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Presentation Cargo Loss Prevention Committee Wednesday, 15 September 1999
CALCIUM HYPOCHLORITE: FIRE IN THE HOLD
James A. Darling
cuss GROUP OF INSURANCE COMPANIES
IUMI Conference Berlin 12·16September 1999
MARINE INSURANCE· REINVENTING OUR BUSINESS
CALCIUM HYPOCHLORITE: FIRE IN THE HOLD!
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James A. Darling Cargo Loss Prevention Committee 1999 )UMI Conference Berlin, Germany
In the world of ocean marine insurance, certain containerships have recently come to represent serious losses with alarming similarities. What do the CMA Djakarta, Aconcagua, D.G. Harmony, Contship France and the Kapitan Sakharov have in common? Each vessel suffered severe damage or total loss from fire. Each vessel transported calcium hypochlorite at the time of the fire. Each of these losses has
generated considerable confusion and controversy as a result.
Calcium hypochlorite (also known as calcium chloride hypochlorite, calcium salt, calcium hypochloride, chloride oflime, chlorinated lime or hypochlorous acid) is a bleaching agent in primary use by the paper, textile and wood industries as well as in water treatment systems for its disinfectant qualities. The principal countries of origin include the United States, Canada, Brazil, Italy, France and China. After a series of maritime disasters involving the chemical, there is growing concern about the safety of
Listed as a Class 5.1 Oxidizer under the International Maritime Organization's International Maritime Dangerous Goods Code, or IMDG, the white powder is shipped under three separate entries. Each entry has a UN number which identifies the version of the chemical primarily for its percent of available chlorine and secondarily for its water content. The IMDG further sets stowage provisions based upon what is perceived to be the inherent volatility of each class and assigns a packing group designation which reflects, among other things, the degree of potential danger each class represents.
Calcium hypochlorite, dry or Calcium hypochlorite mixtures dry
with more than 39% available chlorine and 8.8% available oxygentsic). The IMO requires Stowage "D"- on deck only, and Packing Group (PG) II.
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Calcium hypochlorite, hydrated or Calcium hypochlorite,
hydrated mixtures with not less than 5.5% but not more than 10% water. The IMO requires Stowage "A"- either below deck or on deck, and Packing Group
Calcium hypochlorite mixtures, dry, with more than 10% but not
more than 39% available chlorine; The IMO requires Stowage "A" - either below deck or on deck and Packing Group (PG) III.
According to the IMDG definition, calcium hypochlorite "may, generally by yielding oxygen, cause or enhance the combustion of other material." This reaction is known to be sensitive to the temperature of its immediate environment. As with other hazardous materials that react to changes in ambient temperature, stowage provisions for calcium hypochlorite have become of paramount importance to shippers and insurers alike.
Stowage guidelines for calcium hypochlorite vary depending upon the type/grade of the chemical. As a rule, calcium hypochlorite is recommended to be stowed away from sources of heat in excess of 55 degrees C (13 IF) for periods of24 hours or more. It is also necessary to keep calcium hypochlorite out of proximity to certain other chemicals/substances including ammonium compounds, cyanides, hydrogen peroxide or powdered metals. Again, depending upon the type or grade, calcium hypochlorite may require ventilation for safe transport.
In the early 1970's, fires were being reported frequently on containerships carrying the chemical. At that time, investigations determined that calcium hypochlorite should be stowed on deck in order to avoid exposure to the higher temperatures that can build up below-deck. However, recent incidents would suggest that on-deck stowage is not the long-term fix that Protection & Indemnity clubs hoped for. These recent studies indicate that on-deck stowage exposes the chemical to dangerous levels of radiant sunlight, especially when the containerships sail through equatorial waters.
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Of even greater significance and potential controversy is the suggestion that calcium hypochlorite's critical ignition temperature may not be correctly understood and, thus, not adequately regulated for. The consulting chemists, DR Burgoyne & Co., report that calcium hypochlorite becomes volatile at 35 degrees Cor just 95 degrees Fsignificantly lower than the current IMDG standards.
On July 10 of this year, fire broke out on the 2100-TEU containership CMA Djakarta as it sailed the Mediterranean south of the island Crete. The fire erupted among containers on deck and ultimately required the 2l-member crew to abandon the vessel entirely. The firefighting team had great difficulty extinguishing the blaze because ambient temperatures were high enough to repeatedly re-ignite remaining cargo and subsequently, the Djakarta was grounded off the Egyptian coast. The charterers of the 1998-built containership seemed to indicate that the vessel was carrying one of the dry forms of the chemical that the owners of the Djakarta believe was the cause of the fire. No official findings have been released to date.
Another recent incident involved the 2226- TED containership Aconcagua. In late December of 1998 while sailing off the coast of Equador, the Aconcagua was severely damaged by fire as it transported a cargo of anhydrous calcium hypochlorite. The crew was safely evacuated. Repairs have been estimated to cost between $15 - 18 million. Because the vessel transported the dry, more stable form of the chemical, it was not required to keep the containers on deck. In retrospect, this is raising concerns of experts that stowage differentiations between the "wet" and "dry" forms of calcium hypochlorite may not be adequate.
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The 1799- TEU vessel DG Harmony was declared a constructive total loss for $16 million after an explosion occurred and fire broke out while the ship was off the coast of Brazil last November. The intensity of the blaze caused the crew to abandon the vessel. The Harmony was known to be transporting at least one container of hydrated calcium hypochlorite at the time of the incident. The vessel's insurers have since expressed doubt about the IMDG's guidelines for shipping the chemical and the ongoing investigation into the blaze is looking into whether the calcium hypochlorite was exposed to conditions that would cause it to self-ignite.
Another incident being investigated for possible self-ignition of calcium hypochlorite involves the 1600-TEU containership Contship France. In October of 1997 while docked in Papeete Harbor, Tahiti, the vessel suffered a major explosion that resulted in extensive damage to both the hull and cargo. Although originally thought to have been caused by a cargo of aerosol spray cans, the subsequent investigation is focusing on the shipment of calcium hypochlorite reportedly in the ship's No.3 hold - the site of the explosion.
The hydrated version of calcium hypochlorite is also blamed for the fire onboard the Russian containership Kapitan Sakharov. In 1993, this vessel was abandoned by its crew during a major fire and later declared a total loss. Sadly, two crew members perished in the incident. In 1998, a High Court in London found that the explosion and fire started on deck in an undeclared container of dangerous cargo. Other flammable chemicals onboard contributed to the intensity of fire and, ultimately, the sinking of the vesseL This incident, among others, lends some credence to the theory that calcium hypochlorite can be sufficiently heated by radiant sunlight to cause spontaneous explosion.
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Calcium hypochlorite is marketed in various forms (powder, pellets and tablets) and various concentrations. It is typically shipped in drums and stowed in containers. Recent revisions to the IMDG Code relaxed some of the packaging restrictions to allow for larger quantities of the chemical to be transported in individual drums. Some hazardous material experts believe that shipping calcium hypochlorite in larger quantities contributes to its potential for self-ignition. Others suspect that as yet unidentified changes in manufacturing may render calcium hypochlorite more dangerous than previously thought. In the wake of this series of disasters, insurers are cautioning shipowners and shippers alike to be aware of the potential hazards of the chemical as well as to strictiy follow the IMDG Code for stowage.
Some insurers have even gone as far as to recommend that calcium hypochlorite be excluded from coverage. The London Steamship Owners Mutual Insurance Association has declared that insurers should add calcium hypochlorite to their excluded cargo list, pending review of the IMDG Code. This would require shippers and charterers to request that the exclusion be waived in order to insure their shipments in the meantime.
While the IMDG Code would seem to make classifications clear, labeling each shipment accurately as to its chemical content might have contributed to at least some of the incidents. Obviously, if a shipment is more than 39% available chlorine but is classified as UN2208 --10 to 39% available chlorine, it could be stowed either above or below with no heat source restrictions and therefore have the potential for a devastating accident. For the time being, shippers are well advised to confirm the chemical content of and accurately declare the hazardous commodities they offer for transport. They must pack, label, stow and ship goods in accordance with the IMDG Code as well as identify any secondary or tertiary hazards that could come into play during handling and/or transit. Carriers have the responsibility to accurately identify any cargoes of a dangerous nature and refuse acceptance of those shipments that cannot be identified.
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From an insurance standpoint, monitoring compliance with packing, documenting and shipping regulations would be in order throughout the underwriting process. Thorough investigation after losses to identify contributing causes is also important to help prevent similar occurrences.
Changes in the way calcium hypochlorite is transported and stowed may be in order. If the chemical can indeed begin reacting at just 95 degrees F as suggested by recent studies, stowage on deck, exposed to high ambient temperatures and direct sunlight, may not be prudent. On-deck containers, or even those staged in a terminal awaiting transport, can have internal temperatures that easily can reach 120 degrees F in
summer months. Shippers may want to consider loading the drums of calcium hypochlorite into insulated or refrigerated containers. (Even if not powered, refrigerated containers have significant amounts of inherent insulation.)
Finally, a comprehensive approach to minimizing the obvious hazards of shipping calcium hypochlorite would involve all aspects of its manufacture, sale and transport. Educational programs which address the proper methods of handling, packing, labeling, stowing and transporting calcium hypochlorite should be developed and disseminated sooner rather than later .. Because the IMO's Dangerous Goods Solid Cargo and Container Sub-committee will not meet again until next February, there is little likelihood that changes to the IMDG Code can be expected before that time. Thus, other parties with professional interest may be called upon to fill the void in order to ensure that future containerships do not suffer disastrous losses of both life and property from fire in the hold.
Calcium hypochlorite is the shipping problem dujour. Which of the seemingly hundreds of hazardous, and even innocuous, chemicals will next pop up on the radar screen of the international maritime community? Ifwe are to be positioned for these inevitable events, we are going to need an active, cooperative effort among all of the
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relevant stakeholders, including manufacturers, shippers, carriers, governing bodies and insurers.
The manufacturers must ensure that the product enhancements and related technology do not result in a change in chemistry that will add or increase shipping hazards. The only proven way to do this is by analytical testing, especially under conditions likely to be encountered during transportation through their supply chain.
The Salvage Association has raised concern that potentially dangerous cargo may have been incorrectly declared on manifests. To avoid such mistakes, shippers, including forwarders, consolidators and other cargo intermediaries, must take the data from the manufacturers and accurately declare the shipment and then properly prepare it according to IMDG regulations.
Carriers in all modes must only accept shipments that meet the regulations. Perhaps, they can use the "known shipper" approach that has proven successful in the transport of dangerous goods in the air cargo arena. The known shippers program is a procedure
mandated by the United States' Federal Aviation Agency for use by airlines. It requires airlines accepting shipments to categorize those from whom they accept shipments as either a known or unknown shipper and then treat them accordingly.
Known shippers have consistent working relationships with the airline - the airline knows who they are, what they generally ship and they know the shipper's business profile. Airlines working with a known shipper can reasonably accept cargo without a significant risk that it has been improperly classified or mis-labeled. On the other hand, air cargo from an unknown shipper must have a signed security declaration from the shipper and that cargo must be inspected either by x-ray or physically opening it.
If a program similar to the known shipper approach were instituted for ocean cargo, the likelihood of incorrect or misleading declarations would be reduced. And should an
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incident occur despite these precautions, a known shipper procedure would provide a paper trail to help investigators trace the cause.
The IMO and other rule-making groups must develop a method of verifying that their requirements are validated by laboratory testing and field experience and are consistent with state-of-the-art in the industries they serve.
Insurers must firmly support these actions through policy warranties, punishing policyholders that fail to adhere to both the letter and spirit of the regulations. We also have the duty to add value to our contract by educating insureds on the potential hazards of shipping.
In conclusion, everyone must be in synch and do his or her part. Otherwise we will continue to experience loss of cargo, damage to vessels and negative frnancial effects on the balance sheets of shippers, manufacturers, carriers and insurers alike.
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Acknowledgements and Reference Materials
Captain James McNamara National Cargo Bureau, Inc. 30 Vesey Street, 6th Floor
New York, NY 10007-2914 USA
Norges Handels og Sjofartstidende Grev Wedels plass 9
PO Box 1182 Sentrum N-0107 Oslo, Norway
Captain Frank Zabrocki National Cargo Bureau, Inc. 30 Vesey Street, 6th Floor
New York, NY 10007-2914 USA
Mr. Richard Sbrieve
Air Transport Association of America
1301 Pennsylvania Avenue NW, Suite 1100 Washington, D.C. USA
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