Reported incidents for cargo-related containership fires, have increased in 2019 - with incidents reported every 30 days on average, bucking the 20-plus year average of roughly every 60 days, said TT Club
TT Club risk management director Peregrine Storrs-Fox said “The casualty rate in 2019 is not a comfortable reality for any industry stakeholder – whether the shipper community, logistics and ship operators or the diverse range of insurance providers – and highlights the need to galvanise actions to improve safety, protecting lives and the environment, as well as ships, cargo and equipment.”
While full details of the incidents this year – and those occurring through 2018 – will take time to be confirmed and emerge in the public domain (possibly through litigation), TT Club says that “too many have been reliably reported to concern shipments of charcoal”.
The way charcoal is to be treated in the supply chain, and specifically the maritime mode, will be considered at IMO’s Sub-Committee on Carriage of Cargoes and Containers (CCC) this month. The topic was initiated by a report issued by the German maritime authority arising from investigations into two ship fire incidents.
Mr Fox said “The crucial issue at stake is related to the application of a Special Provision (SP925), which, where applicable, exempts the shipment from the rigours of the dangerous goods regulations.”
TT Club said that for current purposes, the findings of the investigations can be summarised as: testing in relation to self-heating gave inconsistent results, and that linkage between testing and specific consignments was not always possible.
TT Club said that the German submission to CCC is recommending that the IMDG Code no longer permit the transport of charcoal as non-hazardous and that additional steps are taken in relation to stowage on board ships.
TT Club added "Importantly, the submission seeks to delete SP925, albeit it proceeds to propose a new Special Provision. In a commenting submission, ICHCA, with support from TT Club, agrees with the basic premise that charcoal should always be considered as dangerous and with the deletion of the Special Provision, but not the creation of a new one."
The outcome will be reflected in the forthcoming version of the IMDG Code (Amendment 40-20) which enters mandatory force on 1 January 2022 and will be finalised this year).
Elsewhere, the concerns relating to Special Provisions (SPs) in general (and SP925 specifically) are raised in a further document that has broad industry support, including TT Club working with ICHCA, submitted by Liberia and seven NGOs. This addresses the problem of non-declaration and misdeclaration of dangerous goods and proposes a comprehensive review of the maritime SPs in the IMDG Code.
Mr Fox says “Incident reports demonstrate that the SPs in question have been abused as a basis for exempting shipments from the safety provisions of the Code, when in fact the goods were subsequently proven to be dangerous.”
TT Club said that it would be “most welcome” if the outcome of the review reduced areas of uncertainty and opportunities, that prevent carriers and other stakeholders in the supply chain from taking actions to “ensure proper and safe handling and stowage of cargo reflecting the real presented hazards”.