Detecting this misdeclaration requires skill, knowledge and training in the shipowner’s / carriers’ booking offices. Increasingly, specialist software is used to assist the discovery of these shipments. Commencing in 2011, Hapag Lloyd developed their own in-house product called Cargo Patrol which has assisted in the detection of thousands of instances of incorrectly declared dangerous goods
Not every carrier shipowner or carrier is as diligent. For example, carriers’ booking offices usually produce a draft bill of lading after shipping instructions have been received, using the information provided at the time of booking. The final bill of lading is then prepared by the documentation department usually at the last moment before loading the container on board, which can be quite a bit later than when the shipping instructions were first received. It is at this point that a fraudulent shipper can request changes, such as switching the description from an accepted non- dangerous cargo to a dangerous one or adding the correct cargo description in the ‘marks and numbers’ box of the bill of lading. The mismatch can also be for declared dangerous cargoes, with a more dangerous or additional one appearing on the final bill of lading. Documentation department staff usually do not have the same level of training as the booking department staff do, facilitating the oversight of these last-minute changes.
52 | The Report • March 2020 • Issue 91
Misdeclared Cargoes – tightening the booking process!
Ultimately, the critical issue is for shipowners and carriers to know their customers better. Who is the real shipper? We are aware of the dangers of brass plate companies which are established to disguise the identity of the true shippers. These companies can still be identified but this discovery process requires diligence, research, and above all, time - a rare commodity in the container trade. An enhanced new customer vetting process needs to be in place, and it should apply to all shippers and freight forwarders. All booking office staff and agents need to know and trust their customers. This means doing due-diligence checks on new customers and their supply chains or, in the case of slot charterers and freight forwarders, confirming what checks they use on their own customers. It is vital that the manufacturer of the goods – if not the customer – is identified and verified, and that the testing laboratory being used is both reputable and independent of the customer or manufacturer.
We recommend that the following key points are part of the booking process:
• Use of synonym list through due diligence software to detect suspicious shipments
• Clearly defined and enforced booking deadlines for both DG and non-DG cargoes as well as for existing and new customers
• All documents submitted at booking stage are thoroughly examined
• Background checks on all manufacturers to ensure that they actually produce the declared cargo. If that is not possible, due consideration should be given to physically inspecting the goods in the container during the stuffing.
• Dangerous goods training must be provided to all booking office staff, including the dangerous goods desk, the non-dangerous goods desk, the documentation control department, head office and all regional and port offices. It should include full-time, part- time and temporary staff of all levels of seniority.
• Implement deadlines for DG cargoes to ensure that there is sufficient time for due diligence checks on the proposed shipments
• The Harmonized System (HS) is the international standard to describe cargoes for customs purposes. Booking office staff and agents should insist on the use of the correct six-digit HS codes for all bookings, both dangerous and non-dangerous cargoes before considering accepting them for shipment
• Computerised booking systems must also be robust, reliable and secure, with procedures in place for regular software updates and continuous data back-up. The system must be accessible by all booking office staff so that all documentation and communications relating to the booking can be viewed at any time.
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