DANGEROUS GOODS
TAKE A HOLISTIC APPROACH The National Cargo Bureau presents a holistic approach to the growing challenge of mis-declared and undeclared dangerous goods Ports are an integral part of the movement of dangerous goods by sea, the place where millions of TEU around the globe come together each year to begin their journey on water to reach their final destination. Ports and terminals vary in size and capability including adoption of automation and strategic importance. Actions taken at this stage of a journey can be crucial in ensuring that the dangerous goods (DG) carried in containers (approximately 10 per cent of all containers shipped) reach their respective destinations safely and without incident out at sea. In 2020, New York based cargo inspection company, National Cargo Bureau (NCB), published a white paper calling for urgent reform to stem the increasing number of containerrelated incidents caused by undeclared or misdeclared dangerous cargoes. The White Paper was written in response to a Container Inspection Safety Initiative carried out by NCB following the Maersk Honam explosion in 2018. NCB carried out 500 free inspections of a sample of containers at US ports, including imports (which would not normally be part of NCB’s remit), for members of the Cargo Incident Notification System (CINS). The inspection revealed an alarming number of containers carried by sea include mis-declared dangerous cargoes that represent a serious safety risk to port/terminal staff, crew, vessel and the environment. Of the 500 containers inspected, 55 per cent failed with one or more deficiencies; 69 per cent of the import containers containing dangerous goods failed; and 38 per cent of containers with dangerous goods exports failed. Of the import containers with dangerous goods, 44 per cent had problems with the way cargo was secured, 39 per cent had improper placarding and 8 per cent had misdeclared cargo. Of the export containers with dangerous goods, 25 per cent had securing issues, 15 per cent were improperly placarded and 5 per cent were mis-declared. The problem of incidents in ports or at sea is not going away. Container ships are getting larger, and the increasing number of containers means the risk is getting greater. As a result, the problem of undeclared and mis-declared dangerous goods cargo continues to grow. To tackle this issue, a comprehensive holistic approach needs to be adopted by the industry to minimise non-compliance by all supply chain participants. WHAT IS CAUSING THE ISSUE? Regulations and compliance Regulations governing the transportation of dangerous goods were developed to protect life, property and the environment. They impose specific obligations and requirements for all supply chain participants. Each participant must rely on the others to fulfil their obligations or overall supply chain safety will be compromised. The IMDG Code, produced by the International Maritime Organisation is a detailed set of requirements covering the transport of packaged dangerous goods by sea. An increase in players in the supply chain and demands for faster, just-intime deliveries have created complex supply chains. Many organisations offer insufficient training and there is
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inadequate knowledge of dangerous goods and how they should be shipped. Limiting the movement of DG Limits and bans by ports/terminals on which dangerous goods can enter or transit a port can lead to wilful misdeclaration. For example, high demand for calcium hypochlorite which has been implicated in several high profile container vessel fires, can lead to misdeclaration if shippers try to cut corners. The tightening of DG guidelines at ports following the Tianjin incident in 2015 also had a similar effect.
8 A serious incident - the Maersk Honam caught fire on 6 March 2018 while sailing in the Arabian Sea
Vessel sharing and complex supply chains Vessel sharing agreements and carrier alliances mean different versions of port/terminal restrictions can be in play (there is not a single consistent database of port and terminal DG restrictions). In addition, more complex supply chains have evolved with carriers including door-to-door solutions including freight forwarding, warehousing, consolidation and other logistics services as well as ocean transportation. Internal pressures Port and terminal operators and vessel operators have developed processes and procedures for the review, approval, acceptance and carriage of dangerous goods. However, resources, tools, processes/procedures and training can vary greatly and may not be in line with industry best practice. DG legacy systems and a lack of consistent connected DG data can lead to incomplete documentation, improper vessel stowage and/or segregation of DG cargoes. In the case of undeclared or mis-delcared DG the problem becomes much worse and the risk multiplies. The recommendations NCB’s white paper is calling for industry to adopt a comprehensive, holistic and coordinated approach to address the worrying trend of mis-declared and undeclared DG with 12 recommendations including the establishment of a corporate culture for DG compliance with a dedicated DG
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