Although both the SOLAS Convention and the IMDG Code have addressed the stowage of dangerous goods and the associated control measures to cope with safety related issues onboard containerships, catastrophic fire incidents continue to happen. To instruct ship operators, cargo carriers and port personnel, the Safety Considerations for Ship Operators Related to Risk-Based Stowage of Dangerous Goods on Containerships (hereinafter referred to as Safety Considerations) has been prepared by a working group comprising Members of CINS and Classification Societies.

CINS – Cargo Incident Notification System

CINS is a shipping line initiative established in 2011. It was first introduced by five of the world’s biggest container lines: CMA-CGM, Evergreen, Hapag Lloyd, Maersk Line and Mediterranean Shipping Company. There are now 17 shipping line members as well as many advisory members, honorary members and associate members.

To highlight risks posed by certain cargoes and/or packing failures in order to improve safety in the liner shipping industry, CINS collects information on operational cargo-related accidents and incidents from seaborne carriers, analyses global operational information and uploads them into the CINS online database where it captures information and looks for specific incidents which may require immediate action or assessing incident trends. Once areas of concern become apparent, they can be addressed to the IMO or relevant authorities to formulate appropriate recommendations or advice.

Significance of the Safety Considerations

In the last two years, cargo insurers estimate US$130M of cargo was damaged in four containership fires underwritten in London. These were on ER Kobe, APL Vancouver, Maersk Honam and Yantian Express. Five mariners died in the blaze aboard Maersk Honam. Investigation on these incidents highlights the fact that mis-declaration, improper packing and erroneous segregation of cargo are the root causes.

The Safety Considerations are not intended to replace the SOLAS and IMDG requirements, but to add technical instructions on stowage and segregation of Dangerous Goods and higher risk cargoes. Besides, the safety considerations bring to ship operators’ notice the importance of compliance and the risks of carrying commodities which may be declared as not subject to the provisions of IMDG but still present heightened risks, such as charcoal, wood pellets, metal scrap, borings and seed cake.

Objectives of the Safety Considerations

1.      To facilitate security and validity of Dangerous Goods and High Consequence Dangerous Goods;

2.      To prevent fire and spillage incidents from Dangerous Goods and higher risk cargoes;

3.      To protect lives in the event of a fire or spillage incident;

4.      To retain the main engine and propulsion in a fire event;

5.      To retain structural integrity in a fire event;

6.      To facilitate firefighting in the event of a fire or spillage incident.

Developing Six Risk Zones

The CINS working group has developed a risk-based model for the safe stowage of Dangerous Goods according to the classification and properties of commodities. For this purpose, six Risk Zones (RZ) are divided as set out below.

RZ0: General cargo not subject to the IMDG Code

RZ1: IMDG Code cargo which should be effectively extinguished with CO2. Taking consideration of the fire and spillage schedules.

RZ2: As RZ1, but Class 4.3 if IMDG Code permits under deck without mechanical ventilation.

RZ3: Slow reacting cargo. IMDG Code cargo which should be effectively extinguished with water.

RZ4: Flammables, oxidizing, and toxic cargo.

RZ5: Explosives.

General Safety Considerations

1.      Dangerous Goods shall be stowed in accordance with IMDG, SOLAS and the ship’s Document of Compliance for Carriage of Dangerous Goods as well as any requirements set by the Flag State of the ship.

2.      Ship operators should apply appropriate additional standards, policies and procedures in relation to the cargoes and Dangerous Goods being loaded on their ships, taking into account the technical design and characteristics of each ship.

3.      Safe stowage of Dangerous Goods and higher risk cargoes can be enhanced further by utilizing risk‐based Dangerous Goods Stowage Concept methodologies.

4.      Safe stowage of Dangerous Goods and higher risk cargoes should always be based upon the UN Number of each consignment and the related cargo characteristics.

5.      Shippers and Consignors should be prepared to evidence that the goods offered for transport are correctly classified in accordance with IMDG and UN Orange Book.

6.      Where there is concern that the goods may present a HSSE risk, the container and contents may be inspected in order to ensure there is no danger to the crew on board, the ship or any stakeholder in the supply chain.

Stowage Strategies

1.      Stow Dangerous Goods and higher risk cargoes which cannot be extinguished by either water or CO2 on deck.

2.      Dangerous Goods prone to fire or explosion should be segregated from known ignition sources.

3.      Stow explosives furthest away from accommodation and primary life‐saving appliances.

4.      Limited Quantities and Excepted Quantities of goods should be stowed in the appropriate Risk Zone according to the IMDG Class and UN Number.

5.      Empty uncleaned items that may contain the residue of Dangerous Goods should be stowed in same Risk Zone as the classified equivalent.

6.      Non-Dangerous Goods barriers should be introduced between adjacent Risk Zones in the fore-and-aft line of the ship.

7.      IMDG Class 4.3 Packing Group I containers should be restricted to second or third tier or higher depending on lashing bridge height.

8.      Dangerous Goods should not be block stowed unless each individual cargo UN Number, rather than simply IMDG Class, is carefully considered for its own unique properties and characteristics.

9.      IMDG Class 9 cargoes should be scrutinised with particular care to understand inherent hazards and apply adequate safety and security precautions in stowage planning.

10.  Self‐reacting commodities (including but not limited to Dangerous Goods such as charcoal, fish meal, seed cake, hay, cotton, etc.) which are not subject to the provisions of IMDG through application of a Special Provision should be stowed in an accessible position as far as is practicable.

11.  All commodities not subject to the provisions of the IMDG through application of a Special Provision should be stowed in same Risk Zone (see Section 5) as the classified equivalent.

12.  Avoid stocking Dangerous Goods and higher risk cargoes:

(1)   adjacent to accommodation or the engine room;

(2)   in cargo holds above the engine room/shaft tunnel area, or in the bottom tiers in the hold;

(3)   in the rows under deck adjacent to wing fuel tanks and internal bulkhead fuel tanks;

(4)   in the outermost rows on deck;

(5)   in the forward/aft most bay on deck;

(6)   on deck without being protected from direct sunlight;

(7)   over working spaces and walk-ways.

Advice to Members

CINS has admitted that these Safety Considerations serve as only a referral guidance for its members and container shipping lines as it has not effectively addressed vertical and athwartships segregation of Dangerous Goods and higher risk cargoes while many ship operators have established their own stowage and segregation measures. It is the first version and further elements of the Safety Considerations are intended to be developed and published.

In addition, these Safety Considerations are now provided to shipping line organizations and open to complements by masters and mariners. However, as containerships continue to upgrade in sizes, it becomes unrealistic for the master and crew to verify the appropriate classification and segregation of Dangerous Goods. It will be more practical if the CINS suggested Safety Considerations can be accepted throughout the industry with execution scrutinized by technical approval organizations and complements generated in cargo planners.

For further information, please contact your manager at the Club.