Safety in a multimodal world 14


Experts at a recent Nautical Institute conference asked: Are the dangerous goods rules fit for purpose? Mike Bryant reports.


Much work still remains to be done on bridging the gap between the dangerous goods regimes for sea and road transport, said speakers at a recent gathering of industry experts. The industry is still plagued by inconsistency and lines of responsibility are, all too oſten unclear. And participants also stressed the importance of training. The


one-day conference in


Kent last November looked at the regulatory issues affected the movement of dangerous goods by sea and by road, and just some of the challenges of doing both. Going


under the working


title of ‘Dangerous Goods by Sea, Hazardous Goods by Road, IMDG and ADR – Managing the Differences’, the event was organised by the South East England branch of The Nautical Institute, an international body representing maritime professionals involved in the control of sea-going ships and with a general interest in nautical matters. As part of its remit, it seeks to


enhance the professional standing and knowledge of its members and clearly high on its list of priorities is highlighting and reconciling – wherever possible – the differences between the regulatory codes of


the International Maritime


Dangerous Goods (IMDG) for sea freight and its road equivalent, the ADR.


In his opening address, Jeff Hart,


head of the Dangerous Goods Division of the UK’s Department for Transport (DfT) stressed that past experience and the high turnout at the conference strongly suggested that the challenges of meeting these differing regulatory requirements certainly don’t appear to be being met consistently.


“Incidents we


know about are only the tip of the iceberg


” He noted that there are serious


challenges in ensuring safe transport and the regulations are not always being followed. As well as the numerous examples of fires at sea over the last couple of decades resulting from the unsafe shipment of chemicals, explosives or other dangerous cargo, McKay believes there are many more such incidents that happen out on the open ocean that go unreported and never make it to into official data. What incidents we know about


are “only the tip of the iceberg”, he said.


Other issues that McKay


suggests are worthy of far greater investigation include who should take responsibility for a shipment making its way right along a multi- modal supply chain, and whether the training that all the individuals involved along that same supply chain of sufficient quality and coverage. Keith Bradley, hazardous goods


advisor at the Maritime and Coastguard Agency (MCA) says that it is vital to raise awareness of the issues discussed at the seminar. He admits that there is significant


Peter McKay, editor of


Hazardous Cargo Bulletin (HCB) continued that theme, pointing out that while the various regulatory requirements are obviously key to ensuring the safe movements of cargo by sea and by road, it is also vital that they don’t impede the seamless shipping of freight wherever possible.


complexity in the various IMDG and ADR codes, and that regulations differ significantly when they pertain to the individual modes. But given the different safety


requirements of ocean and road- based transport, this is inevitable, Bradley contends. For shipping, regulations have to take into account such factors as the large numbers of people and/or other equipment that can be carried on just one vessel; the fact that a vessel’s evacuation must be avoided if at all possible; that many ships – especially container vessels – only have a very small crew available to fight any fire or deal with any other incident; and that there is no access to emergency services. Likewise, road freight


characteristics that must be taken into account when considering the safe movement of hazardous goods include the huge number and diverse range of trucking enterprises, transport through heavily populated


areas and


negotiating tunnels, for example. Moreover, the regulations will


need to be modified regularly, he says, as they have to take into account changing commercial practices and society’s evolving consumer expectations. In this regard, Bradley


Roger Kagan, a qualified


Dangerous Goods Safety Advisor (DGSA) and a consultant in this field, considers that there are significant differences between IMDG and ADR regulations, not least that many types of freight are subject to one code but not the other – fire extinguishers, vehicles, engines, generators, even oily rags – a point well worth noting for intermodal shippers. The requirements pertaining


to flammable goods, amongst the most


commonly shipped


dangerous cargo, differ markedly, he continued, as they do for segregation of different goods. Packing and packaging marking regulations differ, while the placards and plates required under the ADR and IDMG regimes vary widely, all adding complexity and making the role of a shipper’s DGSA that much more important. Training for those shipping


dangerous goods is vital, Kagan contends. All involved in the process must know not only which questions need to be asked, but which don’t under the relevant regulatory frameworks. Peregrine Storrs-Fox, risk


highlights


the latest changes that will be coming into force in both IMDG and ADR regulations next year, many of which are designed to bring them into line with evolving UN guidelines. He suggests that for those interested in changing guidelines it would be beneficial not only to examine each of the codes’ amendments as they are produced but also monitor the results of UN meeting discussions, which will give a foretaste of likely changes to come further down the road.


management director at the global transport and logistics insurer, TT Club, also believes that training is critical. Moreover, he points out, from an insurer’s point of view, training has to be apparent and provable, while a shipper should also seek evidence of the training undertaken by the staff of its various contractors involved in the shipping of its dangerous goods. “From our point of view, we


see what has gone wrong” (when there has been, for example, a ship fire caused by dangerous goods incorrectly shipped), he observes. The cargo might be dangerous in itself, the loader/packer may have erred, there may be issues with segregation or stowage and the pertinent regulatory or oversight authorities may even have failed in


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their role. Collection and analysis of the


data pertaining to incidents are vital, Storrs-Fox adds, and any lessons learned fed back quickly into the system. Up next was Mike Powell, port


safety manager of the Port of Dover, who looked at the UK’s regulatory framework that governs the handling of hazardous goods in the country’s harbours – the Dangerous Substances in Harbour Areas Regulations – which date back to 1987. Here, too, training is critical,


with all concerned in any harbour handling dangerous goods needing to be fully aware of the requirements relating to them. But, with Dover operating 24/7 and 364 days a year, while handling 70 ferries a day, 9,000 trucks (of which Powell estimates something in the region of 5% will be carrying hazardous goods) as well as 13 million passengers a year, speed as well as safety is important. Powell also pointed out that the


1987 regulations are now 25 years old. While still extremely pertinent, is it not perhaps time for a fresh look at the requirements, he asks?


“The regulations


are 25 years old - is it not time for a fresh look? ”


Two speakers at the conference


addressed container stuffing and weighing. John Leach, head of cargo management for Maersk (Ships), believes that any captain should be completely confident in data showing just how much cargo his ship is carrying out of port, and how much it weighs – but, right now, he can’t be. That is because so many


containers moving through the UK have not been weighed and their weight misdeclared in the relevant


Issue 2 2013


///DANGEROUS GOODS


documentation. Overweight, or indeed underweight loads, can mean onboard containers slipping, going overboard themselves - or worse – significantly threatening the stability of the ship and even causing it to topple. A lot of effort has been made to


guarantee that a verified (loaded) container weight is ascertained just prior to loading as part of SOLAS (International Convention for the Safety of Life at Sea), but so far no success has been achieved, he laments. The secretary general of the


Global Shippers’ Forum (GSF), Chris Welsh, took up this point and highlighted the fact that shippers have come into the spotlight. Combining his role at the GSF


with his work as director of global and European policy at the Freight Transport Association (FTA), Welsh insists that it is not as easy as it sounds for shippers to provide this information. If weighed prior to loading on board the vehicle taking cargo to port, the gross mass of any container can change en-route – for example, due to water ingress. Moreover, the complexities of


groupage/part cargoes makes the task more difficult, while not all shippers have ready access to weighbridges – particularly in less developed countries like China or India. He would like to see at least


some of the responsibility shared by terminal operators, who may well be in a better position to weigh containers just prior to loading onto a vessel. Of course, this is still easier said than done, Welsh agreed. It is just not possible right now for all containers to be weighed at each and every harbour – the equipment isn’t there, and there are massive cost and time implications. Furthermore, Welsh said, such


a measure still doesn’t get round the problem of badly stuffed containers, in which weight isn’t evenly distributed or in which contents will shiſt in rough seas.


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