Introduction
The CTU Code outlines various parties' roles and responsibilities regarding the packing,
storage, handling and transport of CTUs.
Companies causing CTUs to be transported would want to be assured that the activities
undertaken by a service provider are carried out in compliance with international and
national regulatory frameworks, and conform with the CTU Code. It should be noted that
this document applies to international traffic and users of this document should be
aware that national regulations may also apply.
The following example of a due diligence checklist for the provision of packing services
is intended to serve as a guide to what companies causing CTUs to be transported in
maritime traffic should consider when selecting a provider of CTU-related services
(hereinafter referred to as "the Provider").footnote The checklist may be modified to reflect the roles and
responsibilities of other service providers, as described in the annex.
1 Provider name and contact details
Examples of additional information elements that might be requested of the Provider:
- Main activity of company
- Number of employees
- Key personnel and responsibilities
- Services offered
- Membership of professional associations
- Public listing
2 Certificationfootnote
2.1 Is the Provider certified to a quality management system (e.g. ISO 9000) or other
externally audited programmes (e.g. Authorized Economic Operator (AEO))? If "yes", for
which standards and/or programmes has certification been obtained? Is confirmation of
the certification publicly available on websites or are certificates available?
2.2 When was the Provider's compliance with the applicable standards and/or programmes
last audited?
2.3 Is the Provider working towards certification? If "yes", certification to which
standards and/or programmes and by when? If "no", does the Provider have any written
procedures?
3 Written procedures
3.1 Does the Provider have written procedures covering the services to be provided,
including for the detection and reporting of non-compliance with prevailing regulatory
requirements?
3.2 Does the Provider have written procedures to ensure that any equipment required and
used in the services to be provided is maintained and calibrated in accordance with
prevailing regulatory requirements?
4 Packing CTUs
(Note: The following points only apply to service provider involved in packing
CTUs.)
Does the Provider have a copy of the CTU Code and access to the Informative Material?
4.1 Does the Provider have planning procedures to ensure the correct packing and
securing of the CTU?
4.2 Are employees and any subcontractors of the Provider trained in accordance with the
CTU Code?
4.3 Does the Provider maintain training records? In what form are the records maintained
and accessible?
4.4 Is there a designated person responsible for ensuring compliance with the CTU Code
and, if appropriate, other related IMO codes and conventions?
5 Dangerous goods
(Note: The following points only apply for shipments that include dangerous
goods to be packed into and transported in CTUs in maritime traffic. Other modes of
transport will be regulated through the national or international regulations.)
5.1 Does the Provider have a copy of a currently valid amendment to the IMDG Code?
5.2 Are employees and any subcontractors of the Provider trained in accordance with
chapter 1.3 of the IMDG Code?
5.3 Does the Provider maintain training records? In what form are the records maintained
and accessible?
6 General health and safety
Does the Provider have documented health and safety procedures?
7 Supply chain management and sub-contracting
7.1 Has the Provider documented procedures for maintaining CTU integrity?
7.2 Are security measures applied in accordance with the role of the Provider in the CTU
supply chain?
7.3 Are these security measures documented in verifiable records?
7.4 Does the Provider use subcontractors?
7.5 Are sub-contractors selected and assessed in accordance with written procedures?
7.6 Are contractual agreements in place with the sub-contractors used by the Provider?
Annex – Table of the Roles of Entities Involved In the Cargo Transport Unit (CTU)
Supply Chain
The CTU Code and other industry specific guidance documents and enforcement activities
have an important part to play in CTU supply chain safety. Entities involved with this
supply chain are reminded of their roles and how they can effect a culture change,
promoting the safety of workers and third parties while maintaining the integrity of the
cargo.
The table below outlines the various functions in the CTU supply chain that can effect a
culture change. Due to the complexity of the supply chain one or more of the functions
listed in 1 to 1d of the table may be performed by the same entity/party.
Bringing about a culture change in the supply chain requires not only fulfilment of
individual functions but also encouraging all other functions to fulfil their
responsibilities appropriately.
Note: The definitions of functions 1 to 6 of the table are reproduced
from the CTU Code.
Order
|
Function
|
Definition
|
Role in effecting a culture change within the supply
chain
|
Aid
|
1
|
Shipper
|
The party named on the bill of lading or waybill as shipper and/or who
(or in whose name or on whose behalf) a contract of carriage has been
concluded with a carrier. Also known as the sender.
|
Ensure staff and those parties with whom the shipper interacts (e.g. 1a,
1b, 1c and 1d below) are trained, aware of, and use the CTU Code.
|
The CTU Code should be available and easily accessible to staff.
Identify cargo types (e.g. Case study of how to pack steel / bananas,
etc.) prepared by the shipper for easy reference to other supply chain
parties.
Utilize due diligence checklists.
|
1a
|
Consignor
|
The party who prepares a consignment for transport. If the consignor
contracts the transport operation with the carrier, the consignor will
undertake the function of the shipper and may also be known as:
- the shipper (maritime)
- the sender (road transport)
|
Ensure the consignment complies with appropriate Regulations for the
journey to be undertaken
If the consignor contracts the packer: ensure due
diligence checks are carried out on the packer and that the packer has
all the appropriate resources (e.g. material and competent personnel) to
enable tasks to be fulfilled to the required standard.
|
Utilize due diligence checklist.
|
1b
|
Consolidator
|
The party performing a consolidation service for others.
|
Ensure customers are informed of best practice and raise awareness,
(e.g. where packaging deficiencies are noted).
If the consolidator
contracts the packer: ensure due diligence checks are carried out on the
packer and that the packer has all the appropriate resources (e.g.
material and competent personnel) to enable tasks to be fulfilled to the
required standard.
|
The CTU Code should be available and easily accessible to
staff.
Utilize due diligence checklist.
|
1c
|
Freight forwarder
|
The party who organizes shipments for individuals or other companies and
may also act as a carrier. When the freight forwarder is not acting as a
carrier, it acts only as an agent, in other words as a third-party logistics
provider who dispatches shipments via carriers and that books or otherwise
arranges space for these shipments
|
Ensure customers are informed of best practice and raise awareness of
the CTU Code.
|
Advise customers of the CTU Code (e.g. through using note on booking /
quotation forms "See CTU Code").
Record problems and advise customers
accordingly.
|
1d
|
Packer
|
The party that places the goods within the CTU. The packer may be
contracted either by the consignor, by the shipper or by the carrier. If the
consignor or the shipper packs a CTU within his own premises, the consignor
or the shipper is also the packer
|
Management should identify the types of cargo, assess level of training
required, and audit effectiveness of training.
Ensure the packer has all
the appropriate resources (e.g. material and competent personnel) to
enable tasks to be fulfilled to the required standard.
Operational
staff should follow training, make management aware of problems, ensure
guidance is available if necessary for unusual cargoes.
|
The CTU Code should be available or easily accessible to
staff.
Identify cargo types (e.g. Case study of how to pack steel /
bananas, etc. etc.) prepared by manager or supervisor.
|
2
|
CTU Operator
|
The party who owns or operates the CTU and provides empty CTUs to the
consignor / shipper / packer.
|
Ensure customers are informed of best practice and raise awareness of
working with CTUs in general.
Ensure CTUs to be supplied are fit for
purpose.
Ensure customers are advised of their
responsibilities/liabilities if CTU is returned damaged.
|
CTU Code, CSC 1972, and other applicable codes, conventions and
standards are available and easily accessible.
|
3
|
Carrier
|
The party who, in a contract of carriage, undertakes to perform or to
procure the performance of carriage by rail, road, sea, air, inland waterway
or by a combination of such modes.
Can be further classified as:
- road haulier
- rail operator
- shipping line
|
Inform customers of best practice and raise awareness.
|
Advise customers of CTU Code (e.g. through using note on booking /
quotation forms such as "See CTU Code").
Inform customers of availability
of the due diligence checklist.
|
4
|
Intermodal operator
|
The party who provides a service to transfer and/or stow CTUs. May be
subdivided into:
- Maritime terminal (port) operator
- Rail terminal
- Inland waterway port
|
Ensure customers are informed of best practice and raise
awareness
|
CTU Code and similar best practice guidance materials from trade
associations and mode specialists, for rail/water/road to be available to
staff for guidance
|
5
|
Consignee
|
The party to whom a cargo is consigned under a contract of carriage or a
transport document or electronic transport record. Also known as the
receiver.
|
Make sure to report all problems in connection with the receipt of the
CTU and/or its cargo to the shipper, the CTU operator and the carrier as
appropriate.
Implement appropriate training in accordance with the CTU
Code and procedures for unpacking CTUs taking into account particular
hazards associated with opening and entering the CTU.
|
Implement suitable feedback procedures which may include taking
photographs.
|
Additional functions not included or defined in the CTU Code
6
|
Inspectors / surveyors
|
Parties employed by governments or commercial entities to perform
inspection / surveying functions to ensure the safe transport of
CTUs.
|
Inform principal of compliance and/or non-compliance for further action
where appropriate.
|
Applicable Codes and standards (e.g. MSC.1/Circ.1442)
|
7
|
Insurers
|
Entities / parties that provide insurancesfootnote which variously cover loss or damage to cargo,
CTUs, ships and other means of conveyance.
|
Where possible raise awareness of the CTU Code and best practice among
customers and packers of CTUs.
|
Assist in the development of additional advice for specific cargo types
as appropriate.
|