Shipping Containers and the International ILO Regulation

Shipping Containers and the International ILO Regulation: A Complete Guide to Conventions, Safety, and Labor Standards

Shipping containers are now a natural part of global logistics — millions of them cross the oceans every day, transporting goods worth trillions of dollars. A lesser-known fact, however, is that behind this seemingly simple steel box stands an elaborate system of international regulations that extends far beyond technical standards. Alongside the rules of the International Maritime Organization (IMO), the International Labour Organization (ILO) also plays a key role — a specialized UN agency that has shaped standards for working conditions, occupational safety, and social protection for more than a hundred years. In this article, we will explore in detail how the international ILO regulations affect the world of shipping containers, from safety in ports through the working conditions of seafarers to the impacts of containerization on the labor market.

What is the International Labour Organization (ILO) and how does it relate to shipping containers?

History and mission of the ILO

The International Labour Organization (ILO) was founded in 1919 as part of the Versailles peace system after the First World War. Since 1946, it has been a specialized agency of the UN system, headquartered in Geneva. Its unique tripartite structure — representation of governments, employers, and trade unions — makes it the only organization of its kind in the world.

The main mission of the ILO is to adopt international labor conventions and recommendations that set minimum standards in areas such as working hours, occupational health and safety (OHS), social security, freedom of association, or the prohibition of forced and child labor. As of 2026, the ILO has adopted more than 190 conventions.

Why does the ILO deal with shipping containers?

At first glance, it might seem that containers fall purely within the scope of technical standardization and maritime law. Reality, however, is more complex — and this is precisely where the ILO enters the picture. There are three main reasons:

1. Safety of workers handling containers — every container passes through the hands of dozens of people: from dock workers in ports through crane operators to truck drivers. A damaged or poorly marked container can cause fatal accidents.
2. Working conditions of seafarers transporting containers — a modern container ship is a floating workplace for hundreds of crew members, whose rights are protected precisely by ILO conventions.
3. Social impacts of containerization — the introduction of containers in the 1960s radically changed the nature of work in docks around the world. Millions of dock workers lost their jobs or had to fundamentally change their qualifications. The ILO responded to this transformation with specific conventions.

Interesting fact: While in 1960 unloading a ship with 10,000 tons of cargo took up to two weeks and required the work of hundreds of workers, today a container ship with a capacity of 24,000 TEU unloads its cargo within 24–48 hours with minimal human handling.

The following table provides a clear overview of which international organizations participate in regulating various aspects of container transport and where the competences of individual institutions lie:

Difference between IMO and ILO in container regulation

One of the most common mistakes is confusing the competences of the IMO and the ILO. Both organizations are part of the UN system and both deal with maritime transport — but each from a different angle. The following comparison will help understand these differences:

This division is not always clear-cut — an example of overlap is the CTU Code (Code for Packing Cargo Transport Units), which was created as a joint document of the IMO, ILO, and UNECE. We will discuss it in more detail in a separate chapter.

What is the International Convention for Safe Containers (CSC) and who administers it?

Origin and history of the CSC Convention

The story of the CSC (International Convention for Safe Containers) began in the 1960s, when containerization hit world logistics with the force of a hurricane. Standardized containers dramatically accelerated and cheapened transport, but the absence of uniform safety rules led to a growing number of accidents. Containers cracked under the weight of cargo, failed during stacking on ship decks, and fatal impacts occurred in ports.

“Container safety was not a priority in the 1960s — the priority was to transport as much cargo as possible as quickly as possible. It took several tragic accidents for the international community to wake up.” — from research of historical IMO sources

The International Maritime Organization (IMO), in cooperation with the UN and the United Nations Economic Commission for Europe (ECE), therefore initiated the creation of a uniform convention. On 2 December 1972, the International Convention for Safe Containers was adopted in Geneva. It entered into force on 6 September 1977 and has since become a cornerstone of container transport safety.

The Czechoslovak Socialist Republic ratified the convention as early as 8 May 1974, and it was implemented into Czechoslovak, and later Czech, law through Decree No. 62/1986 Coll. Compliance is supervised by the Czech Maritime Authority, which falls under the Ministry of Transport.

Main objectives of the CSC Convention

The CSC Convention pursues two basic, interrelated objectives:

1. Protection of human life and safety in the handling of containers — by setting minimum design requirements for strength and durability, introducing mandatory testing and inspection regimes, and protecting workers in ports, on ships, on railways, and on roads from accidents caused by container failure.
2. Facilitation of international transport — by introducing the principle of mutual recognition of CSC certification among contracting states, simplifying customs and port formalities, and limiting duplicate inspections.

CSC Plate (Safety Approval Plate)

The CSC plate, officially the Safety Approval Plate, is a metal plate permanently attached to every certified container. Without this plate, a container may not be legally used for international maritime or intermodal transport.

The plate consists of three parts:

• Upper third — indication of the CSC regulation issue, the approving authority (e.g., BV for Bureau Veritas, LR for Lloyd’s Register), the container type designation, serial number.
• Middle third — identification of the owner or operator, information on the treatment of the wooden floor (pest prevention), container manufacturer.
• Lower third — approval identification number, month and year of putting into service, maximum gross weight (in kg and LBS), field for the date of periodic inspection.

Every container must undergo periodic inspections under two regimes:

• PES (Periodic Examination Scheme) — first inspection within 5 years from the date of manufacture, then every 30 months.
• ACEP (Approved Continuous Examination Programme) — a continuous inspection programme that allows a more flexible schedule provided that the container undergoes inspections within an approved programme (e.g., at every significant repair or transshipment).

Which ILO conventions apply to dock work and container handling?

While the CSC Convention deals with the technical safety of containers, the ILO focuses on the safety and rights of the people who work with containers. Three key conventions form the backbone of dock work regulation:

ILO Convention C137 — Social Impact of New Methods of Cargo Handling (1973)

C137, officially the Dock Work Convention, was adopted on 25 June 1973 at the 58th session of the ILO General Conference. It was a direct response to containerization — the preamble of the convention explicitly states that “important changes are taking place in the methods of cargo handling in docks, such as the introduction of unit loads, roll-on/roll-off techniques, and increasing mechanization and automation.”

Main provisions of Convention C137:

• National policy on permanent employment (Article 2) — states undertake to promote permanent or regular employment of dock workers.
• Guarantee of minimum income (Article 2) — workers must be guaranteed a minimum number of hours worked or a minimum income.
• Registers of dock workers (Article 3) — registers must be established and maintained for all professional categories, with registered workers having priority in the assignment of work.
• Review of register levels (Article 4) — register levels must be regularly reviewed and any reductions must be accompanied by measures to minimize negative impacts on workers.
• Safety, health, and training (Article 6) — each member state must ensure adequate provisions on OHS and vocational training.

C137 entered into force on 24 July 1975. The Czech Republic, however, has not ratified this convention. As of 2026, the convention is open for denunciation (notice of termination) in the period from 24 July 2025 to 24 July 2026, which reflects the debate on its relevance in the era of fully automated ports.

ILO Convention C152 — Occupational Safety and Health in Dock Work (1979)

While C137 addressed the social upheavals caused by containerization, C152 focused on specific safety standards in docks. It was adopted on 25 June 1979 and remains to this day the most important reference framework for OHS in ports.

Convention C152 defines dock work as all activities related to the loading or unloading of ships and any related work. Key requirements include:

• Safety organization (Articles 4–7) — member states must establish that employers have primary responsibility for safety and ensure cooperation between employers and workers.
• Container terminals (Article 36) — every terminal for container handling must be designed and operated in a way that ensures the safety of workers.
• Lifting appliances and loose gear (Articles 22–25) — detailed requirements for testing before first use, periodic inspections (at least once every 12 months), marking with a unique identifier, record-keeping, and certification.
• Regular inspections — a responsible person must carry out visual checks before each use of lifting equipment.

The following table summarizes the key requirements of ILO C152 for equipment and the workplace:

C152 has been ratified by 27 states, mainly European and Latin American. The Czech Republic is not among them — the convention has not been ratified to date. However, the principles of C152 are reflected in Czech legislation through the Labour Code, the Act on Ensuring Further OHS Conditions (No. 309/2006 Coll.), and decrees relating to occupational safety in transport.

ILO Convention C155 — Occupational Safety and Health (1981)

Convention C155 represents a general OHS framework that applies to all sectors, including ports and logistics. It was adopted on 23 June 1981 and the Czech Republic (or the ČSSR) ratified it. It obliges states to establish a national OHS policy covering the design, manufacture, import, and placing on the market of equipment, including lifting appliances used in ports.

How does MLC 2006 relate to shipping containers?

What is the Maritime Labour Convention

The Maritime Labour Convention (MLC) was adopted by the ILO in 2006 and entered into force on 20 August 2013. It was formerly referred to as the “fourth pillar” of international maritime law — alongside the SOLAS (Safety of Life at Sea), MARPOL (protection of the marine environment), and STCW (training of seafarers) conventions. MLC 2006 consolidated dozens of older ILO maritime conventions into a single coherent document.

Obligations for commercial ships carrying containers

MLC 2006 applies to all commercial ships of 500 GT and above operating in international trade. This includes virtually all container ships, with the exception of small coastal feeders. These ships must carry:

• Maritime Labour Certificate (MLC) — confirmation of compliance with the requirements of the convention.
• Declaration of Maritime Labour Compliance (DMLC) — a declaration specifying how the shipping company meets the individual requirements.

The following table shows the key areas of MLC 2006 and their relevance for the crews of container ships:

Practical impacts for container ship operators

Inspections of compliance with MLC 2006 are carried out by authorized classification societies (e.g., DNV, Bureau Veritas, Lloyd’s Register). If deficiencies are found, the ship’s operation may be suspended or its certificate revoked — which in practice means the ship cannot set sail. For shipowners operating container ships, this represents a considerable financial risk, because every day a ship with a capacity of 20,000 TEU is delayed can mean a loss of hundreds of thousands of dollars.

What is the CTU Code and what is the relationship between IMO, ILO, and UNECE?

Origin and purpose of the code

The CTU Code, whose full name is the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units, is one of the best examples of cooperation between international organizations. It was created because poorly packed or secured cargo inside a container is the cause of a considerable number of accidents — from damage to goods through the overturning of the container during transport to endangering workers who open the container.

The CTU Code is not a legally binding convention, but a practical recommendatory document referred to by other binding regulations (e.g., SOLAS, specifically regulation VI/2 on the mandatory verification of the mass of containers — the so-called Verified Gross Mass, VGM).

Key requirements for containers

From the perspective of shipping containers, the CTU Code sets out:

• How cargo should be distributed inside the container (even weight distribution).
• How cargo should be secured against movement during transport (fastening elements, padding, lashing straps).
• Who bears responsibility for correct packing (the packer).
• How the container should be marked and documented.

Key principle of the CTU Code: Responsibility for safe packing lies with the packer, not the consignor or the shipowner. If the packer fails to follow the prescribed procedures, they bear full legal responsibility for any damage.

Practical significance for logistics companies

According to IMO estimates, up to 65% of cargo damage during maritime transport is caused by incorrect packing or securing inside the container. For Czech logistics companies and freight forwarders, this means that compliance with the CTU Code is not just a matter of compliance — it is a competitive advantage. Companies that demonstrate that their packing practices comply with the CTU Code reduce the risk of insurance events and increase credibility with customers.

What are the practical impacts of these regulations on Czech companies?

Obligations of owners and operators of containers

Every owner of a shipping container in the Czech Republic who wants to use the container for international transport must ensure:

1. Valid CSC certification — whether it is a new or a used container.
2. Periodic inspections — according to the PES or ACEP scheme, carried out by authorized inspection bodies (Lloyd’s Register, Bureau Veritas, DNV, etc.).
3. Recertification of older containers — if the container has lost CSC validity (e.g., the inspection deadline has passed or it has been significantly damaged), it must undergo recertification. This includes a check of structural strength, verification of tightness, inspection of the frame and corner castings, and an assessment of technical safety for further operation.

Czech companies such as Locont s.r.o. or Czechoslovak Lloyd offer complete CSC certification and periodic inspection services, including pressure and tightness tests, at terminals in the Czech Republic, Poland, and Slovakia.

Obligations of employers in ports and depots

Although the Czech Republic has no sea, it operates inland container terminals (e.g., METRANS in Prague-Uhříněves, Česká Třebová, Zlín), where containers are handled using heavy equipment. Employers at these workplaces must:

• Comply with the requirements of Act No. 262/2006 Coll. (Labour Code) and Act No. 309/2006 Coll. on ensuring further OHS conditions.
• Ensure periodic revisions of lifting equipment — gantry cranes, reach-stackers, portal cranes.
• Maintain documentation of inspections and revisions in accordance with the principles of ILO C152 (even though the convention has not been ratified, its standards represent good practice).
• Provide training of employees to the extent appropriate to the risks of the specific job position.

Sanctions and risks for non-compliance

Non-compliance with regulations can have serious consequences for Czech companies. A container without valid CSC certification may be detained in a port, leading to a delay of the entire shipment and penalties from the shipowner. Under MLC 2006, there is a risk of certificate revocation — the ship cannot set sail. In the event of OHS violations at terminals, Czech inspection authorities (State Labour Inspection Office) come into play, which can impose fines in the range of hundreds of thousands to millions of crowns.

What are the current trends and the future of regulation?

Port automation and new challenges for the ILO

Modern container terminals — from Rotterdam through Shanghai to Los Angeles — are undergoing a fundamental transformation. Autonomous cranes, automated guided vehicles (AGV), and robotic transshippers are gradually replacing human operators. The port of Rotterdam (Maasvlakte 2) already operates today with a minimal number of workers — most handling is provided by machines controlled by artificial intelligence.

For the ILO, this poses a new challenge: how to ensure social protection for workers in an industry that is heading towards almost full automation? Convention C137, which responded to the first wave of containerization in the 1970s, now seems outdated — it is no coincidence that it is open for denunciation in the 2025–2026 period.

There is discussion about the need for a new ILO convention or recommendation that would address:

• Retraining of workers whose jobs are disappearing as a result of automation.
• Ethical standards for the deployment of autonomous systems in ports.
• New models of social dialogue between operators of automated terminals, employees, and governments.

Digitalization of inspections and certification

Traditional ILO paper forms (Forms 1–4) for the registration of lifting equipment are gradually being replaced by digital platforms. Companies such as Onix offer cloud solutions that enable:

• Storing certificates digitally and linking them to a specific device using QR codes or RFID tags.
• Tracking inspection deadlines and receiving automatic notifications before they expire.
• Sharing documentation with inspectors or customers in real time.

This trend is inevitable — digital documentation is faster, more accurate, and safer than paper archives.

Environmental aspects

Although environmental protection does not fall primarily within the ILO’s agenda, environmental topics are increasingly affecting working conditions in ports. The transition to alternative fuels (LNG, methanol, ammonia) requires new safety protocols for dock workers. The ILO is cooperating with the IMO in this direction to develop standards for the safe handling of new types of fuels.

Revision of conventions

In addition to C137, which is currently open for denunciation, there is a broader debate within the ILO on the modernization of port standards. The tripartite working group for the Standards Review Mechanism has recommended a review of several older conventions with the aim of deciding whether they should be replaced by more modern tools that would better reflect the reality of automated transport in the 21st century.

Frequently Asked Questions (FAQ)

Does every shipping container need CSC certification?

Yes, every shipping container used for international maritime transport must have a valid CSC certification, confirmed by the CSC plate (Safety Approval Plate). Without this plate, the container may not be legally transported by sea. The exception is containers specially designated for air transport and some special containers.

How often are container inspections carried out under CSC?

The first inspection of a new container must take place within 5 years from the date of manufacture. Subsequent inspections are carried out every 30 months (2.5 years). If the container is included in the ACEP programme (Approved Continuous Examination Programme), the schedule may be more flexible, but inspections are ongoing.

What is the difference between PES and ACEP inspections?

PES (Periodic Examination Scheme) is a traditional scheme with fixed inspection deadlines (first within 5 years, then every 30 months). ACEP (Approved Continuous Examination Programme) is an approved continuous inspection programme that allows the container owner to carry out inspections more flexibly — for example, at every significant repair, maintenance, or return of the container to the depot. ACEP must be approved by the relevant authority.

Has the Czech Republic ratified ILO Convention C152?

No. The Czech Republic has not yet ratified ILO Convention C152 (Occupational Safety and Health in Dock Work, 1979) — nor Convention C137 (Dock Work Convention, 1973). However, the principles contained in these conventions are reflected in the Czech legal system through general OHS regulations, in particular the Labour Code and Act No. 309/2006 Coll.

Who bears responsibility for the safe loading of a container?

According to the CTU Code (IMO/ILO/UNECE Code), the primary responsibility for the correct and safe packing of a container lies with the packer — that is, the person or company that physically places the goods into the container. The packer is responsible for the even distribution of weight, securing the cargo against movement, and correct marking. In the context of SOLAS (regulation VI/2), the shipper is then responsible for the declaration of the verified gross mass (VGM).

Can a container without a CSC plate be transported legally?

A container without a valid CSC plate may not be legally transported in international maritime transport. If the port authorities find that the CSC plate is missing or invalid, the container will be detained. This can lead to significant delays in the shipment, penalties from the shipowner, fines, and in extreme cases even legal disputes.

What are the consequences of violating MLC 2006?

In the event of a violation of MLC 2006, the ship’s operation may be suspended or the Maritime Labour Certificate revoked, which means an effective prohibition on sailing. The inspection is carried out by the so-called Port State Control (state port inspection) in any port the ship visits — regardless of the flag it sails under. For the owner of a container ship, every day of delay represents a loss of tens to hundreds of thousands of dollars.

How do I recognize a valid CSC plate?

A valid CSC plate is a metal plate permanently attached (usually by riveting) to the container structure, most often on the left door end. It must be legible, without signs of damage or unauthorized manipulation. A key piece of information is the date of the next periodic inspection — if this date has already passed, the CSC certification is invalid. The size of the lettering of the designation “CSC SAFETY APPROVAL” must be at least 8 mm.

Which organizations can carry out CSC inspections in the Czech Republic?

CSC inspections and certification in the Czech Republic may only be carried out by authorized inspection bodies accredited for this activity. The best known include Lloyd’s Register, Bureau Veritas, DNV (Det Norske Veritas), and Germanischer Lloyd. In practice, most Czech companies work with specialized companies such as Czechoslovak Lloyd or Locont s.r.o., which provide a complete service, including arranging inspection by an authorized body.

How has containerization changed work in ports?

Containerization has caused the greatest revolution in dock work since the beginning of maritime transport. While in the 1950s, tens of thousands of workers in traditional ports such as London, Liverpool, or New York manually transshipped general cargo, today’s container terminals employ a fraction of that number. The work has changed from physically demanding manual activity to technically specialized positions operating cranes, automated systems, and logistics planning. This transformation led to the disappearance of traditional dock communities, but at the same time dramatically increased efficiency and safety — the number of fatal injuries in modern container terminals is orders of magnitude lower than in the era of manual transshipment.

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