TT Talk issue 140

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17 February 2011. Issue 140 in the series

Welcome to TT Talk Edition 140

Contents:

1. Maintenance of ship’s gear – lessons from ‘Pacific Adventurer’
2. Household Goods (from US FMC press release 4 Jan 2011)
3. Hazardous gases in containers
4. Conclusion

1. Maintenance of ship’s gear – lessons from ‘Pacific Adventurer’

The Australian Transport Safety Bureau (ATSB) recently published its report into the loss of 31 20ft containers from the deck of ‘Pacific Adventurer’. Two of the ATSB safety issues identified were:

The poor condition of much of the ship’s container lashing equipment indicated that the inspection and maintenance regime applied to this critical equipment had been inadequate; and
At the time of the incident, there was no requirement for any third party to inspect or survey the fixed and loose lashing equipment on a ship.

Reading the report, there are in fact a number of issues that could have contributed to the loss of these containers. However, the ATSB identified the most significant of these as the condition of the lashing gear.

The recent publication of the IMO circular CSC.1 / Circ. 138 includes reference to gear carriers (clause 3.3 of the annex to the circular). It agrees that the Convention for Safe Containers does not necessarily cover gear carriers, but it ‘recommended that these units should be included in a maintenance and examination scheme and be subject to periodic inspections’, and it could be implied that the same recommendation should also apply to the loose gear carried.

ILO Convention 152 also requires that all loose gear is maintained and thoroughly examined at least every twelve months. The ship’s master and the ship manager appear to have been deficient in this respect. The report into the loss of the container highlighted three major issues:

The dovetail twistlock deck plates
Evidence collected from the ship showed that many of these deck fittings were so corroded that they easily came apart; in their condition the ship might as well have landed containers directly on the hatch cover.
The interconnecting twistlocks
Both the dovetail and standard twistlocks appeared to be corroded and possibly could not be closed properly. Examples were found where the twistlock was cracked. Poor interconnection between containers on deck has been the cause of stack failures.
The lashing bars and fixtures, in particular the hook terminals and turn buckles
The turnbuckles and lashing rods also suffered from corrosion with extensive material loss (by up to two-thirds in some cases), thus degrading their ability to perform as designed. The independent surveyor estimated that the corrosion had reduced the strength to 43 percent of the equivalent value in sound condition.

Without the holding power of the twistlocks at deck level and the vertical connection between containers, it is possible that the containers slammed up and down stretching the corroded lashing gear hooks, increasing the distance of the slam until the hooks or lashing bars failed. The master had notified the ship’s manager of the defective lashing equipment and had agreed to replace the gear on a gradual basis. Unfortunately the replacement programme had not reached the bay from where the containers were lost.

It is not sufficient to send a simple message to ‘Maintain your gear!’ the consequences of failing to do so must also be examined. In the case of ‘Pacific Adventurer’ all 31 containers sunk, potentially releasing harmful materials into coastal waters. As the containers fell from the ship they punctured the ship’s side above the waterline which did not place the crew in immediate danger, but did permit fuel to leak out with the potential to cause a major environmental catastrophe.

2. Household Goods (from US FMC press release 4 Jan 2011)

Each year, the Federal Maritime Commission in the US receives a substantial number of complaints from individuals who have experienced various problems with their international household goods shipment. Between 2005 and 2009, the Commission received over 2,500 such consumer complaints related to companies moving household goods and vehicles between various locations in the United States and foreign destinations.

Typical complaints allege failure to deliver the cargo and refusal to return the pre-paid ocean freight; loss of the cargo; significant delay in delivery; charges to the shipper for marine insurance that was never obtained; misinformation as to the whereabouts of the cargo; significantly inflated charges after the cargo was tendered and threats to withhold the shipment unless the increased freight was paid; or failure to pay the common carrier engaged by the company as another intermediary. In many cases, a shipper has been forced to pay another carrier or warehouse a second time in order to have the cargo released.

It is recommended that those who ship household goods ensure all documentation is correct with pick up locations, freight charges and estimated time of arrival all clearly stated on documentation. Below is a list of some good practices which will assist in avoiding problems and also the complaints filed with the FMC or elsewhere.

Ensure:

that claims for damage are investigated and handled fairly
subcontractors are not billing charges that were not agreed at the time of the booking
arrival notices are sent to the property owners so that cargo is picked up in a timely fashion, avoiding storage charges
the cargo is always stored in a way that protects it from water damage and theft
where significant delay to the cargo becomes likely, that notification of the delay is sent to the property owner and updated arrival date given.

3. Hazardous gases in containers

Following questions in the Netherlands Parliament, a number of Government Departments in that country have combined to implement an agreement on the joint monitoring of hazardous gases in import containers. This arose from a number of incidents and the aim was to inspect 1,000 containers per year. This close attention to one aspect of the dangers of enclosed spaces has a parallel with the perennial hazards of enclosed spaces on ships, including cargo and related spaces, with which the maritime world has been grappling recently at IMO.

Possible dangers to those whose job is to enter freight containers either during or at the end of a multi modal journey have been known for a long time. One specific danger that has been concentrated on arose from the use of fumigants. Fumigants are used worldwide to prevent the spread of pests, to keep the cargo in good shape or prevent the goods against unwanted insects. Different kinds of fumigants are used, one being Aluminium Phosphide; if this fumigant is not applied properly or there is too much of it, residue can remain. The fact is that a freight container is a very enclosed space with, in most instances, no ventilation at all so dangerous concentrations of toxic gases might remain.

However, it has gradually been realised that there are other possible contaminants as well – those coming from the cargo itself. The International Safety Panel of ICHCA International published one of its Safety Briefing Pamphlets (BP#20) on such dangers in 2006, and has since revised it in 2010. In collaboration between the TT Club and ICHCA, a ‘pocket card’ was published (IIL/4) in early 2010 providing guidance on the dangers of entry into freight containers.

>Please download your pocket guide here<

The aim of the recent Dutch initiative was to ensure that compliance with legislation on hazardous gases in import containers was monitored and its first report covers 1,033 containers that were checked between 1 October 2008 and 1 October 2009. Four methods were used to select the containers for sampling – random selection (250), based on regulations concerning hazardous substances (150), based on customs regulations, cargo type and country of origin (500) and finally a selection based exclusively on cargo type and country of origin.

Excessive concentrations of hazardous gases were found in a total of 106 containers – about 10% of the total. It was established that 17 of this total had been actively fumigated with toxic substances at concentrations exceeding the limit values. Only one of those containers bore a warning sign as required by the IMDG Code. The others neither had any such sign nor any reference to fumigation in the accompanying documentation. The hazardous gases found in the remaining 89 containers were released by the cargo and those most often found were in descending order toluene, benzene, 1,2-dichloroethane, methyl bromide, phosphine, formaldehyde and chloropicrin.

Whilst the percentage found to have airborne contaminants was low, it was, nevertheless, significant and the message is clear to those whose employees are likely to have to enter freight containers during or at the end of their overseas journeys. Be aware of this risk; if in doubt, stop and ask for advice!

4. Conclusion

We hope that you will have found the above interesting. If you would like further information, or have any comments, please email us. We look forward to hearing from you.

Peregrine Storrs-Fox
Risk Management Director
TT Club

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