Intermodal Eye is delighted to welcome a guest post from Peregrine Storrs-Fox at TT Club, a leading provider of insurance and risk management services to the international transport industry.
The safety of containers was initially addressed when there were tens of thousands of units. Now, some 45 years later, there are tens of millions in circulation. The International Maritime Organization (IMO) has been reviewing the processes associated with the Convention for Safe Containers – are you ready for the changes?
The IMO’s review process started with the introduction of the ‘Serious Structural Deficiencies’, which identified the key components of a container and the maximum permitted damage to them, which, if exceeded, can restrict international movement. This is now being further amended to bring clarity to safety levels.
An accident involving 30’ containers collapsing on board ‘Annabella’ in 2007 stimulated a detailed discussion on some of the basic principles of the Convention, particularly relating to the use and marking of such containers. As a result, the IMO have prepared instructions for marking containers with reduced stacking or racking capabilities, aligned to revisions to ‘ISO 6346 – freight containers, coding, identification and marking’. This means the majority of swap bodies and many regional containers will need to be re-marked to alert users to the capabilities that differ from the norm. All changes must be completed by 1 July 2015.
Another accident in Canada prompted a review of the Continuous Examination Programme regime for containers. Under new guidelines, Contracting Parties (the authorities that approve programmes and issue the ACEP reference) will carry out periodic audits. That will mean that a representative could shortly visit your offices to check your process for maintaining containers. Do you know when and where every one of your containers was last thoroughly examined and what proof you have that the examination was carried out?
In addition to the audits, the Contracting Party also has to review all the programmes under its jurisdiction every ten years to confirm that they are still in operation. Failing to provide requested details may result in your ACEP approval being revoked. There are also detailed provisions relating to the transfer of responsibility between container lessor and lessee, so be warned!
We all know the importance of the CSC Safety Approval Plate, its presence permits the container to be used in international maritime transport. Marked on the plate is the Approval Reference. Generally issued by a classification company on behalf of the Contracting Party, this reference links the design with the manufacturer and the classification society. The Identification number is also on the plate; this is essential in tracing the container back to the original manufacturer. You should note that it is no longer permitted to use the container serial number for this identification.
Finally, if a designated control officer feels that the damages found on a container exceed the new safety levels, he can restrict its movement or placement within stacks, for instance on or near the top slots only. With a view to the prevention of containers being lost overboard, it would be inadvisable to have a heavily loaded container with a ‘Top stack only’ instruction!