Denials and delays reported relating to the carriage of radioactive materials by sea
Report
July 2011
Frank Wall CMG

Contents

Introduction5

Container movement: a brief overview6

Shipping companies/alliances6

Ports8

Assessment of the entries/reports in the Database9

Entries/reports9

UN Numbers9

Date of report10

Complainants11

Routes13

Shipping companies16

Denials and delays20

The reasons why28

Denials29

Company policy39

Transit difficulties42

Feeder/partner difficulties44

Regulatory difficulties44

Delays45

Action taken52

Completeness of reports53

The issues54

Appendix 1: Recommendations56

Annexes57

Annex 1: The entries in the Database57

Annex 2: Report Form61

Annex 3: UN Numbers64

Annex 4: Date of Report66

Annex 5: Year of Report67

Annex 6: Complainants68

Annex 7: Routes and Shipments71

Annex 8: Linked Entries/Reports73

Annex 9: Shipping Companies75

Annex 10: Shipping Companies, Routes and Shipments79

Annex 11: Denials and Delays (UN Number)83

Annex 12: Denials and Delays (Year)84

Annex 13: Denials and Delays (Complainant)85

Annex 14: Denials and Delays (Shipping Companies)86

Annex 15: Denials and Delays (Route)88

Annex 16: Denials and Delays (Shipping Companies/Routes)90

Annex 17: Reasons for Denial (UN Number)94

Annex 18: Reasons for Denial (Year)95

Annex 19: Reasons for Denial (Complainant)96

Annex 20: Reasons for Denial (Shipping Company)97

Annex 21: Reasons for Denial (Route)99

Annex 22: Reasons for Denial (Shipping Companies/Routes)101

Annex 23: Company Policy105

Annex 24: Transit Difficulties132

Annex 25: Feeder/Partner Difficulties144

Annex 26: Regulatory Difficulties146

Annex 27: Reasons for Delay (UN Number)149

Annex 28: Reasons for Delay (Year)150

Annex 29: Reasons for Delay (Complainant)151

Annex 30: Reasons for Delay (Shipping Company)153

Annex 31: Reasons for Delay (Route)155

Annex 32: Reasons for Delay (Shipping Company/Routes)157

Annex 33: Delays161

Annex 34: Report Contents (Separate Document)165

DENIALS AND DELAYS REPORTED RELATING TO THE CARRIAGE OF RADIOACTIVE MATERIALS BY SEA

Introduction

1.1The Terms of Reference of this study are to:

  1. review all cases in the IAEA/IMO/ICAO database on denial related to shipping;
  2. categorize each case in respect of the actions required to combat the denial, and
  3. produce a consolidated report describing the actions to be taken as a response to the records reviewed.

1.2The core of this study is based on an analysis of the 182 individual entries of denials or delays contained in the Dangerous Goods Carriage Difficulties database (the Database) in the International Maritime Organization’s (IMO’s) Global Integrated Shipping Information System (GISIS).

1.3After providing an overview of container shipping the Study presents the results of the assessment of the entries in the Database under a number of headings. Details extracted from individual entries are included in a number of Annexes (Annexes 1 to 34) attached to this study.

1.4This study includes a number of recommendations for possible future action. They are included in bold in the text and grouped in an Appendix (Appendix 1).

1.5The study is dominated by the number of entries in the database relating to the shipment of Cobalt-60 from North America and North West Europe. Of the 182 entries in the database some 122 (67%) relate to Cobalt-60 or related shipments (UN Number 2916). A further 46 (25%) relate to the shipment of Tantelite, or similar, cargoes (UN Number 2912).

1.6The study includes a limited comparison of the stated position of individual shipping companies and ports on their approach to the handling of shipments of radioactive material. This is based on an examination of a number of accessible company/port websites.

1.7The material found in the websites examined can appear to stand in marked contrast to the stated, position taken by the company, or port, in the entries/reports in the Database. When considering a particular shipment particularly as denial of shipment, transit or transshipment refusal often appears to be the default position. However, few shipping companies appear to totally prohibit the carriage of radioactive materials on the vessels.

1.8The study also includes an assessments of the completeness of the entries/reports in the Database.

1.9Any study of denials and delays will inevitably focus on the negative aspects of the carriage of radioactive materials. Wider discussion of this study needs to have regard of the need to avoid it being considered as only having a one dimensional perspective of the issue.

Container movements: a brief overview

Map 1: Major Container Routes 2007 (Vessels over 10,000 tons)[1]

Shipping companies/alliances

2.1All the reports of denials or delays in the Database relate to the shipment of radioactive materials in containers on conventional container ships. The worldwide movement of containers (Map 1) is dominated by a number of major shipping companies/groups which offer, effectively, scheduled ship movements on fixed routes between major ports which act as container hubs. Occasionally a major shipping company as well as operating container ships on the major routes will own or operate container terminals at container hubs and may also operate ships providing regional “feeder” services. A number of shipping companies maintain their distinct identity though they are subsidiaries of a major company

2.2Most container shipping companies offer worldwide services though in many cases the actual carriage may be undertaken by another company, or by a combination of other companies. Often there are formal Alliances between major companies – the membership and operational coverage of such Alliances can change over time and other companies can operate services with Alliance members without becoming a member of the Alliance.

2.3Shipping companies/groups establish subsidiaries worldwide. The degree of operational independence of such subsidiary companies can vary, but for the major lines assessment of dangerous goods is often centralized. Company/group ships can fly different flags and there is now little government oversight or direction of companies/groups commercial activities.

2.4Few significant “national” shipping lines continue in operation, though it appears that companies/groups can apply more favorable acceptance policies regarding dangerous goods owned, or sponsored, by “their” government.

2.5On major container routes companies/groups can “pool” their activities to co-ordinate schedules and services. This can mean that a container will be carried by ship operated by a “partner” company/group and the policies of the “partner” on the carriage of dangerous goods, including radioactive material, can influence acceptance. Movement of containers to, or from, smaller ports usually involves the use of “feeder” ships and acceptance of cargo can depend on the policy of the owner or operator of the feeder vessel.

2.6A particular feature of container shipping is the number of container ships that are “chartered-in”. As with “partner” ships decisions on the acceptance of shipments of dangerous goods on “chartered-in” ships can be determined by the particular owner’s policy. There can also be differences between the insurance cover available for owned ships as against those that are “chartered-in”.

2.7Strict adherence to a ship’s schedule is an important operating principle.

2.8Reflections of these complexities can be found in the reports of denials and delays in the Database.

2.9In 2010 the 10 major container shipping companies/groups[2], with the location of their International headquarters, were:

  • APM Maersk[3] (Denmark);
  • Mediterranean Shipping Company (MSC) (Switzerland);
  • CMA-CMG Group (France);
  • Evergreen Group (Taiwan);
  • American President Line (APL) (Singapore);
  • Hapag-Lloyd (Germany);
  • COSCO Container Line (China);
  • China Shipping Container Line (CSCL) (China);
  • Hanjin Shipping (Republic of Korea);
  • Nippon Yusen Kaisha (NYK) (Japan).

Ports

2.10As part of a State’s territory the regulations and procedures applying at ports represent a combination of requirements set by Government and by the port itself. As regards the handling of dangerous goods the procedures can reflect requirements which can exceed those developed internationally. Government officials operate control functions at major ports and it can be occasionally be difficult to determine whether a specific decision on the acceptance of a specific dangerous goods shipment was made by a Government or a Port official.

2.11Major international port groups operate Container Terminals at the major container hubs and have expanded their operations to include terminals at smaller ports.

2.12Most ports require notification several days in advance of the transit, transshipment or delivery of radioactive materials. Many ports limit the berths available to unload such cargoes, prohibit storage in the port area or insist on immediate collection from the ship. Safety, security and environmental protection concerns can combine to complicate or frustrate cargo movements. A number of ports openly decline to handle or allow the transit of radioactive materials.

2.13It is a distinct possibility that the underlying reasons why shipping companies are reluctant to carry radioactive material relate to the restrictions likely to be imposed by the ports a vessel transits through, transships at, or serves. The difficulties of complying with individual port restrictions without compromising a vessel’s schedule may be a significant deterrence towards acceptance.

Assessment of the entries/reports in the Database

Entries/reports

3.1As indicated already (paragraph 1.2) the Database currently holds a total of 182 entries of denials and delays involving the actual, or more often intended, movements of radioactive materials.

3.2Annex 1: Entries in the Database lists the 182 entries using the number allocated to each report in the Database. The Annex also shows:

  • the month/year of each report;
  • the complainant;
  • the documentation supporting each entry, and
  • the action taken following receipt of a report.

3.3The entries in the Database are numbered in the sequence D00001 to D00238. For convenience the entry numbers used in the Annexes dispense with the D0000X, D000XX or D00XXX prefixes.

3.4A copy of the Report Form used to submit reports is at Annex 2: Report Form.

3.5For 161 (88%) of the 182 entries on the Database the original report is attached to the entry. The original report is not attached to 20 entries (12%) and only 1 entry has a report and further related correspondence attached – this was the only “resolved” report. In extracting material from individual entries every effort has been taken to reflect the terms found in the entry/report.

3.6There are occasional inconsistencies between a submitted report and the related entry in the Database.

UN Numbers

3.7The Database includes:

  1. 5 entries (3%) relating to movements, empty flasks ad return packaging, described as UN 2908 – all originally had carried Cobalt 60 (UN 2916)
  2. 117entries (64%) applying to shipments of Cobalt-60 (UN Number 2916);
  3. 45 entries (25%) covering Tantelite or similar shipments (UN Number 2912);
  4. 11 entries (6%) cover shipments described as UN Number 2915, and
  5. 4 entries (2%) covering single shipments of:
  • UN Number 2910 – lead shielding;
  • UN Number 3333 – Radioactive Material Type A Package, Special Form, Fission,
  • a reported delay involving all IMDG Class 7 shipments, and
  • a shipment of Columbite – not IMDG Class 7.

3.8These are illustrated in Figure 1. Details are provided in Annex 3: UN Numbers. Note the dominance of movements of Cobalt-60 (UN Number 2916). Annex 3 also indicates the UN Number and Product Name for each entry in the Database.

3.9When relevant the entries in individual Annexes use the colour coding in Figure 1.

Date of report

3.10As will be seen in Annex 4: Date of Report the numbering sequence of the individual entries (D00001 to D00238) in the Database does not necessarily reflect the date of the individual report on which the entry were based. This mismatch complicates analysis of the entries. Few entries/reports include the precise date the reported difficulty actually occurred.

3.11In summary:

  1. 13 reports (7%) were dated 2006;
  2. a further 13 reports (also 7%) were dated 2007;
  3. 62 reports (34%) were dated 2008;
  4. 51 (28%) were dated 2009, and
  5. 43 (24%) were dated 2010.

This is illustrated in Figure 2. Details are in Annex 5:Year of Report which also identifies the UN Number of the actual, or intended, cargo.

3.12As can been seen in Annex 5 the 5 reports relating to UN 2908 were dated 2006 or 2007. For UN 2912 almost all the reports were dated 2008. All but 1 of the 15 reports relating to UN 2915 were dated 2010. Those relating to UN 2916 are to be found in all 5 years but with a significant proportion in 2009. The 4 reports regarding Miscellaneous shipments are found in 2008. 2009 and 2010.

Complainants

3.13Reports were submitted by:

  1. Industry 110 (60%);
  2. the Tantalum-Niobium International Study Centre (TIC) 38 (21%)
  3. Logistics Companies 15 (8%);
  4. A Government or Government Body 10 (6%);
  5. IAEA 5 (3%), and
  6. the World Nuclear Transport Institute (WNTI) 4 (2%).

3.14As can be seen in Annex 4: Date of Report a number of complainants “grouped” their reports instead of submitting them in strict date sequence. This practice further complicated analysis of the data in the Database.

3.15Those who submitted reports are illustrated in Figure 3. Details are provided in Annex 6: Complainants. Annex 6 also identifies the UN Number of the actual, or intended, shipment.

3.16As will be seen from Annex 6:

(a)the 110 reports submitted by industry were submitted by only 2 companies;

(b)TIC submitted 29 reports relating to 5 identified entities with 9 not specified; (c) WNTI submitted 4 reports relating to 2 identified entities with 1 not specfified;

(d)an Australian Government Department submitted 6 reports relating to 2 identified entities, and

(f)Government entities in China and India submitted 4 reports;

(e)three logistics companies submitted a total of 15 reports, and

(f)the IAEA submitted 5 reports..

Routes

3.17Table 1: Routes seeks to provide an overview of the routes where denials or delays were experienced by reference to the number of reports received relating to each route. Further details are provided in Annex 7: Routes and Shipmentswhich also identifies the UN Number of the actual, or intended, shipment.

Table 1: Routes

Origin / Destination / Number of Reports
Argentina / China / 1
Japan / 4
Thailand / 1
Australia / China / 3
Germany / 1
India / 1
Malaysia / 1
Russia / 1
Thailand / 3
United States / 5
Unspecified / 9
Brazil / China / 7
Russia / 1
Chile / United States / 2
China / Costa Rica / 1
United States / 1
Estonia / United States / 1
France / Brazil / 1
Greece / United Kingdom / 1
Germany / Bangladesh / 4
China / 1
Israel / 1
Hungary / Cuba / 1
India / Cuba / 1
Poland / 1
Yemen / 1
Nigeria / United States / 2
Peru / United States / 10
South America / United States / 1
Tanzania / Belgium / 1
United Kingdom / Ethiopia / 1
Far East / 3
Jordan / 1
Singapore / 2
Thailand / 4
Vietnam / 2
Not specified / 10
Uruguay / United States / 1
United States / Argentina / 4
Brazil / 1
Chile / 1
China / 6
Egypt / 12
Ethiopia / 3
Jordan / 7
Libya / 5
Saudi Arabia / 13
Slovenia / 1
Sri Lanka / 2
Taiwan / 1
Thailand / 2
Tunisia / 7
Venezuela / 2
Asia/SE Asia / 3
Not specified / United States / 1
Not specified / 17
182

3.18 There are 10 entries/reports where the destination is not specified and a further 17 where neither the origin or the destination is reported.

3.19Table 1 and Annex 7 clearly indicate that entries/reports relating to denials and delays relating to the transport of radioactive materials by sea occur worldwide and are not confined to any specific region or route.

3.20There are 13 entries regarding shipment of Cobalt 60 from the United States to Saudi Arabia and 10 relating to similar shipment from the United States to Egypt. The 10 entries concerning Peru to the United States all relate to one shipment.

3.21However, it is notable that while there are a few reports relating to shipments of radioactive materials from Sub-Sahara Africa there are no reports covering shipments to Sub-Sahara Africa. There are also reports relating to the shipment of radioactive materials from Australia but there are no reports relating to shipments to Oceania. While there is only one report of difficulties relating to a shipment to Europe, via Egypt, there are no reports covering shipments within Europe.

3.22There is no way of confirming for this study whether the routes indicated in Table 1 and Annex 7 are truly representative of the worldwide pattern of the movements of radioactive materials by sea. Nor is there any readily accessible information on the number of shipments of, or routes taken by, radioactive material by sea which do not encounter either denial or delay.

3.23Among the 182 entries there are multiple examples of a number of shipping companies being asked to ship the same cargo. It is therefore certain that there are less than 182 individual shipments. Annex 8: Linked Shipments seeks to identify a number of shipments that are clearly linked by approximate date, route and/or consignor/consignee.

3.24There are two examples where the major consignors of Cobalt 60 sought decisions for shipments on unspecified routes and to unspecified consignees from multiple shipping companies. While the accuracy of Annex 8 cannot be guaranteed it is certain that the Database covers significantly less than 182 individual movements (Annex 8).

3.25It would have been helpful if complainants had clearly indicated when their reports were linked when multiple approaches had been made to shipping companies about the same shipment.

Shipping companies

3.26One hundred and fifty two (152) of the entries in the Database identify a specific shipping company, three (3) refer to approaches being made to multiple companies and in 27 reports the shipping company is not specified. This breakdown is illustrated in Figure 4 and the individual companies are numbered in Table 2. Details are in Annex 9: Shipping Companies which again shows the UN Number for individual cargoes.

3.27In Table 2 and Annex 9 each shipping company has been given a “carrier number” this number is also used in related Tables and Annexes.

3.28The entries/reports refer to 44 individual companies – 3 or 4 of which would not necessarily be considered to be shipping companies per se:

  • twenty one (21) shipping companies appear in multiple entries/reports - as can be seen in Annex 9 they include all the major container shipping companies listed in paragraph 2.6 (above), and
  • twenty three (23) companies are referred to in only one report.

Table 2: Shipping Companies

Carrier Number[4] / Entries/Reports
1 / 21
2 / 14
3 / 11
4 / 9
5 / 9
6 / 9
7 / 8
8 / 7
9 / 6
10 / 5
11 / 4
12 / 4
13 / 4
14 / 3
15 / 3
16 / 2
17 / 2
18 / 2
19 / 2
20 / 2
21 / 2
22 / 1
23 / 1
24 / 1
25 / 1
26 / 1
27 / 1
28 / 1
29 / 1
30 / 1
31 / 1
32 / 1
33 / 1
34 / 1
35 / 1
36 / 1
37 / 1
38 / 1
39 / 1
40 / 1
42 / 1
43 / 1
44 / 1
Multiple / 3
Not specified / 27
Total / 182

3.29Annex 10: Shipping Companies, Routes and Shipments seeks to bring together the information in the individual entries/reports on the individual shipping companies, the routes they operate where difficulties have been reported and the UN Number of the shipments involved. There is no corresponding table in this section.

Denials and delays

3.30One hundred and sixty eight (168) (92%) entries report denial of shipment. Only 14 (8%) relate to delays. Figure 5 illustrates the proportion of denials and delay. The colours used to distinguish denials and delays are also used in the related Annexes.

3.31Table 3 shows the instances of denials and delays by UN Number:

Table 3: Denials and Delays (UN Number)

UN Number / Denial / Delay
2908 / 5
2910 / 1
2912 / 35 / 10
2915 / 11
2916 / 115 / 2
3333 / 1
All Class 7 / 1
Columbite / 1
Total / 168 / 14

The same information covering each entry in the Database is shown in Annex 11: Denials and Delays (UN Number).

3.32Of the 168 denials recorded 115 (68%) relate to shipments of UN 2916 with 2 entries recording a delay to an UN 2916 cargo.