Serious Structural Deficiencies

Serious Structural Deficiencies History of SSD and IMO Circular What are SSDs Implications to containers and operators Reporting

History of SSD and IMO Circular In July 2001 a paper was submitted to the sixth meeting of the Dangerous Goods, Solid Cargo and Container Sub-committee concerning the introduction of a “Manual of serious structural deficiencies in CSC Containers” DSC 6 / 14 / Rev1 reported that the Approved Continuous Examination Programme (ACEP) and Periodic Examination Scheme for CSC container inspections were not being satisfactorily followed and that inspections had identified containers with serious structural deficiencies. It was proposed, therefore, to develop a manual of structural deficiencies, which would serve as guidance for inspections under article VI of the CSC Convention. Serious Structural Deficiencies

History of SSD and IMO Circular DSC 6 / 14 / Rev1 provided considerable evidence on the state of containers found in the country’s ports: Containers were found to have a number of defects, some of which could render the container unsafe; Tank containers were found with several defects that adversely affected the connection of the tank barrel to the frame; Containers were found to have been sold still with the original owner’s markings, including ACEP reference numbers. Serious Structural Deficiencies

History of SSD and IMO Circular Inter-sessional correspondence groups set up between DSC 7 and DSC 9 considered original document and a number of other papers submitted. At the plenary session of ISO Technical Committee in 2003 amendments were made to ISO TR 15070 – Rationale for Test Criteria. This amendment identified both the structurally significant components of containers and the extent to which those components can be damaged without adversely affecting safety. The revised Technical Report was submitted to the correspondence group. Serious Structural Deficiencies

History of SSD and IMO Circular Inter-sessional correspondence groups set up between DSC 7 and DSC 9 considered original document and a number of other papers submitted. At the plenary session of ISO Technical Committee in 2003 amendments were made to ISO TR 15070 – Rationale for Test Criteria. This amendment identified both the structurally significant components of containers and the extent to which those components can be damaged without adversely affecting safety. The revised Technical Report was submitted to the correspondence group. The United Kingdom considered the documents submitted by the first correspondence group and the ISO and presented a further paper to DSC 8 which proposed a more “user-friendly” guidance note which incorporated the table of damaged proposed by the ISO in their amendment to ISO TR 15070. Serious Structural Deficiencies

History of SSD and IMO Circular At DSC 9 in September 2004 a drafting group was set up to finalise the work of the correspondence group. The following terms of reference were given: Finalise the Guidance on serious structural deficiencies in containers using DSC 9 / 8 / 1 as a basic document; Prepare an associated draft CSC circular; and Examine the possibility of having a simple reporting procedure through which serious structural deficiencies found in inspection may be collected, collated and disseminated. Serious Structural Deficiencies

History of SSD and IMO Circular The drafting group was able to complete its work and requested the Sub-committee to: Approved the draft CSC circular on Guidance on serious structural deficiencies in containers for submission to the Committee for adoption; With regard to the reporting procedure on serious structural deficiencies, agree with the group’s view that the most effective way is to amend MSC / Circ. 859, at DSC 10. These recommendations were presented to the Maritime Safety Committee in May 2005. Serious Structural Deficiencies

History of SSD and IMO Circular CSC / Circular 134 was published on May 27th 2005. The Circular consists of: The circular itself; An Annex Annex 1 to the Annex identifying the structurally sensitive components Annex 2 to the Annex showing a Control Measures Safety Flow Chart Annex 3 to the Annex showing diagrams of structurally sensitive components. Serious Structural Deficiencies

Serious Structural Deficiencies History of SSD and IMO Circular What are SSDs Implications to containers and operators Reporting

What are Serious Structural Deficiencies The Recommendations on harmonized interpretation and implementation of the Convention, approved by the Maritime Safety Committee, at its sixty-second session (24 to 28 May 1993), and circulated as CSC/Circ.100, paragraph 9.4 . Unsafe containers (article VI, paragraph 1, third sentence), stipulates that, where a container is found by the authority exercising control to have a defect which could place a person in danger, then the container should be stopped. Serious Structural Deficiencies

What are Serious Structural Deficiencies Serious Structural Deficiencies are damages to Structurally Sensitive Components, which in turn are those major components found on a container that ensure the integrity and strength of the container frame. They have been identified as: Top rails Bottom rails Header Sills Corner posts Corner and intermediate fittings Under structure Locking rod assemblies Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

What are Serious Structural Deficiencies

Serious Structural Deficiencies History of SSD and IMO Circular What are SSDs Implications to containers and operators Reporting

Implications to containers and operators Containers found to have one or more defects that exceeds the criteria shown in Annex 1 to CSC circular 134 can be stopped by the officer exercising control (a person authorised by the Administration to inspect containers). Remember ….. Unsafe containers (article VI, paragraph 1, third sentence), stipulates that, where a container is found by the authority exercising control to have a defect which could place a person in danger, then the container should be stopped. Serious Structural Deficiencies

Implications to containers and operators Is it possible to safely move the container? A container being moved on road or rail can be allowed to continue its journey so long as there are no deficiencies on: Bottom corner fittings which prevent proper securing Doors that cannot be properly closed or secured Top or bottom rails disconnected from the side wall Serious Structural Deficiencies

Implications to containers and operators Is it possible to safely move the container? A container being moved by ship can be allowed to continue its journey so long as: it is empty and being moved to a new destination for repair; or the container can be lifted and secured; and It is not over stacked with loaded containers if there is damage to the corner posts Serious Structural Deficiencies

Implications to containers and operators Is the container loaded? Any serious structural deficiency found on an unloaded container should be returned to the originating depot except: If the container is being moved to a new domestic depot for repair prior to loading with a cargo. The container must be safely secured to the transport by the corner fittings, or if these are not satisfactory, then by straps. Serious Structural Deficiencies

Implications to containers and operators Is the container loaded? Any serious structural deficiency found on an unloaded container should be returned to the originating depot except: If the container is being moved to an international depot for repair prior to loading with a cargo. The container must be capable of being lifted (top corner fittings) and secured (bottom corner fittings) Loose components must be secured during transport. Serious Structural Deficiencies

Implications to containers and operators Does the container need to be lifted? Top corner fittings which prevent lifting Damaged bottom rail – cracked welds, cracks in rail Understructure – cross members loose, welds cracked, severely distorted. Doors that cannot be properly closed. A container that requires lifting before unloading that exhibits one or more of the deficiencies listed above should be re-stowed in a safe container. Serious Structural Deficiencies

Implications to containers and operators Does the container need to be lifted? A loaded container that requires lifting before unloading that has damage to the bottom rails (cracks, weld cracks and separation from the side walls), the underside (loose or missing cross members) can be secured to a suitable flatrack container for maritime transport. Lifting of the combined unit should be by the flatrack corner fittings, unless the container is secured by tested liftlocks and webbing strapping. Serious Structural Deficiencies

Serious Structural Deficiencies History of SSD and IMO Circular What are SSDs Implications to containers and operators Reporting

Reporting The recommendation from the drafting group at DSC 9 with regard to the reporting procedure on serious structural deficiencies was to use the process described in MSC / Circ. 859, at DSC 10. This was completed and re-published as MSC / Circ 1202 dated June 2006 This reporting system was developed to report on containers carrying class 1 dangerous goods, however, the reporting of serious structural deficiencies is extended to all CSC containers Serious Structural Deficiencies

Reporting Serious Structural Deficiencies Source DSC 13/6/16

Reporting Serious Structural Deficiencies Total number of units inspected 50212 Total number of units with deficiencies 8951 Total number of deficiencies 10.800 Serious Structural Deficiencies Source DSC 13/6/16