When a single container starts a fire, it may be difficult for the crew to detect which container is burning, due to stowage location, on or under deck, inside stacks, identify the cargo from manifest and engage in effective fire-fighting. Within a short time the fire will spread on to other containers jeopardizing safety of the crew and the vessel.

The only method of under deck firefighting is CO2. Burning cargo packed inside the container may not be extinguished by CO2 as the container will prevent smothering effect. Also, if the goods are oxidizing CO2 will be inefficient.

The effectiveness of spraying CO2 into the hatch is also doubtful for two reasons: First, with a closed container the CO2 cannot act directly on the burning cargo as it will not penetrate through the container wall. Secondly, if the oxygen content of the container or the cargo is high, the CO2 will be completely ineffective.

IUMI Position Paper Firefighting systems on board container vessels

IACS Container ship fire safety data estimates reasons for 50+ fires from 2009 to 2019 including those caused by dangerous goods.

Reasons includes

• Self-heating of dangerous goods
• Lithium-Ion batteries over heating
• Dangerous Goods reacting with water
• Faulty reefer units
• Hot work
• Exposure to sunlight
• Collision
• Others

There are many discussions taking place for enhancing SOLAS provisions related to fire detection and fire suppression considering the increased size of container ships added by the complexity due to diverse cargoes being carried.

Most of the fire cases points to misdeclaration or poorly packed containers. When dangerous goods are misdeclared or not declared the CTU may be loaded without taking into consideration of stowage and segregation rules for the actual goods packed within.

Even if the declaration is correct if the goods are not properly secured inside the CTU it may be subject to damage due to shifting of the packages or or other damages allowing the content to escape resulting in dangerous reactions, fire or explosion.

Mandatory regulations

IMDG Code is the mandatory regulation for transporting dangerous goods and harmful substances in packaged form.

Most of the sections in IMDG Code prescribes the action but does not specifically point out the party or person who is responsible for that action.  The shoulder(s) which need to bear the responsibilities of actions set out in IMDG Code may vary according to the individual countries laws. It remains the prerogative of each government to assign the respective responsibilities.

However four parties are named by the code with respect to their responsibilities

1. Shipper
2. Packer
3. Competent Authority
4. Master of the vessel

Shippers’ and Packers’ responsibilities are named in different sections such as classification, packaging, marking, labelling, placarding, segregation, dangerous goods declaration, loading goods into CTU etc. IMDG Code also refers to CTU Code.

Competent authority is responsible for issuing approvals when required by IMDG Code and allowing exemptions from the provisions of IMDG Code when such exemptions are at least as effective and safe as that required by IMDG Code.

Master’s responsibilities are put forth through SOLAS Chapter VII Part A and MARPOL Annex III, various other transport operations in IMDG Code, MARPOL incident reporting etc.

Majority of the provision of IMDG Code is applicable before loading on ships, that means the shore side is having more responsibilities and any non-compliance from shipper/packer may result in accidents at sea.

Read – “TT Talk – Ship fires often start ashore”

Here lies the complications!

When we say shipper/packer, it is not just one or two persons involved but behind the scenes there will be many who will be playing their parts.

All personnel involved in classifying dangerous goods, assigning proper shipping names, selecting authorized packaging, filling of the goods/ensuring packages are closed correctly, affixing marks/labels, verifying segregation rules, securing goods inside the CTU, selecting tank, filling of tank, affixing marks and placards on CTU, issuing correctly filled dangerous goods declaration etc requires sufficient knowledge in IMDG Code and competency in interpreting the provisions and applying same to the shipments.

How can we achieve compliance in every aspect?

Training!

IMDG Code states “The successful application of regulations concerning the transport of dangerous goods and the achievement of their objectives are greatly dependent on the appreciation by all persons concerned of the risks involved and on a detailed understanding of the regulations. This can only be achieved by properly planned and maintained initial and retraining programmes for all persons concerned with the transport of dangerous goods.”

Training and access to IMDG Code is 1^st step, then build up the competency by continuously referring, interpreting, applying the provisions of IMDG Code for every shipment of dangerous goods and ensure you offer the goods only if you are convinced it meets all applicable provisions of IMDG Code.

When in doubt; do not offer to load or stop loading!