IMO CSC/CRC 134 Guidance on Serious Structural Deficiencies in Containers

The guidance entitled “IMO CSC/CRC 134 Guidance on serious structural deficiencies in containers” was published by the International Maritime Organization (IMO) to enable competent officers to assess the integrity of structurally sensitive components of containers (defined in Article II of the convention) and to help them decide whether a container is safe to continue transport or should be stopped until corrective action is taken.

The criteria given in the appendix of the guide (Annex 1) are used to make immediate out-of-service decisions and are considered a safety standard and should not be used as repair and in-service criteria under a continuous inspection programme or periodic inspection scheme approved by the Safe Container Convention (CSC).

For the purposes of this manual, warehouse means a repair or storage facility or location. Structurally sensitive components means the components described in the manual appendix (Appendix 1) and shown in Appendix 3. These are important in ensuring the safe use of the container during transport.

In terms of serious structural deficiencies and control measures, the following should be considered:

• Control should be exercised on containers that pose a significant risk to security. Authorised officers must notify the container owner or bailee when a container is taken under control.
• Attention should be paid to the deficiencies described in Annex 1.
• It should be noted that the guidance given in Annex 1 is not comprehensive for all container types or all possible deficiencies or combinations of deficiencies.
• Annex 2 provides a security flow chart that can be used to evaluate appropriate control measures.
• It is important to remember that damage to a container may appear serious without posing an obvious risk to safety. Many types of damage, such as holes, may violate customs requirements but may not be structurally significant.
• Major damage may be the result of significant impact, such as that caused by improper handling of the container or other containers or by significant movement of the cargo within the container. Therefore, special attention should be paid to signs of recent impact damage.

The following components are structurally sensitive and should be inspected for serious deficiencies. The criteria given are used to make immediate out-of-service decisions. They should be considered a safety standard and should not be used as criteria for repair and in-service under a container safe contract (CSC) or periodic inspection scheme.

The components and serious structural deficiencies are specified in the standard as follows:

• Upper rails: Local deformation of the rail more than 60 mm or separation of the rail material more than 45 mm in length or cracks or tears.
• Bottom rails: Local deformation of the rail more than 100 mm or separation of the rail material more than 75 mm in length or cracks or tears
• Headers: Local deformation of the header more than 80 mm or cracks or tears more than 80 mm in length.
• Thresholds: Local deformation of the threshold greater than 100 mm or cracks or tears greater than 100 mm in length.
• Corner posts: Local deformation of the post more than 50 mm or tears or cracks more than 50 mm in length.
• Corner and intermediate fittings (castings): Missing corner fittings or cracks in fittings greater than 25 mm, weld separation of components adjacent to fittings greater than 50 mm in length.
• Bottom structure: Two or more adjacent cross members missing or separated from bottom rails.
• Locking bar assemblies: One or more of the internal locking bar assemblies are inoperative.

Loaded containers with damage equal to or greater than the above criteria are considered to endanger a person and the authorized officer must stop such containers as per the contract. However, the authorized officer may allow further movement of the container if it is necessary to move the container to its final destination without removing it from the available means of transport.

The security flowchart shown in Appendix 2 provides additional guidance on the decision process for granting onward movement permission.

Empty containers are usually relocated for repair at a depot chosen by the owner, provided they can be transported safely. This may include a domestic or international move under contract. Any damaged containers that are relocated should be handled and transported with due attention to structural deficiencies.

The impact of two or more incidents of damage to the same structurally sensitive component, even if each incident is less than that indicated in the table above, may be equal to or greater than the impact of that single incident. In such cases, the authorized officer may stop the container and seek further guidance from the contracting authority.

For tank containers, the ship’s attachment to the container frame should be assessed for any readily visible damage such as that indicated in the table. If such damage is found to these components, the container may be stopped and further instructions may be sought by the contracting party.

For platform containers with collapsible end frames, the end frame locking mechanism and the hinge pins around which the end frame pivots are structurally sensitive and should also be inspected for damage.

Among the numerous testing, measurement, analysis and evaluation studies that our organization has carried out for businesses in various sectors, it also provides testing services within the scope of “IMO CSC/CRC 134 Guidance on serious structural deficiencies in containers” with its trained and expert staff and advanced technological equipment.