have meaning in proportion to the degree to which people respect and comply with them. We have looked at the physical failures that create problems, but it is people who drive policy, manage companies, operate production plants, create documents and load containers.
Why do people fail to comply with the IMDG Code?
Individual actions are influenced by organisational procedures and cultures, and vice versa. Here are just some important areas:
● Company rules, standards and resources A large multi-national company can apply ready- made templates for operational safety standards that include the IMDG Code, and have compliance officers to plan training and maintain standards. By contrast, managers of small companies often have limited resources, and these are directed towards managing productivity and everyday problems.
● Business ethics
There are employers in all societies that encourage employees to regard regulations as ‘red tape’ and barriers to productivity. Operators with this mindset find it easy to push aside the IMDG Code, when it is convenient to do so, by simply not declaring cargo as dangerous goods. Again it is the ship that is bearing the risk, not them. This is primitive business thinking, but often prevails, particularly in small companies.
The container packing industry is vulnerable to this attitude. Consider container packing at its most basic. It only requires the rental of a fork lift truck, the construction of a simple container access ramp and use of a piece of land by a roadside to set up business as a container packer. There is not even a requirement for a building. It is an easy entry-level business for a budding entrepreneur with limited funds, and he may not even be aware of the IMDG Code.
Illustration from Book it right and pack it tight, of a typical damage scenario.
The quickest way to get into business:
1 Hire a fork lift truck 2 Make a ramp
3 Rent some land by the side of the road
4 You’re in business as a container packer!
In newly emerging industrial societies workers may transfer, overnight, from traditional agricultural work to industrial processing involving dangerous chemicals. There will be a time lag before such societies develop the instinctive understanding of industrial and chemical hazards that comes from experience. The IMDG Code has evolved over six decades, but it is a new concept to many companies now manufacturing and packing dangerous goods in newly developing regions. They will need help and training to assimilate the IMDG Code into their industrial cultures.
● Communication
In addition to coping with the industrial culture gap, many developing regions are doing business with the world in a second language, usually English. This adds another barrier to perfect understanding. Consider the extract from a safety data sheet below, which is taken from a Far Eastern manufacturer’s website. In the list of hazardous properties it says “Danger of Explosion: Not applicable,” but in the next line under “Fire Hazards” it says, “Material is shock sensitive and potentially explosive.” Lost in translation? The company had a highly technical website advertising sophisticated speciality chemicals but made an error in translation of the sort that can easily be made on a shipping document.
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