• Linked with extensive health problems for crews. Like death, heavy injuries, massive influence in mentally and psychological behavior until traumatic consequential losses.
  • Linked with heavy damages on ship and cargo until probable total loss
  • Linked with acute environmental pollutions and massive interference in marine-/ air environment until obliteration of marine life

Surprisingly, we find in the media and the public only a very limited discussion on this explosive issue. Even during and after the drama about the “Maersk Honam”, the excitement and interest was essentially limited only to the affected maritime organizations, maritime companies, salvage companies, maritime insurers and occasional environmental organizations. But it should interest us all, even if we have no maritime background.

Since years I trace the development in carriage of dangerous goods (DG) on container ships. The reasons are simple to explain. As captain on container ships I want know which DG risk are increasing and which steps need to be taken to improve reduce accidents caused by DG cargo on board. The list of DG in IMDG Code comes more and more longer, the container vessels coming bigger and bigger, the DG cargo volume is continue increasing. This all are factors which have an influence in probable risks in carriage of DG.

The IMO is undertaking a lot to improve the safety in carriage of DG:

  • Permanent updates in further developed test procedures to improve the safe handling of DG,
  • Permanent update for the IMDG Code, present amend 38-16 since January 2018 is compulsory, with the effect that the handling rules of DG coming more strictly.
  • Specialists working hard to find solutions to reduce the risks of accidents with DG on ships.

But we facing again and again heavy accidents, initiated by dangerous cargo on board container ships.

  • Spontaneous ignition of DG cargo
  • Explosions in cargo holds with conflagrations,
  • Detonated deck containers,
  • Heavy injured or killed crew members
  • Total loss of cargo and ships,

are the results of such accidents. And cost the maritime insurers a huge amount of money.

Everybody remembers the last big tragedy aboard “Maersk Honam” begin of March 2018. An explosion in cargo hold 3. An inferno caused by probable detonated DG cargo in cargo hold with very painful experiences for Maersk Line. 5 crew members lost their life, all trials to get the fire under control by the crew without success and in last consequence the order by captain to abandon the ship to rescue the life of the remaining crew. This was the one of the biggest dramas in the last years caused by DG cargo but not the last. Following a list of major accidents triggered by DG cargo on container vessels:

  •  2018 - June 13th “SSL Kolkata”, explosion deck container, sank in shallow water after 3 weeks burning close to Sundarbarns
  •  2018 - March 6th “Maersk Honam”, Indian Ocean, CH 3 explosion in front of accommodation, 5 crew died
  • 2015 - May 1st, “Hanjin Green World”, Suez Canal passage, CH 9 container on fire
  • 2012 –July 14th “MSC Flaminia”, Atlantic Ocean CH 4 Explosion, 3 crew died
  • 2010 – July 7th, “Charlotte Maersk”, off Port Kelang, fire below deck, Calcium hypochlorite
  •  2006 – March 21st “Hyundai Fortune”, Gulf of Aden CH 6 (Behind accommodation /ER) explosion, not declared container laden with DG Class 1.3 G (fireworks)
  • 2003 – October 11th, “Sea Elegance”, close to Port of Durban, undeclared 20' container of calcium hypochlorite (UN 2208) stowed below decks aft of the accommodation with spontaneous ignition, 1 crew died.
  • 2002 – November 11th, “Hanjin Pennsylvania”, off Sri Lanka, initial explosion in cargo hold No. 4 where no Dangerous Goods (DG) were declared. The fire did spread for the next 4 days to cargo hold No. 6 in result with a heavy explosion too. Also there were no declared DG stored. The explosions resulting in a US $235 million loss on ship and cargo. The follow-up costs should have been much higher. 2 crew died.
  • 1999 – July 10th, “CMA Djakarta”, off Egypt, container of Chinese calcium hypochlorite (UN 2208) stowed above deck ignite and explode.
  • 1998 – December 30th, “Aconcagua” off of Ecuador, explosion of Chinese calcium hypochlorite (UN 1748) in a hold.
  • 1998 – April 18th, “SEA LAND Mariner”, sailing off of Crete, explosion and fire of containers on the poop deck. Expandable Polymeric beads (false declaration as Polystyrene) was determined.
  • 1998 – November 9th, “DG Harmony”, off South America, auto ignition and explosion of ten containers of US manufactured calcium hypochlorite stowed in Hold 3.

This list is not complete. A lot of incidents are not listed because they could be successful by crews or external firefighting services controlled and extinguished.

According information by TT Club a known provider in insurance and related risk management services to the international transport and logistics industry showing the statistics that serious container ship fires are now happening once every 60 days on average.

Many years the maritime insurances like GARD, Swedish Club, P&I and others claiming the risk of carriage dangerous goods on board container vessels. Offered safety publications which content advices regarding handling of DG and special risk caused by highly sensitive chemical substances, e.g. Calcium Hypochlorite (DG Class 5.1 / UN No.: 1748, 2208, 2880, 3485, 3486, 3487) give always newest information to refresh the attention and knowledge in handling of such cargo. For outsiders it must be explained, that container vessels carrying a lot of chemical substances which are partly extreme hazardous for spontaneous ignition or explosion. It's not an exaggeration to call them floating ticking bombs. From relatively harmless to easily flammable, explosive, oxidizing, corrosive (acids / alkalis), toxic, radioactive and polluting cargo is all there. Some of these substances need only a very small occasion to react violently and trigger a catastrophe on board. The most dangerous DG classes are in my view DG's of classes 4 and 5 with an extrem high potential in spontaneous combustion and explosive.

What are the reasons that such accidents can happen again and again?

All shippers have the obligation to check and to follow the international valid rules for stowage and segregation inside containers and to deliver the complete filled DG cargo documentations according IMDG Code / HAZMAT CFR 49 (USA). The most important documents for the vessel command are the IMDG Manifests / Packing Certificates. There should be always all relevant information given in following sequence (see below) in IMO Dangerous Goods Manifest in accordance with SOLAS 74 VII/4.2, MARPOL 73/78 Rule 4/ Para 2/ Annex 3, IMDG Code Chapter 5.4. /Provisions 5.4.2.1/ 5.4.3.

The shipper has to declare in the shipper’s declaration:

I hereby declare that the contents of this consignment are fully and accurately described below by the Proper Shipping Name, and are classified, packaged, marked and labelled / placarded and are in all respects in proper condition for Transport according to the applicable international and national governmental regulations.

  Following information has to be filled out

  •  Name of Ship / IMO Number / Call sign
  • Voyage Number / Flag of ship / Port of Loading (POL) / Port of Discharge (POD)
  • Booking Reference or No. / Container Number/ Number and kind of Package/ Proper Shipping Name / IMO Class (primary hazard)/ UN Number (MUST correspond with proper shipping name!)/ Packing Group/ Subsidiary Risk(s)/ Flashpoint in °C / Marine Pollutant (MP)/ DG Mass in kg (Gross/Net weight) / EMS (need additional a PIC 24 h emergency telephone number) / Stowage location on board (Bay/Row/ Tier)

 Packing Certificates has to be issued for all IMDG Cargo container except tank container according IMDG Code Chapter 5.4/ Provision 5.4.2.1 with following content:

“I hereby declare that the goods described above have been packed/loaded into the container identified above in accordance with provision 5.4.2.1 of IMDG Code”

 And following filled out information:

  •   Name of company
  • Name/ state of declarant
  •  Place and date
  •  Signature of declarant

It is definitely to recommend that the loading officer on board has to know the contents of the Provision 5.4.2.1/ 5.4.3

All DG containers and their documentation go through many hands ashore and are checked:

  1. by DG person in charge of the Shipper,
  2. by DG officer of the ports and authorities,
  3. by ship agents of the charterers / by shore stowage planning staff by shipping companies and
  4. finally on board by Chief Mate as cargo officer

If DG are not handled with care, if DG inside containers aren't very well packed, stowed and segregated stored acc. regulations and if DG aren't stowed away from sources which may initiating hazardous situations, if safety procedures ashore will be not followed are risks in advance programmed to get problems with DG on board.

A lot of chemical substances hold the risk of cross reactions in combination with other chemical substances, which are under normal circumstances not to expect. It as an additional risk especially when cargo hold fires/ explosions are in progress. It is only a matter of time then that problems with such type of cargo can occur. With devastating consequences for ship and crew. Those who still remember the shattering pictures of the explosions on a DG cargo site in the port of Tianjin in August 2015 gain an idea of what is being transported on board in today's container shipping.

While the inspectors ashore have every opportunity, with support of the authorities in case of doubt, to open sealed containers and to inspect their contents are this opportunities not given to the ship command team. Captain and Chief Mate have to believe the information in the DG manifests, whether they like it or not. They are the last link in a long logistical chain and have the least influence on all previous processes. But they have an influence if they consistently follow the international guidelines, the instructions of their shipping companies and charterers in dealing with DG cargo.

What might causing risks of incidents with dangerous cargo aboard container vessels?

  1. Ignored incomplete or incorrect filled out DG cargo manifests, caused by multiple stress, lack of concentration, distraction, routine or missing knowledge.
  2. False declared DG cargo with all with them connected problems in following stowage and segregation aboard
  3. Cargo stowage and segregation according approved stowage plan will be not followed during cargo operations, caused by distraction, inattention or other additional tasks of OOW and deck crew while observation of cargo operations on deck, to less persons on deck for cargo operation monitoring
  4. Segregation of DG not according requirements of IMDG Code (away from accommodation/ away from sources of heat like: HFO tank tops, HFO tank locations, Reefer container / away from other DG Classes acc. segregation rules),
  5. Stowage of planned deck DG cargo in cargo holds
  6. Wrong or missing right placarding/ labelling of containers
  7. Not declared DG cargo in cargo holds and on deck which are lead in stowage plan as dry cargo container without restrictions
  8. Not followed packing rules, stowage and segregation rules inside DG containers.
  9. Abuse of declared DG Cargo as “limited quantity” and stowage in false package sizes
  10. Carriage of “temperature controled DG Cargo” (in reefer container) as standard dry cargo container without temperature restrictions

This 10 numerated points are major points based of my own experience as Captain on VLCS. Important must be following remark addressed to ship owners and ship management companies:

On VLCS with a crew of 21 person, only 6 of them are deck crew which are divided in the deck duty system for cargo operation with max 3 persons (officer included) on deck for monitoring cargo operations and one gangway security watch is an gapless effective monitoring not realistic, if 6 to 7 gantries operating in cargo operations. The permanent cost cutting in crew costs causing such problems and consider not real safety aspects. In today cargo operations the new generation of gantries and their operators move one container in 1 minute and 30 seconds. Monitoring of cargo operations by only stevedores or tallymen hold always the risk that failures in container stowage can be not excluded when they let missing the due diligence. It existing ports in some parts of the world where this risk is not to underestimate.

What opportunities have the ship command to intervene against breeching of rules according IMDG Code/ US CFR 49 Hazmat

First of all be aware about the fact that the Captain has all opportunities to stop cargo operations in case of not followed safety matters (SOLAS 74 Chapter XI-2 Rule 8.1).

The close collaboration between Captain, Chief Mate, duty officer and duty crew on deck, I name it Cargo Operation Team Management is a very important part of a successful check of all DG cargo documentation and for an effective monitoring of cargo operations and must be clear defined.

  • The crew has to be well trained about DG and handling of DG while safety trainings on board. This training has to be recorded and certified by trainers. (IMDG Code Chapter 1.3/ US CFR 49 HAZMAT §172.704). Be aware the issued certificates are for 3 yearsvalid only and need a permanent refreshing before expiry time.
  • Everybody on deck has to know which responsibilities and reporting instruction they have to follow
  • Give them clear instructions and guidelines what are the main attention while discharging / loading of DG.
  • Every deck watchman/ duty officer has to receive a valid stowage plan with an extra stowage list for DG cargo with all required relevant DG information according IMDG manifest. Any revision in stowage plans are only approved by CO must immediately handover to the deckwatch as revised plans
  •  All deck watchman/ duty officer / CO need stabile 2-way-UHF radio communication on a clear defined radio channel without disturbances. If disturbances are registed all parties has to be informed about shifts to channels without disturbtions
  • All seen irregularities in handling of IMDG containers has to be immediately reported and stevedores/ tallymen/ foreman informed:

Damages on DG container / leaking DG container/ missing or incomplete DG container labels or placarding / wrong stowage positions / deviations from segregation instructions

Cargo operation in this area has to be stopped to verify the reported deficiencies by responsible officer/ CO.

Only when the situation is clarified after corrective action the cargo operations are permitted to continue with approval by responsible Officer.

  • Keep in mind, when damaged container leaking or container leaking (e.g. tank container) have ALL cargo operations to be stopped! Captain / CO / Foreman / Stevedores/ Port Authorities/ Charterer's representatives/ agent has to be immediately informed. With extreme caution the area must be kept free from any source of heat or fire. Keep everybody far away from area until the CO is able to give all information about DG dangers and introduced steps according EMS. If required release General Alarm! Be ready for SOPEP counter-measures according company SOPEP/ Emergency procedures. Emergency procedures are ALWAYS all hand procedures. Keep an open eye for any health abnormalities in or close to the contaminated area. Shipping Company DG department and fleet management has to be informed asap.
  • After completion of cargo operations the Chief Officer is obliged to hang a dangerous goods list with all necessary data and a stowage plan with the stowage positions of the DG container on the bridge and at public places accessible to all crew members.

For Loading officer must be following considered:

  1. If any wrong or missing details/ entries in DG documentation found, if you are in doubt to DG documentation inform captain/ agent/ cargo planner/ DG port authorities and urge that the problem has to be solved before departure. Add inform your company DG department and request an external DG check to your open points. Company DG departments have always the opportunities to contact the flag state DG authorities as an additional check to give additional support.
  2. Never lose the contenance and keep kind and polite. But be consistent in the matter.
  3. In ports we see often that agents and charterer representatives pushing the ship leading team to quicken the check of the DG cargo documentation. Do not let that affect you.
  4. Take your time especially when you receive a huge amount of IMDG documents. The strength is to be found in serenity. It is like a life insurance for crew and vessel. Take care instead of speed.
  5. If agents, charterer representatives, planning staff are not able to solve claims while port stay don’t accept compromises, like, we will send you the documents at sea. Be strict and deny the loading of such cargo.
  6. If you find some wrong stowage position by DG cargo in planners stowage plan, try to find with him together alternative stowage locations. Where a will is a way. Request also the consultations by Captain to find together solutions. If there is really no opportunity to stow DG container according IMDG/Hazmat rules on board, don’t accept compromises and deny the loading on board.
  7. Be aware and try to arrange that all DG cargo container with sensitive cargo will be stored on deck and not in cargo holds away from accommodation/ resources of heat/ sun influence. (e.g. cargo DG class 4, DG class 5, some cargo DG class 3). Check careful IMDG Code stowage instruction. There are UN Numbers which are only allowed to stow on deck. Any container planned for below deck stowage who contains Calcium Hypochlorite has to be denied and only a deck stowage permitted. When you have a good captain he will you always support in this matter. My Chief Mates get all my support in this point because safety has the absolute priority.
  8. Approve the loading plan only, when everything is clarified, if all DG cargo manifests and packing certificates are checked, all stowage positions according IMDG Code rules, your requested stowage changes are considered and implemented and your loading program is free of any IMDG alarms.
  9. Before you approve the loading plan printout DG list and make a crosscheck. When there is all in range according your corrections than you know it is all the best done from your side to warrant a safe DG container handling
  10. Important for all denied loading of DG it need a water tight statement. This statement has to be fixed in written protest by Captain and must be addressed to Charterer, Agency, Vessel or Management owner, if required for port state authority

Never forget! As long as the vessel stay in port are every possibilities given to initiate corrective actions under inclusion of cargo planners, agents, DG port authorities, DG company representatives and charterer’s representatives.

When the vessel is at sea than the Captain and the crew is alone with probable incidents/ accidents with DG.

That’s why Captains and loading officers has to be strict in all claims regarding DG cargo in ports. It is the once way for the ship leading team to reduce the risk and to get a disaster like “Maersk Honam” be avoided.

The all open question is always how it can be that DG will be not declared or misdeclared and the unknown persons in charge seems have still a calm conscience. How many criminal energy will required by such offenders. This is not more negligence, this complies the legal fact of intention

  • How much unscrupulousness must be present in such individuals that they do not care about the associated dangers.
  • How consciencless are such people have to be to ignore the loss of lives and hundreds of millions of dollars, which also means huge losses for the shipping companies.
  • Who are the responsible people who accept every risk, just to save costs, because that seems to be the only reasons to reduce the considerably higher costs for containers with DG.

It are precisely these criminals who degrade container shipping to a kind of roulette with an unknown outcome. Unfortunately, in this question, all tightening of existing international regulations seem to fail because the backers of such machinations remain so far in the dark.

And as that is not enough, in such accidents on the high seas, the sailors are left pretty much alone with outdated extinguishing agents, which are absolutely unsuitable for fire with special DG classes.

The rules of SOLAS 74 in fire fighting are for special classes of DG in container shipping only limited suitable. All major accidents have shown that carbon dioxide (CO2) has absolutely no firefighting effect. That is not surprising. Fires in holds are not limited to holds, because each container in the hold is a self-contained unit that is not reached by carbone dioxide. The dangerous goods classes 1, 4 and 5 transported on container ships can’t be combated with conventional extinguishing agents on board. This is due solely to the chemical composition and the associated chemical reactions that cause the exact opposite with the usage of water or carbon dioxide.

These dangerous goods classes generate fire temperatures of over 1300 to 1600 degrees Celsius, if carbon dioxide loses every extinguishing effect, as it is decomposed to carbon monoxide (CO) and oxygen (O2). Those who say otherwise did not understand that SOLAS74 regulations were designed for General Cargo Vessels. Today's container ship sizes, with their huge holds and huge amounts of transported high-risk cargo, require urgent revision and adaptation of SOLAS 74 and fire-fighting technologies, such as water/ foam monitors and novel extinguishing agents, which can actually be used effectively. The equipment with dry extinguishing agents (sodium hydrogen carbonate / potassium hydrogen carbonate / sand / cement) for the fire classes B / C and D in their quantity including the necessary extinguishing equipment for large-scale use on deck for fires of DG classes 1 / 4 / 5 is absolutely insufficient. The fire-fighting options on container ships must be completely roofed and adapted to the actual conditions.

But that again costs too much money that many ship owners do not want to take in hand. Then just the current situation is accepted, sunbathing in a quality management, what exactly does not deserve the name in this question and the rest pays the insurance.

Incidentally, the International Union of Marine Insurance takes the same view.

Uwe-Peter Schieder, Vice Chairman of IUMI’s Loss Prevention Committee explains:

At sea, below-deck fires cannot be fought with water and so CO₂ is used instead to displace the oxygen and extinguish the fire. However, if the fire is burning within a container, the box will protect it from the CO₂ and so this method of fire-fighting is rarely successful. Currently there are no other methods of fighting a containership fire below deck.  Even on deck, the crew only have access to hoses and nozzles. They do not have sufficient monitors or foam and so cannot cool the vessel’s structure.

A change in minds and understanding is urgent required to improve the fire fighting capabilites for speciel DG class fires aboard container ships. This requires an immense effort which need IMO, Classification societies, shipbuilders, shipping companies, Maritime Insurances, Ship Safety Institutes, international fire fighting specialists and experienced Captains and ship engineers from container shipping united in one boat to searching effective solutions for future requirements in the container shipping industry in fire fighting

And while we are currently overrun with cyber threat scenarios, the real threats to container shipping are not cyber threat, but the existing acute threats by dangerous cargo and the associated loopholes of not or incorrectly declaring DG, which are in and of themselves good regulations subvert in dealing with DG and really horror scenarios creating.

"Maersk Honam," her crew, and Maersk Line have paid a very high price for it, like all the other cases I've listed, which can’t be justified by anything.

Let's relativize the term threat to what is really threatening, without even ignoring any threat. But we have to rate them correctly. As captain on VLCS I know from my own experience really well, in my view, the threat of dangerous cargo is the FIRST THREAT! The named examples confirm my evaluation.

The views presented hereabove are only those of the author and not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.

Above article has been initially published in Capt. Gunter Schütze LinkedIn account and is reproduced here with author's kind permission


Written by Capt. Gunter Schütze ,

Capt. Gunter Schütze holds a Master Degree of Engineering in Ship Guidance. He currently serves as a freelancer author, while he also contributed in follow-up and completion work on study about the crisis in the German and international shipping, until its publication as e-book in German book trade. He further serves as an active captain aboard of large container vessels.