The freight transport and logistics insurance specialist insurer, TT Club is continuing its battle to convince cargo interests, supply chain professionals and enforcement agencies that the responsibility for mitigating container ship fires is shared by numerous entities involved from end to end of the entire global supply chain. With its estimated sixty-day average occurrence of serious fires being maintained by the Zim Charleston fire in August and the TSS Pearl in the Red Sea in early October, TT is once more urging a more comprehensive approach to arresting the trend.
“There were significant lessons coming from the sad incident on the MSC Flaminia, which cost the lives of three seafarers, particularly from the subsequent legal proceedings that adjudged the shipper and NVOC responsible for root cause errors,” says TT’s Peregrine Storrs-Fox. “Despite the biennial updates to the IMDG Code, including multiple arising from this particular incident, the judge’s assessment that the regulations merely set the ‘baseline’ for good practice remains utterly true today.”
Ensuring compliance with the latest mandatorily applicable version of the IMDG Code is essential as a minimum standard for all those shipping dangerous goods by sea. But the liability judgment in the MSC Flaminia case made it clear that regulations merely set the baseline. “This is an important statement to which any entity inclined to rely solely on the letter of the law when consigning dangerous goods, would do very well to pay heed,” comments Storrs-Fox.
TT advocates a comprehensive approach, striving to bring an understanding of all the factors contributing to these fires to everyone involved in the movement of cargo in containers and therefore underlining their responsibilities for safety. Errors, misunderstandings, mis-declarations and inadequate packing and securing lie at the heart of many significant incidents, both at sea and in storage facilities. Movement of cargo is initiated in the trading of goods – sellers and buyers – who instruct packers and whoever becomes the shipper. They have a duty of care as much as the packers, warehouse operators, forwarders, logistics companies, carriers of all modal types, cargo handlers and terminal operators. Attention to accurate classification and declaration are critical to improve certainty of outcome from end to end. This requires truth as much as awareness of regulations and sound safety practices.
TT’s efforts to disseminate such awareness and knowledge have been long-standing and remain prolific. Along with its sister insurer, the UK P&I Club it has recently up-dated its guideline publication, ‘Book it Right, Pack it Tight’¹. This provides key insights for all involved in dangerous goods’ shipments, including a clear exposé of the more technical aspects of the IMDG Code. The aim is to influence higher standards of compliance by assisting all involved to understand their own duties and the duties of their contractual partners.
Closely related to the issues specific to dangerous goods are the broader aspects of packing cargo in general. While the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code) remains non-mandatory international law, it is clearly referenced from the IMDG Code. Through its participation in the Cargo Integrity Group, TT has contributed to work on the ‘CTU Code – a quick guide’. Once more this has been recently updated and assists those responsible for packing containers, accurately declaring details of their contents in order to access the guidance contained in the voluminous CTU Code itself more easily. There is also a useful Checklist of actions required, which along with the Quick Guide is available in multiple languages.
TT’s campaign to influence all parties continues with a series of Webinars early in 2023 on the subject of container ship fires and the on-going efforts to prevent them. The intent is to attract awareness and debate particularly around innovations that could materially improve the risk, including a number of those whose efforts have been recognised through the TT Club Innovation in Safety Awards over recent years. Thus, these online forums will contribute further to the valuable weight of knowledge and expertise in the arena.
“The complexities of the global container trades increase rather than diminish,” concludes Storrs-Fox. “No one entity can surmount the dangers of these horrific fires, as a consequence it is essential that the entirety of the risk faced should be embraced by all involved through the supply chain if they are to be successfully reduced.”
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