Freight container safety

Overview

All participants in the logistics chain – from owner drivers with one vehicle to large fleet operators, to shippers and warehouse operators – are likely to work with containers on a daily basis as drivers, loaders or handlers.

Accidents may happen at any stage of a container's journey; many of these will be serious or fatal, including crushing and falls from height. These accidents may be caused by human error or failure of technical items.

Typical hazards regarding freight containers in ports

structural failure due to lack of maintenance and wear and tear
structural failure due to overloading, misdeclared weight, uneven or shifted loads
falls from height while working with containers
crush injuries during container manoeuvring and movements
exposure to fumigants used during transit or chemicals given off by cargo that may build up during transit

How the risks can be reduced

All of these can be reduced by proper planning of work and training of workers. Before any work tasks are carried out, the relevant risks should be identified through risk assessment and appropriate control measures put in place to protect against them.

Port Skills and Safety (PSS) have produced a comprehensive 'Health & Safety in Ports' guidance document entitled SIP003 – Guidance on Container Handling that covers these issues in more detail.

This document has been produced by the ports industry, with assistance from HSE, to help dutyholders understand their duties under health and safety legislation and to identify key risks. This guidance also gives examples which dutyholders can use to inform their risk assessments and procedures.

Which laws apply?

Freight container regulations

Under the Freight Container (Safety Convention) Regulations 2017, HSE is responsible for:

issuing approvals for firms who oversee the design and manufacture of containers and
upholding maintenance standards for freight containers in Great Britain through the Approved Continuous Examination Scheme (ACEP) and Periodic Examination Scheme (PES)

The Regulations apply to most types of freight container used at a place of work and require that the containers be:

Approved – Freight containers and their derivatives must have their design, specification and construction approved by an organisation appointed by HSE to carry out this work. Those needing to have their containers approved should approach one of the appointed organisations directly.
Periodically examined – Freight containers must be regularly examined by a competent person and in accordance with arrangements that are approved by HSE to determine whether the container is fit for use and to verify satisfactory maintenance.
Maintained – Freight containers must be maintained in efficient working order and good repair. The Regulations imply more than merely repairing defects as they become apparent through failure or examination – routine inspections should include systematic preventative maintenance to ensure the container is safe for continued use.
Plated – Freight containers must have a safety approval plate permanently affixed, giving information on its status and design parameters. This includes the reference number of the organisation that approved the container, the identification number of the container, its maximum gross operation weight and details of the examination arrangements.
Marked – so that any maximum operating gross weight shown on the body of the container is consistent with the marking on its safety approval plate.

Container design and manufacture approval

The document below sets out the details of the arrangements that operate in Great Britain for the approval of container design and manufacture in accordance with the requirements of the Freight Containers (Safety Convention) Regulations 1984:

It explains that, under these arrangements, HSE will authorise suitable organisations to carry out the functions of approving containers and lay down the conditions that organisations will be expected to meet before being considered eligible for appointment
It give details of the method by which manufacturers and owners of containers may make application for the approval of containers and the procedure to be adopted by the authorised organisations in considering such applications

Those needing to have their containers approved should approach one of the appointed organisations listed below directly.

Companies appointed to approve containers

Container manufacturers must gain approval either for the design type or for individual containers. Approval is given by companies appointed by HSE or alternatively by IMO signatory Governments that have ratified, accepted, approved or acceded to the convention.

For manufacturers and owners who wish to apply for approval, the companies currently appointed to approve containers in Great Britain are:

Lloyd's Register Verification Limited, 71 Fenchurch Street, London EC3M 4BS, Tel : +44 (0)207 423 2428
Det Norske Veritas Ltd, Cromarty House, 67–72 Regent Quay, Aberdeen, AB11 5AR. Tel: 01224 335 000
Det Norske Technical Ltd, Palace House, 3 Cathedral Street, London, SE1 9DE. Tel: 020 7357 6080
Bureau Veritas UK Ltd, Parklands, 825a Wilmslow Road, Didsbury, Manchester, M20 8RE, Tel: 0161 446 4600
Zurich Risk Services, 126 Hagley Road, Edgbaston, Birmingham, B16 9PF, Tel: +44 (0)121 456 1311

Container examination schemes

Approved Continuous Examination Programme (ACEP) Periodic Examination Scheme (PES)

Containers should be regularly examined for their safety and suitability for use in accordance with:

an Approved Continuous Examination Programme (ACEP) or
a Periodic Examination Scheme (PES)

Both schemes require containers to undergo regular examinations, carried out to the same standard and in the same manner. The difference lies only in the frequency with which the examinations are necessary:

Under ACEP the examination is carried out in connection with a major repair, refurbishment or on-hire/off-hire interchange - but the interval between examinations must not exceed 30 months.
Under PES the interval from date of manufacture to first examination must not exceed five years. The container should then be examined at intervals not greater than 30 months.

Operators are permitted to apply for either or both ACEP and PES approval and may operate their fleets under either or both arrangements.

Inspections under both schemes must be carried out by a competent person and cover the following aspects of the container:

corrosion
the condition of welding
the condition of riveting or similar method of fastening
the presence of mechanical damage
the condition of structural components where applicable, eg frame, corner fittings, door and hatch closure gear, floor and external panelling
the validity of the safety approval plate

HSE approves examination schemes for owners or lessees of containers in Great Britain. Organisations wishing to obtain approval for an examination scheme should consider the instructions found in the document 'Conditions for approval of examination schemes or programmes' (The Yellow guide) below, and provide HSE with the following information and assurances:

A formal request for approval of examination arrangements under the Freight Containers (Safety Convention) Regulations 2017.
A statement of whether you propose to carry out examinations under PES, ACEP or both schemes.
Confirmation that the examinations will only be carried out on containers, the design of which has been approved by an organisation appointed by HSE in accordance with the instructions found in the conditions for approval.
Confirmation that the examinations will be carried out by a competent person in accordance with the instructions found in the conditions for approval.

HSE's approved container examination schemes

Please visit the list of current HSE approved examination schemes. It confirms the allocated plate number and the last known company name and address.

Further information

Conditions for approval of examination schemes or programmes

To request approval of an examination scheme, contact HSE at [email protected]

Rail Accident Investigation Branch's (RAIB) - accident reports

Risks from modifying Freight containers and incorrect 'loading' of freight containers

The Rail Accident Investigation Branch's (RAIB) Rail accident reports 17/2012 and 02/2013, asks the Health and Safety Executive (HSE) to raise awareness, amongst users of freight containers of the findings of these investigations.

RAIB publication 17/2012

The RAIB publication 17/2012, reported on a container train incident near Althorpe Park, Northamptonshire, where a partially detached metal panel from a container train struck the cab of a passing track maintenance vehicle, smashing the side window. A similar panel was found trackside, one mile further on. No-one was injured in this incident.

The panels were from two modified freight containers, which now housed power generation equipment and were being exported overseas. The panels covered two ventilation apertures on the container sides. They were fitted to prevent water ingress during the sea journey.

The cause of the accident was the fixings securing the panel had become loose during rail transit.

Since the incident, the company now fits the panels internally within the modified container.

Recommendation

The recommendation asks the Health and Safety Executive to draw the attention of manufacturers and users of modified freight containers, to the need for a competent assessment of the adequacy of bolted joints used to secure exterior attachments, when designing, modifying or repairing containers.

RAIB publication 02/2013

The RAIB publication 02/2013, reported on a wagon on a container train that derailed, and then re-railed, when crossing a section of track connecting two lines (a crossover) at Reading West Junction. No-one was injured.

RAIB concluded that pallets in the container mounted on the wagon had moved during the road journey to the freight terminal. As a result, the uneven loading within the wagon had led to the incident.

The company that had packed the container had no processes at the time to ensure the palletised load could not move in transit. This was critical as this container was only partially filled, allowing space for the heavy pallets to shift, which lead to an unbalanced load.

Recommendation

The recommendation asks HSE to draw attention to those loading (known as 'stuffing' in the industry) containers, using sufficient 'dunnage' or solid packing, to prevent pallets or materials moving, especially when pallets support heavy individual items.

Shippers and freight forwarders should be aware of specific guidance, especially 'Guidelines for packing of cargo transport units' published by the International Maritime Organisation, or equivalent documents.

Staff and operatives should also receive training in the correct loading techniques, as failure to prevent load shift, especially in transit or during handling, may result in incidents with serious consequences.