Undeclared or misdeclared hazardous goods (Dangerous Goods) has been the bane of many vessel operators and shipping lines since the start of carriage of hazardous goods on ships..
The incidents created due to this issue has been increasing over the years with 9 major maritime disasters recorded in 2019 alone and as per TT Club, a containership is involved in a major fire every 60 days..
Apart from the monetary damage to ship and cargo leading to instances of General Average etc, these incidents also result in environmental damages, salvage & wreck removal, operational/production delays and loss of human lives as seen in many incidents like the Maersk Honam..
These also result in loss of revenue for the shipping lines, importers, exporters, insurance companies not to mention years of litigation to assign liabilities..
With the increase in container ship sizes, more and more containers are exposed to an undeclaration or misdeclaration and also poor, incorrect or improper container stowage especially when dangerous containers are not properly identified..
The IMDG Code has been mandatory since January 2004 and has strict protocols in place in terms of the transportation and handling of hazardous cargo..
The IMDG code speaks about the vital nature of proper packaging and labelling in the transportation and handling of the dangerous goods and especially its importance to a safe port system..
These protocols have been put in place to prevent any related incidents and keep our ports, people, and operations safe always..
Transnet, is the State Owned Enterprise in South Africa responsible for all port operations..
As per a statement issued by the Office of the Chief Harbour Master, Transnet National Ports Authority has identified the following risks and challenges that have emerged in the past years which requires immediate attention..
- Lack of knowledge of IMDG – training that is mandatory.
- Non-Declaration or False declaration of IMDG cargo awareness needs to be created
- Misinterpretation of IMDG Code and applicable segregation
- Limited Quantities call for other procedures
- Storage of Transhipment IMDG in the Port and exceeding of the applicable dwell time
- Incorrect or no Labelling on the container
- Incorrect stowage due to incorrect labelling
- Commercial pressure on the Port Authority and Terminals
One of the major concerns is the incorrect labelling of the IMDG containers – that poses a huge risk in the event of an incident – emergency services will not have accurate information and resources to fight a fire or deal with other emergencies.
The consequences of incorrect or no IMDG label on an IMDG container could be disastrous as this could result in the stowage and transport of containers that are not compatible as per the IMDG Code in terms of segregation, thereby increasing the hazards associated with this type of cargo.
It is also the responsibility of accredited packing stations to ensure that the correct labels have been placed on the container, and for terminals to check the declared container manifest against the data in the NAVIS system for inbound and outbound containers and ensure the correct labelling is on the container – any incorrect or missing labels will necessitate delaying the container to be landed or loaded until corrected.
The incorrect declaration and the labelling of IMDG containers could result in delays to the operations and ultimately delays to the vessel carrying the cargo and following vessel.
Procedures to follow:
- All containers must be clearly labelled identifying IMDG cargo.
- The labels must have the correct name of the cargo as per the IMDG code.
- Placards and labels must be attached on all four sides of the container including secondary risk placards as per the IMDG Code.
- Containers with dangerous goods not properly labelled as per the IMDG Code will not be permitted to be discharged from the vessel or enter the terminals until corrected.
- IMDG containers that are not labelled increases the risks in case of emergencies and response times.
- All IMDG cargo must leave the port within 48 hours as per the procedures in place.
- Transshipment of IMDG will require special permission by the Harbour Master of the Port concerned – prior to the vessel loading the cargo.
- All IMDG cargo will be treated as per the marking/label on the container to prevent audit findings – unless limited quantities require another procedure to be followed – Shipper needs to make an application declaring the accurate quantities and measures taken prior to approval from the Port Authority & Terminal.
- All personnel involved in handling or planning of IMDG cargo must be trained and certificated – which will be verified by audits.
Random audits will be conducted by the Terminal & Port Authorities to ensure compliance of the procedures..
A task team has been developed by the Department of Transport and industry players to identify any gaps in the system and to improve on it. Transnet is seeing industry co-operation in assisting this team and providing inputs to ensure safe handling, and transportation of IMDG cargo..
Transnet is calling for strict compliance to the above and all other legislative requirements pertaining to the movement of IMDG..
Transnet has invited anyone with queries with above to contact Capt. Naresh Sewnath on +27 83 307 1228 or email firstname.lastname@example.org..
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