocks, drums, cases, boxes, barrels, and skids. Excluded from the definition

Shipping document means a document used by the shipper to communicate the verified gross mass of the packed container. This document can be part of the shipping instructions to the shipping company or a separate communication (e.g. a declaration including a weight certificate produced by a weigh station). Tare mass means the mass of an empty container that does not contain any packages, cargo items, pallets, dunnage, or any other packing material or securing material. Terminal representative means a person acting on behalf of a legal entity or person engaged in the business of providing wharfage, dock, stowage, warehouse,

or other cargo handling services in connection with a ship. Verified gross mass means the total gross mass of a packed container as obtained by one of the methods described in paragraph 7 of these Guidelines. (See also “gross mass”). Scope of applicability 4 The SOLAS requirements to verify the gross mass of a packed container apply to all containers to which the CSC applies, and which are to be stowed onto a ship determined by the Administration to be subject to SOLAS chapter VI. For example (but not limited to), a packed container on a chassis or trailer to be driven on a ro-ro ship is subject to the SOLAS requirements, if the ship has been determined by the Administration to be subject to SOLAS chapter VI and is not engaged on short international voyages. However, cargo items tendered by a shipper to the master for packing into a container already on board the ship are not subject to these SOLAS requirements. Main principles 5 The responsibility for obtaining and documenting the verified gross mass of a packed container lies with the shipper. 6 A container packed with packages and cargo items should not be loaded onto a ship to which the SOLAS regulations apply unless the master or his representative and the terminal representative have obtained, in advance of vessel loading, the verified actual gross mass of the container. SOLAS regulation III/2 defines “short international voyage” as an international voyage in the course of which a ship is not more than 200 miles from a port or place in which the passengers and crew could be placed in safety, and which does not exceed 600 miles in length between

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legaldetail Annex 2 Draft MSC Circular: Guidelines regarding the verified gross mass of a container carrying cargo the last port of call in the country in which the voyage begins and the final port of destination. Methods for obtaining the verified gross mass of a packed container 7 The SOLAS regulations prescribe two methods by which the shipper may obtain the verified gross mass of a packed container: 7.1 Method No.1: Upon the conclusion of packing and sealing a container, the shipper may weigh, or have arranged that a third party weighs, the packed container. 7.2 Method No.2: The shipper (or, by arrangement of the shipper, a third party), may weigh all packages and cargo items, including the mass of pallets, dunnage and other packing and securing material to be packed in the container, and add the tare mass of the container to the sum of the single masses using a certified method as described in paragraphs 7.2.3 and 7.2.3.1. Any third party that has performed some or all of the packing of the container should inform the shipper of the mass of the cargo items and packing and securing material that the party has packed into the container in order to facilitate the shipper’s verification of the gross mass of the packed container under Method No.2. As required by SOLAS VI/2, paragraph 5, the shipper should ensure that the verified gross mass of the container is provided sufficiently in advance of vessel loading. How such information is to be communicated between the shipper and any third party should be agreed between the commercial parties involved. 7.2.1 Individual, original sealed packages that have the accurate mass of the packages and cargo items (including any other material such as packing material

and refrigerants inside the packages) clearly and permanently marked on their surfaces, do not need to be weighed again when they are packed into the container. 7.2.2 Certain types of cargo items (e.g. scrap metal, unbagged grain and other cargo in bulk) do not easily lend themselves to individual weighing of the items to be packed in the container. In such cases, usage of Method No.2 would be inappropriate and impractical, and Method No.1 should be used instead. 7.2.3 The method used for weighing the container’s contents under Method No.2 is subject to certification and approval as determined by the competent authority of the State in which the packing and sealing of the container was completed. 7.2.3.1 How the certification is to be done will be up to the State concerned, and could pertain to either the procedure for the weighing or to the party performing the weighing or both. 7.3 If a container is packed by multiple parties or contains cargo from multiple parties, the shipper as defined in paragraph 3 is responsible for obtaining and documenting the verified gross mass of the packed container. If the shipper chooses Method No.2 to obtain the verified gross mass, the shipper is then subject to all the conditions given in paragraphs 7.2, 7.2.1, 7.2.2, and 7.2.3. Documentation 8 The SOLAS regulations require the shipper to verify the gross mass of the packed container using Method No.1 or Method No.2 and to communicate the verified gross mass in a shipping document. This document can be part of the shipping instructions to the shipping company or a separate communication (e.g. a declaration including a weight certificate produced by a weigh station utilizing calibrated and certified equipment

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on the route between the shipper’s origin and the port terminal). In either case, the document should clearly highlight that the gross mass provided is the “verified gross mass” as defined in paragraph 3. (Reference to the relevant MSC Circular regarding contact information for the competent authority) 9 Irrespective of its form, the document declaring the verified gross mass of the packed container should be signed by a person duly authorized by the shipper. The signature may be an electronic signature or may be replaced by the name in capitals of the person authorized to sign it. 10 It is a condition for loading onto a ship to which the SOLAS regulations apply that the verified gross mass of a packed container be provided, preferably by electronic means such as Electronic Data Interchange (EDI) or Electronic Data Processing (EDP), to the ship’s master or his representative and to the terminal representative sufficiently in advance of ship loading to be used in the preparation and implementation of the ship stowage plan. 10.1 Because the contract of carriage is between the shipper and the shipping company, not between the shipper and the port terminal facility, the shipper may meet its obligation under the SOLAS regulations by submitting the verified gross mass to the shipping company. It is then the responsibility of the shipping company to provide information regarding the verified gross mass of the packed container to the terminal representative in advance of ship loading. Similarly, the shipper may also submit the verified gross mass to the port terminal facility representative upon delivery of the container to the port facility in advance of loading. 10.1.1 The master or his representative enter into arrangements to ensure the

legaldetail prompt sharing of verified container gross mass information provided by shippers. Existing communication systems may be used for the transmission and sharing of such verified container gross mass information. 10.1.2 At the time a packed container is delivered to a port terminal facility, the terminal representative should have been informed by the shipping company whether the shipper has provided the verified gross mass of the packed container and what that gross mass is. 10.2 There is no SOLAS prescribed time deadline for the shipper’s submission of the verified gross mass other than such information is to be received in time to be used by the master and the terminal representative in the ship stowage plan. The finalization of the ship stowage plan will depend on ship type and size, local port loading procedures, trade lane and other operational factors. It is the responsibility of the shipping company with whom the shipper enters into a contract of carriage to inform the shipper, following prior discussions with the port terminal, of any specific time deadline for submitting the information. Equipment 11 The scale, weighbridge, lifting equipment or other devices used to verify the gross mass of the container, in accordance with either Method No.1 or Method No.2 discussed above, should meet the applicable accuracy standards and requirements of the State in which the equipment is being used. Intermodal container and transhipments

movements

12 The verified gross mass of a packed container should be provided to the next party taking custody of the container. 12.1 If a packed container is transported by road, rail or a vessel to which the SOLAS regulations do not apply and

delivered to a port terminal facility without its verified gross mass, it may not be loaded onto a ship to which the SOLAS regulations apply unless the master or his representative and the terminal representative have obtained the verified gross mass of the container on behalf of the shipper (see also paragraph 19). 12.2 If a packed container is delivered to a port terminal facility by a ship to which the SOLAS regulations apply for transhipment onto a ship to which the SOLAS regulations also apply, each container being delivered is required by the SOLAS regulations to have had a verified gross mass before loading onto the delivering ship. All packed containers discharged in the transhipment port should therefore already have a verified gross mass and further weighing in the transhipment port facility is not required. The delivering ship should inform the port terminal facility in the transhipment port of the verified gross mass of each delivered packed container. The master of the ship onto which the transhipped, packed containers are to be loaded and the port terminal facility in the transhipment port may rely on the information provided by the delivering vessel. Existing ship-port communication systems may be used for the provision of such information in agreement between the commercial parties involved. Discrepancies in gross mass 13 Any discrepancy between a packed container’s gross mass declared prior to the verification of its gross mass and its verified gross mass should be resolved by use of the verified gross mass. 14 Any discrepancy between a verified gross mass of a packed container obtained prior to the container’s delivery to the port terminal facility and a verified gross mass of that container obtained by that port facility’s weighing of the container should be resolved by use of

the latter verified gross mass obtained by the port terminal facility. Containers exceeding their maximum gross mass 15 SOLAS regulation VI/5 requires that a container not be packed to more than the maximum gross mass indicated on the Safety Approval Plate under the International Convention for Safe Containers (CSC), as amended. A container with a gross mass exceeding its maximum permitted gross mass may not be loaded onto a ship. Containers on road vehicles 16 If the verified gross mass of a packed container is obtained by weighing the container while it is on a road vehicle, (e.g. chassis or trailer), the tare mass of the road vehicle (and, where applicable, the tractor) should be subtracted to obtain the verified gross mass of the packed container. The subtraction should reflect the tare mass of the road vehicle (and, where applicable, the tractor) as indicated in their registration documents as issued by the competent authority of the State where these assets are registered. The mass of any fuel in the tank of the tractor should also be subtracted. 17 If two packed containers on a road vehicle are to be weighed, their gross mass should be determined by weighing each container separately. Simply dividing the total gross mass of the two containers by two after subtracting the mass of the road vehicle and the tractor, where applicable, would not produce an accurate verified gross mass for each container, and should not be allowed. Empty containers 18 Shippers of empty containers and operators of empty containers are encouraged to have practices and arrangements in place to ensure that they

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legaldetail Annex 2 Draft MSC Circular: Guidelines regarding the verified gross mass of a container carrying cargo are empty. The tare weight will visually appear on the container in accordance with the International Organization for standardization (ISO) standard for container marking and identification and should be used. (Refer to standard ISO 6346 – Freight containers – Coding, identification and marking) Contingencies for containers received without a verified gross mass 19 Notwithstanding that the shipper is responsible for obtaining and documenting the verified gross mass of a packed container, situations may occur where a packed container is delivered to a port terminal facility without the shipper having provided the required verified gross mass of the container. Such a container should not be loaded onto the ship until its verified gross mass has been obtained. In order to allow the continued efficient onward movement of such containers, the master or his representative and the terminal representative may obtain the verified gross mass of the packed container on behalf of the shipper. This may be done by weighing the packed container in the terminal or elsewhere. The verified gross mass so obtained

should be used in the preparation of the ship loading plan. Whether and how to do this should be agreed between the commercial parties, including the apportionment of the costs involved. Master’s ultimate decision whether to stow a packed container 20 Ultimately, and in conformance with the Code of Safe Practice for Cargo Stowage and Securing, the ship’s master should accept the cargo on board his ship only if he is satisfied that it can be safely transported. Nothing in the SOLAS regulations limit the principle that the master retains ultimate discretion in deciding whether to accept a packed container for loading onto his ship. Availability to both the terminal representative and to the master or his representative of the verified gross mass of a packed container sufficiently in advance to be used in the ship stowage plan is a prerequisite for the container to be loaded onto a ship to which the SOLAS regulations apply. It does, however, not constitute an entitlement for loading.

the SOLAS Contracting Governments. Contracting Governments acting as either port States or flag States should verify compliance with the SOLAS requirements. Any incidence of noncompliance with the SOLAS requirements is enforceable according to national legislation. 22 The ultimate effectiveness and enforcement of the SOLAS container gross mass verification requirement is that a packed container, for which the verified gross mass has not been obtained sufficiently in advance to be used in the ship stowage plan, will be denied loading onto a ship to which the SOLAS regulations apply. Any costs associated with the nonloading, storage, demurrage or eventual return of the container to the tendering shipper of the container should be subject to contractual arrangements between the commercial parties.

Enforcement

Effective date of the SOLAS requirements regarding verified gross mass of a container carrying cargo

21 Like other SOLAS provisions, the enforcement of the SOLAS requirements regarding the verified gross mass of packed containers falls within the competence and is the responsibility of

23 The SOLAS requirements regarding verified gross mass of a container carrying cargo (SOLAS regulation VI/2) are expected to enter into force in [July 2016].

If any members have queries about the IMO SOLAS Convention Amendment or the associated Annex 2 Guidelines on mandatory container weighing, please contact: Capt. Richard Brough, Technical Director | richard.brough@ichca.com

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About ICHCA International The International Cargo Handling Coordination Association (ICHCA), founded in 1952, is an independent, not-for-profit organisation dedicated to improving the safety, security, sustainability, productivity and efficiency of cargo handling and goods movement by all modes and through all phases of national and international supply chains. ICHCA International’s privileged non-government organisation (NGO) status enables it to represent its members, and the cargo handling industry at large, in front of national and international agencies and regulatory bodies. ISP - ICHCA’s Technical Panel - provides technical advice and publications on a wide range of practical cargo handling issues, while its Technical Advice Service provides members with recommendations on a wide range of cargo handling and transport issues, drawing on the experience and expertise of the ICHCA global member community. ICHCA International operates through a series of autonomous national and regional chapters – including ICHCA Australia, ICHCA Japan and ICHCA Canarias/Africa (CARC) – plus Correspondence and Working Groups to provide a focal point for informing, educating, shaping, facilitating and sharing industry knowledge across the global cargo handling community. ICHCA International is a UK-registered company limited by guarantee. Company registration number 4450611 VAT registration number GB 923 526 333

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ICHCA International Ltd secretariat office | c/o Next Level Information Ltd Suite 5, Meridian House, 62 Station Road, London E4 7BA, UK Tel +44 (0)20 3327 0576 | support@ichca.com | www.ichca.com Twitter @ICHCA2 | www.linkedin.com/company/ichca-international