Calls for intrusive inspections of import and export freight to counter the risks of invasive pests in cargo and containers risk disrupting trade more severely than either COVID-19 or the Suez blockage.

Steps being considered by governments concerned about pest control – under the auspices of the International Plant Protection Convention (IPPC)  – include a potential mandatory ‘Certificate of Cleanliness’ for all containers prior to loading on board a ship. 

The Cargo Integrity Group (CIG) partners are firmly opposed to the proposed sweeping mandatory requirements, while recognising that strenuous action is required across all stakeholders in the intermodal supply chain to bring about seismic change to the risks from invasive pest contamination. Compliance and enforcement costs of certifying the 220 million container movements a year would clearly be substantial.  It is estimated that the additional costs to the industry of such measures could be some US$20 billion a year, and this burden would fall disproportionately on exporting countries. Moreover, the infrastructure necessary – for both governments and industry – to implement certification could gridlock global trade.

Urgent action needed

CIG has submitted a statement pinpointing the impractical consequences of the certification proposal. The statement also expresses serious concern over the infestation issue and the Group’s desire to help configure proportionate and effective solutions to reduce the risks. It is recognised that more serious risks occur among certain types of goods, from identified regions and during specific times of year. As a result, the CIG recommendations revolve around a more sensible use of scarce resources in providing proper risk assessments in identifiable trades of prime concern, where mandatory measures can then be imposed as needed.

“More serious risks occur among certain types of goods, from identified regions and during specific times of year”

The CIG accepts there are identified risk areas and cargoes which must be addressed. However, the fact that the vast majority of trade takes place in environments where these risks do not arise, or are insignificant, must also be considered.

The five partners in the CIG recognise the vital importance of focusing on the threat of invasive pests to natural resources across the world, and of the urgency in crafting risk reduction measures that address the situation.  The CIG is committed to ensuring that international trade is conducted in a safe, secure and environmentally sustainable manner. Addressing the serious issue of the transfer of invasive pests between different natural ecosystems is very much a part of that commitment. 

The CIG rigorously promotes the use of the Code of Practice for the Packing of Cargo Transport Units, published by the IMO, the ILO and the UNECE. The Group published its Quick Guide to the CTU Code as a means of increasing awareness of the framework of good practice in relation to all aspects of cargo packing, including addressing phytosanitary concerns and reflecting the Code’s Chapter 8 and Annex 6.

We are calling for urgent action from actors in global supply chains to reduce the risk of pest transference facilitated through international cargo movements. At the same time, we encourage all stakeholders to understand the international debate around invasive pests and be prepared to work with industry counterparts and governments to ensure trade continues uninterrupted.

“We are calling for urgent action from actors in global supply chains to reduce the risk of pest transference facilitated through international cargo movements”

Almost anything concerning the intermodal supply chain comprises complexity; without seeking to over-simplify or claim to be exhaustive, here are some tips:

• Container operators should ensure that any storage of units is on hard, well-drained surfaces, away from vegetation. Releasing units for packing should also involve ensuring that they are checked for pest contamination, including considering the base structure, where possible. Such things will often require you to consider also contractual obligations with depots.
• Shippers, including Beneficial Cargo Owners, should take responsibility to consider the impact of their procurement and fulfilment actions, specifically here relating to pest contamination risks at the point of packing.
• Packers should be alert to all aspects of pest contamination risks throughout the process of packing containers, taking account of the immediate environment, the time of year and use of artificial lighting, for example.
• Intermodal carriers, particularly by road, should consider the routing of vehicles to minimise the contamination risks, for example from debris thrown up from un-made surfaces.
• Receivers should ensure after unpacking that the container is clean and pest free.
• Anyone who spots pest infestations of any description on, or in, intermodal freight containers or their cargoes should alert National Plant Protection or (if contamination is of animal origin) Animal Quarantine agencies.

This video sequence produced by the North American Plant Protection Organization (NAPPO) provides an overview of the risks.

Recommended further reading 

• IPPC best practice guide on measures to minimize pest contamination
  
• IPPC guide to reducing pest contamination 
  
• Joint Industry Guidelines for Cleaning of Containers
• National security - the invasion of pests
• Minimising movement of pests in containers
  

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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