Containers overboard – the absolute exception

Quite often stories are being published about containers falling overboard on the high seas. With this in mind, calls for better marking of containers – and especially those carrying dangerous goods – are quite understandable. However, to improve our ability to locate containers that have gone overboard, the only changes that should be seriously considered are those that are feasible in an emergency, can be applied worldwide, and strike a reasonable balance in terms of their expense and actual benefits.

In the view of the VDR, the following points should be taken into consideration:

  • Such incidents are an absolute exception. In 2021, around 3,000 boxes per year have gone overboard from container ships around the world - which is a negligible share given that more than 150 million containers transported in the same period: it corresponds to 0.0019 percent of the transported containers. For comparison: In 2019 there were 1.74 million passenger flights worldwide with 293 fatalities in plane crashes. This corresponds to 0.017 percent.
  • A comprehensive set of regulations is already in place worldwide, and there are frequent inspections to ensure compliance – especially when it comes to sensitive cargo. For example, there is the International Maritime Dangerous Goods Code (IMDG Code) issued by the IMO. Introduced in 1965, this set of regulations specifies a wide range of legally binding requirements for the classification, labelling, packaging, storage, documentation and handling of dangerous goods on board ships and in ports. This international set of basic rules has been transposed into national law in Germany in the form of the Ordinance on the Transport of Dangerous Goods by Sea.
  • This is one of the many reasons why shipping is such a safe means of transport. Those who are calling for a complete ban on transporting dangerous goods by ship will have to accept the far-reaching consequences that doing so would have on all of our daily lives. Shipping is a global industry. Ships and containers are in service everywhere across the world – so amended regulations must apply worldwide. An exclusively German regulation would put German companies at a disadvantage vis-à-vis non-German one. But, most importantly, it would not achieve its goal, as there would still be a large number of ships operating on the North Sea and the Baltic Sea whose owners would not be subject to German laws.
  • The tracking of containers in general has been the subject of discussions at the IMO for some time already. As part of ongoing digitalisation efforts, many containers could be outfitted in the foreseeable future with lithium battery-powered transmitters known as “tracking and tracing devices”. Many new containers are already being equipped with such transmitters, including refrigerated containers (reefers), which often transport especially valuable cargo. However, the main focus to date has been on tracking cargo in ports or on land in order to optimise global supply chains.

However, there is one problem with this: Although the tracking transmitters are built according to ISO standards, the IMO has not issued any related specifications yet and its committee that deals with dangerous goods is only discussing them now. The goal is to have specifications that also allow such devices to be safely transported on containers with dangerous goods but without requiring the transmitters already in use to be replaced. Transmitters with lithium batteries are themselves considered dangerous goods that could potentially have a dangerous reaction with other substances transported in the containers.
What’s more, these conventional transmitters cannot be located under water, if necessary, which would require special, more sophisticated tracking devices like the ones used in the flight recorders of airplanes. The particularly rugged housing units with a battery or batteries envisioned for this purpose would also have to be able to withstand high hydrostatic water pressure for a longer period of time. However, equipping containers worldwide with both conventional tracking devices and underwater locating beacons of this kind seems unrealistic due to the effort and expense required as well as the actual benefits. In the worst case, the tracking device could be detached from the battery unit during the accident, making it considerably more difficult or even impossible to find the container.
Moreover, a regulation mandating that all dangerous-goods containers be outfitted with such devices can only be implemented with enormous effort and expense, as special containers for dangerous goods are the exception, but standard containers are declared and labelled as such when loaded with dangerous goods. This has to do with the fact that the term “dangerous goods” is deliberately defined very broadly in the IMDG Code and that many products – such as perfume, spray cream and most detergent– are considered dangerous goods within the meaning of the code. For decades, every shipper of these goods worldwide has had to comply with the precise regulations set out in the code when packing them.