CINS recommended practices
Cargo practices recommended by CINS Guidelines include selected requirements of the IMDG Code, combined with additional precautions to ensure the safe carriage of charcoal.
CINS Guidelines recommend that all charcoal shipments should be classified as dangerous goods, even prior to the applicability of the IMDG Code Edition 2024 (Amendment 42-24).
Further recommendations set out by CINS address the following areas: - Container selection - Cargo weathering and packaging - Container packing and vanning survey
- Ship loading, container stowage and segregation
- Documentation requirements.
Preventative measures against charcoal fire incidents
When considering preventative measures, regulatory requirements and industry guidance should be supplemented by a comprehensive risk assessment. This is necessary
to ensure that the measures are applicable to the circumstances of the ship, operational situation, provisions of the Safety Management System (SMS) and the business environment including terminals and customers. If needed, a gap analysis should be carried out and cargo management procedures revised as appropriate.
The following objectives should be considered: - Cargo management and booking process should ensure that cargo containing charcoal is correctly identified and declared.
- Charcoal should be pro-actively treated as dangerous goods even before the 2024 edition of the IMDG Code is in force. In particular, the cargo management process should not enable the two existing Special Provisions (SP 925 and SP 223) and ensure that all charcoal cargo intended as fuel for burning is correctly classified and declared as dangerous goods. It is recommended to align cargo management process with the forthcoming SP 978 (including the requirements for container selection, packaging, stuffing, inspection, stowage and segregation set out in SP 978).
- Where charcoal is traded under names which may conceal its dangerous nature, carriers should implement effective cargo screening, together with the appropriate “Know Your Customer” (KYC) due diligence to ensure the cargo is correctly classified and properly declared.
- Carbonised material intended for manufacturing of UN 1362: CARBON, ACTIVATED has been known to be misdeclared – the cargo management process should take it into account
- The weathering report, the vanning survey, as well as other surveys in place, should effectively identify additional risk factors, such as insufficient weathering of charcoal cargo, wetting of the cargo, or the effect of chemical additives present in the cargo on its stability and propensity to self-heat
- The KYC approach may be effective in reducing the risk by proactively assessing the cargo management prior to container packing and shipping
- Accessible stowage on deck (accessible from a fixed platform, deck or a lashing bridge), exceeding IMDG requirements is recommended. Accessibility is required to enable prompt extinguishing action.
THE REPORT | MAR 2025 | ISSUE 111 | 99
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