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IMDG CODE, SHASHI KALLADA

UN 3166 VEHICLE

From 1st Jan 2012 Vehicles with internal combustion engines are regulated by IMDG Code (35-10) for sea transport. Depending on certain factors vehicles may become hazardous or non-hazardous consignment. Special Provisions 961 & 962 assigned to UN 3166 specifies this.

Vehicle on flatrack - Photo by shashi kallada

Special Provisions 961 and 962 are shown below in tabular format so we can compare the differences easily

Special Provision 961 ( Non Hazardous Vehicles )

Special Provision 962 ( Hazardous Vehicles )

The fuel tank(s) of the vehicle or equipment powered by a flammable liquid fuel is empty and installed batteries are protected from short circuit; Vehicles and equipment shall not show signs of leakage from batteries, engines, fuel cells, compressed gas cylinders or accumulators, or fuel tank(s) when applicable;
The fuel tank(s) of the vehicle or equipment powered by a flammable gas is emptied of liquefied or compressed gas, the positive pressure in the tank does not exceed 2 bar, the fuel shut-off or isolation valve is closed and secured, and installed batteries are protected from short circuit; or  for flammable liquid powered vehicles and equipment, the fuel tank(s) containing the flammable liquid shall not be more than one-fourth full and in any case the flammable liquid shall not exceed 250 l;
The vehicle or equipment is solely powered by a wet or dry electric storage battery or a sodium battery, and the battery is protected from short circuit. for flammable gas powered vehicles and equipment, the fuel shut-off valve of the fuel tank(s) shall be securely closed;
installed batteries shall be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries shall meet the requirements of the United Nations Manual of Tests and Criteria, Part III,subsection 38.3, unless otherwise approved by the competent authority; and
dangerous goods required for the operation of the vehicle or equipment such as fire extinguishers, compressed gas accumulators, airbag inflators, etc., shall be securely mounted in the vehicle or equipment.
The marking, labelling and placarding provisions of IMDG Code shall not apply.

For non-hazardous consignments Shipping Lines may ask shipper to give a statement in writing stating his/her consignment meets the requirement of SP 961.

Sample Statement:

“We confirm that the vehicle meets the requirements of IMDG code Special Provision 961, the fuel tank is empty and batteries are protected from short circuit”

Lines should proactively educate the shippers  that to make vehicles as non-hazardous consignment must meet conditions laid down in SP 961 (see above).

Just writing a letter won’t make haz into non-haz!

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About Shashi Kallada

24 years in Merchant Shipping Last 11 years working on Packaged Dangerous Goods *Ex Sailor *Ex P&O Nedlloyd Dangerous Goods Specialist *Ex Manager Global Dangerous Goods Maersk Line + MCC Transport + Mercosul line and Safmarine South African export) *A Freelance Photographer *An amateur Cyclist

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