Anti-social media robbed the health authorities of the term ‘going viral’. Now, sadly the medical teams have stolen it back with a vengeance. Loathe as many would be to hear the C-word it is a fact that the virus has dominated the global news agenda this year.
In a clear indication of the powerful potential that organisms possess Covid-19 has flourished, dispersing through communities wreaking havoc on human health and crashing through the global economy, much as a bull in a china shop might do.
This pandemic is a warning of the devastation that can be caused by the tiniest of creatures. A truism that already drives shipping’s Ballast Water Management Convention and it must guide the regulations and enforcement that provide the parameters to the movement of containerised goods.
Viral infections are passed on between people, but infestations and diseases can be caused by the simple act of moving an inanimate, inorganic cargo from one place to another and the effects can be devastating.
According to the Food and Agriculture Organization (FAO) of the United Nations, plant pests and diseases are responsible for the loss of up to 40% of global food crops each year. They also cause trade losses exceeding US$220 billion annually.
For the South Korean operator HMM the issue is a major concern, “Basically, discussions and measures to prevent the spread of invasive species might need to take place at the national or intergovernmental level because it becomes [sic] one of main global issues,” said a company spokesman.
According to HMM it is normally the shipping line that takes responsibility for ensuring that containers are cleaned, inside and out, before being delivered to the next customer. However, the International Plant Protection Convention (IPPC), an organisation dedicated to ensuring the health of plant life, believes that everyone across the supply chain must help to mitigate the spread of plant and animal pests through the carriage of containerised cargo.
HMM’s partner in THE Alliance, ONE, said it was unaware of the UN’s assessment of the effects of invasive species, but a spokeswoman added, “we clean and inspect inside of containers based on the industrial standards and agreed methods.” She added, “There is no requirement on the cleaning of the outside.”
ONE’s view that it is unnecessary to clean and inspect the outside of the container is not one shared by the IPPC and is an indication that there is some confusion within the industry over the requirements for reducing the spread of invasive species.
In its March report the authors offer guidance provided by the IPPC’s Sea Container Task Force (SCTF), “By taking recommended actions at critical interchange points, you can keep containers and their cargoes clean and help them move faster and easier through ports to their destination.”
Those actions, according to the insurer TT Club, can include making sure that soil is not deposited on containers in poorly maintained yards, making sure yards are paved, away from vegetation. In addition, checks should be performed constantly at each stage of the containers transportation to ensure it is clean.
Peregrine Storrs-Fox, risk management director of TT Club, said that events such as the migration of the Murder-Hornet to the US, thought to be in, or on, a cargo container, though this is by no means certain.
Reuters reported that “multiple stings from the insect could be fatal. The Murder Hornet also presents dangers to agriculture and to bees. The insect is known to attack honeybees, with a few of the hornets capable of wiping out an entire hive in hours.”
Storrs-Fox also pointed to another Far Eastern invader, the Asian Gypsy Moth which can be destructive to local agriculture and forests.
Gard, a maritime risk management company, said, “Vessels calling at certain ports in the Asia Pacific between May and September should be inspected and “certified free of Asian Gypsy Moth” prior to departure, this to minimise the potential for regulatory action when arriving in a country where this destructive forest pest is not native.”
In March this year, the IPPC produced a document entitled, “Sea container supply chains and cleanliness, An IPPC best practice guide on measures to minimise pest contamination”, which highlighted some of the key issues around the transportation of phytosanitary products in addition to the incidental spread of invasive species through dirt on both the inside and outside of cargo transport units (CTU).
In its report, the IPPC illustrates that the interchange points, the places within the supply chain that the cargo is handed from one member of the logistics chain to the next, are the most likely places for contamination to occur.
“There is international consensus among competent authorities that containers and their cargoes can potentially carry and facilitate the introduction and spread of pests that might pose a serious risk to agriculture, forestry and natural resources. The packing of sea containers with cargo is the most likely stage in the sea container supply chain at which pest contamination can occur,” says the IPPC report.
According to the World Shipping Council (WSC), an association which represents the major container shipping lines, and which is a member of the IPPC’s SCTF, the cleanliness of containers is a shared responsibility.
WSC points out that the IPPC report itself points to this shared responsibility and the lines support the IPPC’s March report.
“A container operator is responsible for the cleanliness of a container when it has direct control of the container. The only place where a shipping company has direct control of the container and an ability to clean it, if required, is in a container depot (also known as “repair depot”). Many containers, however, do not go through a container depot before packing and/or after the container has been unpacked and is being moved without cargo to the next shipper customer or directly to a marine terminal for loading on a ship,” WSC told Container News.
However, some lines are willing to take on the responsibility for container cleaning, as HMM said, “In general, each terminal and off-dock depot has their own M&R [maintenance and repair] facilities, so repair or cleaning work is performed according to the condition of containers when containers are in/outgated,” an HMM spokesman explained.
Furthermore, the WSC argues that it has, “In cooperation with other industry associations developed the Joint Industry Guidelines for Cleaning of Containers that are intended to provide guidance to container depots on how to meet this requirement. These guidelines have been incorporated in the IPPC Guidance.”
Shippers’ and packers’ responsibilities for maintaining the cleanliness of containers and their cargoes are described in both the CTU Code and the IPPC Guidance, said the WSC.
Those descriptions on responsibilities are also in place for consignees and unpackers, said the carrier association. “The language used in both the CTU Code and the IPPC Guidance implies that the consignee is obligated by the terms of the maritime carrier’s contract of carriage to ensure that the container upon unpacking is cleaned and free from pest contamination.”
As such the need for greater regulation is mitigated. However, the confusion over who is responsible needs to be clarified, as the responses from HMM and ONE reveal, the carriers are unclear who is responsible and what kind of checks and cleaning needs to be applied.
Furthermore, ONE believes that the imposition of global standards would be difficult to apply due to the differences in local cultures and practices. HMM, meanwhile believes that it is imperative for discussions on preventing the spread of invasive species should happen at the governmental level.
IPPC agreed with ONE, arguing that “The Phytosanitary community has agreed that the harmonisation of requirements through the development of a draft International Standards for Phytosanitary Measures (ISPM) on minimising pest movement by sea containers (2008-001) is complex to achieve and calls for the collaboration from different stakeholders.”
In its response to Container News IPPC also recognised the implementation of the IMO/ILO/UNECE CTU Code would help prevent the contamination of containers substantially reducing the risks.
“That is why the eleventh session of the Commission on Phytosanitary Measures (2016) agreed that the status of the topic on Minimizing Pest Movement by Sea Containers (2008-001) should be changed to pending and reconsidered by the CPM in a maximum of five years, to allow for the implementation of the CTU Code and Recommendation CPM 10/2015_01 on Sea Containers and an analysis of their impact on reducing pest movement by sea containers,” said IPPC.
In a bizarre twist of fate, it appears the implementation of the CTU code to have been undermined by a virus that was a product of some the insanitary conditions that the industry is attempting to prevent.
For its part WSC, in its representative role for the shipping lines said, “The shipping industry supports, and actively participates in, joint government-industry efforts to raise awareness of the risks of pest contamination of containers and their cargoes, and to encourage voluntary steps by parties in the containerised supply chain to reduce these risks. A leading example of such collaborative efforts, in addition to the IPPCʹs Sea Container Task Force, is the North American Sea Container Initiative (NASCI).
“The shipping industry accepts that under certain circumstances, and based on a proper risk analysis and assessment, specific pest risks may warrant the implementation of focused programmes and requirements on which the public should be consulted.”
Shipping is a global industry and its effects, both economically and environmentally, can be felt globally, it is imperative that the messages that shippers, consignees and other members of the global supply chain can understand and are clear about the guidance.
There is no criticism levelled at shipping lines, or any other body, rather the requirements are that there is clarity within the industry, which will likely mean a regular and widespread reiteration of the requirements for the good of us all.
IPPC and FAO Guidelines for container contamination inspections:
- Visually inspecting the outside and inside of the sea containers for the presence of contaminants such as plants, seeds, insects, egg masses, snails, and soil.
- Where required, sweep, vacuum, or wash containers before packing to remove potential contaminants. It should be noted that environmental factors, such as heavy rains may increase the likelihood of certain types of contamination.
- Ensure cargo packed into the sea container is clean and free of visible contaminants. Regulated articles may require Phytosanitary Certificates that confirm compliance with applicable import requirements.
- Clear and clean the cargo staging and packing area to ensure that it is free from contaminants. Containers placed on grassy areas or soil are more likely to be contaminated by insects, snails and plant parts, including seeds.
- Without compromising safe working conditions, do not keep containers under bright lights, which may attract flying insects, such as moths, to the cargo staging area and increase the likelihood of contamination. If containers must be kept under bright lights, check them regularly for signs of contamination by insects or egg masses and clean containers as needed to remove these contaminants.
- Where appropriate, use baits, traps, or barriers to keep pests out of the cargo staging and packing area. For example, a salt barrier may be used to prevent snail infestations.
The CTU Code identifies additional simple steps and practices that shippers and packers may take to prevent contamination including closing container doors and/or using tarpaulins once packing has started but not yet been completed.
The CTU Code also clarifies that packed containers in international traffic should be sealed. Note that the IPPC Guidance is in conformance with, and reflects, the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code)”.
Interchange Points in the Container Supply Chains and Best Practices to Minimise Pest Contamination.