Concerns have been raised over recent years that the movement of shipping containers facilitates the spread of pests adversely impacting sensitive environments. Both the International Plant Protection Convention (IPPC) and the International Maritime Organization (IMO) have now given endorsement to joint industry guidelines concerning container cleanliness.

In 2013, the International Plant Protection Convention (IPPC) published a draft standard on 'Minimizing Pest Movement by Sea Containers (2008-001)', inviting comments. As a result, a 'Special Topics' session was held in early 2016 at the headquarters of the Food and Agriculture Organization of the United Nations (FAO).

IPPC's governing body, the Commission on Phytosanitary Measures (CPM), recognised that 'the packing of sea containers with cargo is the most likely stage in the sea container supply chain at which contamination can occur'. In this context, it encouraged support of the implementation of the relevant parts of the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code).

Supply chain realities

There are, of course, multiple sources of potential pest contamination. The condition of the structure of 'metal box' and its cleanliness are clearly important elements, both in relation to pest movement and basic protection of the cargo packed. However, there continues to be the need to focus attention on the condition of the goods themselves.

Consequently, representatives of the container industry were present at the IPPC's Special Topics session to explain the realities of container logistics. Salient points made included:

• Container flows are complex and may involve multiple border crossings, handovers of control and transport modes. There are many actors involved and the shipping company, which operates the container, has little direct control over or access to containers except for when they are empty in depots; however, dispatch of an empty container from a container depot is not always part of every trip - some containers being presented for packing immediately after discharging the previous cargo.

• The most likely point of pest contamination is the packing point, over which shipping companies have no control.  The shipper exerts such control, either directly or via contractual agreement with the packer.  The CTU Code provides guidance for the prevention of re-contamination of containers to shippers and those who pack containers, but shipping companies have no means of determining how effective this has been. 

The Special Topics session welcomed the offer by the container industry to develop container cleanliness guidelines to minimise the risk of pest contamination of containers while in the custody of container operators and owners. Consequently, there was agreement to defer a decision on whether to finalise the IPPC 'Minimizing Pest Movement by Sea Containers (2008-001)' standard for a maximum of five years, to allow for the implementation of the CTU Code and Recommendation CPM 10/2015/01. 

Since that time, container industry collaboration to develop the promised guidelines has taken the form of joint work by the World Shipping Council (WSC), the Container Owners Association (COA), ICHCA International and the Institute of International Container Lessors (IICL), and their member companies. TT Club has, through its membership of ICHCA, maintained involvement in this work and participated in related regional initiatives.

Cleanliness guidance

The purpose of the Joint Industry Guidelines for Cleaning of Containers is to assist in minimising the movement of pests by maritime containers, being complementary to the CTU Code and not disturbing applicable local regulatory pest contamination measures and requirements. Importantly, the guidelines seek to follow the IPPC articulated principle that any measures to mitigate pest contamination risks should be justified, practical and proportionate.

"the guidelines seek to be justified, practical and proportionate"

Chapter 4 of the CTU code, 'Chains of Responsibility and Information' states in para.4.1.4:

"All persons involved in the movement of CTUs also have a duty to ensure, in accordance with their roles and responsibilities in the supply chain, that the CTU is not infested with plants, plant products, insects or other animals."

The joint industry guidelines aim to provide guidance on how this may be achieved by container operators, particularly when the units are in container depots prior to their dispatch empty to shippers for packing and, as such, do not address how shippers and packers should avoid or manage the risks that the units become re-contaminated during the packing process. However, it is hoped that they will inspire further guidance for the prevention of re-contamination of containers during packing and from cargo.

The central premise of the guidelines is that any empty container, when dispatched from a container depot under the control of the shipping company, should be 'clean'. The concept of such cleanliness is that the empty container's exterior and interior and, for reefer containers, ventilation inlet grilles and floor drain holes, should have no visible presence of contaminants such as soil, plants, seeds, insects, snails etc, mould and fungi, or excretions.

What is 'visible' is defined as 'detectable by the human eye without the aid of any supporting instruments'. It is specifically recognised that the roof and undercarriage of containers may be difficult to inspect, although clearly, in the spirit of taking proportionate responsibility, container and depot stakeholders should consider the broader environmental conditions in which the units are stored.

The guidelines also set out recommendations on cleaning methods for various types of visible pest contamination, including sweeping, fumigation or washing. It is suggested that local agencies should be called upon to deal with live animals, snakes or birds, and otherwise to offer advice where appropriate.

"TT Club would urge the industry to engage with these guidelines"

TT Club would urge the industry to engage with these guidelines regarding non-pest contamination of containers, as an important part of achieving 'cargo integrity' - ensuring that goods can be moved internationally safely, securely and without cause harm to people, property or the environment. IMO's affirmation of this particular work - which follows that of the IPPC's CPM - is therefore encouraging and appreciated.

We hope that you have found the above interesting. If you would like further information, or have any comments, please email us, or take this opportunity to forward to any colleagues who you may feel would be interested.

We look forward to hearing from you.

Peregrine Storrs-Fox

Risk Management Director, TT Club