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that containers with mis-declared weights are being loaded onto vessels is proof that either, ports and/ or stevedores are practising wilful blindness to mis-declared weights or the handling equipment’s weight function is disabled. Shipowners could enforce detection of containers with mis-declared weights by insisting on handling equipment operating as designed; by requiring ports and/or stevedores to provide DPAs with certification from equipment safety auditors confirming operability of the weight function; and requiring ports to enforce WHS penalties against shippers of offending containers. A measure that would concentrate the minds of shippers of offending containers, would be their international black- listing after one strike, because safety should not require three!


DPA to be


responsible for oversighting


loading plans The DPA was recommended by the UKs MS Notice No 1188, (July 1986):


“Every company operating ships should designate a person ashore with responsibility for monitoring the technical and safety aspects of the operation of its ships and for providing appropriate shore-based back-up.”


The Hon Mr Justice Sheen, referred to this person in his Investigative Report (para 14.2) into the Herald of Free Enterprise disaster in 1987:


This is very sound advice. It is advice which ought to have been unnecessary. A well-run ship- owning company should have been organised in that manner before receiving the Notice.


The IMO requires the DPA to have, inter alia, the experience to:


Gather and analyse data from hazardous occurrences, hazardous situations, near misses, incidents and accidents and apply the lessons learnt to improve the safety management system within the Company and its ships.


The required experience indicates that a DPAs responsibility is active rather than passive, because they are required to analyse accidents and apply the lessons or recommendations to their company’s ships. DPAs should be made responsible for checking container loading plans’ compliance with the CSM, as per of shore-based support to the master. A computerised loading program with fail-safe mechanisms, would facilitate such compliance. The DPA would, as earlier noted, also respond to alerts from container cranes lifting containers with mis- declared weights.


Container stacks to be secured as a block unit


Securing a container stack as a block unit requires lashing bars with turnbuckles, fitted manually between the bases of each tier of containers and lashing eyes or plates on the deck below. With the existing container securing system, only containers stacked three or four high can be secured as a block unit with lashing bars, because the weight of the lashing bars can be handled safely by stevedores. Containers stacked above the 4th tier cannot be secured as block units because the length and weight of the lashing bars required to secure them as block units, are unsafe for handling by stevedores. Because containers stacked above the 4th tier cannot be secured as block units, the container stacks become susceptible to collapse during heavy weather. This means that the existing container securing system is defective. Every shipowner knows that the existing defective container securing system is present on their vessels before, and at the commencement of their voyages. Shipowners who claim ignorance of this defect, leave themselves open to criticism for two reasons: their internal investigation into container stack collapses either on their own, or their competitors’ vessels, if conducted with due diligence, would have readily identified this defect; secondly, it would demonstrate wilful


106 | The Report • September 2022 • Issue 101


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