Dangerous Goods Misdeclaration – A Hazard waiting to happen …
Is the current process of Dangerous Goods acceptance by shipping lines a fool proof way to ensure that there is no misdeclaration ?
Why do shipping lines and vessel operators allow shippers to give the final verdict on the declaration or classification of cargo on the cargo declaration form as Dangerous Goods or not ?
In January 2019 while she was sailing in North Atlantic a fire broke out on Yantian Express.
Investigators considered the declaration of the cargo as coconut pellets was incorrect while the actual cargo was coconut shell charcoal.
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Current process of DG cargo acceptance followed by shipping lines is as follows :
Shipper will provide the MSDS and the Dangerous Goods declaration to the carrier.
Carriers will assess the declaration and MSDS and give the approval for the carriage of the cargo on the vessel.
The problem with this process is that the entire onus of the declaration of the cargo to the shipping line rests with the shipper. An unscrupulous shipper can decide to declare a potentially dangerous cargo as Non Dangerous Goods in order to shave a few pennies off the freight costs.
This would cause risks to the shipping lines and vessel operators. Risks of loss of life at sea due to accidents or improper handling of hazardous cargo due to misdeclaration. Risks of fire on board vessels causing loss to other cargo on board and the vessel itself.
IMDG Code is the mandatory regulations for carriage of dangerous goods and marine pollutants in packaged form. The Code places the responsibilities of classification, packaging, consignment procedures, etc on Shippers. However, the Code cannot verify or enforce compliance. It is left to the member countries to enforce or verify through random inspections.
Shipping Lines faced similar problems of misdeclaration of weights by shippers for general cargo in containers. Several mishaps later, the VGM regulation was put into place to ensure that the shipper declares the correct weight on all shipping documents. This step has been fairly successful to reduce untoward incidents at sea.
Why don’t shipping lines take a similar stand for regulating the acceptance of Dangerous Goods ?
Implementing a process to regulate the DG cargo acceptance can be done quite easily. Instead of following a system of self declaration by shippers and punitive measures for incorrect declaration, it is quite possible to ask shippers to carry out container wise inspection by third party inspection companies and the acceptance of the cargo for shipment can be done based on the certificates issued by the inspection companies.
Large chemicals manufacturing companies can be asked to provide self declaration of the cargo as usual but with a one time (perhaps annual) audit of the loading stations to ensure adherence to the cargo declaration.
The shipping industry still operates based on the inherent positive values of trust and self responsibility. This trait is being misused by a few shippers to mislead shipping lines to accept cargoes that may not be “NON DG” as declared.
The outcome of such shady practices may be huge accidents and claims.
There is an imminent need to correct the cargo acceptance process by shipping lines for a safer method of carriage of Dangerous Goods by Sea.