CONSIDERATION OF REPORTS OF INCIDENTS INVOLVING DANGEROUS GOODS OR MARINE POLLUTANTS IN PACKAGED FORM ON BOARD SHIPS OR IN PORT AREAS

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1 E SUB-COMMITTEE ON CARRIAGE OF CARGOES AND CONTAINERS 4th session Agenda item 8 CCC 4/8/4 21 July 2017 Original: ENGLISH CONSIDERATION OF REPORTS OF INCIDENTS INVOLVING DANGEROUS GOODS OR MARINE POLLUTANTS IN PACKAGED FORM ON BOARD SHIPS OR IN PORT AREAS Comments on documents CCC 4/8, CCC 4/8/1, CCC 4/8/2 and CCC 4/8/3, including an analysis of inspection results and wider issues of awareness of the CTU Code Submitted by ICHCA International Ltd. SUMMARY Executive summary: This document comments on the reports submitted under agenda item 8 (Consideration of reports of incidents involving dangerous goods or marine pollutants in packaged form on board ships or in port areas) Strategic direction: 12.3 High-level action: Output: Action to be taken: Paragraph 20 Related documents: CCC 4/8, CCC 4/8/1, CCC 4/8/2, CCC 4/8/3 and MSC.1/Circ. 1442, as amended by MSC.1/Circ.1521 Introduction 1 This document is submitted in accordance with the provisions of paragraph of the document on Organization and method of work of the Maritime Safety Committee and the Marine Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5) and provides comments on documents CCC 4/8 (Germany), CCC 4/8/1(Sweden), CCC 4/8/2 (Chile) and CCC 4/8/3 (United States). 2 In MSC.1/Circ.1442, as amended by MSC.1/Circ.1521, governments are urged to implement inspection programmes for Cargo Transport Units (CTUs) carrying dangerous goods and to report their findings to the Organization. The results have been duly submitted to IMO over the preceding years, usually accompanied by a summary of such reports compiled by the Secretariat.

2 Page 2 3 ICHCA, supported by its member organization, TT Club, has analysed the reports submitted up to and including CCC 3, and the summary of the TT Club findings is contained in the annex. 4 ICHCA and its industry partners have held several seminars to raise awareness of the CTU Code and dangerous goods regulations, and to highlight the impact of non-compliance. It is apparent that the low level of reporting and potentially enforcement in many parts of the world have a detrimental impact on supply chain culture and compliance. Observations 5 As can be seen in the annex, the number of Member States reporting, in comparison with those in membership of IMO, has always been less than 10% and currently stands at about 2.5%. At the time of writing, just four reports had been submitted to CCC 4. 6 The number of inspections performed has never exceeded 80,000, and currently represents something less than 4 per 100,000 packed containers moved. 7 The deficiencies regularly found in this small sample are quite alarming:.1 "Placarding and Marking", being the key visual risk alert for all supply chain stakeholders, evidences a rapidly increasing trend to 67.5% in Wrongly placarded units can create a major hazard, as exemplified in Vancouver in 2015 when a container packed with dangerous goods caught fire, as well as numerous incidents on board ship; and.2 more importantly, "Stowage and Securing" deficiencies, reported to be causative in many cargo-related incidents, average in excess of 20%. 8 ICHCA's recent seminar on dangerous goods, in which a representative from the IMO Secretariat participated, heard reports of widespread disregard of dangerous goods regulations, with one shipping line revealing that many shippers use alternative terms for dangerous goods to avoid surcharges and having to comply with additional measures, including any ship or port restrictions, as well as the regulations themselves. The potential scale of the problem 9 Calculating the actual number of dangerous goods shipments is complex, but some estimates are that declared volumes comprise up to 10% of all container movements. UNCTAD calculates in its Review of Maritime Transport that there were approximately 180 million TEU movements in Assuming 60% of 180 million TEU equates to actual CTUs, 50% of those are laden, of which 10% contain declared dangerous goods, then approximately 5.4 million units annually are packed with dangerous goods. 10 It might also be assumed that more care and attention is given to consignments of declared dangerous goods. However, extrapolating the findings mentioned in 8.2 above, it might be anticipated that some 1.16 million units packed with declared dangerous goods in 2015 could have had such a deficiency. 1

3 Page 3 11 This figure does not account for the many units that are shipped where dangerous goods have not been declared, nor those for non-regulated cargoes; it may be expected that deficiencies would be more prevalent where more detailed regulations are not deemed to apply. It can be seen by this basic analysis that the problem is potentially vast. What can be done to address the problem in the industry? 12 ICHCA and its partners (TT Club, GSF and WSC) have an awareness campaign on the importance of the CTU Code, to which IMO was one of the sponsoring organizations, along with the ILO and UNECE. This campaign started at European Shipping Week earlier this year, which the IMO Secretary-General and Senior Deputy Director attended. 13 This campaign continues and has been well supported by the IMO Secretariat throughout. As part of the campaign, there will be a joint presentation from the four organizations at this session of the CCC Sub-Committee. 14 While the IMDG Code is mandatory, the CTU Code is not, albeit referenced from the IMDG Code and SOLAS. The evidence from recent events is that awareness of the CTU Code is very low and therefore compliance with good practice will be poor. 15 We have highlighted above the potential scale of deficiencies with dangerous goods consignments, where shippers and packers are likely to be more diligent; it may not be unrealistic to suggest that the scale of deficiencies across non-regulated CTU shipments could be greater in relation to poorly packed and secured cargoes. 16 All IMO Member States, and indeed non-port States, should be encouraged to adopt the principles embodied in MSC.1/Circ.1442, as amended by MSC.1/Circ.1521, and step up their activity with regard to inspections and reporting. 17 It would appear that the inspection programme needs to be reconsidered. The following recommendations are made:.1 while the substance of MSC.1/Circ.1442 applies to all cargo types packed in CTUs, the title appears to restrict application to cargo declared to be dangerous. It is recommended that the title be amended;.2 governments should be asked to identify what issues prevent them from inspecting CTUs and reporting the findings to IMO in a consistent and statistically viable fashion;.3 inspections compliant with MSC.1/Circ.1442 are also carried out by entities that are not Competent Authorities. Such activity should be encouraged and facility made for it to be reported to IMO; and.4 consideration should be given to advances in scanning technologies that may permit improved and risk-based inspections to be carried out more effectively. 18 ICHCA would advocate that training in CTU Code precepts, at least, could be considered in the same way that training in the appropriate aspects of the IMDG is mandated for all that are involved in consigning dangerous goods. 19 ICHCA and its partners would respectfully urge IMO Member States and industry bodies to work together to raise awareness of these issues, encourage reporting of non-compliance, and help to raise safety standards throughout the CTU supply chain.

4 Page 4 Action requested of the Sub-Committee 20 The Sub-Committee is requested to consider the above comments, especially the recommendations in paragraph 17, the little data that is available and the potential scale of the issue, and consider what might be done to raise awareness and compliance in both governments and industry alike. ***

5 Annex, page 1 ANNEX Analysis of IMO Consolidated Reports 2001 to 2015 (source TT Club) Units with Deficiencies Type of deficiencies (number of units) Inspection Year DSC / CCC CA Reports Number of Units Inspected Number Percentage Placarding & Marking Stowage/ Securing Segregation of Cargo CSC Plate & Container Structure ,825 1, % ,732 2, % 1, , , ,677 1, % 1, ,301 1, % , ,284 7, % 2, , ,879 1, ,416 8, % 4,151 1,061 1, , , ,212 8, % 3,978 1,132 1, , , ,869 10, % 4,517 2,400 2, , , ,196 10, % 5, , , , ,350 6, % 3, , , ,567 8, % 4, , , ,043 8, % 3, , ,929 8, % 4,426 1,129 1, , ,195 4, % 3, ,263 3, % 2, Totals 623,859 94,206 45,219 10,620 16,511 5,513 25,823 1,016 12,010 3,384 Averages ALL Averages 5 yr Averages 10 yr 7 41,591 6, % 3, , , ,399 6, % 3, , ,504 7, % 3, , , Percentage Deficiency analysis Inspection Year Placarding & Marking Stowage/ Securing Segregation of Cargo CSC Plate & Container Structure % 14.12% 25.40% 4.39% 12.11% 0.53% 2.49% 5.28% % 9.21% 21.92% 8.77% 24.37% 0.56% 6.16% 7.19% % 13.67% 22.94% 3.56% 16.48% 1.05% 10.14% 1.14% % 6.02% 49.34% 1.34% 11.29% 1.71% 1.61% 0.27% % 6.90% 14.99% 1.82% 6.81% 0.91% 21.92% 18.58% % 10.00% 14.12% 2.94% 19.36% 0.80% 12.49% 1.14% % 10.48% 11.56% 6.47% 22.40% 0.73% 11.11% 0.41% % 16.09% 14.91% 3.98% 23.16% 1.55% 9.60% 0.42% % 6.20% 12.19% 5.37% 24.76% 0.76% 13.07% 0.69% % 3.45% 16.91% 2.04% 13.83% 0.10% 12.96% 0.42% % 6.14% 8.66% 6.33% 27.18% 0.68% 10.62% 1.93% % 9.54% 4.04% 7.85% 32.53% 1.67% 2.47% 6.86% % 10.52% 10.14% 5.79% 25.00% 0.40% 6.64% 0.29% % 3.06% 12.81% 0.73% 15.93% 0.54% 6.34% 0.36% % 1.70% 6.06% 0.44% 21.93% 0.12% 2.23% 0.00% Averages ALL Averages 5 yr Averages 10 yr 37.65% 8.84% 13.75% 4.59% 21.50% 0.85% 10.00% 2.82% 43.81% 7.30% 8.36% 5.28% 25.85% 0.76% 6.45% 2.21% 39.98% 8.83% 11.56% 4.72% 23.26% 0.83% 9.57% 1.26% 80.00% 70.00% 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% Placarding & Marking Stowage/ Securing Segregation of Cargo CSC Plate & Container Structure