Tackling the Evolving Challenge of Cargo Fires at Sea

Introduction

Cargo fires at sea are no longer isolated incidents. They are becoming more frequent, more complex to manage and far more severe in their consequences. What is emerging is not simply a rise in incidents, but a systemic risk that is reshaping maritime safety, operations and liability exposure.

For shipowners, operators, seafarers and insurers, this calls for a more practical and connected approach to risk management, one that reflects how these incidents develop in reality, rather than how they are addressed in theory.

A risk escalating on multiple fronts

Recent industry data and operational experience point to a clear and concerning trend: cargo fires are increasing in both frequency and severity.

According to the Cargo Incident Notification System (CINS), container cargo fires in 2023 occurred on average once every nine days, compared to around once every two weeks in 2020. 

This upward trend is also reflected more broadly across the industry. The International Union of Marine Insurance (IUMI) has reported a continued rise in large vessel fires. Similarly, the Nordic Association of Marine Insurers noted in its 2025 mid-year hull report that, since 2015, fires have accounted for 16 of the 26 claims exceeding USD 20 million, making them the leading driver of major losses.

Several key factors are driving this escalation:

• Misdeclared cargo remains one of the most persistent challenges. While many high-profile incidents involve dangerous goods on containerships, misdeclaration is also a concern in bulk shipping, where cargoes such as coal and fertilisers are often incorrectly declared. Investigations into scrap metal fire incidents have similarly revealed the presence of undeclared hazardous items, such as lithium batteries and gas canisters containing flammable gases.
• The rapid growth in lithium-ion battery shipments further illustrates how the risk landscape is changing. At the same time, regulatory provisions such as Special Provision 188 (SP188), originally intended to simplify the carriage of smaller batteries, are now being questioned for potentially creating gaps in declaration and traceability. While these risks are often associated with containerships and vehicle carriers, they are not confined to these sectors. Battery Energy Storage Systems (BESS), which consist of large numbers of lithium-ion batteries assembled into modules, are increasingly transported on bulk carriers and general cargo vessels, further extending the risk profile across a wider range of ship types.
• Limitations in onboard fire detection and extinguishing systems further compound the challenge. Existing systems are designed for incipient fires rather than large-scale or rapidly developing incidents, thereby reducing the window for effective intervention and increasing the likelihood of escalation.

These factors do not act in isolation. They reinforce each other, creating conditions where an apparently manageable incident can quickly escalate into a major casualty. Once a cargo fire takes hold, it often becomes significantly more difficult to control.

The consequences extend well beyond damage to the ship. They include serious risks to crew safety, substantial cargo losses, environmental impact, and prolonged disruption to operations and commercial arrangements.

One of the most pressing challenges in such cases is securing a suitable place of refuge. Although this can help stabilise the situation, it is often difficult to achieve in practice.

Despite the IMO’s guidelines on places of refuge (Resolution A.1184(33)), there is no obligation on coastal States to accept a ship in distress. As a result, responses are often influenced by environmental considerations, potential exposure to port infrastructure and local communities, as well as the availability of capacity, technical capabilities and, in some cases, the broader policy and political context.

In the case of fire-damaged ships, these concerns become even more acute. The presence of active fire, hazardous cargo and uncertain stability makes acceptance more difficult, often causing delays that can significantly worsen the overall outcome.

The gap between regulation and reality

A key theme emerging from both operational experience and industry discussion is the widening gap between regulatory frameworks and onboard realities. 

That is not to say regulation is standing still. Amendments to enhance fire safety requirements for Ro-Ro, passenger and cargo ships entered into force on 1 January 2026, introducing strengthened provisions on fire detection, video monitoring, water-based extinguishing systems and structural fire protection. While most requirements apply to ships built on or after this date, existing ships will also need to comply with certain provisions by their first survey after 1 January 2028.

In parallel, IMO’s Sub-Committee on Ship Systems and Equipment (SSE), at its twelfth session in March 2026, finalised draft SOLAS provisions on portable infrared thermal imagers for ships carrying containers on or above the weather deck, as well as draft amendments on water mist lances. These are expected to apply to ships constructed on or after 1 January 2032.

At the same session, an action plan has also been agreed to enhance fire safety on ships carrying new energy vehicles and battery electric vehicles. This includes a focus on Pure Car and Truck Carriers (PCTCs), alongside the development of interim guidelines on fire safety measures and video-based monitoring and detection systems, with draft SOLAS amendments targeted for entry into force in 2032.

However, the pace of regulatory development continues to lag behind the speed at which cargo profiles, ship design and operational exposure are evolving. This is particularly evident in the area of training and competence.

The IMO’s Sub-Committee on Human Element, Training and Watchkeeping (HTW) has identified gaps in the current STCW Convention and Code, including areas related to modern fire risks, new energy vehicles and emerging technologies. Against this backdrop, questions are being raised about whether current training frameworks fully reflect the complexity and nature of modern cargo fire scenarios. The growing presence of battery-powered vehicles, hazardous cargoes and high-density stowage arrangements presents challenges that go well beyond traditional fire response assumptions.

Although progress is being made, crew are often required to manage situations that exceed the limits of both equipment and training. Until this gap is narrowed, much of the responsibility will continue to sit at the operational level.

Moving from awareness to action

While the risk landscape continues to evolve, there is already a strong body of practical measures capable of reducing both the likelihood of cargo fires and the severity of their consequences. The challenge lies not in awareness, but in consistent implementation.

Effective risk mitigation depends on three areas: prevention, early detection and response capability.

1. Strengthening prevention at source

The first and most critical line of defence remains cargo integrity. Most of the serious incidents continue to trace back to misdeclared or undeclared cargoes.

At the centre of this approach is the strengthening of booking and declaration processes, supported by robust Know Your Customer (KYC) practices. Effective prevention depends on a clear understanding of who is shipping the cargo and what is being shipped.

Key measures include thorough documentation checks, scrutiny of vague or unusual cargo descriptions, and clear escalation processes. Due diligence should extend across the supply chain, including manufacturers, freight forwarders and testing bodies where relevant.

Training for booking staff is equally important to recognise high-risk cargo profiles and potential red flags. Digital screening tools, such as the WSC Cargo Safety Program, together with targeted vanning surveys (remote or physical inspection of containers at the time they are being packed), can provide an additional layer of control.

Industry collaboration plays an important role here. Initiatives led by organisations such as the Cargo Incident Notification System (CINS) and the World Shipping Council (WSC) continue to improve data sharing and promote more consistent standards.

Our publications such as Book it Right, Pack it Tight, Carefully to Carry, Risk Focus: Carriage of Vehicle Cargoes and Lithium Batteries Whitepaper provide practical guidance to support better decision-making at the earliest stage of the cargo journey.

2. Enhancing detection and onboard capability

Prevention alone is not sufficient. It must be supported by ongoing improvements in onboard detection and response.

This is an area where technology is beginning to play a more prominent role. The UK Club, through its partnership with the Safetytech Accelerator’s Cargo Fire and Loss Innovation Initiative (CFLII), is actively supporting the development of advanced detection solutions. These include multi-sensor systems, infrared monitoring, fibre-optic heat detection and other emerging technologies aimed at identifying combustion at its earliest stage.

The earlier a fire is identified, the greater the opportunity to contain it before it escalates into a major casualty.

3. Bridging the gap in training and preparedness

Alongside technological advances, training must evolve in step with the risks crew are increasingly expected to manage.

In response to these challenges, the UK Club has partnered with leading marine emergency responders REACT to provide bespoke workshops for members alongside an e-learning programme for containerships. Together, these initiatives address lithium-ion batteries, dangerous cargo and emergency preparedness, with a particular focus on decision-making under pressure. They aim not only to teach firefighting techniques, but to deepen understanding of fire behaviour, operational limitations, and the principles of a safe and effective response.

More broadly, this reflects a shift in thinking. It is no longer realistic or sustainable to expect crew to manage large, complex and rapidly escalating cargo fires through traditional methods alone. Training must therefore extend beyond firefighting itself to place equal emphasis on risk awareness, escalation thresholds and sound decision-making under pressure.

Conclusion

Cargo fires have become one of the defining safety challenges facing the maritime industry today.

While regulation continues to evolve, the risk must be addressed now through a more proactive approach grounded in operational reality and reinforced by stronger controls, earlier detection and more effective training.

Ultimately, reducing cargo fire risk will depend on narrowing the gap between what is required on paper and what is achievable in practice, while ensuring crew are equipped with the tools, information and training needed to respond safely, confidently and effectively.