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1
–Risk and Compliance
Management in the
Chemical supply chain
Radharamanan
Panicker
2
• Hanjin Pennsylvania, freshly delivered by a south
Korean shipyard, set sail to Hamburg (Germany) fully
laded with containers.
• On 11 November 2002, 150 km south of the Sri Lankan
coast, a fire began in the hold.
3
• Containers with phosphorus and fireworks caught fire
and exploded.
• The fire was understood to have started below deck and
the fireworks were supposed to be carried on deck.
• The similarity of the explosions and fire onboard Hanjin
Pennsylvania to CMA Djakarta case
• A commodity known as calcium hypochorite has been
identified as the main cause
4
• March 2006 MV Hyundai Fortune set sale for Europe
from China
• Massive explosion and blaze on board the vessel while
vessel passing through Gulf of Aden
5
6
7 containers with fireworks was believed to be the cause of an
explosion & subsequent blaze on board
Story repeats
• Fire breaks out on 15500 TEU Eugen Maersk
inside a container- 21ST June 2013
– The blaze happened
when the ship was in
the Gulf of Aden
heading from Asia to
Europe
– Fire revives concerns
about misdeclared
cargo
7
It’s dangerous flying
• UPS flight DC-8-70 from Atlanta to Philadelphia on 8th
Feb 2006
• Smoke smelled 23 minutes prior to scheduled landing
• Emergency declared and crew decided to land the
aircraft immediately
• SMOKE/FIRE warning light illuminated 3 minutes prior to
landing.
• Aircraft burst in to flames upon emergency landing in
Philadelphia.
• Crew evacuated through cockpit windows using escape
ropes
• Total hull loss with zero reportable injuries.
• Undeclared Hazardous Material aboard: amyl methyl
ketone and tire repair kits.
Indian Post
• Shipment of 200 sets of Agarbattis loaded
to be loaded on freighter aircraft of Indian
post caught fire on ground- April 2008
• Agarbatti was not what caused the fire.
• Each Agarbatti had one match box
attached to it – One free for every pack
• Match box is class 4.1.
• Friction caused match box to initiate fire
Other Issues
• Cargo Bomb:
– Cargo shipped from Yemen to various airports
in UK and US thru FEDEX
– Disguised Bomb using Printer Toner
• Incidents related to Lithium Batteries
– New guidelines
Risk from Dangerous Goods
• Dangerous goods becomes dangerous
– moment they are spilled or get in contact with
another substance and start reacting.
• Eg - acids (HCL), basic (caustic soda) affect light metals
of which aircraft made
– flammable gases build up extreme explosives
mixtures in combination with air;
Risk from Dangerous Goods
• Sheer amount of dangerous goods shipments
being transported means that there will be
some accidents over a sufficiently long period
of time
– release dangerous goods into the environment
• Environmental disaster
– Can cause exposure to toxic chemical which are
extremely harmful to human health
• Injury or death.
– When happening inside the flying aircraft, it is
catastrophic
• Air France flight from Brazil to Paris
Need for Global Regulation
• Global trade needs uniform and common
standards of regulations
– Multiple country, language, local culture etc
• UN committee of experts classifies all
dangerous goods
– Model Regulation
• Used for developing modal regulations
16
Fundamental Principle of Regulation
• Dangerous goods can be safely
transported provided it is
Classified
Identified
Packed appropriately
Marked and labeled
properly
Documented
“ Shipper”
Basis of Regulation
UN CoE
Recommendation for
transport of DG
Orange book
IAEA
Regulation for
transport of R.M.
TS-R-1
ICAO
T.I For safe transport
of DG by air
ICAO- TI (Legal doc)
IATA
Dangerous Goods
Regulation
DGR
Additional Operators
requirement
UN
Recommendations
(orange book)
IMO ICAO PIPELINE & HAZARDOUS
MATERIALS
SAFETY ADMINISTRATION
IAEA
ST-1 (Radioactive
material)
IMDG Code ICAO-TI 49
CFR
IATA
IATA DGR
Basis of the Regulations
EC
WP15
ADR
Dangerous Goods
1. capable of posing a risk to
Substances or
Articles
Health Safety Property Environment
Dangerous Goods
2. shown in the list of dangerous goods in the
regulations
3. Classified according to 9 classes identified by
UN committee of experts
Why do accidents happen
Human error has been cited as a major cause
of dangerous goods transport incidents.
Deliberate non declaration – possible ?
• Freight cost by both sea and air are higher for
dangerous goods than general cargo
• Non acceptance of Dangerous goods by some
carriers – sea or air causing hardship to exporters
wanting to send their goods.
Why do accidents happen
• Study done by Cargo Incident Notification
System group (CINS) covering a period of
around 18 months to April11
– Cause of accidents
• Poor Packing 30%;
• Misdeclared DG- 24%
– Continent or country
• India- 9%
• Study was to raise awareness of the risks some
people are taking with other people’s lives
23
Analysis by Incident type
Source CINS
46
24
15
6
3 21111
Leakage
Miscelleneous
Others
Fire
Flexitank structural
integrity failure
Explosion
Inspection
Smuggling weapons,
arms etc
Overpressure valve gas
release
Radiological
contamination
24
Analysis by Potential Cause
Source CINS
30
24
17
13
7
5
4 0
Poor packaging
Misdeclaration
Others
Undetermined
Incorrect packing
Incorrect storage
Handling error
Overweight
25
Analysis by Continent
Source: CINS
31
16
9
20
11
13
Europe & US
China
India
Rest of Asia
Africa
Rest of World
26
Risk Mitigation
• Risk mitigation strategies involves
– identifying first by the shipper the nature of
risk posed by their product
– developing appropriate practices in line with
international and national regulations
– ensuring training of all the personnel involved
in the logistics of transporting dangerous
goods.
Is Non compliance an Option
• International and national regulation on transport
of Dangerous goods are mandatory for shippers
to follow
– Packing, marking, labeling, documentation
– Training
• IMDG code is now mandatory for application
• Mandates certain obligatory responsibility on
shippers
28
Is Non compliance an Option
 SHIPPER'S DECLARATION
I hereby declare that the contents of this consignment
are fully and accurately described below by the proper
shipping name, and are classified, packaged, marked
and labelled/placarded and are in all respects in proper
condition for transport according to the applicable
international and national government regulations.
 Shipper’s declaration key document
 Only authorized personnel within the organization should sign it
 Binding organization to future liabilities
29
Is Non compliance an Option
• Non compliance is penal offence and punishable
with huge penalties or imprisonment
• The Pipeline and Hazardous Materials Safety
Administration (PHMSA) of US action on
violation by shippers/forwarders
– 151 cases and 312 tickets of civil penalty actions-
2013
• collection of $1,875,544 in fines.
• In 2005 the total amount was $1.807.789,- FAA penalties not
included
– Two weeks back 3 companies notified with penalties
ranging from USD 50000 to USD 80000 for violation
30
Is Non compliance an Option
• Scope and complexity EH&S compliance fast
becoming a major concern that spans virtually
every industry.
– More and more stringent EH&S regulations
• Reach programme is an example
– Risk and compliance management, including the safe
and proper management and handling of hazardous
materials – a challenge.
• A strong commitment to chemical compliance is
critical.
• The cost of non-compliance
– no longer limited to just fines and penalties or
31
Is Non compliance an Option
• workplace safety of affected employees.
• Compliance and risk increasingly associated
– brand, image, customer loyalty, supported by
performance and trust.
• Age of facebook or social media
• 3M makes it mandatory for their vendors to comply with
Regulatory requirement effective 2012
• New Company Act 2013 makes it obligatory for
declaration to board by key management about
compliance
– Not just financial but all compliance
– Penalty for non compliance severe leading to
reputational loss 32
Can DG handling and compliance
outsourced
• Yes
– Capability of Vendor and willingness to take your risk
– Experienced vendor with deep EHS knowledge and
expertise, as well as one who understands the
intricacies of all phases of the product lifecycle.
• Benefits
– working with a third party provider can greatly simplify
the process and facilitate compliance.
– It helps the company focus on the broader and more
strategic compliance initiatives
– outsourced vendor takes the lead on data collection and
management, regulatory research and administrative
compliance tasks. 33
Responsibility
35
DGM (Dangerous Goods Management Network) is a leading international organization
acknowledged as experts in dangerous goods and hazardous materials.
DGM Company Profile
Founded in 1987, DGM develops comprehensive
dangerous goods solutions to a large variety of
customers of all sectors and industries
DGM guarantees global range of services based
on regulatory knowledge, confidence and
practical experience in compliance with
dangerous goods regulations (ICAO-IATA DGR,
IMDG, ADR, 49 CFR, RID), safety standards and
customer requirements
36
Index
More than 45 locations operating all over the world
Global presence across the 5 continents2014DGMworldwidelocations
Global Presence
37
Corporate PresentationAbout DGM
PRODUCTSTRAININGCONSULTANCY OPERATIONS
Consultancy
Areas of consultancy and advice:
Transport Regulations (Air, Sea, Road,
Rail, Multimodal)
DGSA Dangerous Goods Safety Adviser
DG Audits & Management Systems
(M)SDS & CLP-GHS
Storage of Chemical Products
Security
38
Corporate PresentationAbout DGM
PRODUCTSTRAININGCONSULTANCY OPERATIONS
Operations
DGM provides the following operations
services:
Classification and identification of DGs
Packing and repacking of shipments
Check on packaging specifications and
criteria (UN tested packagings)
Labeling and Marking
Documentation
39
Corporate PresentationAbout DGM
PRODUCTSTRAININGCONSULTANCY OPERATIONS
Training
DGM provides the following operations
services:
IATA Top Ten Accredited Training School
(ATS)” in 2011 and 2012
IATA-DGR, IMO-IMDG, ADR, RID 49 CFR
and Multimodal Trainings
Custom design training solutions
Worldwide trainings
More than 12 languages
40
Corporate PresentationAbout DGM
PRODUCTSTRAININGCONSULTANCY OPERATIONS
Products
DG Materials
Publications
Safety and Security
Software
Explosafe
41
www.dgmindia.in
www.dgmsupport.com
Thank you for your attention
My Contact:
rgpanicker@dgmindia.in

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Risk and Compliance Management in the Chemical supply chain -Radharamanan Panicker

  • 1. 1 –Risk and Compliance Management in the Chemical supply chain Radharamanan Panicker
  • 2. 2 • Hanjin Pennsylvania, freshly delivered by a south Korean shipyard, set sail to Hamburg (Germany) fully laded with containers. • On 11 November 2002, 150 km south of the Sri Lankan coast, a fire began in the hold.
  • 3. 3 • Containers with phosphorus and fireworks caught fire and exploded. • The fire was understood to have started below deck and the fireworks were supposed to be carried on deck. • The similarity of the explosions and fire onboard Hanjin Pennsylvania to CMA Djakarta case • A commodity known as calcium hypochorite has been identified as the main cause
  • 4. 4 • March 2006 MV Hyundai Fortune set sale for Europe from China • Massive explosion and blaze on board the vessel while vessel passing through Gulf of Aden
  • 5. 5
  • 6. 6 7 containers with fireworks was believed to be the cause of an explosion & subsequent blaze on board
  • 7. Story repeats • Fire breaks out on 15500 TEU Eugen Maersk inside a container- 21ST June 2013 – The blaze happened when the ship was in the Gulf of Aden heading from Asia to Europe – Fire revives concerns about misdeclared cargo 7
  • 8. It’s dangerous flying • UPS flight DC-8-70 from Atlanta to Philadelphia on 8th Feb 2006 • Smoke smelled 23 minutes prior to scheduled landing • Emergency declared and crew decided to land the aircraft immediately • SMOKE/FIRE warning light illuminated 3 minutes prior to landing. • Aircraft burst in to flames upon emergency landing in Philadelphia. • Crew evacuated through cockpit windows using escape ropes • Total hull loss with zero reportable injuries. • Undeclared Hazardous Material aboard: amyl methyl ketone and tire repair kits.
  • 9.
  • 10.
  • 11.
  • 12. Indian Post • Shipment of 200 sets of Agarbattis loaded to be loaded on freighter aircraft of Indian post caught fire on ground- April 2008 • Agarbatti was not what caused the fire. • Each Agarbatti had one match box attached to it – One free for every pack • Match box is class 4.1. • Friction caused match box to initiate fire
  • 13. Other Issues • Cargo Bomb: – Cargo shipped from Yemen to various airports in UK and US thru FEDEX – Disguised Bomb using Printer Toner • Incidents related to Lithium Batteries – New guidelines
  • 14. Risk from Dangerous Goods • Dangerous goods becomes dangerous – moment they are spilled or get in contact with another substance and start reacting. • Eg - acids (HCL), basic (caustic soda) affect light metals of which aircraft made – flammable gases build up extreme explosives mixtures in combination with air;
  • 15. Risk from Dangerous Goods • Sheer amount of dangerous goods shipments being transported means that there will be some accidents over a sufficiently long period of time – release dangerous goods into the environment • Environmental disaster – Can cause exposure to toxic chemical which are extremely harmful to human health • Injury or death. – When happening inside the flying aircraft, it is catastrophic • Air France flight from Brazil to Paris
  • 16. Need for Global Regulation • Global trade needs uniform and common standards of regulations – Multiple country, language, local culture etc • UN committee of experts classifies all dangerous goods – Model Regulation • Used for developing modal regulations 16
  • 17. Fundamental Principle of Regulation • Dangerous goods can be safely transported provided it is Classified Identified Packed appropriately Marked and labeled properly Documented “ Shipper”
  • 18. Basis of Regulation UN CoE Recommendation for transport of DG Orange book IAEA Regulation for transport of R.M. TS-R-1 ICAO T.I For safe transport of DG by air ICAO- TI (Legal doc) IATA Dangerous Goods Regulation DGR Additional Operators requirement
  • 19. UN Recommendations (orange book) IMO ICAO PIPELINE & HAZARDOUS MATERIALS SAFETY ADMINISTRATION IAEA ST-1 (Radioactive material) IMDG Code ICAO-TI 49 CFR IATA IATA DGR Basis of the Regulations EC WP15 ADR
  • 20. Dangerous Goods 1. capable of posing a risk to Substances or Articles Health Safety Property Environment
  • 21. Dangerous Goods 2. shown in the list of dangerous goods in the regulations 3. Classified according to 9 classes identified by UN committee of experts
  • 22. Why do accidents happen Human error has been cited as a major cause of dangerous goods transport incidents. Deliberate non declaration – possible ? • Freight cost by both sea and air are higher for dangerous goods than general cargo • Non acceptance of Dangerous goods by some carriers – sea or air causing hardship to exporters wanting to send their goods.
  • 23. Why do accidents happen • Study done by Cargo Incident Notification System group (CINS) covering a period of around 18 months to April11 – Cause of accidents • Poor Packing 30%; • Misdeclared DG- 24% – Continent or country • India- 9% • Study was to raise awareness of the risks some people are taking with other people’s lives 23
  • 24. Analysis by Incident type Source CINS 46 24 15 6 3 21111 Leakage Miscelleneous Others Fire Flexitank structural integrity failure Explosion Inspection Smuggling weapons, arms etc Overpressure valve gas release Radiological contamination 24
  • 25. Analysis by Potential Cause Source CINS 30 24 17 13 7 5 4 0 Poor packaging Misdeclaration Others Undetermined Incorrect packing Incorrect storage Handling error Overweight 25
  • 26. Analysis by Continent Source: CINS 31 16 9 20 11 13 Europe & US China India Rest of Asia Africa Rest of World 26
  • 27. Risk Mitigation • Risk mitigation strategies involves – identifying first by the shipper the nature of risk posed by their product – developing appropriate practices in line with international and national regulations – ensuring training of all the personnel involved in the logistics of transporting dangerous goods.
  • 28. Is Non compliance an Option • International and national regulation on transport of Dangerous goods are mandatory for shippers to follow – Packing, marking, labeling, documentation – Training • IMDG code is now mandatory for application • Mandates certain obligatory responsibility on shippers 28
  • 29. Is Non compliance an Option  SHIPPER'S DECLARATION I hereby declare that the contents of this consignment are fully and accurately described below by the proper shipping name, and are classified, packaged, marked and labelled/placarded and are in all respects in proper condition for transport according to the applicable international and national government regulations.  Shipper’s declaration key document  Only authorized personnel within the organization should sign it  Binding organization to future liabilities 29
  • 30. Is Non compliance an Option • Non compliance is penal offence and punishable with huge penalties or imprisonment • The Pipeline and Hazardous Materials Safety Administration (PHMSA) of US action on violation by shippers/forwarders – 151 cases and 312 tickets of civil penalty actions- 2013 • collection of $1,875,544 in fines. • In 2005 the total amount was $1.807.789,- FAA penalties not included – Two weeks back 3 companies notified with penalties ranging from USD 50000 to USD 80000 for violation 30
  • 31. Is Non compliance an Option • Scope and complexity EH&S compliance fast becoming a major concern that spans virtually every industry. – More and more stringent EH&S regulations • Reach programme is an example – Risk and compliance management, including the safe and proper management and handling of hazardous materials – a challenge. • A strong commitment to chemical compliance is critical. • The cost of non-compliance – no longer limited to just fines and penalties or 31
  • 32. Is Non compliance an Option • workplace safety of affected employees. • Compliance and risk increasingly associated – brand, image, customer loyalty, supported by performance and trust. • Age of facebook or social media • 3M makes it mandatory for their vendors to comply with Regulatory requirement effective 2012 • New Company Act 2013 makes it obligatory for declaration to board by key management about compliance – Not just financial but all compliance – Penalty for non compliance severe leading to reputational loss 32
  • 33. Can DG handling and compliance outsourced • Yes – Capability of Vendor and willingness to take your risk – Experienced vendor with deep EHS knowledge and expertise, as well as one who understands the intricacies of all phases of the product lifecycle. • Benefits – working with a third party provider can greatly simplify the process and facilitate compliance. – It helps the company focus on the broader and more strategic compliance initiatives – outsourced vendor takes the lead on data collection and management, regulatory research and administrative compliance tasks. 33
  • 35. 35 DGM (Dangerous Goods Management Network) is a leading international organization acknowledged as experts in dangerous goods and hazardous materials. DGM Company Profile Founded in 1987, DGM develops comprehensive dangerous goods solutions to a large variety of customers of all sectors and industries DGM guarantees global range of services based on regulatory knowledge, confidence and practical experience in compliance with dangerous goods regulations (ICAO-IATA DGR, IMDG, ADR, 49 CFR, RID), safety standards and customer requirements
  • 36. 36 Index More than 45 locations operating all over the world Global presence across the 5 continents2014DGMworldwidelocations Global Presence
  • 37. 37 Corporate PresentationAbout DGM PRODUCTSTRAININGCONSULTANCY OPERATIONS Consultancy Areas of consultancy and advice: Transport Regulations (Air, Sea, Road, Rail, Multimodal) DGSA Dangerous Goods Safety Adviser DG Audits & Management Systems (M)SDS & CLP-GHS Storage of Chemical Products Security
  • 38. 38 Corporate PresentationAbout DGM PRODUCTSTRAININGCONSULTANCY OPERATIONS Operations DGM provides the following operations services: Classification and identification of DGs Packing and repacking of shipments Check on packaging specifications and criteria (UN tested packagings) Labeling and Marking Documentation
  • 39. 39 Corporate PresentationAbout DGM PRODUCTSTRAININGCONSULTANCY OPERATIONS Training DGM provides the following operations services: IATA Top Ten Accredited Training School (ATS)” in 2011 and 2012 IATA-DGR, IMO-IMDG, ADR, RID 49 CFR and Multimodal Trainings Custom design training solutions Worldwide trainings More than 12 languages
  • 40. 40 Corporate PresentationAbout DGM PRODUCTSTRAININGCONSULTANCY OPERATIONS Products DG Materials Publications Safety and Security Software Explosafe
  • 41. 41 www.dgmindia.in www.dgmsupport.com Thank you for your attention My Contact: rgpanicker@dgmindia.in