Prepare for new rules on container cleanliness

During the past two years, the issue of invasive, damaging pest species being inadvertently transferred between countries by global goods shipments has risen higher up the agenda.

Invasive species that migrate from one location to another can lead to the extinction of plants and animals, reduce biodiversity, and cause irreversible change to native habitats. A September 2023 report by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services puts the global costs to society at USC423bn every year.

The report also assesses existing measures to limit the transfer of pests through international sea trade as ‘poorly managed’. Some governments and shipping authorities, including the World Shipping Council (WSC), have already called for regulations to tighten current rules on container cleanliness; accordingly, a change is increasingly likely.

This may include the introduction of measures ranging in severity from the drafting of straightforward voluntary guidelines to the introduction of a new International Standards for Phytosanitary Measures process – like that currently in force for international movements of wood – that will impose strict rules for cleanliness, loading standards, and a declaration of cleanliness from the shipper/loader for every container dispatched. Most agree that some kind of change is inevitable, and will increase the cost of shipping as a result.

With around 250 million container movements around the world every year, it is critical that any new laws imposed mitigate the risk of pest infestations, but are proportional and reasonable to the impact on shipping and related industries.

The international removal and relocation industry became actively involved in this issue more than two years ago, when FIDI and IAM agreed to work together to represent the interests of the sector with a single coordinated voice. They published a joint statement on their position in December 2021.

The Australian International Movers Association (AIMA) introduced them to the Global Shippers Forum (GSF), which had been representing its own membership on this issue and become part of the international taskforce set up by International Plant Protection Convention (IPPC). The associations have been working closely together on a resolution.

A moderate stance
FIDI Secretary General Jesse van Sas says: FIDI and IAM have jointly agreed to support the GSF’s moderate stance on this issue, calling for voluntary, rather than mandatory, measures to reduce the transfer of pests throughout the supply chain and container pathway process, and advocating for a simplified version of the principle of ‘custodial responsibility’ (which requires each stakeholder in the supply chain to inspect and clean the container before passing the box on to the next stakeholder).

This should focus on pest-preventing actions at the origin of a shipment (‘bugs should remain at home’) and be supported with communications to ensure all stakeholders understand the risks associated with moving invasive pests.

It’s important that these measures should not hold legal liability for any company in the broader shipping community as many of the IPPC member countries may choose to adopt regulations based on the final CPM [Commission on Phytosanitary Measures] guidelines, which are expected to be issued in 2024.
IAM President Brian Limperopulos says: ‘We are grateful to the Global Shipping Forum for its leadership and coordination on this issue. Due to the complexities of the shipping industry, there is no one-size-fits-all approach that can work for all stakeholders, but each group can do their part to prevent the spread of pests in sea containers.’

According to AIMA Chairman Philip Gordon, as the WSC – which represents 95 per cent of shipping companies – is ‘hoping to see an outcome where shipping lines and container owners are not required to do anything to contribute to resolution of the problem’, finding consensus between different parties on this issue hasn’t always been straightforward.

‘This is not a simple matter, and trying to get agreement from multiple countries and other interested parties is a really tough ask,’ he says. ‘Shipping lines have a vested interest in keeping the status quo and many countries have their own issues they wish to have recognised, too.’

Gordon adds that, while only a handful of countries are driving for tougher legislation, even a local or regional change will impact on shippers, because they are operating internationally.

A need for PR
James Hookham, Director of the GSF, says the organisations believe the most effective way forward is by conducting an extensive publicity campaign to alert shippers and other parties in the supply chain to this issue, and the relatively simple things they can do to significantly cut the risk of transfer.

‘We are advocating for a step-up in awareness programmes and the promotion of custodial responsibility, which requires each party having possession of a container (shipper, port, terminal, carrier, etc) to ensure it is, and remains, free of pest contamination. For a shipper to do that they need the assurance that the empty container they are packing is ‘pest free’ and we have asked the shipping industry to make more information available to container users about which countries an empty container has recently visited, when it was last washed and disinfected, and whether it has carried cargoes at high risk of containing pests.’

Gordon says, for a voluntary system to work, ‘we all need to accept that, at some time, we will receive a container that is contaminated in some way’. He advocates a simple system, within which container users log performance scores that are kept on record and available to all users. ‘If the score from one party falls too low, there needs to be a code for how that party will rectify their position,’ he says.

It is not practical or realistic to expect shippers to return clean containers every time, as it would take time and incur cost. Instead, says Gordon, a voluntary points- based scheme would see container users giving a black mark to shipping lines for providing a dirty container (verifying this with photos). Pushing back on shipping lines to request they pay for cleaning is likely to backfire, he adds, as this ‘would only result in them increasing their charges to offset the likelihood of this in the future – a lose-lose outcome’.

Tech solutions
Technological innovation is likely to feature in future solutions, Gordon says. In Australia and New Zealand, for example, tests are being pioneered that can detect brown marmorated stink bugs using DNA/RNA testing from a sniffer device placed inside the doors of a container at origin, and allowing direct targeting for treatment of the affected containers.

Thanks to the IAM/FIDI/GSF collaboration, the IPPC set up the Container Cleanliness Industry Advisory Group, with FIDI’s Secretary General, Jesse van Sas, and Boris Populoh, of IAM, representing the removal and relocation industry. The GSF has also set up a working group representing a range of industries to define a joint strategy and actions, which FIDI and IAM have both joined.

The two moving associations attended 2022 and 2023 IPPC workshops for national plant protection organisations from around the world and the IPPC working group charged with preparing and writing official recommendations. This was to support the GSF and explain the role of international movers in global supply chains. Proposals at these workshops have included:

• Moving from wooden floors in containers to steel and composite floors
• Focusing on custodial responsibility for cleanliness, with each stakeholder required to inspect and clean the container before passing it on to the new user in the supply chain
• Publication of data online, allowing shippers to evaluate risk by seeing the history for each container, including where it has travelled, when it was last cleaned, and how it was cleaned
• Developing new technology, such as ‘smart containers’, to help facilitate the changes.
• The upshot of the collaborative work to date has been a softening of initial proposals, which includes withdrawing the need for verified pest prevention declarations, initially requested by the WSC, and inclusion of a carrier’s responsibility for container cleanliness in the final draft of custodial responsibility recommendations.

A final decision
The IPPC launched an open call for feedback on the final draft to the CPM Recommendations for Minimising Pest Risk Associated with the Sea Container Pathway by the end of September 2023. FIDI and the IAM, with the input of AIMA and the GSF, made a joint submission.

As this issue of FIDI Focus went to press, the CPM Focus Group on Sea Containers was scheduled to consider the responses before reaching conclusions by the end of the year. It will present a revised version of the draft CPM recommendations for adoption to the plenary CPM meeting in April 2024 (CPM-18).

Hookham says: ‘So far, we have been successful in persuading a CPM working group to take a proportionate approach – but the crunch comes in April.’

The measures introduced may be compulsory or voluntary, or a mixture of both. FIDI will report back to Affiliates with key developments as they happen.

‘In the meantime, we should encourage all our staff to be more vigilant around the issue of pests,’ says Gordon. ‘We need to develop a culture of checking before loading a container, to ensure it is free from pests or evidence of pest, and then, while loading, we should be on the lookout for pests.

‘The hard part is that, at origin, the pests are often just insects you are familiar with – but you need to realise that they may not live where the goods are going and, as such, need to be dealt with. There are many species of ants, for instance, that are very invasive and have not taken hold in other countries, so they should not be allowed to go into the container with your loads.’

He adds that most in the supply chain expect that change of one form or another is now inevitable. ‘The momentum is too great to think that nothing will happen regarding the matter of cleanliness of containers and, at some stage in the not-too-distant future, we will all need to make some changes in our processes to do our bit to minimise the risk to other countries.’

FIDI has published a text and video resource page on FIDINET, available to all FIDI Affiliates and featuring more information and best practices on this important topic. See: fidinet.fidi.org/resource-pages/ pest-contamination.

Please check past issues of FIDI Focus and visit www.fidifocus.org for more information. For any further questions, contact Marie-Pascale Frix at: Marie-Pascale.Frix@fidi.org

Best practice from FIDI’s PCGs

Each booker, origin and destination agent has a role to play in mitigating contamination and infestation in an international move process.

The FIDI Professional Cooperation Guidelines (PCGs) provide best-practice guidance and advice on how to prevent contamination/infestation at origin and at destination. These include:

Preventative actions at origin:

1. Verify the cargo-worthiness of the conveying container before loading the consignment.
   Containers provided by the ocean-carrier/shipping company or third-party vehicle for conveyance of the consignment must be inspected and certified by the origin agent. They must be confirmed as internally clean, dry, and wind/ watertight – free of any contamination, wet damage or dampness, physical damage, rust deterioration, holes and/or damaged or worn rubber door seals.
   Any container or vehicle that does not satisfy these conditions should be considered as not ‘fit for purpose’ – and not used.
2. Do not proceed with loading if the container, truck or case is damaged, wet, damp or contaminated.
3. Take a photograph of the damage or contamination.

Preventative actions at destination:

1. Verify the cargo-worthiness of the container at the point it comes into your care.
2. Before removing the seal and unloading, record the external condition of the container and note any damage, fault, or contamination.
3. On completion of unloading, examine and record the internal condition of the container to verify its condition as clean, and wind and watertight.
4. Take any photographs of damage and/ or contamination.
5. Report any discrepancy to the booker, shipping line agent or carrier immediately.
6. Note any visible contamination at the unloading and unpacking stages.

Actions in the event of contamination and/or infestation
If the consignment shows either visual presence of mould and/or mildew, or associated wet damage, damp or fungal odour suggesting mould or mildew contamination, or any other contamination or infestation, it is important to act quickly and decisively. If discovered at the time of handling the consignment, the following steps must be followed by the applicable handling agent:

1. If mould and/or mildew contamination is present on the goods at origin place of collection, the origin packing team must not proceed with packing or loading and/or removal of the affected goods from residence until a further response/ course of action has been agreed with the transferee and approved by the booker.
2. If mould and/or mildew contamination is discovered or suspected to be substantially present on the goods before delivery into the transferee’s residence – for example, when opening and/or unstowing goods from the sea-container, liftvan or case, or when removing the packaging material or unpacking contents from cartons – the destination/ delivery agent must immediately halt the delivery and unpacking service until a further response/course of action has been agreed with the transferee and approved by the booker.
3. 
   The agent handling the consignment must inform the transferee of the presence or suspected presence of mould or mildew contaminated goods, and explain that they are required to isolate the consignment pending further instructions (from the booker).
4. Contact the booker immediately (before proceeding any further), to agree upon an appropriate response; or (see below).
5. If, because of time zone/business hours difference, the booker is not immediately available to agree an appropriate response, the agent handling the consignment should take the following immediate precautionary steps in the interest of the transferee and the booker:
   1) Do not continue to deliver into the transferee’s residence any goods that are contaminated by mould or mildew (or strongly suspected of contamination).
   2) Do not leave any contaminated goods or packages in situ at the transferee’s residence; immediately and carefully remove (to outside) any actual or suspected contaminated goods
   (that may have) already been taken inside the residence.
   3) Secure all contaminated goods, where possible by stowing back into the original container, liftvan or case, ready for removal from site, or otherwise safely isolate the items away from the transferee’s residence and return the contaminated consignment to the handling agents’ warehouse, pending further instructions from the booker.

FIDI PCGs best practice guidance can be downloaded from FIDINET.