Policy & Compliance
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labelled/marked and declared correctly for transport. The small – frankly criminal – minority are motivated to avoid compliance, entering cargo into the supply chain that presents a great risk to all. Once lithium batteries, particularly those shipped under SP188, are placed into the intermodal supply chain, there is very little opportunity for the cargo to be checked visually or otherwise to verify compliance. Due diligence is therefore critical: know your customers, understand their processes and satisfy yourself that they are taking the required actions in preparing and declaring the cargo correctly. Due diligence is... critical. Accurate, unambiguous and timely communication between contracting parties is also vital, ensuring that critical information is shared with all actors in a given supply chain. Conclusion History illustrates that the most catastrophic losses associated with the carriage of lithium batteries have unfortunately occurred so far in the air mode. All surface modes are, however, exposed to these risks. There may be fewer reported incidents, but a number of container fires are suspected to have involved lithium batteries. Furthermore, the technological advances, modal shift away from air and societal appetite for electric vehicles all point to an emerging risk. For all actors who contract to transport lithium batteries, developing a thorough understanding of this particular cargo is a prudent step, not least covering the safety aspect. Feedback from the industry indicates a number of ill-informed enquiries and additional documentary demands for such shipments, causing delays and frustration. For some incidents at sea, it has fallen to an over-stretched crew to respond, with limited resources. Emergency response for lithium battery fires is already complex on land – whether in transit or during storage and handling. The risk is that once on fire the commodity is hard to extinguish and prone to develop rapidly, generating substantial heat. Early detection, possibly through thermal imaging, may be critical, but carriage at sea, potentially stowed where not readily accessible and adjacent to other cargo, presents an environment that is highly challenging to all involved should anything go wrong.
inclusion under SP188, whereas newer more efficient batteries may not. There is pressure from the manufacturing industry to increase the current criteria for qualification under SP188 to be inclusive of more powerful lithium batteries. This requires careful, independent scrutiny to ensure that the primary objective of only permitting the carriage of
dangerous goods that satisfy specified safety provisions is achieved.
Mitigating the risk As with many cargo types, the majority of shippers will take all practicable steps to ensure that their cargo meets specifications, achieves certification and is classified, packaged, packed,
BIFA is grateful to the TT Club for permission to reproduce this article that originally appeared in TT Talk 8 February 2022.
April 2022
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