Feature: Cargo Integrity – A Unified Approach
Read Seaways online at http://www.nautinst.org/seaways August 2019 | Seaways | 25
On analysing reports submitted to IMO in the past, TT Club has
established that less than 10% of member states report the results
of container inspections at any one time. The percentage reporting
currently stands at about 2.5%; on average only four or five of the 170
member states regularly report. Of the inspections that are carried
out, as many as 75% are typically in the US. Even there, at a sample
rate of less than 0.05% of packed units, this is an extremely low rate
of inspection. This is not sufficient to enforce the regulations, derive
change requirements or provide evidence of frequent transgressors.
Improving transparency
In 2011, five of the top liner operators formed the Cargo Incident
Notification System Organisation (CINS - see http://www.cinsnet.com)..)
This organisation aims to capture key incident data in order to provide
an early warning of worrying trends, including both cargoes that
display dangerous characteristics and unsafe practices in the container
supply chain. Today, some 18 liner operators are members of CINS,
representing over 85% of container slot capacity.
The need for improved transparency is key for many other actors
in the supply chain, most notably shippers and forwarders, who
are responsible for packing the containers and providing the initial
declarations of what they contain. Ports and terminals need to become
more knowledgeable about safety procedures and be vigilant in
minimising errors. In particular, the procedures governing dangerous
goods handling around the world are complex. Each consignment
has to navigate the chosen carrier’s own house policies, physical ship
constraints and any restrictions applied at ports/terminals at the point of
loading, transit, transhipment and discharge. This complexity and lack
of standardisation can be bewildering even to the most experienced
shipper. It is also intensely inefficient and hugely burdensome for all
stakeholders.
Technology can offer a solution to these issues. For example, Exis
Technologies, with the support of TT Club and its sister insurance
mutual, UK P&I Club, developed a portal integrating information on
such restrictions. The Hazcheck Restrictions Portal has been designed
to simplify the end-to-end management of dangerous goods booking
processes, taking account of port, terminal, carrier, ship and partner
line restrictions.
Training and enforcement
Technology is not the only answer, though, and the need to deliver the
message of cargo integrity throughout the supply chain is clear. TT
Club has updated and revised its publication Book it right and pack it
tight, (available free of charge online at https://bit.ly/2Ggn1dY) which
provides a thorough introduction and guidance on the provisions of the
IMDG Code.
The need for increased training of those employed by shippers,
consolidators, warehouses and depots to pack containers and other
transport units is repeatedly demonstrated by the consequences of
inappropriate load distribution and badly secured cargo within CTUs,
including bodily injury.
While training to achieve ‘competence’ – or the ability to do a job
properly – is required by law for dangerous goods, it is fundamental for
all cargo operations and needs to be followed through. This means that
training records not only should be maintained but also available. The
general lack of enforcement continues to undermine the effectiveness
and safety of the system for all cargo types. While the International
Maritime Dangerous Goods (IMDG) Code is mandatory and all
IMO member states are required to incorporate its requirements in
national law, enforcement is little known and inspections are few and
far between. More general safety (and security) inspections are too
infrequent to bolster voluntary adherence to good practice.
The importance of carrying out due diligence was set out in relation
to the Code of Practice for Packing of Cargo Transport Units (CTU
Code) in IMO Circular MSC.1/Circ.1531. While this envisages
checks being undertaken to seek assurance in relation to a contractor, it
also provides a good model for service providers to ‘know the customer’.
The CTU Code stands as non-mandatory international law, and
is structured in such a way that it may be incorporated into national
legislation. Many jurisdictions will rely on this detailed guidance as
demonstrating good industry practice. All direct stakeholders need to
become familiar with the contents of the CTU Code, and develop ways
to implement and encourage compliance.Pushing for change
TT Club and its partners will continue to put pressure on UN agencies,
governments and the full range of direct and indirect stakeholders
involved in the intermodal supply chain, recommending changes
to improve safety, and identifying practices and behaviours that can
undermine certainty of outcome and increase risk.
To be effective, any call for cargo integrity must take a broad
approach. We cannot rely on the power of regulation or the vigilance
and discipline of carriers or port operators alone. Instead, the industry
must carry the safety message far and wide. We must engage with
indirect stakeholders, such as those involved in fiscal, health, security
and anti-trust regulation, and embrace technical innovations that
can assist in monitoring and condition reporting. Those involved in
inspections, surveys and advice to the packing industry globally are also
key to engaging with risk perception and management across the cargo
sector.
Recognising the huge range of influences affecting the safety,
security and environmental performance of the supply chain shows
the scale of the challenge that we are facing. But it must be addressed
in order to achieve the significant culture change that is required to
ensure the safety of cargo – and lives – at sea.Peregrine Storrs-Fox is the Risk Management Director of the
international freight and logistics insurer, TT Club