De-mystifying hazardous fees imposed by shipping lines for POVs (Personally Owned Vehicles)

September 29, 2023

Many thanks to Allyson Nordstrom-Geraghty at Arpin for passing on this explanation of how hazmat fees work.

Question: 1)What extra precautions does the steamship line take when booking as a hazardous fee? And 2) If they charge a hazardous fee, is it a special vessel, just wondering what you get for the extra charge?

 

  • “Hazmat fees” or a hazmat booking fee/surcharge is a charge paid to help a hazmat-related company (e.g., steamship line) cover costs related to their compliance with hazmat safety standard (properly declaring vs mis declaring cargo).  The goal is having the container properly declared and safely loaded/stowed aboard a vessel as it pertains to both the IMDG code and the CFR.  (The International Maritime Dangerous Goods (IMDG) Code & The Code of Federal Regulations)

 

  • Hazmat bookings involve extra people at the line when bookings are made – working with both the line’s traditional booking team, but also, the line’s hazmat team, which is specifically trained in the IMDG code (and is likely required to renew their training every 2-3 years to be able to ultimately approve the booking under the IMDG code and the line’s individual requirements).  Everyone handling hazmat/DG, including me, is required to keep an active training certificate on file that must be renewed every few years (this is also stated in the IMDG and CFR).

 

  • The fee is also associated with the lines having to do extra leg work to ensure they’ve notified the trans-shipment ports of transit that their vessel contains hazmat (so the local port operators in the host country/countries are made aware when they’re loading from one vessel to the next.  At times, depending on the routing in place, the line may have to re-do the routing because a certain port in rotation doesn’t allow for the trans-shipment of hazmat/DG (this has happened to us a few times already – a good example is the Port of Piraeus).  It can also be attributed to partner vessels they may “ship share” routes with (before or after the US flag leg) that may not allow hazmat on their vessels in these situations.  

 

  • The loadmasters of the vessel must take special care when it comes to hazmat/DG FCL containers and their load plans – depending on the hazardous class, containers are often required to be placed on different decks (closer to the open/top deck or even on the open decks) to ensure they are following IMDG/SOLAS and their own internal requirements (Safety Of Life At Seas, which is part of the entire UN treaty within the International Maritime Organization).  Certain UN declarations based on class and code, require very specific instructions and placement. 

 

  • Specific to booking vehicles as hazmat/DG – there are a set of CTU’s that we’re required to follow when it’s specifically declared as such.  It involves extra lashing/blocking/bracing, and in general, education, to ensure that the hazmat POV is properly “contained” for safe transport.

 

  • There’s also the extra liability and added risk - if a line is agreeing to transport hazmat/DG.  While the IMDG code takes every precaution to instruct on how to handle/pack/load/transport hazmat/DG, at the end of the day, we’re all still transporting a specific class of dangerous goods (there are a total of nine classes).  Dangerous goods can be unpredictable and there’s always a risk involved when transporting them – we all take on that risk.