Industry Issues


Joint Industry Guidelines for Cleaning of Containers

The container industry has worked collaboratively to develop joint industry guidelines for the cleaning of containers.  The purpose of the joint industry guidelines for cleaning of containers is to assist in minimizing the movement of pests by sea containers and their cargoes.  The guidelines are complementary to the guidance given in the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units – better known as the CTU Code. They do not replace applicable local regulatory pest contamination measures and requirements nor do they replace individual ccontainer operators' cleaning guidelines. .Further, industry guidelines regarding container cleaniless for non-pest contaminations such as paint, oil, etc. fall outside the scope of these guidelines.

Background:
     
In 2013, the International Plant Protection Convention (IPPC) published a draft standard on “Minimizing Pest Movement by Sea Containers (2008-001)”, and invited “conceptual comments” on the draft.

The World Shipping Council (WSC), the International Chamber of Shipping (ICS) and the Container Owners Association (COA) in response to the IPPC’s invitation filed joint industry comments. The industry comments as well as relevant IPPC documents and a summary of events are available on the IPPCs’ website.  

The IPPC’s governing body, the Commission on Phytosanitary Measures (“the Commission”), at its tenth session (2015) decided to hold a Special Topics session during its eleventh session (2016) to consider the issues regarding pest movement by sea containers, including whether to proceed with the finalization of the draft standard.  

Also at its tenth session, the Commission adopted “Recommendation CPM-10/2015/01 on Sea Containers.  The Recommendation confirms that ‘the packing of sea containers with cargo is the most likely stage in the sea container supply chain at which contamination can occur’.  It encourages National Plant Protection Organizations (NPPOs) to, among other actions, support the implementation of those parts of the CTU Code that address pest contaimination of containers and their cargoes.  The Recommendation also sets out the principle that any measures to mitigate pest contamination risks should be justified, practical and proportionate.  

The Special Topics session took place on April 7, 2016, at the headquarters of the Food and Agriculture Organization of the United Nations (FAO) in Rome, Italy.  The container industry was represented as observers by the World Shipping Council and the Container Owners Association.   

The container industry provided a presentation to the Special Topics session on container logistics. Salient points raised in the presentation include:

  • Container flows are complex and may involve multiple border crossings, handovers of control and transport modes. There are many actors involved and the shipping company, which operates the container, has little direct control over or access to containers except for when containers are in container depots; however, dispatch of an empty container from a container depot is not always part of every trip (so-called “street turns”).
  • The most likely point at which pest contamination could occur is the packing point over which shipping companies have no control.  The shipper exerts such control, either directly or via contractual agreement with the packer.  The CTU Code provides guidance for the prevention of re-contamination of containers to shippers and those who pack containers, but shipping companies have no means of determining how effective this has been.  

The container industry also proposed that, as part of the Commission’s consideration and decisions on how to move forward with the sea container pest contamination work item, the industry be requested to develop joint industry container cleanliness guidelines to minimize the risk of pest contamination of containers while in the custody of container operators and owners.

The Special Topics session agreed to defer a decision on whether to proceed with the finalization of the “Minimizing Pest Movement by Sea Containers (2008-001)” draft standard for a maximum of five years, to allow for the implementation of the CTU Code and Recommendation CPM 10/2015/01 and an analysis of their impact on reducing pest movement by sea containers.  In addition, the Special Topics session welcomed the container industry’s proposal to develop joint industry guidelines for cleaning of containers, and requested to be kept informed about developments.  

The Special Topics session also requested the CPM's executive body ("the Bureau")  to consider the development of a "set of complementary actions" to assist in assessing and managing the pests threats associated with sea containers, and to propse such a possible program of complementary actions to CPM-12 (2017).

Joint Industry Guidelines for Cleaning of Containers

Since the IPPC Commission’s 2016 Special Topics session, the container industry has worked collaboratively to develop joint industry guidelines for cleaning of containers. Specifically, WSC, COA, ICHCA and IICL, and their member companies, worked together on this project. Subsequently, the International Chamber of Shipping (ICS) and BIMCO have expressed support for the joint industry guidelines.

The guidelines are complementary to the guidance given in the CTU Code. They do not replace applicable local regulatory pest contamination measures and requirements nor do they replace individual container operators' cleaning guidelines.

Chapter 4 of the CTU code, “Chains of Responsibility and Information” states in para.4.1.4: “All persons involved in the movement of CTUs also have a duty to ensure, in accordance with their roles and responsibilities in the supply chain, that the CTU is not infested with plants, plant products, insects or other animals…”.  The joint industry guidelines aim to provide guidance on how this may be achieved by container operators for those containers that are in their control, i.e. when containers are in container depots prior to their dispatch empty to shipper customers.  

The guidelines do not address how shippers, and packers acting on their behalf, should avoid that containers be contaminated during their packing.  However, the guidelines may serve as an inspiration for the development of guidance for the prevention of re-contamination of containers during packing.

The joint industry guidelines were submitted to both the IMO and the IPPC in 2017 and both organizations welcomed and expressed appreciation for the development of the guidelines. 

IPPC developments since the 2016 Special Topics session

As instructed by the Special Topics session, a “Complementary Action Plan” was presented to CPM-12 (2017) for discussion and endorsement.  

The agreed action plan includes the following:

  • Development of a joint IPPC/IMO/industry protocol on data generation to be completed by CPM-16 (2021).
  • Monitor the uptake and implementation of the CTU Code through industry reporting and NPPO monitoring.
  • Verify the efficacy of the CTU Code in ensuring the arrival of clean sea container through monitoring for pest contamination by NPPOs.
  • Increase awareness of pest risks of sea containers through e.g. publication of pest risk management guidance material, notification to industry on the pest risks, and possible international actions by NPPOs.
  • Establishment of a Sea Container Task Force to supervise, monitor and report on the implementation of the aforementioned actions, including providing advice on how the CTU code or any other instrument could be updated, and provide a final report on its activities to CPM 16 (2021).

The first meeting of the IPPC Sea Container Task Force (SCTF) was held on 6-10 November 2017, in Shanghai, China. The report of the meeting is available here.

North American Sea Container Initiative

In February 2017, in support of the IPPC’s Complementary Action Plan, the NPPOs of the United States and Canada launched the North America Sea Container Initiative (NASCI) in partnership with a number of container supply chain industry organizations, including the World Shipping Council, and border inspection agencies. The initiative’s main objective is to raise awareness and to mitigate contaminant pests associated with sea containers and their cargoes.

The NASCI working group has developed a Sea Container Cleanliness bulletin that has been translated into Spanish, French, Mandarin, Russian, and Japanese. The IPPC’s Sea Container Task Force recognized the value of this bulletin and agreed that it should also be used by other countries and regions. The NASCI bulletin has also been used for the development of an IPPC fact sheet on sea containers. Additionally, the NASCI working group has developed key promotional information for the U.S. and Canada NPPO web sites  that includes links to the Sea Container Cleanliness bulletin, the CTU Code, the Joint Industry Guidelines for Cleaning of Containers, and a PowerPoint presentation about carrier conveyance contamination developed by the U.S. NPPO and its border inspection counterpart. CBP. Other ongoing and planned activities under the NASCI initiative are described in a joint U.S./Canada submission to CPM-13 (2018).

The U.S. and the Canadian governments’ approach, stressing cooperation, education and awareness raising, is being applauded by the container supply chain stakeholders as an important and considered initiative in the joint government and industry efforts to minimize pest contamination of containers and their cargoes.  

Pest Contamination Cleaning Guidelines