"Your local government
voice on marine pollution"

Kommunenes Internasjonale Miljøorganisasjon

Local Authorities International Environmental Organisation

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Maritime Safety and Pollution
        Working to reduce maritime accidents and cargo spills


The Problem... Lost cargo containers


There is now wide spread concern about a recent spate of accidents in European waters and one of the worlds major carriers is conducting investigations why so many containers are being lost over the side of so many ships. A number of global carriers have suffered incidents over the years, many of which go largely unreported. Up to 10,000 containers a year could be lost worldwide through accidents of one form or another, according to a recent industry estimate, of which about a quarter are washed overboard.  Recent incidents have involved a NYK Line ship losing about four dozen containers in the English Channel in November 2007 and the P&O Nedlloyd Mondriaan lost 58 containers over the side off the Dutch coast, and then another 50 a couple of weeks later in the Bay of Biscay.


Watch KIMO President Albert de Hoop explain the significance of this issue below.



A Case Study: The Grounding of the MSC Napoli


The recent beaching of the stricken container ship MSC Napoli off the Devon coast on 20th January 2007 exemplifies the complex issues surrounding maritime safety standards. The vessel suffered flooding to the engine room during force 8 gales. This occurred in International waters within the French Search and Rescue Zone. The 26 crew abandoned ship and were safely rescued by helicopter. The MSC Napoli was carrying some 2,400 containers and 3,600 tonnes of heavy fuel oil. Over 100 containers were lost overboard that night, more were lost in subsequent poor weather. Oil escaping from the vessel was minimised, but some found its way ashore, mostly drifting eastwards towards Dorset.



Industry expansion has compromised on-board health and safety
Bad ship design, flimsy containers, faulty twist locks, bad stowage, shoddy maintenance, poor seamanship, top heavy container stacks, mis declared cargo, weather, commercial pressure, communication failure or a combination of these factors all contribute to an increasing amount of incidents. The audit of the containers removed from the MSC Napoli and the deadload calculated on departure, indicated that the declared weights of many of the containers carried by the vessel were inaccurate. While there are many contributory factors, one classification society has now added its voice to the growing lobby in favour of weighing every container before it is loaded onto a ship and there is also a case for building more robust containers which have remained unchanged in basic design for half a century. This would be the most effective way of preventing containers from crashing into the sea or from stacks collapsing.  Approximately 50% of the worlds shipping tonnage carry non-toxic substances as bulk goods, in containers or as general cargo.


Tonnage increases on increasingly antiquated vessels  

There has been a rapid increase in the worldwide containership fleet, which has grown by 140% from 32.6 to 78.3, million gross tons  since 1994. This rise has been accelerated in recent years as Post-panamax ships have started to join the fleet with capacities of 9000 TEU’s (Twenty Foot Equivalents). Even larger vessels than these are in the pipeline, with the China Ocean Shipping Group building four 10,000 TEU vessels, and the predictions are that vessels will reach an optimum size of 12,500 TEU’s by 20103. The North Sea region is no exception with the container port capacity forecast to increase by 21.18 million TEU’s over the next five years to 74.56 million TEU’s. Transshipment of containers through the North Sea has also been forecast to increase by 60-90% in the period from 2001-2010. Containerships and general cargo ships may carry hugely varied cargo's anything from polythene, training shoes, and tobacco to garden gnomes and there also may be many different cargo's in a single container. It may also be difficult to reconcile containers that have been lost over the side with the ships manifest.

 Higher sailing speeds, higher number of accidents

Containerships operate at much higher speeds in order to move cargos around the world quickly and keep delivery times down. Modern containerships are designed to operate at service speeds of up to 27 knots  much faster than tankers or bulk carriers. This high speed will result in greater impact in

collisions and groundings resulting in more damage to the vessel when compared to lower speeds. Therefore there is a greater risk that containers will be lost overboard if an accident does occur. The ever-increasing incidents of lost containers that are arriving on coastlines and beaches are now becoming an issue for coastal local authorities. Although most of these incidents involve non-toxic pollution such as consumer goods more and more incidents are involving toxic material which adds a further burden to local emergency services.  As the main providers of cleanup responses Local Authorities have to bear the cost of such incidents.

The impact of lost cargo on the surrounding coastline

In the case of the MSC Napoli a colossal volume of cargo was lost overboard. Most of these containers washed up on the Branscombe coastline soon after the vessel had become grounded at sea. Luckily the majority of the Napoli's cargo was non-toxic, however, the variety of goods washed up on the beaches caused local authorities significant problems; in terms of organising the clean-up of the scattered cargo and the need to prohibit the illegal collection of goods by the general public. In the past, coastal municipalities were left to provide finances for the cleanup operation. The clean-up of the Napoli's cargo was bound to be expensive. The Napoli was carrying 3,600 tonnes of heavy fuel oil. A percentage of this was lost into the sea, however the local authorities were able to contain the spill.





What KIMO proposes


KIMO, in recognition of the need to improve the compensation regime for coastal communities in relation to Non-Toxic pollution, in order to reduce the pollution load on our sea and coastal waters demonstrates towards a series of sea-changes to industry standards. 

All European governments, the European Commission and Parliament to act in unison at the International Maritime Organisation (IMO) to establish measures to:

Reduce the loss of containers from shipping

Develop measures to identify and retrieve lost containers

Ensure that all containers should be weighted before shipment

Introduce financial penalties and compensation regimes for the retrieval of lost containers


And to work towards a Convention on Liability and Compensation for Damage in Connection with the Carriage of Non-Toxic Substances including strict liability on ship owners for pollution from their vessels, compulsory insurance for all vessels and a reserve fund to cover any shortfalls in compensation.


Recognition of our efforts in this field

In December 2008 Devon County Council published its official public enquiry into the MSC Napoli incident in January 2007. Their comprehensive investigation into the incident also proposed a series of potential improvements to the regulation of the cargo shipping industry. The enquiry fully supported KIMO's campaign to develop a convention for liability and compensation arising from non-toxic pollution.


Download the Devon County Council MSC Napoli Public Enquiry here.



The Problem... Ship-to-Ship Transfers

The volume of crude oil and petroleum products being transported from the Baltic and Barents Seas has dramatically increased since 2000.

Exports from the Baltic alone have risen from 67.7mt to 158.7mt today a 250% increase and a further three fold increase is expected by 2015, resulting in an estimated 16,825 tanker movements per year. Due to the shallow draught in the Baltic Sea VLCC’s (Very Large Crude carriers) are unable to enter Baltic ports and therefore the oil must be transported by smaller shuttle tankers through the Baltic before being transferred in Ship-to-Ship (STS) operations to VLCC’s in the North Sea. The vast majority of STS operations occur in open water within a few miles of the coast and only have contingency plans that cover a small-scale spill. Further more there are no International regulations relating to STS, only guidelines, and few national regulations. For example, in the UK, Government does not have the power to ban STS operations in its territorial waters and can only ask for improvements in the contingency planning.  

Therefore the risk of a major accident involving a STS operation will increase over the coming years.

If an accident does occur it will be exacerbated by the fact that the crude oil involved is REBCO (Russian Export Blend Crude Oil) and HVFO (Highly Viscous Fuel Oils), similar in consistency to the oil carried by both the Erika and Prestige. These heavy crude oils pose a significant threat to the marine environment and a large spill would be economically devastating for any coastal community affected. For example, the ultimate cost from the Prestige spill is expected to reach around €5 billion, however only €175 million was paid out in compensation from the IOPC Fund. 

The increasing number of transfers also increases the probability of the introduction of more non-native invasive species into the North Sea region. Invasive species can be transported in ships ballast water and released when the ships deballast during loading. They can cause extreme ecological and economic damage as in the case of the Zebra Mussel in North America, which costs an estimated $100 million per year in damage and control measures.




What KIMO proposes


As outlined in KIMO Resolution 1/06, KIMO urges Northern Seas States to act in unison at the International Maritime Organisation (IMO) and within the European Union to establish regulations for Ship-to-Ship transfers in all waters, incorporating the basic principles below:



  • Port States should have the power to refuse applications for ship-to-ship transfers within their territorial waters
  • Applications to carry out ship-to-ship transfers must include a Environmental Impact Assessment
  • Applications for ship-to-ship transfers must have a contingency plan to cover a worst-case scenario spill
  • Tugs and emergency response vessels, with the capacity to deal with a worst case scenario spill, must be on station for the duration of the transfer
  • Provision of a local pilot for the duration of the transfer and berthing operations
  • Set minimum requirements for the moorings, fenders and stability of the vessel during transfer.
  • Restrictions on operations in poor weather conditions
  • A ban on deballasting in coastal waters
  • The restriction of ship-to-ship transfers to designated harbour areas, where appropriate
  • Local Authority(s) involvement in the approval process at the earliest opportunity


Press Releases 

UK Should Follow Australia's Lead In Targeting The Cause of Lost Containers - 09 February 2010
The Australian government has begun a Focused Inspection Campaign of container shipping to make sure containers are correctly loaded and secured. KIMO UK urge the UK government to follow Australia's lead and take action by introducing more robust checks on container lashings and ensuring similar regulations are brought to the International Maritime Organisation as soon as possible. Read more... 

KIMO Baltic Sea stops dumping of contaminated silt - 12 January 2009
KIMO Baltic Sea successfully lobbied the Klaipeda State Sea Port Authority and the Lithuanian government to halt the dumping of silt contaminated with heavy metals into the Baltic Sea. Read more...

KIMO Agrees action on lost containers - 20 October 2008
At the KIMO annual general meeting, delegates unanimously approved the organisation's latest resolution on lost containers. Read more...

KIMO Welcomes Forth Ports Decision to Abandon Ship-to-Ship Transfers Plans - 02 February 2008
Yesterday common sense finally prevailed when Forth Ports Plc abandoned plans to tranship 7.8 million tonnes of Russian crude oil per year in the Firth of Forth, near Edinburgh. The operations would have threatened several environmentally sensitive sites and placed responsibility for clean up operations, in the event of an oil spill, onto the Local Authorities around the Forth not the Port themselves.

Containership Disaster Highlights North Sea Ministers Lack of Action - 23 January 2007
The grounding of the MSC Napoli in Lyme Bay, off the Devon Coast, on Sunday the 21st of January is exactly the type of incident that North Sea Ministers and Senior Officials decided was not worthy of action at the North Sea Ministerial Meeting on Shipping and Fisheries in Göteborg last May. KIMO International had called on Ministers to take action to protect coastal communities from the impacts of pollution from containerships however these requests fell on deaf ears despite previous commitments. Read more...

KIMO UK Condemns MCA Decision to Allow Ship to Ship Oil Transfers in Forth - 14 July 2006
KIMO UK today condemned the decision by the Maritime Coastguard Agency to allow the transfer large volumes of Russian crude between huge oil tankers offshore in the Firth of Forth. Read more...

Ship to Ship Oil Transfers in Forth Opposed by KIMO UK - 01 June 2006
KIMO UK has opposed the proposals in a written response to the UK Maritime Coastguard Agency (MCA) and written to Deputy Scottish Environment Minister Rhona Brankin asking her to use her powers to stop the practise in this highly environmentally sensitive area. Read more...

Coastal Communities call for Single Directive Maritime Safety - 11th October 2003
Local politicians representing 5 million inhabitants from Northern European coastal communities have called for the European Commission to condense all existing and proposed legislation on maritime safety into a concise and comprehensive single Directive.




Debate on Lost Containers and Compensation in the European Parliament

Last year the Secretariat and President met with MEP’s from the Transport and Tourism Committee and officials from the European Commission to raise our concerns with compensation from non-toxic pollution and lost containers. Following on from those meetings the Secretariat developed an oral question for Brian Simpson MEP, Chair of the Transport Committee, to highlight our concerns to the Commission. The debate, held on the 21st October 2010 in Strasburg, was fairly robust and highlighted KIMO’s concerns to the Commission.

Read the full transcript of the debate here...

Watch video coverage of the debate here... 

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