Industry is looking to plug a gap in the safe transport of dangerous goods with guidance on dealing with the hazards that exist in intermediate storage
There has been an increase in the number of incidents involving containerised dangerous goods at sea in recent years, as the pages of HCB have frequently reported. At the same time, though, there has been a similar level of occurrences on shore in warehouses, especially in port areas, where dangerous goods are prepared for or stored after sea transport. Some of these incidents, such as those in Tianjin in 2015 and in Beirut in 2020, have hit the headlines but, as ever, these are only the tip of the iceberg. Industry is concerned that any of the many other smaller incidents taking place around the world could have a similarly catastrophic outcome if rules and procedures are not followed.
There is, though, a problem. The transport of dangerous goods, whether packaged or in bulk, is well regulated, with consistent rules in place around the globe and, to a large extent, across transport modes. The storage of packaged dangerous goods in warehouses, on the other hand, is not subject to a consistent set of rules; such regulation as exists is often local in nature, with relatively light or even non-existent oversight by enforcement agencies.
In the event of an accident, investigations are seldom made public, as they too are often the responsibility of a local agency. According to those involved in the containerised chain, though, a common cause of incidents in warehouses is incorrect handling and storage, including improper or ineffective segregation, as well as issues relating to the prolonged storage of material that can affect its stability. Both of these factors were at play in the Tianjin and Beirut disasters, with too much ammonium nitrate being stored for too long in a facility that also contained material with the potential to initiate a major explosion.
When such accidents happen, those involved in the transport chain, including the container lines and freight forwarders, are often called in to help handle the response and to provide subject matter expertise on the dangerous goods involved. It has become clear to industry that there is a need for more guidance on dangerous goods warehousing in port areas, despite the plethora of existing regulation and standards.
GET IT TOGETHER
In response to that need, four industry organisations have developed a guidance document. The Dangerous Goods Warehousing White Paper is co-authored by the International Cargo Handling Coordination Association (ICHCA), the International Vessel Owners Dangerous Goods Association (IVODGA), the National Cargo Bureau (NCB) and the World Shipping Council (WSC). The contents of the white paper have been shared with relevant maritime regulators and the International Maritime Organisation (IMO) with an invitation to consider including the white paper and associated checklist in its various instruments, codes and circulars, as appropriate.
IMO revised its Safe Transport of Dangerous Cargoes and Related Activities in Port Areas (MSC.1/Circ.1216) in 2007 but, the authors say, while this does contain valuable advice and recommendations, it is very much a ‘high-level’ document. In contrast, the white paper contains practical guidance on the systematic and documented management of dangerous goods in warehouses.
The value of the white paper has been recognised by endorsement from a range of influential industry representatives, including the Baltic and International Maritime Council (BIMCO), the Bureau International des Containers (BIC), the Container Owners Association (COA), the Council on Safe Transportation of Hazardous Articles (COSTHA), Danish Shipping, the International Chamber of Shipping (ICS), the International Federation of Freight Forwarders Association (FIATA), the International Group of P&I Clubs (IGP&I) and the TT Club.
MEETING A NEED
Explaining the need for the white paper, Uffe Ernst-Frederiksen and Ken Rohlmann, both representing IVODGA, say: “The temporary or long-term storage of dangerous goods in a facility necessitates careful planning, supervision and continued due diligence. While the major disasters in Beirut and Tianjin have been widely reported, there are many other incidents around the globe that do not garner the same attention, but which have the potential to escalate. There are existing international, national and local regulations for dangerous goods in transit for various modes of transport but there is no direct equivalent for warehouses.”
Furthermore, in any transport chain there will be a range of dutyholders, each subject to the appropriate regulations and standards, which impose specific obligations and requirements. Each dutyholder has to rely on the level of compliance shown by the preceding player in the chain and the goal of ensuring end-to-end safety can be compromised if any one dutyholder fails to fulfil its obligations. Intermediate storage along the supply chain, not subject to the same detail of regulation, therefore represents a weak link in the chain.
The Dangerous Goods Warehousing White Paper and its accompanying Checklist detail the risks involved in storing and handling dangerous goods and, importantly, the measures to be taken to contain those risks. Topics covered include: competency and training of workforces; property construction; fire protection; security equipment and protocols; and emergency response procedures. It is intended as a practical guide to systematic and documentable processes for those managing and operating storage facilities to ensure ongoing safety but also that incidents are containable if and when they arise.
“A pivotal element of our guidance is a Warehouse Checklist,” adds Richard Steele of ICHCA. “Given our aim to provide a practical management tool, we believe the Checklist format is a significant addition to the other elements of the white paper. Broken down into eight key functional areas of operation, this comprehensive 14-page Checklist is designed as both a planning guideline and a review tool, as well as an everyday device for maintaining safety management vigilance.”
LIMITS OF THE POSSIBLE
The white paper notes that there are many factors that can affect the safe and secure storage of dangerous goods in storage facilities and warehouses. Those include adherence to applicable standards, workforce integrity (especially in terms of effective training), the construction and protection of warehouses (i.e. using non-combustible materials and having effective security controls in place), operational controls, storage conditions, and emergency response and preparedness.
The authors recognise that the white paper cannot address all circumstances and they note that applicable regulations and standards will always take precedence. However, the white paper and its associated checklist do offer a good place to start when considering safety in warehouse storage, whether in port areas or elsewhere.
The white paper also offers a selected list of links to existing standards and guidance documents, including legal provisions in place in the EU, the US, Ireland, the UK, Belgium and Australia, International Standardisation Organisation (ISO) standards, guidance from a number of trade associations and references to press reports on significant incidents.
The white paper and its associated checklist can be downloaded free of charge from the websites of the bodies involved.