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IMDG has tightened the transport conditions for the dangerous goods charcoal

In the seven years between 2015 and 2022, at least 68 fires were documented on ships that were caused by the transportation of charcoal. The International Maritime Organization (IMO) has now reacted and made important changes to the IMDG Code. In future, charcoal must be declared and transported as class 4.2 dangerous goods without exception. At the same time, the “CINS (Cargo Incident Notification System)”, together with the “International Group of P& I Clubs” and the “TT Club”, has published “Guidelines for the safe transportation of charcoal in containers”.

Cause of charcoal fires - often caused by misdeclaration and incorrect transportation conditions

A well-known example is the incident on the Yantian Express, on which a fire was started in January 2019, presumably by falsely declared charcoal. In the middle of the North Atlantic, a fire suddenly broke out on the deck above hold 9 on the container ship in winds of between 8 and 9. After the breathing air cylinders on board were exhausted, the crew had to stop active extinguishing work. It was not until the evening of the next day that an ocean-going tugboat that had been brought in brought further help from outside. However, the fire continued to spread and the crew was evacuated. After eleven days, a team of professional firefighters arrived and it took another six days to bring the fire under control. The last source of the fire below deck was only extinguished on January 26 – more than three weeks after the fire broke out. Investigations revealed that pyrocarbon cubes had apparently ignited themselves. Self-ignition can occur with this material at temperatures as low as 50 degrees Celsius. The goods had presumably been incorrectly declared.(Source)

The fire on the Sea Voyger in 2022 was less serious. The cargo ship was on its way from Malaysia to Europe when misdeclared charcoal ignited in the cargo hold. The cargo was insufficiently ventilated and the charcoal began to heat up during the voyage. Due to the high ambient temperatures and inadequate ventilation, the temperature of the charcoal rose above the critical point. The crew reacted quickly by flooding the affected cargo hold and thus containing the fire. The ship returned to the nearest port, where the cargo was safely unloaded and the damage assessed.

There was a fire on the “Ocean Star” in 2021 after charcoal, which was declared as normal cargo, caught fire during transportation. The charcoal was stored near heat sources, which accelerated the spontaneous combustion process. This fire was also caused by the inadequate ventilation and was aggravated by the proximity to hot machinery, which increased the temperature of the charcoal. Thanks to the quick reaction of the crew, the fire was controlled and extinguished before it spread further.

What makes charcoal so dangerous?

The transportation of charcoal poses considerable risks, particularly due to its tendency to self-heating. This property can lead to fires if the charcoal is transported in containers or closed holds. During the transport phases, it is possible that the temperature may rise due to inadequate ventilation or incorrect storage, which promotes self-heating. If a certain temperature is exceeded (around 50-60°C depending on the charcoal), the exothermic reaction can be accelerated, which can lead to spontaneous combustion.

This situation is exacerbated by the susceptibility to oxidation, which generates more heat than can be dissipated by natural cooling. The porous structure of charcoal facilitates oxygen absorption, which leads to slowly progressive oxidation. The oxidation process of carbon in charcoal releases heat. If this heat is not dissipated sufficiently, the temperature of the charcoal continues to rise.

There are four factors that significantly increase the risk of charcoal spontaneously combusting during transportation:

  • High ambient temperatures accelerate the oxidation process and increase the risk of spontaneous combustion.
  • Moisture can increase the conductivity for heat and favor the reaction.
  • Closed containers or poorly ventilated holds prevent the dissipation of heat, which increases the risk of self-heating.
  • Impurities or mixing with other flammable materials can increase reactivity.

This is why the correct declaration of charcoal is so important to ensure safe stowage for transportation. Incorrectly declared or inadequately packaged charcoal increases the risk considerably.

The new IMDG requirements for charcoal

From January 1, 2025, an important amendment to the International Maritime Dangerous Goods (IMDG) Code (Amendment 42-24) will come into force, which will become binding from 2026. This states that charcoal must be declared and transported as dangerous goods without exception. The IMDG Code classifies charcoal as a self-igniting substance in dangerous goods class 4.2. These changes are aimed at increasing safety when transporting charcoal and preventing fires. The main changes:
  • Charcoal must be declared as dangerous goods without exception.
  • Correct packaging and adequate ventilation during transportation are essential.
  • Specific documentation such as safety data sheets and auto-ignition certificates must be submitted.

The impact on the logistics industry is obvious:
  • The stricter regulations lead to additional costs for declaration, packaging and transportation, which can result in higher costs.
  • Companies must adapt their logistics processes to the new security standards.
  • In the long term, these changes will significantly reduce the risk of fires and accidents, which will improve safety for ships, crews and cargo.

Which substances are affected by the new requirements?

Charcoal is a collective term for numerous quite different materials. For the purposes of hazardous substance regulations and the IMDG Code, charcoal is defined as a self-igniting substance that tends to heat up on contact with air. This also includes specific forms such as barbecue charcoal, shisha charcoal or nargila charcoal, which have been more frequently involved in fires in the past. Different trade names can disguise the true nature of the load, which makes correct declaration all the more important. Coal scrap, coal dust and fine coal are also affected by the regulations.

Important precautions for charcoal transporters

Even though the new IMDG regulations have already been adopted and published, they will not become binding until January 1, 2026. The industry should have time to adapt to these new regulations. However, misdeclaration of goods has always been strictly prohibited. Safety in logistics should always be a top priority – out of concern for the people who transport our goods and out of concern for our environment.

The “Guidelines for the Safe Carriage of Charcoal in Containers”, version 1.00 of which was published by CINS and can be downloaded free of charge here, contain extensive information on the safe transportation of charcoal in containers.

The new regulations of the IMDG Code are an important step towards greater safety in the logistics chain. That is why we at Leschaco emphatically welcome the new IMDG regulations.

Cover illustration: © Sergey Ilin – stock.adobe.com

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