The UN agencies are necessarily constrained by the submissions that are raised, either by member states or affiliated organisations. Relevant here are the container inspection findings that are reported to IMO annually. Those lodged for 2022 continue to be too sparse to guide decision-making (and below the annual average count over the last two decades), while demonstrating continuing concerns in key safety issues such as placarding (the external alert) and effective packing.
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It is heartening that the National Cargo Bureau (NCB) are 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.
Perhaps a ground-breaking initiative is the Cargo Safety Program recently announced by World Shipping Council that seeks to standardise cargo screening across the liner shipping industry, combining this with container inspections and creating a machine learning powered feedback loop, linking also to a ‘Verified Shipper Database’. There are a number of technology providers who deliver parts of such a matrix, but combining all elements has the potential not just to tackle non- or mis-declaration, but also beneficially segregate and reward those actors who habitually adopt good practice.
It is in everybody’s interest to improve certainty of outcome; innovations and initiatives such as these have the potential to deliver far beyond regulatory change.
TT regularly focuses on regulatory compliance and the adoption of sound safety practices. In this regard, we would remind all actors of the judgment statement in ‘MSC Flaminia’ that regulations set the baseline for safety. In other words, it is insufficient merely to comply where you have reason to believe that other factors need to be taken into account. Using a simple universal analogy: traffic speed restrictions are not intended to urge the driver to adopt a given speed. Good driving practice requires that all hazards are continually, and fully assessed, and appropriate actions taken accordingly.
Lithium-ion batteries
The topic arguably giving rise to most debate in the transport and logistics industry – lithium ion batteries, in their various forms – has yet to reach centre-stage at regulatory level. It is, however, almost a year ago that TT published the joint whitepaper on this, raising a number of calls to action. Subsequent papers, such as the guidance produced by CINS or the best practices from IUMI, have demonstrated both developing safety thinking and the need for further robust research.
The global need for decarbonisation and related demand for effective battery storage drive research towards power output and speed of recharge, but not necessarily enough towards 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. In part, this requires 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.
Incident investigations – such as following the serious fire aboard ‘Freemantle Highway’ – will doubtless shape diverse regulatory change, but there must surely be opportunity to get ahead and in the meantime implement safety innovations to protect seafarers, broader workforce, assets and the environment.
What is changing?
The revised ‘Book it Right and Pack it Right’ 108 page pdf guidance is available to download at
https://bit.ly/46sZNeC. Or scan the QR code.
This article was originally published on the TT Club website and is reproduced here with our thanks.
THE REPORT | DEC 2023 | ISSUE 106 | 55
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