Batteries – SP188 Exemptions in Containerized Transport

In containerized transport of batteries, there is a significant safety gap wherein multiple batteries, each of which is individually exempt under Special Provision (SP) 188, are loaded within the same cargo transport unit (CTU). Owing to a lack of hazard communication, these shipments are treated as general cargo during transport despite the elevated hazard profile within the CTU. This safety gap has led to safety and fire incidents in maritime transport, a typical example of which is shown in a formal investigation report cited within this document. The existing gap poses wider implications for all involved, including ports, coastal States, seafarers, ships and the marine environment.

This document informs that a potential regulatory solution has been tabled at the SCETDG sixty-eighth session owing to the intermodal nature of SP188. In conclusion, CCC 12 is invited to consider this issue from the maritime perspective as a matter of urgency, with a view to improving the regulation within the next amendment (44-28) to the IMDG Code, which enters into force mandatorily on 1 January 2030, and hence follow a dual approach as specified in the action to be taken.

Read the full submission here.