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Published: 23 June 2014
Countdown to CSC changes
Bill Brassington of ETS Consulting outlines imminent changes to the International Convention for Safe Containers (CSC).
At the recent Multimodal 2014 show, discussions moved to the International Convention for Safe Containers (CSC) and the complexities of the text. These discussions reflected a debate concerning the interpretation of various new clauses and paragraphs that has been exercising various organisations in recent months and stimulated by the ever approaching completion date set at July 1st 2015.
The International Maritime Organisation (IMO) has been reviewing the processes associated with its major safety convention for the movement of containers. This review process has involved a number of incremental steps, each initiated by an incident or a concern raised by a member Government. The process started with the introduction of Serious Structural Deficiencies, a small list of major components and the maximum damage permitted after which designated officers can stop or restrict international movement.
These inspection criteria were published in the IMO circular CSC Circ. 134 on May 27th 2005. The circular provided guidance on serious structural deficiencies in containers to enable authorised officers to assess the integrity of structurally sensitive components of containers and to help them decide whether a container is safe to continue in transportation or whether it should be stopped until remedial action has been taken.
An accident in Canada prompted a further review of the approved continuous examination programmes (ACEPs) under which the majority of the world’s 31M TEU of containers are maintained. A paper submitted to the IMO identified damage to the top corner fitting. The investigation had considered the mass of the cargo carried, and the material used in the corner fitting, and concluded that the accident occurred due to “excessive wear of the corner pockets”. Consequently, Canadian authorities requested that corner fittings were included in regular and ACEP examinations.
This prompted a number of responses. The circular on serious structural deficiencies was amended along with a review of the Supplement to the Convention. Contracted parties were required to audit approved programmes and a new guide for preparing maintenance schemes was published.
Another accident in 2007 involved European swap bodies on board the MV Annabella. They collapsed while being transported in the Baltic, stimulating a detailed and thorough discussion on the basic principles of the Convention, and specifically whether the container had to have any stacking strength at all. Eventually the IMO prepared instructions for marking containers with reduced stacking capabilities. The International Organisation for Standardisation (ISO) was requested by the IMO to provide a means that containers with reduced stacking or racking capabilities can be easily identified.
Finally concern about the values of the serious structural deficiencies has driven the IMO to add a safety level to the table of serious structural deficiencies.
The IMO has just published the 2014 edition of the International Convention for Safe Containers, 1972 that included all of the amendments made over the last few years. The most significant change is found in Annex I - Container Testing, Inspection, Approval and Maintenance. Regulation 1 - Safety Approval Plate, Paragraph 3, considers that containers built with an allowable stack mass (1.8g) less than 192,000 kg or a racking value less than 150 kN shall be considered as having limited stacking or racking capacity and shall be conspicuously marked in accordance with the latest edition of ISO 6346 - Freight containers, Coding, Identification and Marking.
Realising that this change could not be implemented immediately, the IMO permitted a phase-in period requiring that these containers shall be marked at or before their next scheduled examination or before a date approved by the Government of the country, but no later than July 1st 2015. It is this paragraph that has been the main subject of the debate mentioned earlier.
Paragraph 3 starts, “Where the Administration considers a new container satisfies the requirements of the present Convention…” Some have argued that this means the marking of containers in accordance with ISO 6346 only applies to containers built after the publication of the amendment. However we need to look at the Convention in further detail and the definition included in the original text and the amendment included in CSC.1/Circ. 138/Rev.1.
The Convention defines that a new container means a container, the construction of which was commenced on or after the date of entry into force of the present Convention. The Convention also defines existing containers as a container which is not a new container. The reason for the differentiation was to identify the method of approval for containers built before and after the publishing of the original Convention.
Since many countries did not enact legislation in their own country at that time, the amendment shown in CSC.1/Circ. 138/Rev.1 permits Administrations to define the date on which construction of a container shall be deemed to have commenced for the purposes of determining whether a container should be considered as “new” or “existing”. This date will generally be the date on which legislation concerning the Convention was enacted and does not refer to an individual series of containers. For example, the differentiating date for Germany is September 1982.
Therefore, the Convention has placed a mandatory requirement that all containers built after 1972 or a date defined by the owner’s Administration shall be marked in accordance with ISO 6346, whether they are newbuilt or 20 year old units. That means the majority of the swap bodies and many regional containers will require the changes to the size type code.
In Germany, instructions have already been put into place whereby competent authorities, in the course of regular random container inspections, who find non-compliant containers, either packed or empty, are required to stop them until the container has been remarked.
With the introduction of the guidelines for preparing continuous examination programmes, Contracting Parties, ie the party that approves the programme and issues the ACEP reference, will know what will be expected of the periodic audits. That will mean that a representative could shortly visit owners’ offices to check on the process of maintaining containers, including record keeping and adherence to the written scheme or programme. Do you know when and where every one of your owned or operated containers was last thoroughly examined and what proof have you that the examination was carried out?
In addition to the audit of the scheme, the Contracting Party also has to review all the schemes under their jurisdiction every ten years to confirm that they are still in operation. Failing to provide requested details may result in ACEP approval being revoked.
Did you know that if you do not operate an approved maintenance programme and you lease a container which has one, you must inspect all the containers after 30 months and then mark them with your own next examination date? If the leased container is marked with a next examination date and you operate an approved programme, (ACEP) at the first opportunity that a thorough examination is carried out in line with your own scheme, the container must be marked with your ACEP reference. If both the lessor and the lessee operate ACEPs then you may not need to do anything.
We all know the importance of the CSC Safety Approval Plate. Its presence, along with an ACEP reference or next examination date, permits the container to be used in international maritime transport. Marked on the plate are a number of important references. The first is the Approval Reference, generally issued by a classification company on behalf of the Contracting Party. This reference links the design with the manufacturer and the classification society.
The second reference is essential in tracing the container back to the original manufacturer and this is the Identification Number. Under previous versions of the CSC, it was allowed to use the container serial number for this number, but that is not now permitted. There must be a unique reference issued by the manufacturer, which relates to their manufacturing process and not to the original purchaser. If you are still using the container serial number as the identification number on the Safety Approval Plate, ask your manufacturer to change to their own serial number immediately.
In service, what changes can affect you?
Designated control officers can issue the container operator with instructions that restrict their movement or placement within stacks if they feel that damages found on a container exceed the new safety levels. This may prevent lifting using certain methods, or stacking except on or near the top slots.
Safety in the supply chain is paramount and one of the most important control systems used to reduce risk is to ensure that the container in maintained in a safe condition. While the majority of those who examine and repair containers are experienced in assessing its conditions, the majority of those involved in the supply chain just know that it is a steel box and assume, perhaps wrongly, that they are all suitable for the task.
Unfortunately, we know that this is not the case. Accidents resulting from poor maintenance and examination do happen, sometimes with catastrophic results. The International Convention for Safe Containers attempts to reduce those risks.