The 375th Standing Advisory Committee on the Carriage of Dangerous Goods in Ships was held on Friday 3rd March 2017 in Spring Place at Maritime & Coastguard Agency in Southampton and PSS was in attendance.
The following are preliminary Minutes of meeting, with official minutes to be distributed in the near future
Last meeting of this SAC was on 29 Jan 2015. There was no meeting in 2016 as Keith Bradley was due to retire and a replacement had not been found at that stage. Ms Helen North is the new DG representative at MCA and chaired the Meeting. The terms of reference for the SAC are set out in MGN 340 and going forth, the Plan is to hold two meetings a year, one in Southampton and the other in London.
Incident of undeclared dangerous good (Organic Peroxide)
Limited confirmed evidence is available on this case at this time as the MCA are currently investigating the incident.
The following details are thought to be correct, but may need to be adjusted in the light of a concluded investigation.
- A van was recently stopped by French authorities at Calais.
- 120 litr3es of organic peroxide – Type F – was being transported in the vehicle intended for a passenger RoRo ferry to the UK.
- Reportedly, when the driver was asked by the French authorities it was stated that the goods were for ‘personal use’.
- Based on this incident, the French authorities estimate potentially 125 similar movements a month.
- The goods were not declared at time of shipping.
- If this type of material is being transported, undeclared, then there is an associated enhanced fire/explosion risk.
Why does Organic Peroxide pose a danger?
The main hazards related to organic peroxides are fire and explosion. Organic peroxides may also be toxic or corrosive. Depending on the material, route of exposure (inhalation, eye or skin contact, or swallowing) and amount of exposure, they could harm the body. Corrosive organic peroxides can also attack and destroy metals. The peroxy group is chemically unstable. It can easily decompose, giving off heat at a rate that increases as the temperature rises. Many organic peroxides give off flammable vapours when they decompose and these vapours can easily catch fire.
Most undiluted organic peroxides can catch fire easily and burn very rapidly and intensely, this is because they combine both fuel (carbon) and oxygen in the same compound. Some organic peroxides are dangerously reactive, they can decompose very rapidly or explosively if they are exposed to only slight heat, friction, mechanical shock or contamination with incompatible materials.
Refusal to Ship notifications
MCA presented data showing non-compliances (sufficient to generate a refusal to ship decision) as reported to MCA by DFDS, Eurotunnel and P&O for the period of May 2016 to July 2016. 513 instances were reported to MCA in total. The most frequent non-compliances were:
- DGN not completed/incorrectly completed and Quantities Exceeded (mostly from Eurotunnel).
- There were 68 ‘repeat offender’ hauliers. Ten companies had been refused over seven times and one company had been refused 43 times.
Carriage of Waste Batteries
A number of incidents have occurred recently related to the carriage of mixed waste batteries (mainly believed to be car batteries) and in particular, cargo intended for carriage on board ro-ro vessels (UN2794, UN2795, UN2800). Currently, UK Chamber of Shipping ferry members have stopped the carriage of this cargo due to safety concerns. (Reportedly a fire on a truck which destroyed the vehicle/cargo in approximately 30 minutes) The UK Chamber of Shipping has discussed this matter with the ICS Dangerous Goods Panel where it was advised that the container sector had not encountered any similar incidents as the relevant cargo was properly shipped i.e. waste batteries are drained and discharged completely before shipment. Nevertheless, the Danish Shipowners Association has reported similar incidents on ro-ro vessels. To this end, the Danish Maritime Authority has developed guidelines for RoRo vessels with respect to the carriage of waste batteries.
UN 3509 Packaging, Discarded, Empty, Uncleaned
The UK Chamber of Shipping members have reported that although UN 3509 shall not be used for sea transport and is prohibited on Passenger and Cargo Vessels according to IMDG 37-1, operators are continuously presented with this cargo.
Declaration of Marine Pollutants
The UK Chamber of Shipping members have reported that they are encountering a considerable number of discrepancies in the documentation submitted for the shipment of marine pollutants. In particular, while provision 220.127.116.11.1 of the IMDG Code requires that the proper shipping name of generic or ‘’not otherwise specified’’ entries which are classified as marine pollutants shall be supplement with the recognised chemical name of the constituent which most predominantly contributes to the classification as marine pollutant, this is not always being declared. Instead, when challenged, shippers would provide the same name as required by the Special Provision 274. The Chamber has discussed this matter in the past with the MCA who advised that it indicates a lack of training and therefore was brought to the attention of British International Freight Association during the SAC meeting.
Lack of enforcement after an incident
The UK Chamber of Shipping members have raised concerns with regard to what they perceive to be a lack of enforcement from the UK authorities after incidents related to the carriage of dangerous goods. For example, an incident was described involving a spill of asbestos from a lorry, during a UK ferry crossing. The spillage was responded to and cleaned up by the vessel operator and the authorities were notified. However, reportedly, no action was taken by HSE/the authorities against the vehicle operator. However HSE were not represented at the meeting to respond to this.
DG Movements without Placards
It was suggested that anecdotally (based on stock turnaround) that up to 75% of containers and vehicles containing declared DGs arrive at ports without a complete set of affixed placards. This means that ports/operators often have to hold large stocks of placards/labels at ports to fill gaps. Holding this stock can involve significant cost and although the cost is usually passed on to the shipper, there is still a significant administrative burden even where costs are recovered.
The date of the next meeting is tentatively scheduled for October 2017.