Peregrine Storrs-Fox, Risk Management Director at TT Club, has noted that the biennial cycle of maritime Dangerous Goods regulations will see the next amendment become mandatory on January 1st 2024, and thus provided “a valuable opportunity to consider the trajectory of changes or improvements in safety for the freight supply chain”.
The provisions relating to the transport of Dangerous Goods are revised regularly. While the overall governance of the regulations and the Dangerous Goods List is centred in Geneva and housed in the United Nations Recommendations on the Transport of Dangerous Goods, (the UN Model Regulations), the London-domiciled IMO has responsibility for the implementation of these regulations in the maritime mode.
Since the next version of the International Maritime Dangerous Goods Code (IMDG code), (Amendment 41-22), will shortly enter mandatory application TT Club has, in conjunction with UKP&I, updated the well-established ‘Book it right, pack it tight’ publication to provide general assistance and route map to the industry in these important matters.
While there have inevitably been numerous changes embedded in this IMDG Amendment, a number of consequential debates remain underway at this inter-governmental level. IMO committees are currently seeking to reach finalization on how to fashion a revised safety framework regarding the transport by sea of Charcoal / Carbon (UN 1361). Storrs-Fox said that “this vexed issue, frequently resulting in fires while in the supply chain, has encountered protracted debate”.
The concerns relate essentially to lump charcoal that is intended for burning on barbecues, etc, which sometimes have been treated with accelerants.
Tests and research are ongoing to determine certain particular hazards, but it appears that there is agreement over key safety measures that may be adopted. These will become mandatory only from January 1st 2026 in Amendment 42-24. There remain some concerns relating to the differentiation between this cargo and Activated Carbon (UN 1362), which is produced from the raw material. Further, there are non-lump forms of Charcoal, such as those produced for artists materials, that have quite distinct burning, cooling and packaging processes. Storrs-Fox said that “deft handling of such issues will be required by regulators, carriers and enforcement agencies”.
Although lithium-ion batteries, particularly in motor vehicles, are already high-profile, Storrs-Fox noted that lithium ion batteries, in their various forms, have yet to reach centre-stage at regulatory level.
TT published a joint whitepaper on this nearly a year ago, while subsequent papers, such as the guidance produced by CINS or the best practices from IUMI, “demonstrated both developing safety thinking and the need for further robust research”.
The global need for decarbonization and related demand for effective battery storage have been driving research towards power output and speed of recharge. However, said Storrs-Fox, there had not necessarily been enough research as regards safety through the supply chain and end-to-end life cycle. “TT continues to lobby for engagement between manufacturers and the transport industry to reach a common understanding of the hazards presented and how these can best be controlled”, said Storrs-Fox.
He said that in part this would require thorough independent scientific research – as much for the existing and legacy chemistries as for what is emergent, “since the former will continue in circulation for many years, including in increasing states of degradation”.
What is changing?
UN agencies were necessarily constrained by the submissions raised, either by member states or affiliated organizations. Storrs-Fox said that the container inspection findings that are reported annually to the IMO (a UN agency) were in 2022 too sparse to guide decision-making – and well below the annual average count over the last decade – “while demonstrating continuing concerns in key safety issues such as placarding (the external alert) and effective packing”.
TT Club found it heartening that the National Cargo Bureau (NCB) was repeating a broad-based inspection initiative to shed more light on general container packing safety. “Indeed, the work of the Cargo Integrity Group, where TT was a founding partner, continues to be highly important in promoting safe packing practices, linking to the IMO/ILO/UNECE CTU Code”, Storrs-Fox wrote.
The Cargo Safety Programme recently announced by World Shipping Council, which seeks to standardize cargo screening across the liner shipping industry, could be a groundbreaking initiative.
Storrs-Fox concluded that it was in everybody’s interest to improve certainty of outcome. “Innovations and initiatives such as these have the potential to deliver far beyond regulatory change”.