Month: February 2012

SOLAS Chapter II-2 & IMDG Code

SOLAS Chapter II-2 Regulation 19 is about Carriage of Dangerous Goods. The purpose of this regulation is to provide additional safety measures in order to address the fire safety objectives for ships carrying dangerous goods.

Due to changes in IMDG Code the said chapter of SOLAS also underwent certain changes.

These changes are made by Maritime Safety  Committee RESOLUTION MSC.269(85) and came into effect from 1st Jan 2011.

Applicable to :

  1. New Ships – keel laid on or after 1st Jan 2011
  2. Existing ships must comply to the changes during the first renewal survey after 1st Jan 2011
  3. Cargo ships of 500 GRT or more and passenger ships constructed on or after 1st Sept 1984
  4. Cargo ships of less than 500 GRT constructed on or after 1st Feb  1992
  • Class 2.3 now divided into 2.3 and 2.3 with subsidiary risk 2.1
  • Lower flashpoint range for flammable liquids changed from ≤ 23°C to FP < 23°C
  • Upper limit of flashpoint is changed from FP 61°C to FP 60°C
  • Class 4.3 is divided into 4.3 Solids and 4.3 Liquids
  • Class 8 having a flashpoint FP ≥ 23°C and subsidiary risk of 6.1 need an additional bilge system as per regulation II-2/19.3.5
  • Class 9 which may emit flammable gas – electrical equipment must be of certified safe type of at least IIB T4, IP55.

 The Document of compliance for the carriage of dangerous goods as per regulation II-2/19.4 of the SOLAS Convention will be replaced for existing ships during next class renewal.

 Table 19.3 is replaced by the following table:

Notes below

11 When .mechanically-ventilated spaces. are required by the IMDG Code.

12 Stow 3 m horizontally away from the machinery space boundaries in all cases.

13 Refer to the IMDG Code.

14 As appropriate for the goods to be carried.

15 FP means flashpoint.

16 Under the provisions of the IMDG Code, stowage of class 5.2 dangerous goods under deck or

in enclosed ro-ro spaces is prohibited.

17 Only applicable to dangerous goods evolving flammable vapour listed in the IMDG Code.

18 Only applicable to dangerous goods having a flashpoint less than 23ºC listed in

the IMDG Code.

19 Only applicable to dangerous goods having a subsidiary risk class 6.1.

20 Under the provisions of the IMDG Code, stowage of class 2.3 having subsidiary risk class 2.1

under deck or in enclosed ro-ro spaces is prohibited.

21 Under the provisions of the IMDG Code, stowage of class 4.3 liquids having a flashpoint less

than 23ºC under deck or in enclosed ro-ro spaces is prohibited.

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Application of IMDG Code

IMDG Code is applicable to all ships to which SOLAS 1974, as amended, applies and which are carrying Dangerous Goods.

Regulation 1 of Part A, Chapter VII, of SOLAS 1974, as amended, defines dangerous goods as the substances, materials and articles covered by the IMDG Code.

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Packagings for substances which may become liquid

IMDG Code prohibits certain type of packagings for substances which may become liquid during transport. Below are the list of packaging prohibited

Packagings

Drums: 1D and 1G

Boxes: 4C1, 4C2, 4D, 4F, 4G and 4H1

Bags: 5L1, 5L2, 5L3, 5H1, 5H2, 5H3, 5H4, 5M1 and 5M2

Composite: 6HC, 6HD2, 6HG1, 6HG2, 6HD1, 6PC, 6PD1, 6PD2, 6PG1, 6PG2 and 6PH1

 

Large packagings

Flexible plastics: 51H (outer packaging)

 

IBCs

For substances of packing group I:

All types of IBCs

For substances of packing groups II and III:

Wooden: 11C, 11D and 11F

Fibreboard: 11G

Flexible: 13H1, 13H2, 13H3, 13H4, 13H5, 13L1, 13L2, 13L3, 13L4, 13M1 and 13M2

Composite: 11HZ2 and 21HZ2.

FICHA DE EMERGÊNCIA

Brazilian Dangerous Goods Regulations, Transporte Terrestre de Produtos Perigosos ( Land Transport of Hazardous Products ) requires an emergency card to company each dangerous goods carried by a vehicle. Section 5.4.2 ” Outras informações e documentos”, Other information and documents, 5.4.2.1(d) states as below

Emergency card to be used in  case of any accident and incident with instructions provided by the consignor as information received from the manufacturer or importer of the load, which contains :

1.The nature of the risk posed by dangerous products transported, as well as emergency measures;

2. Provisions for first aid or safety measures when the substance come in contact with any person

3. Measures to be taken in case the package is broken or there is a spillage

4. In case if the vehicle fails measures to be taken for continuance of journey.

5. Phone numbers of emergency fire department, police, civil defense agency environment and, when appropriate, competent bodies for Classes 1 and 7, along the route.

6. Incompatible products

There are requirements about the format of the document ( FICHA DE EMERGÊNCIA ) with red side stripe etc. I have done a very crude translation of the regulation from Portuguese to English. Readers knowing Brazilian regulations are requested to correct me for updating most accurate information here

Responsibilities in IMDG Code

Most of the sections in IMDG Code prescribes the action but does not specifically point out the party or person who is responsible for that action.  The shoulder(s) which need to bear the responsibilities of actions set out in IMDG Code may vary according to the individual countries laws. It remains the prerogative of each government to assign the respective responsibilities.

However regarding Classification of dangerous goods IMDG Code specifically states it is the responsibility of shipper or the competent authority where specified in the Code.

Responsibility of classification of most of the classes remains with shipper but IMDG Code delegates the responsibility to competent authority in below cases

 Class 1 ( Explosives ) : Classification shall be approved by the competent authority of the country of manufacture.

 Class 4.1 Self-reactive substances: Which are not listed in section 2.4.2.3.2.3, IBC520 or T23

 Class 5.2 Organic Peroxides: Which are not listed in section 2.5.3.2.4, IBC520 or T23

Segregation of Dangerous Goods

Rules pertaining to segregation of dangerous goods is explained in chapter 7.2 of IMDG Code.

Chapter 7.2 is divided as below

  • 7.2.1 General
  • 7.2.2 Segregation of packages
  • 7.2.3 Segregation of cargo transport units on board container ships
  • 7.2.4 Segregation of cargo transport units on board roll-on/roll-off ships
  • 7.2.5 Segregation in shipborne barges and on board barge-carrying ships
  • 7.2.6 Segregation between bulk materials possessing chemical hazards and dangerous goods in packaged form
  • 7.2.7 Segregation of goods of class 1
  • 7.2.8 (Reserved)
  • 7.2.9 Segregation for goods of class 7

Chapter 7.2.2 Rules for Segregation of packages one must follow when consolidating various dangerous goods into a shipping container. There are various rules including General. Segregation Groups, Special Provisions for segregation and Segregation within containers.

Below are the Ideal steps to be taken while checking segregation between two dangerous goods packages.

1. Check the general rules

2. Determine the class and subsidiary risk(s) of each substance, if any

3. Determine if the dangerous goods are according to Limited Quantities, Excepted Quantities or special provisions of segregation if so follow same

4.Determine for each substance if there is any specific segregation
requirement in column (16) of Dangerous Goods List in Volume 2 or transport document

4.a.1 If there are no segregation requirements in column (16) of Dangerous Goods List and in the transport document then use segregation table in accordance with the general rules to reach the conclusion whether allowed to be stuffed in same container or not

4.b.1 If there are segregation requirements in column (16) of Dangerous Goods List and in the transport document use Segregation table taking into account any specific segregation provisions and the general rules and determine the specific segregation provisions (eg; segregation groups) then ensure the most stringent requirements are taken. you will get the answer whether allowed to be loaded in same container or not.

If any segregation rule is applicable between the packages then both cannot be loaded in same container except for segregation provision “away from” which may be loaded with the approval of competent authority.

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MARPOL

International Convention for the Prevention of Pollution from Ships (MARPOL), 73/78, is a combination of two treaties adopted in 1973 and 1978 by International Maritime Organisation.

This convention includes regulations to prevent and minimize pollution from ships. It has six annexes as below.

Annex I   

Regulations for the Prevention of   Pollution    by Oil

Annex II    

Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk

Annex III   

Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form

Annex IV   

Prevention of Pollution by Sewage from Ships

Annex V 

Prevention of Pollution by Garbage from Ships

Annex VI    

Prevention of Air Pollution from Ships

IMDG Code 35-10 & MARPOL

MARPOL Annex III , Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form,  is reproduced in IMDG Code 35-10 section 1.1.2.2.  Annex III has 8 regulations and an Appendix as below

Regulation 1       = Application

Regulation 2       = Packing

Regulation 3       = Marking and Labelling

Regulation 4       = Documentation

Regulation 5       = Stowage

Regulation 6       = Quantity Limitation

Regulation 7       = Exceptions

Regulation 8       = Port State control and operational  requirements

Appendix

CRITERIA FOR THE IDENTIFICATION OF HARMFUL SUBSTANCES IN PACKAGED FORM

For the purposes of this Annex, substances identified by any one of the following criteria are harmful substances:

Section 2.9.3 of IMDG Code 35-10 sets out the classification criteria for Environmentally hazardous substances (aquatic environment)

Chapter 2.10 defines Marine pollutants as “substances which are subject to the provisions of Annex III of MARPOL 73/78, as amended”

Index of IMDG Code 35-10 and Column 4 in Dangerous Goods Lists in chapter 3.2 identifies Marine Pollutants with symbol P.

However when a substance, material or article possess the properties of  marine pollutant but not identified in IMDG Code as such it shall be transported according to the relevant provisions for carriage of marine pollutants.

Packages containing marine pollutants must be marked with the recognized chemical name of the marine pollutant and bear the Marine Pollutant mark set out in section 5.2.1.6.3 of IMDG Code 35-10 which is shown below

dimensions shall be at least 100 mm × 100 mm, except in the case of packages of such dimensions that they can only bear smaller marks.

However single packagings and combination packagings  having :
– a net quantity of 5 l or less for liquids; or
– a net mass of 5 kg or less for solids

need not be marked.

Containers containing marine pollutants must be marked with marine pollutant mark having minimum dimensions of 250 mm x 250 mm one on each side and one on each end of the container even if the container contains packages not required to bear the marine pollutant mark

Nail Polish Remover

Nail polish

Nail polish removers are mainly organic solvents used for removing nail polish. Most of the nail polish removers contain acetone a highly volatile and flammable liquid. Some are made containing ethyl acetate.

ACETONE is listed as UN  1090 & ETHYL ACETATE UN 1172 in IMDG Code.

Acetone

Some of the acetone free nail polish removers contain Ethanol, Methyl Ethyl Ketone, Denatonium benzoate, other solvents and colours.  

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Photographic Chemicals

A black-and-white image showing a (monochrome) photograph being developed.

Before the arrival of digital cameras photographs has to have the touch of a professional if not we cannot see photos we clicked.  The film need to be processed and later made into visible image.

Matte glass cork next to cilindrical tube

Various chemicals are used in this process. Processing of films and light sensitive paper in photography is still widely used.   Certain of these chemicals are considered as hazardous goods in transport regulations.

Some of the photographic chemicals are listed below

  • (4-(N-ethyl-N-2-methanesulfonylaminoethyl)-2-methylphenylenediaminesesquisulfate monohydrate
  • Potassium hydroxide
  • Potassium carbonate
  • N-ethyl-N-2-methanesulfonylaminoethyl)-2-methylphenylenediaminesesquisulfate monohydrate
  • Ethylenediaminetetraacetic acid
  • Diethylene triamine pentaacetic acid
  • Nitrilotriacetic acid

Since these chemicals falls under Clas 8 ( corrosive substances ) acids and alkalis keeping both in same shipping container is prohibited by IMDG Code. However special provisions of segregation in IMDG Code allows with certain restrictions such as package size 30 L or 30 KG packing groups II & III acids and alkalis to be shipped together in same container provided the shipment meets the requirement specified in related segregation provisions.

If you are shipping out photographic chemicals by sea going containers or carrying it with you by air you need to check with the carrier for applicable regulatory compliance or restrictions.

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