Policy & Compliance
Barbecue season may be over, but the dangers posed by the carriage of charcoal in containers is ever-present. Not just for barbecues
purification. In spite of environmental concerns, it is estimated that global production of charcoal is over 50 million tonnes
D ata collated by Cargo Incident Noti fi cation System (CINS) shows that there were at least 68 fi re incidents on board ships during the period between January 2015 and December 2022 that exclusively involved consignments of charcoal that were produced to be used as a fuel intended for burning. Misdeclarations Most of these incidents also arose from consignments that had been misdeclared and therefore the carrier was not aware of the hazards presented. Charcoal has many uses as a metallurgical fuel, cooking and heating fuel, a reducing agent, and for other industrial processes such as filtration and
per year, much of which will be transported across the globe in containers. In September 2024 CINS, in conjunction with the International Group of P&I Clubs and the TT Club, published Guidelines for the Safe Carriage of Charcoal in Containers . Charcoal is considered to be a self-heating substance and, as such, falls under the requirements of the International Maritime Dangerous Goods (IMDG) Code. The publication details: cargo issues; provisions of the IMDG Code; container selection; container packing; ship loading: container stowage and segregation; and
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documentation.
Emergency contact details A press release issued by the Cargo Integrity Group, part of the International Cargo Handling Coordination Association (ICHCA), in mid-September reminded all parties involved in the carriage of dangerous goods of the need for an emergency contact telephone number to be provided, following recent experiences reported by its partner organisations
Shippers of dangerous goods must therefore take appropriate measures to establish access to an appropriate and knowledgeable person or persons and include their telephone contact number on the transport documents and safety data sheets, to ensure full compliance with this requirement. The Cargo Integrity Group points out that the IMDG Code starts from the premise that the transport of dangerous goods is prohibited, unless they are shipped in accordance with the applicable regulatory provisions. Only when mandatory regulations and guidelines are followed can it be expected that such cargoes are able to be transported safely. Extreme diligence and accurate emergency response information is necessary to prevent minor incidents from becoming major casualties. Failure to comply with these requirements may result in shipments being refused for transport by terminals or shipping lines and parties may incur heavy fines and product liability risks in any legal actions.
T he majority of dangerous goods shipments are carried and handled without incident. Nonetheless, should an incident occur despite all safety precautions, it is essential that the necessary steps to respond to the dangers can be taken swiftly and reliably by those attending the scene. A requirement of many national dangerous goods regulations for transport by sea, in order to comply with international dangerous goods regulations, including the IMDG Code, is that a suitable 24-hour emergency response number must be provided within shipping documentation, safety
data sheets or other compliant means for each shipment of dangerous goods. The phone number must be answered by a person who is knowledgeable of the dangerous goods being shipped and has comprehensive emergency response and incident mitigation information for the product or products in the shipment or has immediate access to a person who has that information. This phone number must not have a call-back function, such as the use of voicemail or pager, nor be a general answering service. The number must be current during the shipment and monitored 24 hours a day.
22 | November 2024
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