Sea Container Risk Management Policy (SCRMP) and Standards for sea container inspection stands frequently asked questions
Sea Container Risk Management Policy (SCRMP)
Why were inspection activities changed?
T he department required all sea containers entering Australia between 2001 and 2009 to undergo an external inspection as part of its increased quarantine intervention policy.
Inspection data collected during this period demonstrated that almost all containers landing in Australia complied with its biosecurity container cleanliness requirements and did not pose a significant biosecurity risk.
What is this policy?
The Sea Container Risk Management Policy (SCRMP) was developed to manage the detection and intervention of biosecurity risk material on the external surfaces of sea cargo containers entering Australia.
In line with a number of policy reviews, SCRMP's focus is 'targeted management to minimise the risk of entry, establishment or spread of exotic pests and diseases on the external surfaces of sea containers entering Australia'.
The high level of biosecurity compliance and the development of SCRMP, represents an outstanding achievement by both the department and shipping industries, emphasising that ‘ biosecurity is a shared responsibility’.
The success of SCRMP continues to rely on addressing hygiene and other biosecurity risks associated with sea containers offshore before they are imported .
What are the key features of SCRMP?
Better targeting and departmental intervention for containers on high risk sea cargo pathways, for example, containers originating from giant African snail countries, countries with a history of high levels of other high risk contamination and containers destined for rural delivery.
More efficient targeting of higher risk containers for mandatory intervention by implementing electronic holds and enhanced inspection protocols for all containers moving to or through rural areas, including containers being land bridged by rail or road.
Intervention based on risk assessment and management for lower risk containers moving to metropolitan destinations.
Increased surveillance and possible third party industry arrangements for external inspections, including a revised approach, based on the analyses of available data and verification activities for empty containers both on and offshore.
Does this change compromise Australia’s biosecurity?
No. Instead of screening all containers, the department pays more attention to containers that pose the greatest biosecurity risk .
How does SCRMP affect industry?
For some industry members nothing will have changed.
A small number may have experienced an increased level of surveillance (e.g. empty containers).
The majority of industry stakeholders have benefited with fewer interceptions and more efficient passage of goods through the cargo logistics chain.
What are the benefits?
- An intelligence based approach to managing biosecurity risk.
- Targeted allocation of departmental resources.
- Enhanced biosecurity regulation that facilitates trade while focusing on targeted intervention.
- Management of biosecurity risks offshore prior to loading, minimising the threat of an exotic pests or diseases establishing in Australia.
When did the changes occur?
SCRMP was implemented, through a phased approach, in 2010. Phase 1 is complete and Phase 2 is currently being implemented.
Who should be contacted for further information?
your local regional office or
the Cargo and Mail Section in Canberra about sea container hygiene requirements.
Standards for sea container inspection stands
Why were the Guideline standards for container inspection stands reviewed and changed?
The Department of Agriculture and Water Resources (the department) commissioned a review of the Risk assessment for support and inspection of large containers—final report v4 (2001) by Dr R Platfoot, Covaris Pty Ltd.
The department also commissioned the reviewers to draft a new s tandards to replace the Guideline s tandards for c ontainer i nspection s tands.
The new Standards for sea freight container inspection stands were developed to ensure that the department is providing:
- up-to-date Australian standards on engineering and design, construction and repair requirement
- nationally consistent inspection and certification regime for container inspection stands
- clarification on the qualifications required by persons inspecting and certifying inspection stands
- a current and accurate overarching document that can be referenced by industry
- a safe working environment for all personnel.
The Standards came into effect on 16 June 2014.
All inspection stands must meet the requirements/criteria of the Standards if the stand:
- already exists and is intended to be used by biosecurity officers to inspect containers
- is used for inspecting containers from countries listed on the Country Action List (CAL)
- any situation where a biosecurity officer needs to stand underneath a container for other types of inspection
- is a newly constructed inspection stand to be used by biosecurity officers.
From 16 June 2014, only stands certified under the Standards will be accepted for use by the department, biosecurity officers will only use approved, certified sea freight container inspection stands that satisfy the new Standard.
The department does not consider that effective inspections on high risk containers on pathways, such as CAL, can take place on a skeleton trailer. Uncertified stands or skeleton trailers will not be suitable for biosecurity officers to use in this situation.
Other inspections of the undersides of containers (e.g. wharf-gate inspections and rural tailgate inspections) can take place on skeleton trailers provided there is no need for a biosecurity officer to stand underneath the container for the inspection.
Are the Standards applicable to all container stands or just stands used by biosecurity officers?
Any stand that is to be used by biosecurity officers must meet the requirements in the Standards. Stakeholders can choose to adopt the Standards in other circumstances but there is no requirement to do so.
If there is a chance that you would require biosecurity officers to perform an inspection of containers while they are placed on a stand, you must ensure your stand meets the department’s requirements.
Inspections and certification
Do engineers have to supply operators with a statement of certification?
Yes. Qualified engineers must supply operators with a statement certifying that the stand meets the requirements of the Standards. Operators are then required to send a copy of the certification, qualifications and photos to the local department’s regional port/cargo manager.
A sample Statement of Certification is included at Appendix D of the Standards. Engineers are not required to use this sample but it does contain all the information that is needed to meet the requirements of the Standards and therefore be acceptable to operators and the department.
Engineers are encouraged to also add a letterhead to any certification they provide.
Why do stands only have to be inspected and certified in alternating intervals of 2 years?
Purpose-built inspection stands will only require certification by a qualified engineer every four years after the initial certification. Inspections by a structural inspector occur two years after each certification. This is done to ensure the stand is fit for use and
is a consequence of the introduction of the Accident/Incident Report Sheet (Appendix B) and the Criteria for Limiting Defects and Associated Repair Actions (Appendix C) of the Standards.
Following any damage, including impact, the stand must be inspected and assessed by a structural inspector in the first case (and qualified engineer if required).
Any required repairs inside the tolerance limits of Appendix C are to be completed by the structural inspector. Any required repairs outside the tolerance limits of Appendix C, must be completed and the stand recertified by a qualified engineer prior to reuse.
Inspection, repair and possible re-certification are ongoing, reportable and auditable activities to ensure the safe working condition of the inspection stand.
Note: This schedule of inspection applies to purpose-built stands only. Modified containers such as flat racks, are to be inspected and certified in alternating yearly intervals, that is, certified every two years and inspected by a structural inspector each year after certification.
Why does the owner/provider of an inspection stand have to have a maintenance plan?
The maintenance plan is to ensure compliance with the inspection and recertification schedules. The log may be audited by the department.
Modified flat racks as inspection stands - Why are the inspection/certification requirements different than for other inspection stands?
Modified flat racks may have been used for carrying cargo in the past. It is difficult to ascertain what damage flat racks may have sustained prior to being modified to become an inspection stand. The flat rack may not have sufficient rigidity or robustness to be used as an inspection stand.
An increased inspection schedule is required to ensure structural integrity.
Modified flat racks are not acceptable for the design and construction of new stands.
Is there a requirement for a stand’s certification to be kept at the premises?
Yes. All inspector and engineer’s qualifications, stand certification, biennial checks and Accident/Incident Reports and repair actions are to be kept in a log/report. This log must be accessible to department staff to check compliance.
Copies of inspector and engineer’s qualifications, certification and Accident/Inspection Reports and repair actions are to be sent to the department’s regional port/cargo manager as per the inspection schedule.
Damage and repair
Who has the responsibility for the inspection/assessment of the stand after it has been damaged?
A structural inspector is responsible for the initial assessment of any damage to a stand as per the Accident/Inspection Report Sheet and the Criteria for Limiting Defects at Appendix B and C (the Standards).
What do I do if I notice damage to a stand?
If you notice any damage or wear and tear, report the situation to the owner/provider representative and/or your supervisor.
The structural inspector will assess the stand using an Accident/Inspection Report and refer to the Criteria for Limiting Defects at Appendix B and C (the Standards) to assess the level of damage and associated repair actions.
What is the level of damage that requires a stand to put out of service?
The structural inspector will assess whether the damage is within the tolerance levels of Appendix C (the Standards) and perform the repairs if necessary. If it is within the tolerance levels, the stand does not need to be removed from service and does not need to be recertified.
If the damage is outside the tolerance levels of Appendix C (the Standards), the stand must be removed from use and repaired. The stand is then required to be inspected by a qualified engineer and recertified. A new/updated certification plate will need to be attached prior to reuse.
The department’s regional port/cargo manager must be advised that the stand is out of service.
Can an out of service tag system be used when the stand is found to be damaged?
Yes. If the stand is taken off line, an out-of-service tag system may be used, however it would be administered by the premises and recorded in its maintenance log.
It is the responsibility of the premises to:
- provide an out-of-service tag system
- advise the department’s regional office that the stand is out of service
- provide alternative inspection arrangements.
It is the responsibility of industry to ensure that the employment of qualified engineers and structural inspectors meets the requirements as per Section 6 of the Standards.
What qualifications does a structural inspector need?
A structural inspector requires competency in steel structures. This competency can be obtained by meeting one of the following three criteria:
- successful completion of Transport and Logistics training packages: TLIB2086A (Apply awareness of structures fundamentals) and TLIB3088A (Examine Steel Structures) and 5 years’ experience in the inspection of steel structures
- welding Inspector Certificate as recognised by the Welding Technology Institute of Australia (WTIA)
- more than 15 years’ experience in the inspection or fabrication of steel structures in addition to approval by a qualified engineer with a membership of institute of Engineers, Australia (MIEAust) or equivalent.
Copies of these qualifications must be provided to the department with inspection results.
The structural inspector is not required to be an independent worker to the site/premises authority.
What qualifications does a structural engineer need?
Qualified engineers must have EITHER of the following degree qualifications:
- Bachelor of Civil or Structural Engineering from an Australian institution or overseas equivalent
- Bachelor of Mechanical Engineering from an Australian institution or overseas equivalent PLUS demonstrable experience in the design or fabrication of steel structures in excess of five years.
Qualified engineers must also have ALL of the following:
- Chartership with the Institute of Engineers
- Valid state certification (if required)
- Be an independent worker to the site/premises authorities
Copies of these qualifications must be provided to the department with inspection result and/or certification.
Can a mechanical engineer certify the stand?
Yes. In the case where an engineer with a Bachelor of Mechanical Engineering has more than five years demonstrable experience in the design or fabrication of steel structure, this experience is acceptable in lieu of a Bachelor of Civil or Structural Engineering.
The primary difference between a structural and a mechanical engineer is the nature of the work they perform. Structural engineers design structures, such as bridges, buildings and communications towers. Mechanical engineers focus on mechanical elements, such as machines and parts.
Container stands are stationary structures and the current understanding by the department on advice from industry is that the stands should be designed and certified by a suitably qualified engineer.
What sort of evidence does a mechanical engineer have to produce to verify more than five years demonstrable experience in the design or fabrication of steel structures?
A mechanical engineer needs to provide a CV or logbook, going back a minimum of five years that states relevant projects the mechanical engineer has worked on.
To be relevant these projects must involve the design or fabrication of steel structures.
For each project the CV/logbook must detail:
- the project’s scope of work
- the dates when the work was undertaken
- the company the engineer work for at the time
- the client for the works/project.
Why does the engineer have to be chartered with Engineers Australia?
Chartership with Engineers Australia provides the department with confidence that the engineer possesses competencies that are nationally recognised and standardised. To gain chartership, engineers are formally assessed and tested through in-depth interviews and a comprehensive process of providing evidence of work.
Department staff do not have the knowledge or expertise to assess years of experience as a measure in determining the competency of an engineer.
Note: It is the responsibility of industry to ensure that the employment of qualified engineers and structural inspectors meets the requirements as per Section 6 of the Standards.
General design requirements
How can I easily identify if the stand meets the design criteria?
A user can view the certification plated fixed to the stand to see if the stand certification is current.
Current certification is kept by the operator in a log or record kept on the premises and copies are sent to the department’s regional port/cargo manager. If the inspection stand has current certification signed by a qualified engineer then it meets the Standards.
The technical information in Section 4 of the Standards is for use by the qualified engineer.
The records of certification must be:
- held by the site/premises
- copied and sent to the regional port/department office
- displayed on the certification plate attached to the stand.
The stand does not have a certification plate. What should I do?
All records, including date of manufacture, inspection and certification reports and damage and maintenance reports, are to be kept by the owner/provider and kept in a log.
Confirm that the stand has a current certification by viewing the inspection and maintenance log/reports:
- report a missing plate to premises staff/supervisor
- verbally request a replacement plate
- complete an Accident/Incident Report requesting the plate is replaced within 2 working days
- advise department staff of situation and action.
If the log confirms that the stand has a current certification, the department regional port/cargo manager or supervisor may approve the stand’s use by biosecurity officers.
Premises must replace missing plates within 2 working days. If the plate is not replaced within the time frame, biosecurity officers will not use the stand until the plate is replaced.
Is the stand ID number unique to the premises, or unique Australia wide? Who provides this number?
The numbers are unique to the premises and location, and companies with multiple sites need to differentiate the sites.
Companies are responsible for developing their own unique numbering system.
Can the floor of the stand be more than one step height off the ground?
Yes. If the change in level from the ground is 300 mm or less, access may be gained without the provision of an intermediate step.
Where the change of level is greater than 300 mm, intermediate step/s must be provided as long as each step is a standard step height (not less than 150 mm and not greater than 215 mm). Steps must be designed to AS1657 Platforms, Walkways, Steps and Ladders.
Do I have to use gathering guides to secure and locate the container on the stand?
Gathering guides are a suggestion only. Stacking cones can still be used in place of, or in conjunction with, gathering guides. As long as the stand design and construction allows containers to be:
- located correctly on the stand
- prevented from moving horizontally under stability load combinations
- placed and moved by plant and equipment (via corner castings or fork tine holes).
Safety and training
What is an acceptable and safe distance for a forklift to be working around the stand when officers are performing a container inspection?
Each premises and department region must have a WHS risk management in place. This is to ensure the safety of all personnel working around inspection stands, the equipment used to move containers and any other vehicular traffic.
Are premises staff who load and unload containers required to be trained in or aware of AS 3711.10-2000 in the handling of containers when placing and removing containers from the stand?
Yes. This requirement may be audited by department staff.
How do personnel involved with the inspection of containers on stands, work out the weather conditions such as wind speed, in a simple and practical method?
It is the responsibility of the site/premises (under their own WHS procedures) to determine safe/unsafe weather conditions such as wind speed.
The site/premises is to advise all personnel if environmental factors are outside safe working practice.
your local regional office or
Cargo and Mail Section in Canberra about sea container hygiene requirements.