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Ferry operators are compelled, both legally and ethically, to operate to the letter of the IMDG Code in the carriage of dangerous goods. There is however in the freight market regular misunderstanding by customers of the requirements of the code in terms of e.g. labelling. While ferry operators do the utmost to address this and help the customer, it is in some cases seen as a negative by customers if, for example, a unit is not shipped as booked because of a deficiency in either labelling or paperwork, or because the goods carried have restrictions in terms of stowage.

By necessity of operation and schedule, vessels operate to tight in-port schedules and as such problems may also occur if a unit is presented late for shipping when a ship is partly loaded and the required stowage space has already been filled by cargo which was already there for loading. Ferry operators therefore specify cut-off times for hazardous shipments in order to ensure the planned stowage can be accomplished.

In cases where there may be an unneveness in the standards of vigilance applied by ferry operators, those who “do the right thing” are often penalised by losing a load to a competing operator. There is naturally a commercial down side to this especially in current market conditions, however a moral obligation and legal requirement exists to do things correctly, and this should be appreciated by customers in organising what they do.

I would also add that a recurring problem is the non-removal of labelling by freight operators when a hazardous load has been tipped and a unit returns to port either empty or laden with a non – hazardous backload. This may cause difficulties in terms of load allocation, cargo determination, or in a worst case scenario with an incident at sea, those dealing with it on board really have to act in terms of what they see. If a hazardous labelled unit is involved in e.g. a fire scenario, this will influence actions taken in dealing with the incident. There is therefore a clear responsibility to have all labels removed where a unit is NOT carrying dangerous goods.

Regulations aside, ferry companies try to serve customers to the highest degree, but there must be an appreciation by feight operators that ferries are not simply an extension of the road, and that units presented for shipping must be secure, safe, properly manifested and labelled according to the needs of undertaking a sea journey.