Loss Prevention Advice
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INTRODUCTION
The transportation of military cargo by sea is an operation that requires meticulous planning and a robust understanding of regulatory frameworks, safety standards and security protocols. In an era of geopolitical tensions and increased demand for defence logistics, moving military goods – ranging from small arms ammunition and riot control agents to armoured vehicles and explosive ordnance – presents challenges far beyond those of ordinary commercial shipments. At the core of this process lies the International Maritime Dangerous Goods (IMDG) Code, developed by the International Maritime Organization (IMO). Though often treated as a compliance checklist, the IMDG Code is, in practice, a living document that sets the standard for maritime safety and risk management when dealing with hazardous cargoes, including military consignments.
SANCTIONS, EXPORT CONTROLS AND DUE DILIGENCE
In addition to operational hazards, shipping military cargo involves navigating a complex web of international sanctions and export controls. Many defence-related items are subject to restrictions under UN Security Council Resolutions, European Union regulations, or the laws of individual states such as the United States’ Office of Foreign Assets Control (OFAC). Operators are obliged to screen shippers, consignees and any intermediaries against relevant sanctions lists. Failing to do so can result in severe consequences, including seizure of the cargo, suspension of trading licenses, and the loss of protection and indemnity (P&I) insurance coverage. This article does not cover the necessary screening and sanction checks required, and it is therefore prudent to seek legal advice from counsel experienced in sanctions compliance before proceeding.
Full advisory at the following link.
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Highlighting incidents of concern regarding coal shipments from the north-east Coast of the United States (US), based on Marine Safety Alert 07-25 issued by the US Coast Guard (USCG).
On occasion, coal loaded from ports on the north-east coast of the US has shown methane (CH₄) readings in cargo holds exceeding 20% of the Lower Explosive Limit (LEL) during voyages, even when the shipper’s cargo declaration did not indicate that the cargo was liable to emit methane.
According to the IMSBC Code Schedule for Coal, the shipper shall provide in writing the characteristics of the cargo, especially whether the cargo is liable to emit methane.
Full advisory at the following link.
https://britanniapandi.com/wp-content/uploads/2025/10/Coals-Emitting-Methane-Update.pdf
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This circular is to draw attention to incidents of concern regarding shipments of coal from North-East Coast USA. Incidents have involved explosions resulting in the displacement/removal of hatch covers.
The US Coast Guard issued a Marine Safety Alert in February 2025 highlighting some of the issues: (https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/CG-5PC/INV/Alerts/USCGSA_0725.pdf)
The issues are complex, and incidents remain under investigation. This circular is not therefore intended to provide views or guidance on issues arising in the USCG alert. The purpose of this circular is to raise awareness given the potential for harm to people and the environment. It is also to recommend that members contact their Clubs if they plan to fix or charter a ship to load coal from the North-East Coast USA, or where under an existing fixture a ship is ordered to load such cargo.
This will enable the Underwriters to provide Members with relevant information to understand and manage the risks. Given the complexities this may involve a recommendation that members seek expert advice.
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Key recommendations regarding the identification, management, and mitigation of both temporary and permanent hazards onboard ships to prevent slips, trips, and falls.
There is a distinction between temporary or operational hazards, and those that are permanent or exist by nature of the ship’s structures or arrangements. However, for both, early identification and subsequent action to make these hazards safe are key.
Temporary hazards – mitigate and remove promptly
Temporary hazards should ideally be identified during the work planning and risk assessment processes. Constant vigilance from all personnel, along with adequate work equipment and safe work procedures are also required to reduce the risk. This is particularly important during periods such as dry dock, when many hazards may be present simultaneously.
Slipping hazards are generally the results of leakage, spillage or poor housekeeping. Effective preventative measures include adequate maintenance, good operational practices and regular cleaning. Ongoing cleaning (not just upon completion of a task) during maintenance and other work can be overlooked but is vitally important to keep the workplace safe. No one should enter a machinery space without proper personal protective equipment, regardless of the task being carried out or the length of time inside.