Regulation and improving fire-fighting techniques have proven inadequate to stem the tide of serious incidents costing lives, significant cargo losses and ship damage.

London 10^th November, 2022

The freight transport and logistics insurance specialist insurer, TT Club is continuing its battle to convince cargo interests, supply chain professionals and enforcement agencies that the responsibility for mitigating container ship fires is shared by numerous entities involved from end to end of the entire global supply chain.  With its estimated sixty-day average occurrence of serious fires being maintained by the Zim Charleston fire in August and the TSS Pearl in the Red Sea in early October, TT is once more urging a more comprehensive approach to arresting the trend.

“There were significant lessons coming from the sad incident on the MSC Flaminia, which cost the lives of three seafarers, particularly from the subsequent legal proceedings that adjudged the shipper and NVOC responsible for root cause errors,” says TT’s Peregrine Storrs-Fox.  “Despite the biennial updates to the IMDG Code, including multiple arising from this particular incident, the judge’s assessment that the regulations merely set the ‘baseline’ for good practice remains utterly true today.”

Ensuring compliance with the latest mandatorily applicable version of the IMDG Code is essential as a minimum standard for all those shipping dangerous goods by sea. But the liability judgment in the MSC Flaminia case made it clear that regulations merely set the baseline.  “This is an important statement to which any entity inclined to rely solely on the letter of the law when consigning dangerous goods, would do very well to pay heed,” comments Storrs-Fox.

TT advocates a comprehensive approach, striving to bring an understanding of all the factors contributing to these fires to everyone involved in the movement of cargo in containers and therefore underlining their responsibilities for safety. Errors, misunderstandings, mis-declarations and inadequate packing and securing lie at the heart of many significant incidents, both at sea and in storage facilities. Movement of cargo is initiated in the trading of goods – sellers and buyers – who instruct packers and whoever becomes the shipper. They have a duty of care as much as the packers, warehouse operators, forwarders, logistics companies, carriers of all modal types, cargo handlers and terminal operators. Attention to accurate classification and declaration are critical to improve certainty of outcome from end to end. This requires truth as much as awareness of regulations and sound safety practices.

TT’s efforts to disseminate such awareness and knowledge have been long-standing and remain prolific.  Along with its sister insurer, the UK P&I Club it has recently up-dated its guideline publication, ‘Book it Right, Pack it Tight’¹.  This provides key insights for all involved in dangerous goods’ shipments, including a clear exposé of the more technical aspects of the IMDG Code. The aim is to influence higher standards of compliance by assisting all involved to understand their own duties and the duties of their contractual partners.

Closely related to the issues specific to dangerous goods are the broader aspects of packing cargo in general. While the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code) remains non-mandatory international law, it is clearly referenced from the IMDG Code. Through its participation in the Cargo Integrity Group, TT has contributed to work on the ‘CTU Code – a quick guide’². Once more this has been recently updated and assists those responsible for packing containers, accurately declaring details of their contents in order to access the guidance contained in the voluminous CTU Code itself more easily.  There is also a useful Checklist of actions required, which along with the Quick Guide is available in multiple languages.

TT’s campaign to influence all parties continues with a series of Webinars early in 2023 on the subject of container ship fires and the on-going efforts to prevent them.  The intent is to attract awareness and debate particularly around innovations that could materially improve the risk, including a number of those whose efforts have been recognised through the TT Club Innovation in Safety Awards over recent years. Thus, these online forums will contribute further to the valuable weight of knowledge and expertise in the arena.  This year’s Safety Award entry process is nearing its conclusion but further information is available HERE

“The complexities of the global container trades increase rather than diminish,” concludes Storrs-Fox.  “No one entity can surmount the dangers of these horrific fires, as a consequence it is essential that the entirety of the risk faced should be embraced by all involved through the supply chain if they are to be successfully reduced.”

¹ https://www.ttclub.com/news-and-resources/publications/birpit

² https://www.ttclub.com/news-and-resources/publications/ctu-code-a-quick-guide

About TT Club

TT Club is the established market-leading independent provider of mutual insurance and related risk management services to the international transport and logistics industry. TT Club’s primary objective is to help make the industry safer and more secure. Founded in 1968, the Club has more than 1,100 Members, spanning container owners and operators, ports and terminals, and logistics companies, working across maritime, road, rail, and air. TT Club is renowned for its high-quality service, in-depth industry knowledge and enduring Member loyalty. It retains more than 93% of its Members with a third of its entire membership having chosen to insure with the Club for 20 years or more. www.ttclub.com

Insurers TT Club and UK P&I Club have teamed up with scientific consultants, Brookes Bell, and issued a whitepaper highlighting the continuing safety threat created by the transportation of lithium-ion batteries.

The publishing of a whitepaper by insurance providers TT Club along with its fellow Thomas Miller managed business, UK P&I Club, and technical and scientific consultancy, Brookes Bell brings greater awareness of the dangers inherent in the transport of lithium-ion batteries, particularly by sea. The increased demand for ‘green power’ for a wide range of portable devices such as mobile phones, mobility aids and recreation, manufacturing and power storage, through to larger products, such as electric vehicles will undoubtedly result in the production and transport of these batteries rising exponentially in the coming years.

The whitepaper outlines many of the numerous challenges facing the transport industry and raises awareness of the potentially catastrophic situation that can be caused by battery failure, thus in part correcting the widely held perception in the maritime community that risks in the supply chain of such products are relatively small.

Commenting on the need for rapid recognition of the risks, Peregrine Storrs-Fox, TT’s Risk Management Director said, “Recently, serious and sometimes catastrophic incidents involving lithium-ion batteries have become more commonplace, with fires reported in all modes of transport – ocean, air and land — as well as in warehouses and where such consignments are at rest. 

As Loss Prevention Director of the UK P&I Club, Stuart Edmonston is no stranger to the damage ship fires can cause, “The consequences of battery failure and the resultant thermal runaway must be clearly understood and the correct procedures for handling them adhered to throughout their lifespan.  The dangers can exist no matter the status of the battery; charged, semi-charged, used, second-hand or scrap, and whether present in devices and vehicles or packaged separately.”

The topics covered in this comprehensive whitepaper include details of the background science behind lithium-ion batteries, the dangers associated with transporting them and why they arise, such as insufficient testing and incorrect declaration. The paper also provides a review of current dangerous goods (DG) regulatory provisions, focusing on the International Maritime Dangerous Goods (IMDG) Code, with recommendations for change or further work. The final section of the paper discusses the current state of the firefighting provision and changes that could be implemented.

However, the authors don’t limit their risk prevention advice to technology aimed at extinguishing fires once begun but also put forward guidelines to help pre-empt dangerous incidents by correct classification and declaration, safe and effective packaging, mandatory markings and labelling, uniformity of regulations regarding testing and suitable storage environments while batteries are awaiting transport.

Speaking of the growing risk, Karwei So, Managing Scientist at Brookes Bell concludes, “While increased industry awareness is crucial and technology to monitor and restrict fires is advancing, the increased capacities of batteries and the expected rise in trade volumes means regulations are potentially not fit for purpose, having been slow to catch up.” 

The joint paper outlines initial ‘calls to action’ in a number of respects, impacting not simply those tasked with moving this commodity and their regulators, but most importantly any industries involved in manufacturing or using this increasingly crucial power source, who enter the goods or related products into the freight supply chain.”

The full text of the ‘Lithium batteries whitepaper’ can be downloaded free of charge HERE

About Brookes Bell

Founded in 1903, Brookes Bell is a leading multi-disciplinary technical and scientific consultancy serving the marine and energy sectors. They investigate, troubleshoot and advise on a broad range of marine and energy matters and enjoy a reputation for being the ‘go-to’ firm for casualty investigation, forensic analysis, technical dispute resolution and expert witness work. Working across the UK, Europe, Asia Pacific and the Americas, Brookes Bell has a global presence allowing them to provide their expert services wherever clients need them to be. Alongside Brookes Bell’s investigative and expert witness services they have a state-of-the-art laboratory, The Lab at Brookes Bell, providing the marine, energy, industrial and manufacturing industries with access to world-class forensic analysis and investigative services.

https://www.brookesbell.com/

About TT Club

TT Club is the established market-leading independent provider of mutual insurance and related risk management services to the international transport and logistics industry. TT Club’s primary objective is to help make the industry safer and more secure. Founded in 1968, the Club has more than 1100 Members, spanning container owners and operators, ports and terminals, and logistics companies, working across maritime, road, rail, and air. TT Club is renowned for its high-quality service, in-depth industry knowledge and enduring Member loyalty. It retains more than 97% of its Members with a third of its entire membership having chosen to insure with the Club for 20 years or more.

https://www.ttclub.com

About UK P&I Club

UK P&I Club is a leading provider of P&I insurance and other services to the international shipping community. Established in 1865, the UK P&I Club insures over 240 million tonnes of owned and chartered shipping through its international offices and claims network. ‘A (Stable)’ rated by Standard & Poor’s with free reserves and hybrid capital of $597m, the UK P&I Club is renowned for its specialist skills and expertise that ensure ‘best in class’ underwriting, claims handling and loss prevention services.

https://www.ukpandi.com/