The perils of packing – Hazardous Cargo Bulletin
CONTAINERS Pressure is building on shippers to do more to prevent accidents and incidents arising as a consequence of improperly packed containers, particularly those carrying dangerous goods. TT Club’s Peregrine Storrs-Fox* examines the issues
The TT Club, a specialist freight insurer, is on a mission to heighten awareness of the dangerous consequences of improperly packed containers. Effective cargo management is critical at all points in the supply chain. Thus, there is edge to the current debate in the container industry concerning incidents that damage both cargo and containers, and cause injuries and fatalities. The issues involve questions about what cargo is in the container, how much of it there is and how it is packed. The debate has reached the most influential maritime forum, the International Maritime Organisation (IMO).
Much recent industry attention has been focused on the necessity to have an accurate weight for the cargo packed in every sea-going container. Initially, debate surrounded the degree to which inaccurate weights cause accidents – stack collapse, road and terminal vehicle overturning, crane failure or even contributing to ship loss. Conclusive evidence is not easy to collate, but sufficient nevertheless to require greater rigour.
However, the reality is that accurate weighing of containerised cargo is but a small part of safety in the supply chain. The way in which cargo is packed in containers is arguably more significant, as it can lead to shifting loads and cargo spillage. Accident investigations frequently identify poor weight distribution, improperly packed cargo and inadequate dunnaging, chocking and securing.
IMO, together with the International Labour Organisation (ILO) and the UN Economic Commission for Europe (ECE), is developing a Code of Practice for Packing Cargo Transport Units (CTUs). A survey undertaken as part of the preparation of this Code confirmed that it is not weight per se, but inappropriately stowed and secured cargo that is the major cause of such accidents. The TT Club believes it is vital that the issue of safe cargo packing now be given as much attention as that of accurate cargo weights.
TT Club’s own claims experience shows that 65 per cent of all incidents involve loss or damage to cargo and, of these, more than one-third result from poor packing. This trend is borne out by statistics from the container lines’ Cargo Information Notification System (CINS), where some 35 per cent of incidents investigated are found to have been caused by poorly or incorrectly packed containers.
The Club’s experience, and that of its members and of a number of consultants that have researched the problem, reveals a variety of ‘bad practices’. Often personnel involved in packing CTUs – trailers, swap bodies and railcars as well as containers – struggle to get a heavy item in and then believe that it will never move in the unit during transit. Even if they consider it might move, they seem to believe that 25 mm square batten nailed to the floor will stop it. Additionally, many also believe that placing the heavy load near the door will make it easier to get it out again, without thinking of the consequences of such weight distribution in different modes of transport.
The Club has come across instances of large-diameter, heavy steel coils placed on the floor of a container. Knowing that they need to stop the coils rolling, the packers nailed insubstantial 50 x 50 mm battens in front and behind. Such woefully inadequate blocking and bracing is all too common. Equally, cargoes covering the majority of the floor of CTU are often not secured in the belief that, since there are few gaps, they will not move or not by much.
As a result of such practices, heavy cargo items can break through the sides of containers, coils fall through the floors or, simply, the entire cargo is found to have been smashed once it reaches its destination.
There is clearly inadequate awareness of the dynamic forces imposed on cargo during transit. In order to make the nature of these forces more understandable, consider that a domestic washing machine goes through about 6,000 movements in a typical wash cycle. A transatlantic voyage on a container ship may put cargo through some 160,000 similar movements.
There is an element of ‘out of sight, out of mind’ of course. Once those who packed the container at origin close the doors they are generally relinquished of all responsibility. The modern container passes through so many handling processes on its subsequent journey that it can be difficult to pinpoint liability for an incident, even if poor packing is suspected. The consequences, however, are vast in terms of injury and loss of life as well as damage to cargo and other property.
Training is required
As a consequence of these frequent problems, the TT Club commissioned Exis Technologies to develop CTUpack e-learning(TM), an online training tool for those involved in the loading and unloading of containers and other CTUs. Both organisations hope that industry’s attention can be focused on the significant and dangerous implications of bad packing and the training required to address the problem.
The CTUpack e-learning course is aligned with the current IMO/ILO/UN ECE Guidelines for packing CTUs, as well as being informed by the developing Code of Practice. Beginning with the foundation course, which was launched in September, it will comprise modules that include topics such as ‘cargo’ or ‘transport’ and elements – the equivalent of lessons – covering areas like ‘forces and stresses’. In the future the course will evolve to reflect developments and updates to the Guidelines/Code of Practice, and there is scope for additional modules to incorporate special cargoes and more advanced training elements.
CTUpack e-learning follows the well established IMDG Code e-learning training course from Exis, which is also sponsored by TT Club. Both courses are relevant to the risk management approach that the Club has always fostered within the global freight transport community. As in other operational sectors of the industry, training is clearly the number one loss prevention measure and, if adopted as a core feature of an operator’s culture, can greatly reduce the number of incidents incurred globally each year throughout the industry.
Regulations and the Code of Practice</>
The TT Club is not alone in promoting the use of such best practice guidelines for cargo packing procedures. For many years the International Convention for the Safety of Life at Sea (SOLAS) and the International Maritime Dangerous Goods (IMDG) Code have referenced the 1997 edition of the IMO/ILO/UN ECE ‘Guidelines for Packing CTUs to assist those involved in packing containers and other transport units. The same publication is quoted in numerous other documents produced by trade organisations, carriers and governmental organisations in an attempt to provide their constituents with packing advice.
However, ILO research entitled Safety in the supply chain in relation to packing of containers, published in 2011, found that only 15 per cent of packers use the guidelines. The majority of respondents – scarcely representing the global packer industry – were unaware of the CTU Packing Guidelines. Even where their existence was recognised, they were often perceived as rules applying only to the shipping lines. Subsequently, ILO’s global dialogue forum concluded that the existing guidelines should be updated and revised, and importantly formulated as a non-mandatory – but enforceable – Code of Practice.
It was also agreed that there was a need to improve the collection and publication of data on accidents arising from the improper packing of containers, including consideration of the standard classification of accidents in order to identify related road and other accidents.
In October 2011 a Group of Experts was nominated by the three UN agencies, comprising representatives from maritime and shore-based safety enterprises; trade, academic and risk management organisations; government agencies and individuals with packing expertise. The Group started work on revising the existing document and upgrading it to a Code of Practice. Their final draft was to be considered at the meeting of IMO’s Dangerous Goods, Solid Cargo and Containers Sub-committee (DSC) in September this year, followed by review by the other UN bodies concerned.
The Code of Practice for Packing Cargo Transport Units (CTU Packing Code) is a far more comprehensive document than the original guidelines, providing all parties in the supply chain information about their responsibilities, with details of how to pack and secure packages and cargo items taking account of transport forces, load distribution and the CTU’s anchor and lashing point strengths. It also places a responsibility on the shipper to declare correctly the composition of the cargo, as well as the gross mass of the packed CTU.
Communication is the key
Plenty of good work is being done but communication still remains a challenge. ILO’s research clearly found that the current packing guidelines are not generally reaching those who are actually packing CTUs and therefore recommended that its replacement should be readily available in a format that can be used by packers across the globe. It was also agreed that the CTU Packing Code should be promoted as the source of best practice for safety in the supply chain.
The substantial investment of time and money to draw together this wealth of expertise to develop the CTU Packing Code will only be worthwhile if effective global dissemination and use of the Code is achieved. The launch of CTUpack e-learning represents what the TT Club hopes will be an important contribution to broad dissemination of sound information on best practice.