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back to combustible or mis-declared cargos in containers, including batteries, charcoal and chemicals such as calcium hypochlorite, an ingredient in cleaning products.

In March 2022, the US Coast Guard (USCG) issued a safety alert about the risk posed by lithium batteries following two separate container fres caused by mis-declared cargo. The frst, saw a shipping container waiting to be loaded onto a container ship bound for China catch fre. According to the USCG, the bills of lading indicated that the container was carrying ‘syn- thetic resins’ when, in fact, it held used lithium-ion batteries.

In a similar incident in August 2021, a container full of discarded lithium batteries caught fre while being trans- ported by road to the Port of Virginia, where it was due to be loaded onto a container ship. The cargo was mis-declared as ‘computer parts’. These incidents would have been poten- tially “catastrophic” had the containers caught fre after being loaded aboard the container ships, the USCG said.

It is estimated that around 10% of all containers loaded on board ships contain declared dangerous cargo. However, around 5% of containers shipped consists of undeclared dan- gerous goods — either due to administrative error or being deliberately mis-declared. For example, this would equate to 1,000 teu or more of undeclared dangerous cargo on board a 24,000 teu ultra-large container vessel.

In 2019, the International Union of Marine Insurance (IUMI) and other stakeholders co-sponsored a submission to the International Maritime Organization (IMO) Sub Com- mittee on Carriage of Cargoes and Containers proposing a comprehensive review of the International Maritime Danger- ous Goods Code (IMDG Code), which defned and classifed dangerous goods, as well as procedures for declaration. At present, some of those commodities are not considered dan- gerous and do not need to be declared as such by the shipper to the carrier.

The Author

Khanna

Captain Rahul Khanna is Global Head of

Marine Risk Consulting at Allianz Global

Corporate & Specialty. He served more than 14 years on board merchant ships in all ranks, including Master of large oil tankers.

To read the full Allianz Safety & Shipping Review 2022, please visit: https://www.agcs.allianz.com/news-and-insights/reports/ shipping-safety.html