This follows a recent inspection initiative that revealed an alarming number of containers with misdeclared dangerous cargoes that represent a serious safety risk.
As such, the National Cargo Bureau (NCB), the US inspection body for Dangerous Goods regulations, is calling for industry to adopt a comprehensive, holistic and coordinated approach to address this worrying trend.
The inspection initiative also showed that 55% of containers were non-compliant with 43% failing to secure dangerous goods correctly within the container itself. Approximately 6.5% of containers carrying dangerous cargoes had been misdeclared.
It has been reported that, on average, a containership suffers a major fire every 60 days. However, in 2019, there were nine major containership fires, suggesting that the frequency of incidents is increasing.
It is strongly suspected that these vessel incidents were caused by issues related to poorly stowed, undeclared or misdeclared dangerous cargoes. With more containers being carried and containerships getting bigger, risks are increasing in number, value and concentration.
Reasons may include:
- the difficulty of supply chain stakeholders complying with a myriad of regulations;
- a poor understanding of what constitutes a dangerous cargo and what is required to transport it;
- the increasing complexity of multi-modal supply chains; carriers and ports restricting or refusing to move or receive certain dangerous cargoes;
- varied internal company challenges; and
- the continuing threat of bad actors.
Hence, the NCB white paper details 12 recommendations to ensure a safety culture for dangerous goods:
- Establish a corporate culture for DG compliance. A key premise to establishing a robust culture is creating an awareness of the importance and responsibility for all employees to comply with applicable regulations and company policies.
- Establish a Dangerous Goods department with full authority, and backing from senior management, on all matters concerning acceptance and transport of DG shipments.
- Establish a compliant DG training program that includes mandatory general awareness training for shore-based personnel throughout the company, where applicable, with function specific training where necessary.
- Establish disciplined “cut-off” times for booking and acceptance of DG cargo for receipt of final, certified and signed DG shipping papers / DG declarations; and for physical receipt of DG containers.
- Incorporate integrated digital tools that automate critical compliance functions. This would include a tool to screen initial booking data and subsequent documentation such as dangerous goods declarations and bill of lading shipping instructions for “key” words or phrases to detect undeclared or misdeclared dangerous goods before cargo is accepted.
- Establish a DG documentation process that requires certified and signed DG shipping papers to be in hand, reviewed for acceptance and validated against approved booking information before shipments are loaded to a vessel.
- Establish a DG planning process that is strictly controlled. Planners should only plan and load shipments included on a load list approved by the DG department. Any changes to the load list or stowage plan should be approved by the DG department.
- Adopt a risk-based strategy for stowage of dangerous goods that enhances safety on board containerships. This strategy would not replace the SOLAS and IMDG requirements for stowage and segregation, and should complement, but not substitute ship operators’ existing measures for the carriage of properly declared dangerous goods.
- Establish a receiving in-gate process for DG cargo that incorporates a centralized data base to provide automatic display of correct container marking and placarding during inspection and review of DG cargo at the gate to avoid errors, increase compliance and speed of the in-gate process.
- Establish a DG container inspection program to validate integrity and ensure proper marking and placarding of the container; to ensure compatibility and proper securing of cargo stuffed in the container; and to check, where possible, for proper package labelling and marks, the existence of damage, leaks or spills or potential undeclared cargo.
- Establish a vessel inspection process for DG cargo that fosters good communications between vessel, terminal planners and assigned shipping line planner during loading operations.
- Create one common, centralized DG data base that the industry can access and update on an ongoing basis. This data base should include details that can be analyzed to determine trends, improve standards and better target resources to address recurrent issues and their root causes.
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