COVID Protection equipment restrictions for exportation

The United States Federal Emergency Management Agency (FEMA) has filed a temporary final rule to amend export restrictions on certain types of personal protective equipment products (“PPE materials”) used in the response to the COVID-19 pandemic.

While this rule remains in effect, transportation companies are unable to export any of the designated materials without their explicit approval.

The rule covers five types of personal protective equipment (PPE):

  • Surgical N-95 Filtering Facepiece Respirators, including devices that are disposable halfface-piece non-powered air-purifying particulate respirators intended for use to cover the nose and mouth of the wearer to help reduce wearer exposure to pathogenic biological airborne particulates.
  • PPE surgical masks, including masks that cover the user's nose and mouth and provide a physical barrier to fluids and particulate materials.
  • PPE nitrile gloves, specifically those defined at 21 CFR 880.6250 (exam gloves) and 878.4460 (surgical gloves) and other such nitrile gloves intended for the same purposes.

Level 3 and 4 Surgical Gowns and Surgical Isolation Gowns that meet all the requirements in ANSI/AAMI PB70 and ASTM F2407 – 06 and are classified by Surgical Gown Barrier Performance based on AAMI PB70. at 21 CFR 880.6250 (exam gloves) and 878.4460 (surgical gloves) and such gloves intended for the same purposes.

  • Specific syringes and hypodermic needles (whether distributed separately or attached together). The designated materials are piston syringes and hypodermic needles that are either:
  • Piston syringes that allow for the controlled and precise flow of liquid as described by 21 CFR 880.5860, that are compliant with ISO 7886-1:2017, and use only Current Good Manufacturing Practice (CGMP) processes; or hypodermic single lumen needles as described by 21 CFR 880.5570 that have engineered sharps injury protections as described in the Needlestick Safety and Prevention Act.

This, albeit temporary, should not come as any surprise given the PPE supply disruption experienced last year. The entire rule is available on the Federal Register.

Current U.S. trucking industry situation

Here are some statistics about the current state of the U.S. trucking industry:

  1. Not Enough Drivers- There’s been a severe shortage in the trucking industry since 2018. Currently, it’s estimated that the industry needs at least 100,000 more drivers and companies are having difficulty attracting and retaining drivers.
  2. CDL Training Dropping- To make the driver shortage worse, the rates of commercial driver’s license (CDL) training is also dropping; 40% decrease since 2019. Of course, driver training schools shutting down due to the pandemic has not helped.
  3. Spot Market Remains High- The spot market has done well this year with an over 100% increase last month vs. same time in 2019.
  4. Trucking Is Big Business- It’s estimated that jobs related to the trucking industry (~7.95 million) account for nearly 5.8% of all full-time jobs in America.
  5. Trucks Move (Almost) Everything- Trucking is responsible for moving most freight (72.5%) around the country, and it’s said that every good you purchase was on a truck at some point.
  6. Many Miles- Trucks move goods driving over 300 billion miles per year.
  7. Mostly Small Operations- There are almost 2 million different carriers in the U.S. with > 91 percent operate 6 or fewer trucks
  8. Insurance Rates Skyrocket- Insurance rates have been climbing for years due to huge settlements against carriers. Premiums are rising on average 12% annually, and some carriers are facing a 20% to 30% increase each year.
  9. Low Annual Income- Despite the demand for drivers, and some truckers making nearly $100,000 per year, the average driver’s income remains at $43,680, $3,000 less than median American income.

2020 was a difficult year for everyone; Covid-19 disrupted nearly every industry, but trucking recovered rather quickly and is on track to do better this year.

Cargo hold ventilation

INTERCARGO, the Standard Club and DNV GL have jointly developed a guidance document called “Cargo and Cargo Hold Ventilation” which looks at the specific risks associated with types of cargo and how ventilation should be applied to mitigate them.

By far the most common threat to cargo integrity is the condensation of air moisture, which can cause agricultural products to spoil, steel products to rust, and other cargo types to undergo unwanted chemical reactions.

When it settles on the cargo, it is referred to as ‘cargo sweat’, while condensation on the ship’s structural members inside the cargo hold is called ‘ship sweat’. Both phenomena are directly related to the dew point, the temperature at which air becomes saturated with water, triggering condensation.

Ventilation is the established means to mitigate these risks but deciding when and how to ventilate can be complex since in some cases, ventilation may actually aggravate the hazard by increasing the amount of moisture and oxygen interacting with the cargo, thereby accelerating the processes which taint the cargo.

There are two basic types of ventilation – natural and mechanical or forced ventilation. Natural ventilation relies on air circulation driven by convection, with outside air entering and inside air exiting the hold through vents located above the deck level. Today’s bulk carriers typically have hinged-door type ventilators located at the sides of the hatch covers. These can be opened or closed depending on the relative wind direction to ensure adequate surface ventilation and prevent sweat inside the hold.

Mechanical ventilation systems actively blow air across or through the cargo hold. Where flammable gases might be present, the ventilation fans must be designed to avoid sparking and ignition or explosion.

It takes careful consideration of all influential factors and proper preparation ahead of a voyage to make sure that the cargo hold ventilation achieves the intended purpose

The document closes with two case studies which illustrate how improper or inconsistent application of ventilation rules can cause cargo damage and financial loss, and how proper documentation during a voyage is key to a ship’s ability to defend itself against cargo claims. A brief glossary of terms, a cargo temperature and ventilation log template, and a dew point table are included as additional practical tools.

The basic rule-of-thumb for ventilation is when going from cold to hot, ventilate not; while from hot to cold, ventilate bold.

For more details, go to:

Containers in the Ocean

There are calls for an urgent review of container lashing practices and stack height restrictions after another box ship lost a huge number of containers in the Pacific Ocean.

The 13,092 TEU Maersk Essen, in route from China to Los Angeles, lost about 750 containers on January 16th during heavy seas.

This is the third such serious incident on the same trade lane in less than two months, the ONE Apus loss of more than 1,800 containers on 30 November and the Ever Liberal on Christmas Eve.

According to a World Shipping Council report, an average of just 1,382 containers are lost at seas each year from around 5,000 container vessels in operation transporting 226 million containers annually.

The Standard Club has studied these losses and developed a list of contributory factors.

  • Bigger, stiffer ships
  • More powerful ship engines
  • Higher wind loading
  • Parametric rolling of ships
  • Synchronous rolling of ships
  • Ship contact with seabed
  • Green water and wave impacts
  • Improper container stowage
  • Overweight containers
  • Poor packing of containers
  • Structurally weak containers
  • Inadequate container securing
  • Adjacent container stack clashing

This is quite a laundry list and it would appear more than one was at play in these casualties and will vary case-case.

FYI, A report published last year by the UK’s Marine Accident Investigation Branch (MAIB) into the January 2018 loss of 137 containers in the Pacific from the UK-flagged 13,460 TEU CMA CGM Washington, concluded that the collapse of container stacks was caused by several factors, including excessive racking loads.

Also, traditionally mariners were wary of Winter North Atlantic passages; perhaps now the focus should be on the North Pacific.

Pirates event

The MOZART, a containership built in 2007 was attacked by pirated off Sao Tome Island, Africa on January 23rd.

The fully cellular vessel came under attack approximately 100 nautical miles northwest of the island. The pirates breached the citadel and one crew member was killed and 15 crewmen were abducted.

The remaining three crew members were able to navigate the vessel to safe waters off Gabon, despite damage to the vessel's controls and electronic navigation equipment.

Shipowners are reported to be seeking to establish contact with the kidnappers to secure the abducted crew members' earliest and safe release.

The ship was set to call at ports in UAE, India, Sri Lanka, Lagos, Nigeria, and South Africa was carrying nearly 3,000 containers.

Mis-declare goods 1

On 6 March 2018, five crew members aboard the Maersk Honam died when a fire swept through the 15,262TEU vessel in the Arabian Sea. An investigation by the flag state, Singapore, has concluded that the most likely cause was the decomposition of a dangerous cargo being carried in a block of 54 containers in the forward section of the ship.

The Singapore Transport Safety Investigation Bureau (TSIB) report notes that the fire probably started in a block stow of 1,000 tons of sodium dichloroisocyanurate dihydrate (SDID).

This is a chlorinating agent commonly used for disinfecting water, and in the food industry. Investigators noted that the secondary hazards of chemical decomposition and instability of the substance had not been identified in the International Maritime Dangerous Goods Code because SDID is classified under Class 9 rather than the more stringent Class 5.1 (oxidizing substances) even though it has similar chemical properties to Class 5.1 substances, such as calcium hypochlorite, including the potential for self-decomposition.

The TSIB report also points to several problems with the onboard response to the fire despite the good efforts demonstrated by the crew in taking care of each other and saving lives during the emergency, it was noted that the fire alarm was not raised at the onset of the event, causing a delay in the closure of the magnetic fire doors of the accommodation, and non-closure of exterior ventilation vents thus resulting in toxic smoke entering and spreading within the living quarters.

Investigations also revealed that the muster list did not clearly identify the roles of everyone onboard, which resulted in some of the crew waiting to be given instructions. In addition, firefighting flow charts within the ship emergency response plan did not ensure that all the ventilator flaps/dampers were closed as one of the primary fire-fighting actions, regardless of the location of fire.

The report points out that the IMDG Code requirements for SDID failed to recognize its potential thermal instability and permitted it to be stowed under-deck where the main fixed fire-fighting system was CO2, which is ineffective to tackle fires associated with such materials.

Dangerous Goods with oxidizing properties such as SDID should be considered for stowage on-deck but away from direct sunlight, where water could be used more effectively.

Again, another instance where several seemingly unrelated elements conspired to create a major casualty. Maersk has taken steps to prevent similar accidents; there is a call for a review of the IMDG classification of SDID and a reminder to ship operators of its inherent hazards.

Well there is the trifecta: containers lost overboard, piracy and fire. It seems that ocean carriers operating containerships are dealing with several loss-causing events

Mis-declare 2

Then we have mis-declared cargo. A recent incident reported in the CINS database relates to a fire in a container during a vessel’s voyage from Shekou, China to Singapore. During the voyage, smoke was reported from a container located deep in the cargo hold. The crew released CO² which quelled the smoke and extinguished the fire.

The cargo had been declared as Manganese Dioxide cells and shown on the bill of lading as Electronic Goods. The Packing List and Commercial Invoice revealed Lithium Ion Batteries. The investigation is underway to determine why this cargo of lithium batteries ignited.

Dry Bulk safety in vessels

Both RightShip and INTERCARGO have strongly and consistently advocated the need for significant improvements to dry bulk safety standards (DryBMS). Late last year, the organizations, along with input from stakeholders, collaborated on a single set of best practices and key performance indicators aimed at improving safety, environmental and operational excellence.

Supported by the International Chamber of Shipping (ICS) and BIMCO, the hope is that DryBMS will be adopted across the industry.

Interested parties are invited to sign up for the DryBMS newsletter to receive regular updates regarding the development and finalization of the standards. The draft version is now available to download on the DryBMS website at and the team will continue to review feedback sent to

Maritime safety

With several challenges facing the maritime sector, safety continues to be a priority for the International Chamber of Shipping (ICS). To ensure that the very best guidance is available for the chemical tanker sector, ICS has launched a new edition of the standard reference work for those working on tankers carrying chemical cargoes, the ICS Tanker Safety Guide (Chemicals).

The fifth edition provides chemical tanker operators and crew with up-to-date best practice guidance for safe and pollution-free operations on ships regulated under MARPOL Annex II.

Fully aligned with the latest edition of ISGOTT (the International Safety Guide for Oil Tankers and Terminals), the ICS guide can be purchased from ICS Publications.

The newest document is designed to simplify to make it easier and thus more likely to be used. Techniques successfully applied in the aviation sector have been incorporated making the checklists more effective and giving the maritime industry greater understanding of human factors, the chief cause of errors and accidents. The authors identified key safety issues such as risk assessments, enclosed space entry and PPE (Personal Protective Equipment).


The information for much of the content was taken from several public sources that to the best of the undersigned’s knowledge is accurate. The views expressed in this document should be regarded as the opinion of the undersigned and not ones made in his capacity as an employee of Chubb.

Anyone wanting additional information on any of the topics covered should contact the above signers.