INTERNATIONAL MARITIME ORGANIZATION
E
IMO
FACILITATION COMMITTEE
35th session
Agenda item 10.1
FAL 35/10
7 November 2008
Original: ENGLISH
SHIP/PORT INTERFACE
Facilitation of shipments of dangerous cargoes
Submitted by Canada
SUMMARY
Executive summary:
This document provides information on a briefing for FAL 35, as a
follow up to FAL 34 outcome, Canada proposes to provide an update
from the IAEA International Steering Committee, and previous IMO
Correspondence Group on denial of transportation of radioactive
materials
Strategic direction:
1; 8
High-level action:
1.1.2; 8.2.1; 8.3.1
Planned output:
1.1.2.3; 8.2.1.5; 8.3.1.4
Action to be taken:
Paragraph 7
Related documents:
FAL 34/19, FAL 34/10/6; FAL 33/12/3, resolution A.984(24) and
FAL.6/Circ.12
General
1
Under this agenda item, the Committee will be invited to consider matters relevant to the
facilitation of shipments of dangerous cargoes, in particular class 7 radioactive materials.
At FAL 34 the Committee requested the Secretariat to conduct a trial of the ad hoc mechanism
within the IMO Secretariat for the resolution of difficulties in the carriage of IMDG Code class 7
radioactive materials, and to report on its experience to FAL 35.
Background
2
Through the FAL Committee, the Organization has been integral in raising awareness and
in supporting both processes and systems established to resolve denials of shipment of
radioactive materials. The Organization first became involved with this issue at FAL 31 and
significant action has been taken and positive results achieved since then.
For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.
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3
Radioactive materials are widely used globally, from uranium for energy production, to
tantalum and niobium for electronics, to medical isotopes for diagnosis and treatment of disease,
to Cobalt-60 for sterilization of medical products, food irradiation and cancer treatment.
The timely, cost effective and efficient transportation of these products is required in order for
the global economy and population to reap the many benefits they provide.
Report on experience with the mechanism for the resolution of difficulties in the carriage of
IMDG Code class 7 radioactive material
4
It was agreed at FAL 34, in order to assist in providing a report on the experience with
this trial to date, that Canada will be presenting an update for the denials of shipment issue and
actions towards finding solutions on the following topics:
•
•
•
•
•
•
a review of actions accomplished
current state of action plans
review of the integrated IMO, IAEA, ICAO approach to denials, including the
IAEA International Steering Committee on Denial of Shipment of Radioactive
Materials
Denials database and summary of data received to date
Examples of positive results arising from actions to date
Suggested next steps needing FAL and Member State participation and
endorsement.
Continued efforts
5
It should be realized that the denial issue is far from being resolved and it is imperative
that FAL and all Member States continue to support and participate in the identification and
resolution of root cause issues. Fortunately, and thankfully through the efforts of many in
Administrations and organizations, there has been progress towards a resolution of some of the
problems, and it is expected that such efforts need to be continued.
6
Key findings to be presented in this briefing are attached at annex for the Committee’s
review prior to the session.
Action requested of the Committee
7
The Committee is invited to note the above updated information and take action as
appropriate.
***
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ANNEX
Background
•
FAL 33/12/3 – Canadian submission regarding experience in denials of shipments of
Cobalt-60 by sea
!
Created Correspondence Group to prepare a Working Process by which IMO, with
IAEA, will manage denials
•
FAL 34 – Report by Correspondence Group (FAL 34/11/2) and agreement on Denial
Report Form and Working Process; Secretariat requested to monitor denials and report
back at subsequent FAL and General Assembly meetings
•
IAEA Conference Resolution re Denials of Transport (2005)
•
IAEA “International Steering Committee on Denials of Transport of Radioactive
Material” established 2006; IMO standing member.
IMO Resolution A.984(24)
•
Carriage of IMDG Code class 7 radioactive materials, when carried out in compliance
with the relevant provisions of chapter VII of the 1974 SOLAS Convention, the
IMDG Code and the recommendations contained in MSC/Circ.675 (currently
MSC.1/Circ.1216) on Recommendations on the safe transport of dangerous cargoes and
related activities in port areas meet the necessary safety requirements and should be
facilitated;
Marine Denials
Experience to date:
•
•
Port in-transit and trans shipment refusal, carrier refusal, Port Authority/municipal
authority refusal, co-sharing
Regulatory inconsistency, additional national regulations, route restrictions, general
class 7 restrictions
Impact:
•
•
Denial and inability to ship to delayed transit
Extreme time and cost of transport (road transport from foreign Port)
Broad geographies
•
•
South America, Mediterranean, Middle East, parts of Asia Pacific and Africa are difficult
to serve
Impact on end users, and subsequently industry and public health is significant
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ANNEX
Page 2
Reasons for Denials: IMO/IAEA findings
•
•
•
•
Negative perception about radiation – lack of awareness and information of the industry
Concerns of cost and extent of training of those who handle radioactive materials
Multiplicity and diversity of regulations governing handling, use and transport of RAM;
lack of harmonization between Member States. Result: duplicative, overlapping and
sometimes contradictory regulatory requirements
Lack of outreach with resultant lack of public awareness about the need and applications
of RAM, and the extremely stringent regulatory environment in which they are managed
Facilitation is Underway
Turn denials into facilitation
•
•
•
•
UN integration – IMO, IAEA, ICAO
National involvement – consistent regulations, integrated with IAEA and IMO facilitation
initiative
Association integration – VOHMA, ICS, ICHCA, IAPH, IATA, …
Industry initiative – Carriers, Ports, Forwarders, Customs, supply chain, etc.
IAEA Steering Committee
Action Plan
Awareness
•
•
•
Institute a database to record all denials (all modes, all geographies)
Access data, define root cause of denials, establish action plan to resolve
Educate all parties involved of the very rigorous standards in place re transportation
Training
•
Improve awareness and understanding of transportation supply chain and stakeholders
regarding transport safety regulations and experience
Communication
•
Improve the integration and transparency between producers, shippers, users, carriers,
authorities, regulators and the Public
Lobbying
•
For marketing, outreach, and promotion of industries shipping radioactive materials and
for promoting a positive image regarding the use of these materials
Economics
•
Mitigate deleterious and burdensome costs associated with shipping denials and delays
Harmonization
•
of international and national regulations and standards, of Port and Port Authority
requirements, of carrier requirements and of the process used to report denials of shipments
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Page 3
IAEA Steering Committee (SC); Regional Networks
•
•
Multiple countries assimilated by region (Latin America, Mediterranean, Asia Pacific
countries including Australia and some Middle East countries, French/English speaking
countries in Africa)
Aim – facilitating communication on denials and ultimately facilitating radioactive
material (RAM) transport globally
Benefits:
•
•
•
•
Geographically similar countries working together to resolve “local” denial issues
Global representation at SC meetings
Specific points of contact in the regions and Member States
Involved for further communication and coordination of actions
IAEA; National Focal Points (NFP)/Regulatory Database
•
•
•
•
IAEA requested all Member States to nominate a single point of contact (regulatory) to
deal with denials – NFP
IAEA consolidating a listing of regulations impacting RAM transport from all
Member States
Both of these initiatives are relatively new but are being accepted by Member States
quickly
Good benefits to industry (and SC) – ability to more effectively ship product
IMO/IAEA/ICAO: Denials Database
•
•
•
•
•
•
•
One database for all 3 UN Organizations
Heart of the Denials program – data drives root cause determination and actions
Denial Report Form and the Working Process initially developed and approved by IMO,
subsequently by IAEA SC
Reports submitted by industry, Member States, Industry Associations, NGOs
Need increased awareness of denial process
Database growing with >100 reports now filed
IMO managing database
Joint Denial Database: Summary to Date
•
•
•
•
~80% of all denial reports submitted to IMO relate to transport of Cobalt-60
(for medical/health purposes)
~60% due to carriers
~20% due to Ports/Port Authorities
~20% due to other reasons
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Page 4
Moving in the Right Direction
Examples with satisfactory resolution of previous denials:
•
•
Late 2007 – ocean routings changed precluding ability to ship Cobalt-60 to a number of
Asia Pacific countries
Early 2008 – inability to effectively ship RAM into and out of Port of Santos, Brazil
Proposed Next Steps:
1. Ongoing FAL and IMO support of denials action plan and joint IMO/IAEA/ICAO
involvement in Denials Steering Committee.
2. Member State (MS) help in making industry and licencees in your countries aware of
IAEA SC and denial reporting process.
3. Determination of what is deemed “confidential” in Denial Report.
4. Continued IMO Secretariat involvement in monitoring denials (with subsequent
reporting) and in helping facilitate resolution of root causes of denials.
5. Need MS representatives on IMO and IAEA Committees to integrate, and with their NFP,
push to identified and improved RAM shipment facilitation.
6. New regulations, technology and programmes integrated and standardized as much as
possible.
7. Non-governmental Organization (NGO) and Association integration of common goals:
IAPH, ICHCA, VOHMA, ICS, etc.
8. IMO Secretariat takes lead in forming a FAL Intersessional WG of Permanent
Representatives of countries where denials are occurring with goal of resolving reasons
for denials.
In Conclusion:
•
•
•
•
•
•
•
•
Significant forward movement in efforts to facilitate shipments of RAM
UN bodies supportive of work underway
Denial Reporting Form and Working Process agreed to and being used by IMO, IAEA
and ICAO
Denials database is being populated and results evaluated by IMO/IAEA/ICAO
Action plans in place AND integrated at country, regional and international levels
Action plans are providing specific, identifiable, positive results for our industry
Ongoing actions and involvement of IMO, MS, NGOs and Associations is critical to
resolving the denial issue
Special thanks to IMO Secretary-General, the IMO Secretariat, FAL, IAEA, MS, NGO,
and associations for the positive movement we have seen to date.
___________
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