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Statutory Documents - IMO Publications and Documents - International Codes - CTU Code - IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units - Chapter 4. Chains of responsibility and information

Chapter 4. Chains of responsibility and information

 Note: Definitions are given in chapter 2.

4.1 Chain of responsibility

4.1.1 In general, transport operations using CTUs in particular, involve various parties each of whom have a responsibility to ensure that the cargo is transported through the supply chain without incident. Notwithstanding any national legislation or contracts between the involved parties the chain of responsibility discussed below identifies functional responsibilities of the parties involved.

4.1.2 Although the carrier generally, in a contract of carriage is responsible under that contract to deliver the cargo in the same condition as received, it is the shipper who should deliver a cargo which is safe and suitable for transport. Thus, the shipper remains responsible for any deficiency of the CTU that is a result of poor packing and securing. However, when the shipper is neither the packer nor the consignor, the packer and the consignor should fulfil their obligation to the shipper ensuring that the CTU is safe for transport. If not the shipper may hold those parties responsible for any faults or deficiencies that can be attributed to poor packing, securing, handling or reporting procedures.

4.1.3 Within this chain of responsibilities, each party in the chain should comply with their individual responsibilities and in doing so increase safety and reduce the risk of injury to persons involved in the supply chain.

4.1.4 All persons involved in the movement of CTUs also have a duty to ensure, in accordance with their roles and responsibilities in the supply chain, that the CTU is not infested with plants, plant products, insects or other animals, or that the CTU is not carrying illegal goods or immigrants, contraband or undeclared or misdeclared cargoes.

4.1.5 The supply chain is a complex operation and individual modes of transport may have defined terms for parties within the supply chain which are not consistent with other modes of transport.

4.1.6 A single entity may undertake one or more of the functions listed below. The flow of information between the functions is discussed further in annex 1.

 4.2 Functions within the supply chain

Between the different functions involved in an intermodal transport chain, the tasks are assigned as follows:

4.2.1 The CTU operator is responsible for providing CTUs that:

  • Are fit for purpose;
  • Comply with international structural integrity requirements;

  • Comply with international or national safety regulations;

  • Are clean, free of cargo residues, noxious materials, plants, plant products and visible pests.

4.2.2 The consignor is responsible for:

  • Correctly describing the goods including the mass of the total payload;
  • Notifying the packer/shipper of any unusual transport parameters of individual packages, for example, the offset of the centre of gravity or transport temperatures which should not be exceeded or undercut;

  • Ensuring that packages and unit loads are suitable to withstand the stresses which are to be expected under normal transport conditions;

  • Providing all the information that is required for proper packing;

  • Ensuring that goods in packages and unit loads are adequately secured to prevent damage during transport;

  • Ensuring that goods are ventilated so that any noxious or harmful gases are permitted to vent off before packing;

  • Ensuring that dangerous goods are correctly classified, packed and labelled;

  • Ensuring the dangerous goods transport document is completed, signed and transmitted to the packer, forwarder, shipper (if not the consignor) and carrier as applicable.

4.2.3 The packer is responsible for:

  • Ensuring that the CTU is checked before packing and that the condition of the CTU is suitable for the cargo to be transported;
  • Ensuring that the floor of the CTU is not overstressed during packing operations;

  • Ensuring that the cargo is correctly distributed in the CTU and properly supported where necessary;

  • Ensuring that the CTU is not overloaded;

  • Ensuring that the cargo is sufficiently secured in the CTU;

  • Ensuring that measures are put in place to prevent the movement of plants, plant products and visible pests, such as closing doors and tarpaulins once packing has started but not taking place and lights that minimize the attraction of insects;

  • Properly closing the CTU and sealing it, when required, and reporting seal details to the shipper. CTUs used for international transport should be sealed;

  • Fitting marks and placards to the CTU as required by dangerous goods regulations;

  • Fitting the fumigation mark if any fumigant has been used as part of the packing process;

  • Accurately determining the gross massfootnote of the CTU and transmitting it to the shipper;

  • Ensuring that no incompatible dangerous goods are packed. Account should be taken of all dangerous goods legislations during the complete transport chain;

  • Providing the container/vehicle packing certificate (new document or signed statement in the dangerous goods transport documentation as appropriate) and forwarding any documentation to the shipper.

    The packer should also pass on information relating to any freight container with a reduced stacking capacity (less than 192,000 kg marked on the CSC safety approval plate)footnote, to the shipper.

4.2.4 The shipper is responsible for ensuring that:

  • The work distribution concerning packing and securing is clearly agreed and communicated to the consignor and carrier/carriers;
  • A suitable CTU is used for the intended cargo for the intended transport;

  • A CTU is requested which is safe for transport and is clean, free of cargo residues, noxious materials, plants, plant products and visible pests before being supplied to the consignor or packer;

  • Suitable modes of transport are selected to minimize the risk of accidents and damages for the actual cargo;

  • All required documents are received from the consignor and from the packer;

  • The cargo inside the CTU is fully and accurately described;

  • The gross mass of the CTU is accurately determined;

  • The accurate description of the cargofootnote is communicated to the carrier as early as required by the carrier;

  • The verified gross mass is communicated to the carrier as early as required by the carrier;

  • In case of dangerous goods, the transport document and (for sea transport) the packing certificate is transmitted to the carrier before the transport commences respectively as early as required by the carrier;

  • In the case of temperature controlled goods, the correct temperature set point is entered into the control unit and onto the transport/shipping documents;

  • Ensuring that a seal, where required, is affixed immediately upon completion of the packing of the CTU;

  • The seal number, where required, is communicated to the carrier;

  • Any extraordinary properties such as reduced stacking capacity or out of gauge are communicated to the carrier;

  • The shipper's declaration is accurate;

  • Shipping instructions are despatched to the carrier on time and that the CTU meets the outbound delivery window;

  • The CTU arrives at the terminal before the stated cargo cut off time;

  • The information concerning the consignment, description of packages and, in the case of freight containers, the verified gross mass is transmitted to the consignee.

4.2.5 The road haulier is responsible for:

  • Confirming that the gross mass, length, width and height of the vehicle are within the national road/highway regulations limits;
  • Ensuring that the driver is able to get sufficient rest and does not drive when fatigued;

  • Except when the CTU is a trailer, securing the CTU properly on the trailer or chassis;

  • Moving the CTU in such a manner that there are no exceptional stresses placed on the CTU or the cargo.

4.2.6 The rail haulier is responsible for:

  • Handling the CTU in a manner that would not cause damage to the cargo;
  • Except when the CTU is a rail wagon, securing the CTU properly on the rail wagon.

4.2.7 The intermodal operator is responsible for:

  • Ensuring that appropriate pest prevention methods are in place, which may include removal of muds and soils from the CTU;
  • Complying with annex 2.

4.2.8 The carrier is responsible for:

  • Monitoring agreed temperatures in the CTUs where applicable and reacting to changes as appropriate;
  • Securing the CTU on the means of transport;

  • Transporting the CTU in compliance with agreements and all applicable regulations;

  • Providing trained personnel to deal with all cargo types (break-bulk, bulk wet and dry cargoes, dangerous goods, out of gauge, refrigerated, uncontainerized).

4.2.9 The consignee/receiver of CTUs is responsible for:

  • Not overstressing the floor of the CTU during unpacking operations;
  • Correctly ventilating the CTU before entering;

  • Confirming that the atmosphere within the CTU is not hazardous before permitting persons to enter it;

  • Detecting any damage to the CTU and to notify the carrier;

  • Returning the CTU to the CTU operator completely empty and clean, unless otherwise agreed;

  • Removing all marks, placards or signs regarding the previous consignments.

4.2.10 Shippers of empty CTUs and operators of empty CTUs are encouraged to have practices and arrangements in place to ensure that they are empty.

4.2.11 All parties identified within section 4.2 should minimize the risk of recontamination of CTUs when in their custody. This may include the following:

  • Implementation of appropriate pest management programs;
  • Removal of any plants, plant products or visible pests taking into account the roles and responsibilities of each party within the supply chain and, further, the impossibility of inspecting the interior of closed and sealed CTUs for recontamination.

    For more information see annex 6.

4.2.12 All parties should ensure that the flow of information is transmitted to parties identified in the transport contract along the supply chain. The information should include:

  • The identification, in accordance with a risk assessmentfootnote, of risks to the integrity of the CTU that may be present for all or some part of the journey;
  • CTU identification;

  • Seal number (where required);

  • Verified gross mass of the CTU;

  • Accurate description of the cargo carried in the CTU;

  • The correct description of dangerous goods;

  • Correct and appropriate transport documentation;

  • Any information required for safety, security, phytosanitary, veterinary, Customs or other regulatory purposes.


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