|
To view this email in a browser click here
|
 |
|
 |
 |
2 March 2011. Issue 141 in the series
|
|
|
|
|
|
Welcome to TT Talk Edition 141
Contents: 1. Growing convergence of interests
2. The IMO initiative – measurement of gross weight
3. The ILO initiative – improving packing and securing within CTUs
4. Closing comments
5. Conclusion
1. Growing convergence of interests
It can be difficult to have relevant perspective when developments inevitably take time to come to fruition, but the last six months has been quite remarkable in the maturing of safety awareness in the unit load industry. This is most welcome, since the Club has regularly, over the last decade and more, raised concerns from its claims experience relating to the correct stowage and securing within ‘cargo transport units’ (CTU), and declaration of weight and contents.
One immediate catalyst for the current debate has been the publication of the ‘Lashing@Sea’ report by the Maritime Research Institute Netherlands (MARIN), which was the conclusion of a three year research project initiated in 2006. The primary focus of the report – as its name suggests – was a review of lashing and securing on board ships (ro-ro and heavy lift as well as container ships). The findings of the research demonstrated that otherwise sound securing practices are vulnerable to conditions beyond the design parameters. Key among the causes of stow instability were the unreliability of container weight information and vertical weight distribution errors due to inappropriate stow sequence. These lead to extreme GM load conditions that additionally challenge bottom tier container integrity, where information and monitoring systems available to the ship’s crew need improvement. One of the recommendations, therefore, was that gross mass should be measured and used in ship planning.
The benefits that could be derived by the international supply chain ensuring that what is put into the chain is accurately known are incontrovertible. The maritime legal infrastructure has long existed that is capable of being used, with little modification but appropriate policing, to achieve enhanced compliance for that mode. This is likely to lead to greater adherence to good practice in related issues in cargo management, improving both safety and security throughout the supply chain. Furthermore, one of the chief benefits of the unit load concept is that the cargo being carried is not handled individually throughout its transit. Thus, if a change in law or culture can ensure that cargo is accurately weighed when it reaches the maritime mode, it is likely to be effectively measured at the point of stuffing the unit.
This edition of TT Talk therefore focuses on some of the important developments. However, first, it is worth offering some definitions to improve the differentiation of terminology and concerns.
(i) Misdeclaration of gross mass, over or under, can erode or even compromise the safety of the conveyance on land, impact stack stability, both ashore and at sea, and impact the stability of the ship itself. Containers may be stacked too high or too low for their correct mass, or inappropriate decisions taken in relation to other CTUs in the supply chain.
(ii) An overweight CTU is one where the gross mass exceeds the permitted maximum axle loading for road and rail systems in individual countries. Where the CTU enters the supply chain and reaches a transport system that has known maximum gross mass limitation below that of the laden unit, it is correctly stated as ‘overweight’.
(iii) Where the payload of a laden CTU is such that the mass exceeds the rated maximum gross mass of the unit, it is overloaded. This relates to ‘safe working loads’ and may impact equipment other than the CTU itself.
The issues discussed here relate primarily to ‘misdeclaration’ of gross mass at the point at which a CTU is entered into the supply chain. While such a unit may, rarely, also be ‘overloaded’ in relation to the capacity of the unit or ‘overweight’ in relation to one or more parts of an intermodal movement, this is not the focus of this edition of TT Talk.
The term ‘CTU’ is used to mean ‘Cargo Transport Unit’, comprising in this context both freight containers, as well as road/rail freight vehicles used in ro-ro operations.
It is also technically necessary to draw a distinction between ‘weight’ and ‘mass’. ‘Mass’ relates to the property of object regardless of its environment. ‘Weight’ denotes either mass or the force of gravity acting on it. Thus, the forces involved during an ocean voyage (particularly pitch or surge) will materially change weight, although the mass will be consistent. However, this TT Talk will use the two words synonymously but relating to the meaning of ‘mass’.
2. The IMO initiative – measurement of gross weight
Mike Compton, Technical Advisor to ICHCA International, provides the following commentary on the current IMO process.
Now that the date has passed for final submission of papers for the 89th meeting of the IMO’s Maritime Safety Committee (‘MSC’) due to take place 11-20 May 2011, it is possible to look objectively at the subject of misdeclaration of container weights.
Whereas at one time with all sea freight and handling charges being based on weight and handling plant having much lower levels of safe working load the question of the correct gross weight of cargo was of paramount importance, in recent years none of this has applied. However, as the official report into the stranding of ‘MSC Napoli’ revealed, consistent misdeclaration, ie declaring 10t instead of 15t, can have an adverse impact on stack weights and even on the total deck loading. Indeed, it is not unknown for ships officers to find that their ship is down to its marks with planned cargo for the voyage still awaiting loading. In the case of ‘MSC Napoli’, it was found that there were several hundred tonnes of cargo undeclared in the deck stows and 20% of the containers were more than 3t over the declared weight. Checks could not be made on under deck cargoes in that investigation due to water saturation, but it is logical to assume a similar level of discrepancy. As such, this has become a serious problem and the MARIN Report into the stresses on both lashing gear and containers during a ship’s passage also drew attention to the weight issue.
This report was considered by the IMO’s Dangerous Goods, Solid Cargoes and Containers Sub Committee (‘DSC’) at its 15th meeting last September and, in relation to weight of containers, it invited member governments to submit proposals for MSC/89 for a new work item on this issue. This is in accordance with normal IMO procedures and such a proposal has been submitted. The only decision for MSC to make is whether to take up the issue and, in view of the situation and the obvious potential deleterious effect on the safe operation of shipping, it can hardly do otherwise. The paper, which is also from the Netherlands government that submitted the MARIN Report to DSC/15, points out that SOLAS already requires declaration of the goods and gross mass, and that any further consideration on this issue will need to build on that.
There are various views as to how this might be achieved with the World Shipping Council proposing that container terminals should be mandated to perform the weighing function. Equally, it is known that port equipment manufacturers have accepted a challenge to bring about a situation where all lifting machines used in the marine environs have the ability to weigh the loads being handled and that this is a standard feature on all items of plant on sale in the future. They will also look at packs for retrofitting and both approaches will relate to the smallest pallet truck used to load goods into containers up to the largest machines used on terminals.
If the proposal to IMO is adopted, it will be the normal procedure for MSC to instruct DSC to propose the best way for the issue to be dealt with and, applying the usual minimum timescale, it would mean that an amended IMO position could be adopted in May 2013.
It is clear that this issue should be addressed and that IMO is the right international body to do so. It is also clear that the way to do this is to build on the current SOLAS requirements and the first steps have been taken to achieve that goal.
3. The ILO initiative – improving packing and securing within CTUs
There is a separate initiative underway in the ILO to update the ‘IMO/ILO/UN ECE Guidelines for Packing of Cargo Transport Units (CTUs)’ which were last reviewed in 1997. This further enhances safety and will assist in the process of ensuring that cargo is properly loaded and secured within CTUs.
The recently published report from the International Labour Organization (ILO), entitled ‘Safety in the Supply Chain in relation to Packing of Containers’, is an urgent wake-up call to a largely cost-focused and sometimes complacent industry; it should be required reading for anybody connected with the stuffing of containers. The report was put together by Bill Brassington of ETS Consulting.
The report highlights that the inherent container custom of inaccurate cargo weights, coupled with a bad stow, is an intermodal accident waiting to happen; on every road, rail, barge, feeder, terminal, ship, 24/7 365 days a year. The poor practices of an unregulated unit load industry – represented benignly in the form of ubiquitous multi-coloured boxes on our roads and at ports – are exposed by the ILO report, but probably comes as little surprise to insiders.
The report argues strongly that ignorant or deliberate misdeclaration should be a particular concern to a modern industry, 'because the victims of accidents attributed to poor practices in packing containers can be the general public, transport workers, or their employers, who have no control over the packing of containers'. It also bemoans that 'container shipping is the only sector of the industry in which the mass of a cargo is not accurately known', concluding that the intermodal chain is at risk from this absence of effective regulation.
The ILO’s Global Dialogue Forum brought together representatives from the government, employers’ organisations and trade unions. The Forum reviewed the report, and examined strategies and policies to help constituents in ILO member States forge a common approach throughout the supply chain for the correct application of the appropriate standards in packing CTUs. This could pave the way for a substantial improvement in supply chain safety and at the end of the Forum it was reported that there was substantial consensus between the social partners.
Below is a selection of important findings addressed by the report:
- Lack of training and knowledge of available standards is a significant reason for poor practices in the packing of containers.
- Existing standards and guidance are inadequately disseminated, leading to a lack of awareness of this information, not only among workers and their employers, but other stakeholders and authorities, such as police, OSH inspectors, OSH doctors, etc.
- Misdeclaration and the lack of information on CTU contents and weight are found throughout the supply chain.
- Packing and unpacking of different consignments in the same CTU are often inappropriately planned and coordinated.
There is widespread agreement that IMO/ILO/UNECE Guidelines for packing of CTUs are necessary. The three organisations have now been requested to proceed with the revision of the existing guidelines for packing of CTUs. Improvements in the packing of CTUs and safety in the supply chain could be sought through their voluntary application and improved dissemination.
The need for appropriate skills and competencies in all components of the supply chain should be addressed through effective training. However, guidelines on consistent standards of training need to be established in order to ensure that correct training on techniques and practices is implemented.
Finally, it was recognised that there is a need to improve the collection and publication of data on accidents related to the improper packing of CTUs.
4. Closing comments
The current international engagement with these issues is welcome. The focus of the Club’s loss prevention activities over many years has ranged from dangerous goods, stowage and securing of cargo within containers, shippers’ weight and content declaration to concerns around equipment integrity arising from apparent abuse evidenced in certain claims.
As noted by Mike Compton, the IMO is ideally placed to deal with issues of gross mass declaration, and the resultant debate will no doubt lead to an appropriate legal and practical outcome that will improve safety through the industry. The ILO initiative will also drive important changes in the shipper and consolidator community. The Club supports these industry initiatives and will itself engage in the development of proposals.
We would appreciate feedback and comments from readers. For those who are 'wired', you might like to join the related discussion hosted by Cargo Systems on Linkedin.
5. 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
TT Talk is a free electronic newsletter published as occasion demands, by the TT Club, 90 Fenchurch Street, London, EC3M 4ST, United Kingdom.
You can also read this newsletter and past issues on our website:
If you do not wish to receive future editions, please use the 'Unsubscribe' link at the foot of this email. If you have received this edition via someone else and you would like your own personal copy in future, please reply to this email and send your name, company name and e-mail address.
|
|
|
|
The materials contained in TT Talk have been prepared for information purposes only, and are not a substitute for legal advice. Whilst every care has been taken to ensure the accuracy of the materials,
the editor, any contributor or the TT Club accept no responsibility for loss or damage which may arise from reliance on information contained in TT Talk.In the United States TT Club Mutual Insurance Ltd.
is approved as a surplus lines insurer in most states and is accessible through properly licensed surplus lines brokers.
For Company Registration Information please click here:
To guarantee delivery of future communications please add enews@ttclubnews.com to your address book and safesenders list.
|
|
|
|
|
|
