To be or not to be Compliant?

By August 4, 2020 September 14th, 2020 49 CFR, Transportation of Dangerous Goods

With all of the dangerous goods regulations in place, we expect a certain level of safety when encountering the various modes of transportation. Whether it’s on the road, in the air, or in the water, we rely on dangerous goods shippers to not only follow the regulations, but follow them correctly. Unfortunately this is not always the case, some dangerous goods shippers simply don’t realize what they are shipping is actually dangerous goods, some misunderstand the regulations and ship them incorrectly, and some know they are shipping dangerous goods and choose not to be compliant. Recently, The National Cargo Bureau released some statistics they compiled over the previous year and found an alarming level of un-declared and non-compliant dangerous cargo in container shipments.

How Severe is This issue?

The National Cargo Bureau (NCB) is a non-profit organization created to assist the United States Coast Guard in discharging its responsibilities. Recent data by the NCB shows they conducted more than 32,000 dangerous dry and tank goods inspections in the U.S. over the last year and found that nearly eight percent were non-compliant due to poor stowage, unsecured packaging, undeclared dangerous goods, as well as other issues. In addition, in another recent container inspection safety initiative involving 500 containers, the NCB says 55 percent of shippers failed to comply with the regulations. This initiative concluded that 43 percent of non-compliant shipments were not secured correctly within the container, and six percent of the containers carrying dangerous goods had been undeclared. This information is quite discouraging and it doesn’t seem to be improving as on average a containership suffers a major fire every 60 days, and that the frequency of incidents seems to be increasing per the NCB. Unfortunately incidents like these often result in severe damage to the vessel, various goods in transit, and more importantly loss of life.

What’s Next?

Due to the statistics the NCB provided, The U.S. inspection bureau is calling for urgent reform to achieve industry-wide compliance and create an enhanced internal safety culture for the cargo industry. As a result, The NCB has created a list of recommendations designed to create a better safety culture and combat the increasing risk of incidents. First the NCB recommends establishing a corporate culture of compliance, including enhanced training programs, and establishing specific dangerous goods departments to manage these shipments. They also recommend having cut-off times for accepting dangerous shipments as well as enhanced documentation processes. The NCB is confident that these recommendations as well as some others will be effective in reversing the current trend of increasing containership fires. These recommendations can be found at the link below:

http://www.natcargo.org/Holistic-Approach-For-Undeclared-Misdeclared-And-Other-Non-compliant-Dangerous-Goods_White-Paper-by-NCB.pdf

How Can ICC Help?

Falling in line with the NCB recommendations, ICC provides extensive training and consulting for the shipment of dangerous goods across all modes of transport. This training will ensure that dangerous goods shippers are adequately packaging, labelling, and properly declaring shipments of dangerous goods. In addition we offer plant audits which will help you ensure all of the issues below are addressed before dangerous goods shipments leave your dock. 

  1. Packaging standards
  2. Labeling of packages and containers for 49 CFR, TDG Clear Language, IATA, IMDG and/or WHMIS 2015
  3. Shipping documentation
  4. Safety data sheets (SDS)
  5. Health and safety issues
  6. Safety signs
  7. Workplace labeling
  8. Risk/Hazard identification
  9. Security
  10. GHS implementation

It is up to us as a dangerous goods community to work together to prevent any damage and loss of life due to non-compliant shipments. Feel free to contact ICC for your training and consulting needs at 1-888-442-9628 in the U.S or 1-888-977-4834 in Canada.

Sources:

https://www.bifa.org/news/articles/2020/jul/ncb-reports-alarming-level-of-misdeclared-dangerous-cargo

https://www.maritime-executive.com/article/urgent-reforms-needed-to-address-shipment-of-dangerous-goods

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Michael Zendano

Michael Zendano

Michael Zendano started with ICC Compliance Center back in 2016 with several years in the packaging field as a Quality Control Manager. In addition, he has 8 years experience in teaching. Michael works at the Niagara Falls Office as the Regulatory Packaging Expert where he manages packaging projects and procedures and is a member of the Institute of Packaging Professionals (IOPP) and The Chemical Packaging Committee (CPC) . Degrees: M.S. Science of Education.