SAFETY March 2020 Container fires: misdeclaration of dangerous goods must be curbed By Ashok Srinivasan, Manager, Maritime Safety & Security at BIMCO Upto90%of such blazes go unrecorded Growing concern over fires on board container ships has prompted the industry to look for ways to fight the misdeclaration of dangerous goods, which is believed to be a main cause of container fires. Over the past 50 years, the size and cargo capacity of container ships have grown tremendously because of economic growth, increased competition, economies of scale, increased efficiency and improvements in technology. While this has fuelled significant advances in design, construction, stability, navigation and the propulsion systems of ships, improvements to safety systems have lagged behind, particularly when it comes to fire safety. Improvements to safety systems have lagged behind, particularly when it comes to fire safety The broad consensus among major stakeholders is that a prime cause of fire on board container ships is as a result of misdeclared or undeclared dangerous cargo. The problem goes beyond the maritime industry and needs a coordinated effort from all parties to cut incident rates. The cost of declaring dangerous goods The container-packing industry is huge and involves many players at various levels. Misdeclaration of dangerous goods happens for a variety of reasons but most can be categorised as either deliberate or done in ignorance. Education of shippers through proper training programmes is the way forward to ensure shippers do not misdeclare because of ignorance. Deliberate misdeclaration, however, is another matter. It is mainly done to sidestep the costs involved and thereby gain a commercial advantage over competitors. The difference in cost between declaring a cargo dangerous or not declaring it as such is significant and it is this that motivates shippers to bend the regulations and sometimes break them. To tackle the problem of misdeclaration, the industry must take a close look at this extra cost, also known as “dangerous cargo surcharge”. This is easier said than done. It is true that dangerous goods go through higher levels of scrutiny at every stage of their transit and need additional care, all of which come at a cost. No shipping liner would benefit from removing this surcharge, as it would hit their own bottom lines. Not only that, containers – unlike other solid bulk cargo or oil cargo – travel between multiple entities, and even via competing companies, before reaching their destination. Therefore, an effort by just one company may not be visible across the entire spectrum and may even have a negative effect on that company’s operations. A number of fires have broken out on board these ships in the past few years, some of which have resulted in loss of life. However, not all incidents are reported, with estimates suggesting that up to 90% of such blazes go unrecorded. Given the vast difference in the economies of countries and the range of goods transported from one to another, it may be in the wider interest of all to look into this issue in a more coordinated manner. BIMCO is working closely with its members and industry partners to find practical solutions to the problem of undeclared or misdeclared dangerous cargo. In addition, several container liners have already joined forces to tackle the issue. Some of the actions now under way include: The difference in cost between declaring Container inspection programmes – The National Cargo Bureau conducted a physical inspection1 of 500 containers and recorded a 55% failure rate. While this may seem a huge number, most was as a result of, for instance, failed securing of cargo within the container or failed placard placements. Even so, the misdeclaration rate of the cargo itself was 8% for imported containers. Several such inspections are under way. Risk-based stowage guidelines – A new stowage concept based on the risk each container poses has been developed through a coordinated effort by major container liners. This concept goes above and beyond the existing statutory stowage requirements and offers a higher margin of safety. The International Maritime Organization (IMO) established a working group2 last year to look into certain special provisions (SP) of the International Maritime Dangerous Goods (IMDG) code, which were believed to be used by certain shippers to misdeclare cargo. If certain dangerous cargoes fulfil a set of criteria under an SP, these can be shipped as non-dangerous cargo. An example of this is charcoal – a dangerous cargo and liable to spontaneous combustion – which does not need to be declared as dangerous cargo if it passes certain self-heating tests required by SP925. Efforts are being made to educate and encourage shippers into declaring dangerous goods properly. Major container liners are sharing knowledge gained from cargo incidents3 to help each other. Direct competitors joining forces and sharing safety-related data to ensure a reduction in these incidents is a welcome step forward, not just for these companies and seafarers, but also the industry at large. Despite this development, anti-competition laws prohibit shipping companies sharing details of those who willfully engage in malpractice. Procedures are also in place to penalise – and even prosecute – those shippers which, even after being educated about the dangers involved, continue to display rogue behaviour by misdeclaring or not declaring cargo properly. 1 http://www.natcargo.org/hazardous_stowage_and_segration_review.html 2 IMO docs – CCC6/14 3 Cargo incident notification system – www.cinsnet.com Connect with BIMCO a cargo dangerous or not declaring it as such is significant Photo (top): iStock / primeimages Facebook Twitter Linkedin YouTube Ashok Srinivasan is Manager, Maritime Safety & Security at BIMCO. He is responsible for coordinating BIMCO’s initiatives on a variety of technical, operational and regulation related matters and represents BIMCO at meetings held at the International Maritime Organization (IMO) and the International Association of Classification Societies (IACS) to name a few. He holds a master mariner education, dynamic positioning officer, marine lead auditor and an MBA from Copenhagen Business School and has been a visiting faculty at the marine colleges in India, teaching navigation, safety and cargo related courses. Ashok is also an experienced seafarer with 18 years in the maritime sector, starting his career with A.P. Moller Maersk.