The difference between pre-carriage and on-carriage needs to be understood very clearly by the exporter, importer, shipping line, forwarder, clearing agent, insurance and everyone else involved in order to ensure that the relevant roles, responsibilities, costs and risks are clearly defined..
To read more click on Difference between pre-carriage and on-carriage
From 1st January 2016 the 37th amendment of IMDG Code published in 2014 is in force.
Segregation of dangerous goods have different provisions like, general provisions, segregation inside containers, Segregation on container ships, Segregation on ro-ro ships, Segregation on general cargo ships, Segregation between barges on board barge carrying ships.
Click on image below to access general segregation table and take “Three Steps” to check segregation within a container.
Before checking the Segregation Table, you must be aware that there are;
ON 22nd May2014 The Maritime Safety Committee adopted the amendment to IMDG Code 37th amendment in accordance with article VIII(b)(iv) of the International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended. When the clock strikes midnight on 31st December 2015 officially IMDG Code 37th amendment comes into force.
2015 witnessed fires on board container ships and the devastating Tianjin Explosions. When the investigations are over the results may fix the reasons or point to suspected smoking guns. Accidents do happen but on compliance to the regulations increases the possibility of accidents and swells the damaging effects of it many folds.
The only way to prevent or reduce the possibility of accidents out at sea while carrying packaged dangerous goods is by strict adherence to IMDG Code. This can only be achieved by properly planned and maintained initial and retraining programmes for all persons concerned with the transport of dangerous goods.
Another step is to correct the copies of IMDG Code with editorial corrections issued by International Maritime Organization. This is very important as certain typographical corrections directly relates to segregation, stowage and packaging.
The Errata and Corrigenda to IMDG Code 37th amendment issued in December 2015 can be downloaded at http://tinyurl.com/pl4lac8 . After downloading user must correct each section with pen and where necessary cutting and pasting the hard copy.
I wish all the readers a Happy, Safe and Successful 2016!
Wish all readers a joyous holiday season and a wonderful new year filled with safety and success !
There are two reasons for nitrogen padding or blanketing in tank containers. “Safety” & increasing product “Shelf Life”. In both the cases this is achieved by reducing oxygen level in tank. Basic composition required to start a fire is Oxygen, Fuel & Ignition source. Nitrogen padding removes or reduces the oxygen to such level to avoid possibility of ignition. Food industry use nitrogen padding to avoid oxidation and increase shelf life.
Why nitrogen? Nitrogen is widely used in padding as its inexpensively available. Carbon dioxide or argon can also be used for padding purpose however carbon dioxide may be reactive to certain cargo. Oil tanker ships employ inerting of cargo tanks. Inert gas supply to tanks can be done by scrubbing & cooling of flue gas from ship’s boilers. Reducing the ullage oxygen level achieves high level of safety in storage and during transport.
Lower explosive limit (LEL) is the lowest concentration of vapour or gas in air which can be ignited and Upper Explosive Limit (UEL) is the highest concentration of vapour or gas in air which can be ignited. Both LEL & UEL is measured in per cent. LEL & UEL may vary depending on the pressure and temperature. Hydrocarbon oil vapours may burn with less than 11% oxygen in air. Achieving oxygen level to below certain percentage for different cargo is necessary for correct inert condition.
Flammability range of crude ethanol is LEL 3.3% to UEL 19%. To achieve inert condition for ethanol oxygen need to be limited to below 8% LOC (Limiting Oxygen Concentration).
In ISO Tank containers purging the tank can be done by pressure or by mixing and venting. Purging by pressure require more nitrogen. Up to 6 x volume is required to achieve level of oxygen to 0.5%. In mixing and venting with 4 x volume change of nitrogen can achieve oxygen level to 0.4 %.
Loading under nitrogen blanket requires the tank to be pressurized with nitrogen then commence loading. While loading the addition of cargo will increase the pressure which can be maintained by operating airline valve. Correct safe operation procedure must be strictly adhered to while carrying out this operation.
Apart from safety nitrogen blanketing can increase the product shelf life by arresting oxidation. Nitrogen is used in blanketing edible oil to avoid rancidity, in wine shipments and in many other food grade products.
UASC, United Arab Shipping Agency (India) Pvt Ltd, organized a Workshop for Safe Transport of Dangerous Goods by Sea under SOLAS & MARPOL Conventions. The two days workshop, held from 11th to 12th of December 2015, covered General awareness Familiarization + Documentation and Security Provisions under IMDG Code & chapter XI-2 of SOLAS 74, as amended, and of part A of the International Ship and Port Facility Security (ISPS).
Participants deliberated the current practices of industry against regulatory requirements of IMDG Code.
The workshop was conducted by www.shashikallada.com
The Northern India Steamer Agents Association or NISAA organized a two days Workshop on Dangerous Goods at Delhi on 20th 21st of November 2015. The organizers, NISAA, gathered 45+ delegates from various sectors of shipping industry, which included, Liners, CFSs, ICDs, Rail Operators & Forwarders under one roof deliberating latest Rules and Regulations for safe handling of Dangerous Goods in Multimodal Transport.
The workshop on IMDG Code, attended by 20 organizations under NISAA’s umbrella, was conducted by Shashi Kallada who explained basic regulatory frameworks of IMDG Code, International Rail, Road, River transport of packaged dangerous goods from shipper to consignee through rail, road, river haulage and carriage by sea under SOLAS, 1974, as amended & MARPOL 73/78 conventions of IMO and country specific differences of India’s Major trading partners such as U.S., U.K., EU, CIS, Japan, Korea, OECD & more.
Participants actively took part in discussions, deliberations and raised questions on day to day practice v/s regulatory norms for enhancing safety and simplifying the process for shipping, handling and temporary keeping of dangerous goods in their custody.
Shridhar Subramaniam, EC Member of NISAA together with Atul Sachdev Secretary of NISAA kick-started the program. The two days action packed event was concluded by certification of attendance hosted by Capt. Ajay Kaura, President of NISAA, who reiterated the importance of safe handling of dangerous goods in multimodal transport.
NISAA, took another major step in their continuous support to industry by organizing this event.
Organisations attended the workshop:
Water, water, everywhere, And all the boards did shrink; Water, water, everywhere, Nor any drop to drink.”
= The Rime of the Ancient Mariner
Transport regulations classifies substances (solids and liquids) which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities under Class 4.3.
Some of these substances may emit flammable gases which forms explosives mixtures with air and can be ignited with even an unprotected light bulb.
The decision logic for classification of Class 4.3 is based on Test methods are given in the United Nations Manual of Tests and Criteria, part III, 33.4.1.
1. Occurrence of spontaneous combustion at any step during the test, or
2. At least 1 litre of flammable gas is generated by per kilogram of substance in an hour.
An example of Class 4.3 is ‘CALCIUM CARBIDE’, when in contact with water or moisture in air calcium carbide rapidly evolves acetylene, a highly flammable gas, which may be ignited by the heat of the reaction.
According to news reports the infamous ‘Tianjin Blast’ involved vast quantities of calcium carbide.
Another chemical under Class 4.3 is ‘ALUMINIUM PHOSPHIDE’ which is also toxic. Aluminium Phosphide when in contact with moist air or water evolve phosphine, a spontaneously flammable and highly toxic gas.
Pesticides made from aluminium phosphide falls under Class 6.1, toxic, however it will still evolve deadly phosphine gas. The rate of production is lesser than the classification criteria of Class 4.3.
All substances under Class 4.3 must be packed in hermetically sealed packagings. And certain solid substances permitted in bulk containers must be under a nitrogen blanket.
Packing Group for Class 4.3 is assigned on basis of reaction to water and rate of evolution of flammable gas as per below table.
Shipboard Emergencies: if a package or container carrying Class 4.3 is on fire the firefighting is to be carried out as per FIRE SCHEDULE Golf.
General comments: In a fire, exposed cargoes may explode or their containment may rupture. Fight fire from a protected position from as far away as possible. Use of copious quantities of water at once is recommended to cool down the heat radiation of the fire and to cool down heated cargo nearby. Only as a secondary effect, water will start or intensify burning of that material. Do not use small quantities of water – this will react strongly.
On Deck Container on Fire: If the fire is not igniting nearby cargoes, let the fire burn. Otherwise, cool the burning transport unit with copious quantities of water. Try to avoid getting water into the container.
Under Deck Container on Fire: Stop ventilation and close hatches. The fixed gas fire-extinguishing system should be used. If this is not available: Do not use water onto the material in enclosed spaces under deck. With open hatches, cool nearby cargo with copious quantities of water, although the fire could intensify for a short period of time. Do not spray small quantities of water onto the fire, use copious quantities of water.
Special Firefighting Media: LITHIUM, non-pyrophoric and MAGNESIUM POWDER require the use of dry Lithium chloride or dry sodium chloride or graphite powder to extinguish the fire. Do NOT use water or foam.
Response to spillage on board ships are divided into different categories of Class 4.3 substances as below.
Class 4.3 label is upper half symbol of flame (black or white), figure ‘4’ in bottom corner and background “blue”. The colour blue signifies dangerous reaction with water.
There are substances which are outside the classification criteria of Class 4.3 but still dangerous when carried in large quantities such as Direct Reduced Iron (DRI). Direct Reduced Iron is classified as “MATERIAL HAZARDOUS IN BULK” under The International Maritime Solid Bulk Cargoes (IMSBC) Code.
Class 4.2 includes: Pyrophoric substances, which are substances, including mixtures and solutions (liquid or solid), which, even in small quantities, ignite within 5 minutes of coming into contact with air. These substances are the most liable to spontaneous combustion & Self-heating substances, which are substances, other than pyrophoric substances, which, in contact with air without energy supply, are liable to self-heating. These substances will ignite only when in large amounts (kilograms) and after long periods of time (hours or days).
Classification of Pyrophoric Substances
Pyrophoric means “fire-bearing”. United Nations Manual of Tests and Criteria, part III, 33.3.1.4 & 33.3.1.5 lays out the criteria for testing and classification of pyrophoric solids and liquids respectively. These are extremely hazardous substances as they can start burning upon coming into contact with air. Pyrophoric liquids are comparatively easier to handle as solids require glow box sealed and flushed with inert gas. Liquids are stored in hydrocarbon solvents or in mineral oil. These substances are stored and transported in specialized cylinders and tanks.
Procedure for testing pyrophoric solid: One to two ml of the powdery substance to be tested should be poured from about 1 m height onto a non-combustible surface and it is observed whether the substance ignites during dropping or within 5 minutes of settling. This procedure should be performed six times unless a positive result is obtained earlier. If the sample ignites in one of the tests, the substance should be considered pyrophoric and should be classified in packing group I of Division 4.2.
Procedure for testing pyrophoric liquid: A porcelain cup of about 100 mm diameter should be filled with diatomaceous earth or silica gel at room temperature to a height of about 5 mm. Approximately 5 ml of the liquid to be tested should be poured into the prepared porcelain cup and it is observed if the substance ignites within 5 minutes. This procedure should be performed six times unless a positive result is obtained earlier. If a negative result is obtained, then A 0.5 ml test sample should be delivered from a syringe to an indented dry filter paper. The test should be conducted at 25 ± 2 °C and a relative humidity of 50 ± 5%. Observations are made to see if ignition or charring occurs on the filter paper within five minutes of addition of the liquid. This procedure should be performed three times using fresh filter paper each time unless a positive result is obtained earlier.
Finely divided aluminium and iron have pyrophoric properties.
Depending on their properties organometallic substances may be classified in class 4.2 or 4.3 in accordance with section 2.4.5 of IMDG Code.
Loading on board ships and emergency response
In the old days when size of ships were smaller certain pyrophoric substances were prohibited to be carried on board vessel when she is also carrying Class 1 explosives. This is to prevent a fire when there is explosive cargo on board. Today the rule is to keep the pyrophoric container “Separated longitudinally by an intervening complete compartment or hold from” Class 1 explosives. Thus on deck stowage will be;
Vertical: Prohibited,
Athwartships: Prohibited,
Fore & Aft: Minimum horizontal distance of 24 meters.
There is no spillage control measures as within 5 minutes of coming out of packages these substances will start burning hence spillage schedule is firefighting.
Examples of Pyrophoric substances: tert-Butyllithium, Diethylzinc, Triethylaluminium
Self-heating substances & Classification: Self-heating of a substance is a process where the gradual reaction of that substance with oxygen (in air) generates heat. If the rate of heat production exceeds the rate of heat loss, then the temperature of the substance will rise which, after an induction time, may lead to self-ignition and combustion. The ability of a substance to undergo oxidative self-heating is determined by exposure of it to air at temperatures of 100 °C, 120 °C or 140 °C in a 25 mm or 100 mm wire mesh cube.
Pistachio: Author Paolo Galli
Section 33.3.1.6 of UN Manual for Tests and Criteria lays down the procedure for classification and assignment of packing group for Class 4.2 Self-heating substances. Oily cotton waste and wet cotton are classified under self-heating as they may start fire spontaneously. Most oil bearing seeds have this nature. Copra when loaded on ships must be kept as dry as reasonably practical & protected from all sources of heat. Provide a good through ventilation for bagged cargo. During the voyage regular temperature readings shall be taken at varying depths in the hold and recorded. If the temperature of the cargo exceeds the ambient temperature and continues to increase, ventilation shall be closed down.
There are four factors which determine or contribute to a substance to under self-heating or spontaneous combustion.
Compost of organic material can run into spontaneous combustion. When self-heating causes temperature to rise up to 150 Deg C – 200 Deg C self-ignition occurs. Smothering the compost pile top layer and waiting for fire to die down may take 1 to 2 years! A container stuffed with pistachio can show the properties of spontaneous combustion. Container must be stowed protected from sunlight to avoid possibility of same.
A young woman of Russian origin is reported to be attacked by acid at Varanasi in India. She is living in a rented house, apparently came to India to experience the country, its culture, at the most holiest among holy places in this sub continent. The suspect, who carried out this dastardly act is the son of the landlord of this unfortunate woman. She has suffered chemical burns on her right shoulder and face.
The attack is carried out “with the intention to disfigure, maim, torture, or kill”[1] The long term consequences of these attacks may include blindness, as well as permanent scarring of the face and body along with far-reaching social, psychological, and economic difficulties [2]
Acid attack victim: Cambodia, 2007
How much more a person can go down in his or her status for throwing acid on another person? Why we do not have severe punishments and/or education to prevent such horrible incidents?
As per studies conducted: Motivations for attacks against women in India are: spurned love and affection, sexual jealousy, economic or land disputes, hate or revenge (http://cgi.unc.edu/research/carolina-papers/health-papers.html)
More than stronger legal provisions we need to educate the society how heinous ,uncultured and dastardly is to attack an unsuspecting victim by throwing chemicals on him or her. A change in cultural outlook is essential to stop acid attack!
Among all hazardous classes, 1 to 9, Class 4 has very diverse nature of divisions. In a series of articles let’s try to understand in layman’s term what these divisions represent as danger during transport by sea, what are the differences in emergency response out at sea for these divisions.
Class 4 is divided as below
Class 4.1 Flammable Solids
Class 4.1 Solid Desensitized Explosives
Class 4.1 Self-Reactive Substances
Class 4.2 Pyrophoric Solids
Class 4.2 Pyrophoric Liquids
Class 4.2 Self-Heating Substances
Class 4.3 Substances Which, In Contact With Water, Emit Flammable Gases
This article will cover description of Class 4.1 Flammable Solids & Solid Desensitized Explosives.
What are solids? Definition in the transport regulations says “Solids are dangerous goods, other than gases, that do not meet the definition of liquids in this regulation”. When we look at the definition of liquids we will know that paper or a book is solid. But will it make paper or book Flammable Solids? Answer to this question is, partially, YES! They are flammable but, paper and book, not flammable solids for transport regulations. So how do we decide which solids are flammable as per transport regulations?
For transport regulations, solids are flammable if they can be ignited by brief contact with an ignition source such as a burning match, and if the flame spreads rapidly (Readily combustible) or trough friction. This does not take into consideration of deliberately setting goods on fire, like in the case of arson.
United Nations Manual of Tests and Criteria, part III, 33.2.1, sets out the test procedure for flammable solids.
In the test if the burning time is less than 45 seconds and the flame passes through the wetted zone then the solids are considered as Class 4.1, packing group II. If the wetted zone zone stops the flame propagation for at least 4 minutes and if the burning time is less than 45 seconds packing group III is assigned.
Solids which may cause fire through friction are to be classified in class 4.1 by analogy with existing entries (such as matches) until definitive criteria are established and packing group for these solids shall be assigned by analogy with existing entries or in accordance with any appropriate special provision.
For metal powders or metal alloys if the zone of reaction spreads over the whole length of sample in 5 minutes or less packing group II is assigned. Packing group III should be assigned to metal powders if the reaction spreads over the whole length of the sample in more than five minutes but not more than ten minutes.
During test if the result of screening test and the burning rate test are negative then substance is not considered as readily combustible solids of class 4.1
Examples of Flammable Solids
Flammable solids and metal powders have different firefighting requirements. Most flammable solids are assigned with general fire schedule, which is to Create water spray from as many hoses as possible. For metal powders the recommendation is “If the fire is not igniting nearby cargoes, let the fire burn. Otherwise, cool the burning transport unit with copious quantities of water. Try to avoid getting water into the container.”
Explosives substances which are wetted with alcohols or water or diluted with other inert substances forming a homogeneous solid mixture suppressing their explosive properties are classified as solid desensitized explosives. The desensitizing agent is to be distributed uniformly throughout the substance. If this substance encounter lower temperature during transport which may freeze the water a suitable solvent like alcohol may be added to lower the freezing point. However the compatibility of the solvent with substance must be checked. Some of the solid desensitized explosives under class 4.1 is classified as Class 1 explosives when in dry state.
For solid desensitized explosives the firefighting on board ships is more dangerous due to the nature of cargo. When involved in fire the sudden short term events such as explosion may endanger the safety of the ship. All crew must be made aware that there is high explosion hazard with this cargo and must undertake firefighting from well protected area.
If the cargo is not on fire but spilled from ruptured packages the crew must avoid all sources of ignition which includes naked lights, unprotected light bulbs, electric handtools, friction and must wear non-sparking footwear. By using fire hose the spilled cargo must be wetted and never allowed to get dried. Wash away the spilled material over board with copious quantity of water.
Liquids, or mixtures of liquids, or liquids containing solids in solution or suspension which gives off a flammable vapour at or below 60°C closed-cup test is classified as flammable liquid in transport regulations. Flashpoint is the lowest temperature of the liquid at which its vapour forms an ignitable mixture with air.
GHS & Transport Regulations Classifies flammable liquid under below Categories
Packing group assist the shipper to select the right package.
Certain flammable liquid which are viscous, such as paints, enamels, varnishes, adhesives and polishes, having a flashpoint of less than 23°C may be placed in packing group III provided it meets the conditions laid down in part III, chapter 32.3, of the United Nations Manual of Tests and Criteria, which includes:
Flammable liquid which has flashpoint of more than 35°C may be exempted from provisions of IMDG Code if it does not sustain combustion. The criteria for a liquid to be not sustaining combustion is if;
Flammable Liquid also includes
Example: Benzoic Acid Molten has a flashpoint of 121 Deg C and its melting point is 122 Deg C, When transported as Molten the cargo temperature is greater than 122 Deg C which is higher than its flashpoint.
2. substances transported or offered for transport at elevated temperatures in a liquid state, which give off a flammable vapour at temperatures equal to or below the maximum transport temperature.
Example: Bitumen
While filling flammable liquid into packages the filler must ensure to take measures to prevent dangerous electrostatic discharge and must strictly adhere to the degree of filling for tanks.
Flammable liquid may have additional risk of toxicity or corrrosivity. For those liquids, having multiple hazards and are not listed by name in IMDG Code the shipper must classify them according to part 2.0 & 2.3 of the Code taking great attention to precedence of hazards, Classification of substances, mixtures and solutions with multiple hazards.
Class 3 also includes liquid desensitized explosives which are explosive substances dissolved or suspended in water or other liquid substances, to form a homogeneous liquid mixture to suppress their explosive properties. Follwing are the entries in IMDG Code for liquid desentisized explosives:
Emergency Response on board ships
For carriage on board ships flammable liquids are permited to be loaded on or under deck as per the stowage category assigned in IMDG Code for a particular UN Number with the assigned packing group and as per Document of compliance for ships carrying dangerous goods under the provisions of regulation II-2/19 of the 1974 SOLAS Convention, as amended.
In Document of Compliance permitted stowage in under deck spaces are separately listed for
Class 3 Flashpoint < 23°C
Class 3 Flashpoint ≥ 23°C to ≤ 60°C
Class 6.1 liquids Flashpoint < 23°C
Class 6.1 liquids Flashpoint ≥ 23°C to ≤ 60°C
Class 8 liquids Flashpoint < 23°C
Class 8 liquids Flashpoint ≥ 23°C to ≤ 60°C
Certain flammable liquids will float on water and if firefighting personnel direct the water jet on to the liquid it may result in spreading of fire further creating greater danger. During fire heated flammable liquid will release vapours which will burn with explosive effect. Firefighting personnel must stay in well protected area and use water spray to cool down the temperature of the liquid and vapour.
Vaporized flammable liquid may result in devastating Vapour Cloud Explosion. Some of the flammable liquids are corrosive to skin or to ships hull. Long term toxic effects are not classified and labelled hence ships personnel must take great care while dealing with spillage or fire involving flammable liquid. It is highly recommended to use self-contained breathing apparatus while dealing with flammable liquid incidents and accidents on board vessel.
General Comments for fighting fire of Non-Water Reactive Flammable Liquids:
Container fire on deck: Cool burning transport units and nearby cargo exposed to the fire with copious quantities of water.
Container fire under deck: Stop ventilation and close hatches. Use cargo space fixed fire-extinguishing system. If this is not available, create water spray using copious quantities of water.
Gas transportation around globe is primarily done by ocean gas carriers and regional transport is done through pipelines.
Transportation of gas by gas carrier vessels is regulated under The International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code).
Transport of gases in packaged form by sea is regulated by IMDG Code.
During transport gas may be in any 5 of below physical conditions
Carriage of gas has various risks in ocean transport and the risk varies with the properties of gas involved. For safe carriage requirement gases are classified into
2.1 Flammable gases
2.2 Non-flammable, non-toxic gases
2.3 Toxic gases
Among all classes of dangerous goods the most deadliest is Class 2.3 (Toxic gases). The moment toxic gas escapes from its containment it can kill. This is the reason why IMDG Code prohibits stowage of empty uncleaned packages of class 2.3 under deck though empty uncleaned packages of other classes are permitted to be stowed under deck even if stowage under deck when full is prohibited
Gas may be permitted for transport in cylinders, tubes, Pressure drums, bundles or cylinders, MEGCs or tanks. It is the shippers responsibility to select the authorized and appropriate packaging for transporting gas.
Gases which are heavier than air is a silent killer when leaked under deck as it may settle on the bottom of the cargo space.
Class 2.2 includes oxidizing gases which can cause or contribute to fire. The oxidizing property of gases is to be determined according to ISO standard 10156:2010
While moving cylinders into containers and securing same, person in charge must ensure cylinders are not subject to rough handling, rolling on the floor or striking violently against each other. Rough handling of cylinders may cause delayed explosion for acetylene gas.
Due to the shape of the cylinders there are options for labeling according to part 5 of IMDG Code which permits reduced size labels to be secured on the shoulder of cylinder. This method of labeling must meet the conditions of ISO 7225:2005 “Gas cylinders – Precautionary labels”.
There are different packing instructions for chemical under pressure, gases, cryogenic receptacles & metal hydride storage system and there are articles and equipment which contain gas example Aerosols, refrigerating machines, pneumatic components etc. Classification of these article are basis the hazardous class of gas contained and the quantity.
Refrigerating machines containing less than 12 KG class 2.2 gas is excpempted from the requirement of IMDG Code. Similarly aerosols of class 2.2 with less than 50 ml capacity and not having any toxic substances are exempted.
Tanks designed to carry refrigerated liquefied helium is a special equipment. These tanks contain liquefied nitrogen to absorb the heat from helium and keep it in liquid form through the journey. Helium is non toxic, odorless and colorless gas with boiling point at sea level -268.9 deg C. There are special operational methods to keep the tank operating to maintain the pressure and temperature of helium with the help of nitrogen. Generally the shipper’s representative will board the vessel and instruct the ship staff how to achieve this.
Liquefied helium when escapes from tank is extremely low in temperature which can cause dangerous cryogenics burns and embrittlement of carbon steel.
When loaded on vessel ship staff will send out daily readings to shipper which includes below parameters.
Exemptions under class 2 ( gases ) are listed in chapter 2.2 of IMDG Code which includes
For carriage on board ships, the Document of compliance with the special requirements for ships carrying dangerous goods under the provisions of regulation II-2/19 has separate entries for Classes 2.1, 2.2, 2.3 flammable & 2.3 non flammable gases.
Segregation Table of IMDG Code 37-14 is amended for Class 2.1 as Separated from Class 4.3.
Prohibition of transport of dangerous goods by sea is based on different rules; the primary prohibition comes from IMDG Code.
Any substance or article which, as presented for transport, is liable to explode, dangerously react, produce a flame or dangerous evolution of heat or dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport are forbidden from transport by sea.
Following are forbidden from transport by all modes of transport.
Above prohibition is promulgated through United Nations Model Regulations 18th Revised Edition which is adopted by IMDG Code through chapters 1.1 and 3.3.
Dangerous Goods which may be acceptable by other modes but prohibited specifically for sea transport is listed in chapter 3.3 of IMDG Code, special provision 900, which are:
Let us look up some of the above prohibited chemicals’ properties to understand why they are prohibited for transport by sea.
METHYL NITRITE
EXTREMELY FLAMMABLE. Will be easily ignited by heat, sparks or flames. Will form explosive mixtures with air. Silane will ignite spontaneously in air. Vapors may travel to source of ignition and flash back. Cylinders exposed to fire may vent and release flammable gas through pressure relief devices. Containers may explode when heated. Ruptured cylinders may rocket. (Source 2012 Emergency Response Guide)
ETHYL NITRITE
Decomposes under exposure to air, light, water or heat to evolve toxic nitrous fumes. Inhalation of ethyl nitrite vapours, even in small quantities, rapidly affects the heart and can be dangerous.
PERCHLORIC ACID
Commercially available is up to 72% acid by mass. Perchloric acid becomes a strong oxidizer when heated or at higher concentration. Organic, metallic and non-organic salts formed from oxidation are shock sensitive and pose a great fire and explosion hazard. There are many documented accidents resulting from perchloric acid. [1].
CHLORIC ACID, AQUEOUS SOLUTION
With more than 10% chloric acid is prohibited due to its strong nature of oxidizing. It may deflagrate or explode upon contact with combustibles and organic materials.
Shipping Line’s Prohibition & Rejection
Apart from prohibition by IMDG Code, each Shipping Line has their own prohibition and restriction list. This contains outright prohibition, quantity limitation or acceptance from vetted shippers. Lines prepare this list basis accident happened in the industry, on their own vessel or envisaging greater liability.
Economic comparison of freight earned on a 20 or 40 ft box to the losses due to an accident caused by cargo within it will be hugely disproportionate.
In general, some lines prohibit or heavily restrict below:
Apart from this shipping lines have specific UN Numbers under each class either prohibited or restricted acceptance from certain shippers only.
Chemicals falling under Australia Group, Basel Convention, The United Nations Convention Against Illicit Traffic In Narcotic Drugs And Psychotropic Substances, and other similar international conventions and protocols may also be prohibited or restricted by carriers.
The cargo offered by shipper, whether falling under prohibited list or not, may get rejected by a line for any of below reasons.
In transport regulations dangerous goods are assigned to one of the nine classes according to the danger of the most predominant of the dangers they present.
Class 1: Explosives (divided into Division 1.1 to 1.6)
Class 2: Gases
Class 2.1: flammable gases
Class 2.2: non-flammable, non-toxic gases
Class 2.3: toxic gases
Class 3: Flammable liquids
Class 4: Flammable solids; substances liable to spontaneous combustion; substances which, in contact
with water, emit flammable gases
Class 4.1: flammable solids, self-reactive substances and solid desensitized explosives
Class 4.2: substances liable to spontaneous combustion
Class 4.3: substances which, in contact with water, emit flammable gases
Class 5: Oxidizing substances and organic peroxides
Class 5.1: oxidizing substances
Class 5.2: organic peroxides
Class 6: Toxic and infectious substances
Class 6.1: toxic substances
Class 6.2: infectious substances
Class 7: Radioactive material
Class 8: Corrosive substances
Class 9: Miscellaneous dangerous substances and articles
Dangerous Goods upon change in their physical properties either change the hazard class or may bring in additional risks. This will trigger change in UN Number assignment and emergency response.
Let us look at some examples.
Air
If we compress the air above 200 KPa it becomes Compressed Air and is assigned to UN 1002 Class 2.2
If we liquefy the air, then it turns to Refrigerated Liquefied Air is assigned to UN 1003 Class 2.2 with subsidiary risk 5.1.
Refrigerated liquefied air is more dangerous with its oxidizing property and can cause fire when it is leaked. Additionally, ship’s super structure exposed to it can turn brittle and effect the stability.
Metals – Iron
A piece of iron is not dangerous goods however if it is changed to powder it turns into pyrophoric metal. Liable to ignite spontaneously in air. If shaken, may produce sparks. In contact with water, evolve hydrogen, a flammable gas. Iron powder is classified as Class 4.2, substances liable to spontaneous combustion, UN Number 1383.
A container carrying iron powder if in any chance starts burning on board ship the advice is to let the container burn, do not try fighting the fire, if necessary cool the nearby containers with copious quantities of water. Never use water or foam directly to brining iron powder. Fire may be smothered with dry inert powdered material.
Metals – Aluminium
Aluminium on change of shape present different dangers and is equally nasty when involved in fire.
When finely divided aluminium dust is scattered, it is easily ignited by naked lights, causing explosion.
Anhydrous & Hydrated
Sodium sulphide is corrosive when hydrated and spontaneously combustible when anhydrous. Corrosive substances are assigned to Class 8 which can materially damage other goods and living tissue.
There are various parties involved in different aspects of transporting dangerous goods in packaged form by sea. Each party have their one role(s) and responsibilities for compliance to IMDG Code ensuring safety at sea and protection of marine environment.
Below is the list of provisions which require exemption. Approval, authorization or involvement by competent authority. National competent authorities may use this list to delegate duties among their departments or bodies they have authorized to perform these duties.
Section No. Indicative description of Competent Authority’s role
1.1.1.8 Notifying infringements by an entity who is from the jurisdiction of another competent authority
1.3.1.1 Auditing an entity for verification of employee training
1.3.1.3 Verifying IMDG Code training records and setting period for record keeping
1.4.0.1 Applying additional security measures
1.4.2.3.4 Verifying security training records and setting period for record keeping
1.5.2.3 Inspecting effectiveness of Radiation Protection Programme
1.5.3.1 Quality assurance inspection for special form radioactive material, low dispersible radioactive material and packages
1.5.4.1 Special arrangements for transport of radioactive materials
2.0.5.3.1.1 Sent notification for transboundary movement of waste
2.0.5.3.3 Authorizing transport of solid waste in bulk cargo transport unit and road vehicles
2.1.3.2 Class 1 Explosives, classification
2.1.3.4.1 Exclusion from Class 1 Explosives
2.1.3.5.2 Assigning fireworks on basis of analogy
2.2.2.1.2 Flammability of gas –
2.2.2.3.1 Gas mixtures
2.4.2.3.2.4 Classification of self-reactive substances not listed in 2.4.2.3.2.3
2.5.3.2.5 Classification of organic peroxides not listed in 2.5.3.2.4
2.6.3.6.1 Live infected animals
2.7.2.3.3.2.3 acceptance threshold for special form radioactive material
2.7.2.3.3.8.2 Alternative volumetric leakage assessment -radioactive material
2.7.2.4.6.1 Classification as Type B(U), Type B(M) or Type C packages – radioactive material
2.9.2.2 Designating substances to be environmentally hazardous
2.9.2.2 Genetically modified live animals
2.9.4. Verification of tests data, calibration data etc. of Lithium Batteries
2.10.2.6 Excluding a substance mixture or article from Marine Pollutant requirements
3.1.2.6.2 Gases requiring stabilization during transport
3.3.1 – Special Provisions
16 – Authorization for transport of Samples of new or existing explosive substances or articles – UN 0190
76 – Authorizing Transport – various entries
127 – Authorizing inert materials other than listed by IMDG Code for phegmetizing properties – UN 2907
133 – Authorizing packaging other than listed in P409 and dispensation of EXPLOSIVE subsidiary risk label – UN 2956
178 – Authorizing explosives articles under N.O.S. Entries
181 – Dispensing EXPLOSIVE subsidiary risk label for Organic Peroxides and Self-reactive Substances
232 – Authorizing packaging other than tanks for UN 3257 3258
237 – Exempting nitrocellulose membrane filters
239 – Authorizing transport of Sodium batteries with liquid elemental sodium – UN 3292
250 – Authorizing transport of samples under The Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction – UN 3315
266 – Authorizing transport of explosives with less phlegmatizer than specified
271 – Classifying nitroglycerin under Class 4.1
272 – Classifying nitroglycerin under Class 4.1
278 – Classifying Nitroglycerin Mixture, Desensitized, Liquid, Flammable under PG I and packaging for same
283 – Acceptance of quality-assurance standard for manufacturing Articles Pressurized Pneumatic – UN 3164
288 – Classification of NITROGLYCERIN MIXTURE, DESENSITIZED, LIQUID – UN 3357
301 – Authorizing transport of Dangerous Goods in Machinery or Apparatus with more than LQ volume – UN 3363
309 – Approval or Ammonium Nitrate Emulsion, Suspension or Gel – UN 3375
311 – Approval of DESENSITIZED EXPLOSIVE, LIQUID, N.O.S. – UN 3379
356 – Approval of metal hydride storage system – UN 3468
363 – Approval of containment system and more than 1500L fuel for Dangerous Goods in Machinery or Apparatus – UN 1202 1203 1223 1268 1863 3475
364 – Approval of test for transport in Limited Quantities – UN 0012 0014
376 – Defective Lithium Batteries
925 – Approving laboratory for testing charcoal – UN 1361 1362
926 – Authorizing personnel for issuing certificate of moisture content in copra – UN 1363
928 – Exempting fishmeal from the provisions of IMDG Code – UN 1374 2216
929 – Permitting transport of Seed Cake (a) under Seed Cake (b) – UN 1386
952 – Authorizing bulk container for UN 1942
959 – Authorizing transport of waste aerosols on long international voyages – UN 1950
961 – Approving certain Lithium Batteries in vehicles – UN 3166
962 – Approving certain Lithium Batteries in vehicles – UN 3166
964 – Authorizing laboratory for testing Potassium Nitrate
4.1.1.15 Extending period of plastics drums and jerricans, rigid plastics IBCs and composite IBCs with plastics inner receptacles.
4.1.2.2.2.2 Authorizing transport of IBC beyond last inspection date
4.1.3.6.2 Design type approval for pressure receptacles
4.1.3.6.6 Approving alternate method for periodic inspection of pressure receptacles
4.1.3.6.9 Marking of pressure receptacles not meeting the criteria of chapter 6.2
4.1.3.7 Authorizing packaging, IBCs and Large packaging not listed in the packing instructions
4.1.3.8.1 Authorizing transport of unpackaged articles other than Class 1
4.1.4 List of packing instructions
P099 Approving packaging for specific goods
P101 Approving packaging for specific goods
P200(1) Pressure relief device
P200(2) Frequency of periodic inspection for pressure receptacles which make use of composite materials
P200(4.k) Minimum wall thickness for pressure drums
P200v increasing interval of periodic inspection for steel cylinders
P201 Approval of cylinders – UN 3167, 3168, 3169
P405 Authorizing transport of dry phosphorus in projectiles or hard-cased articles – UN 1381
P620 Alternative packagings for the transport of animal material
P902 Requirement of pressure receptacles UN 3268
P905 Cylinders – UN 2990, 3072
P907 Filling density of cylinders
IBC099 Approving IBC for specific goods
IBC520 Approving IBC for organic peroxides and self-reactive formulations not listed in IBC520
LP99 Approving Large Packaging for specific goods
LP902 Requirement of pressure receptacles UN 3268
4.1.5.15 Large and robust explosives articles
4.1.5.18 Approval of packaging
4.1.6.1.14 Requirements for pressure receptacles
4.1.7.2.2 Authorizing organic peroxides and self-reactive substances of type F in IBC
4.2.1.9.1 Compatibility of dangerous goods and portable tank
4.2.1.9.4.1 Increasing or Decreasing the maximum mean bulk temperature for degree of filling in tanks
4.2.1.13.3 Authorizing self-reactive substances and organic peroxides with an SADT less than 55°C in portable tanks
4.2.1.16.2 Degree of filling for class 7 substances in portable tanks
4.2.3.6.4 Allowing higher initial degree of filling for refrigerated liquefied gases
4.2.3.7.1 Procedure for calculating actual holding time – refrigerated liquefied gases
4.2.5.1.1 Authorizing portable tanks for dangerous goods not authorized in portable tanks
T23 Assigning control and emergency temperature for organic peroxides & self-reactive substances in tanks
TP4 Degree of filling for substances in class 7
TP9 Authorizing transport of certain dangerous goods in tanks
TP10 Approving lining for tanks with material other than lead
TP16 Approval of pressure device on tank
TP23 Setting special condition for transport in tank
TP24 Approval of device to prevent the build-up of excess pressure due to the slow decom position of the substance transported in tank
4.3.1.3 Authorizing bulk containers for substances not authorized by IMDG Code
4.3.2.4.2.4 Authorizing single infected articles without plastic bag
4.1.1.15 Extending usage of plastics single packaging beyond 5 years
4.1.2.2.2 Approving transport of IBC beyond 6 months from last periodic test/inspection
4.1.3.6.2 Design type of pressure receptacle
4.1.3.6.6 Alternative method for inspection of pressure receptacle
4.1.3.6.9 Marking of pressure receptacle not meeting part 6.2
4.1.3.7 Authorizing packaging, IBCs and Large Packaging not specifically authorized by IMDG Code
4.1.3.8.1 Authorizing transport of unpackaged articles other than explosives
5.1.5.1.2 Shipment approvals for Radioactive materials
5.1.5.1.3 Shipment approval by special arrangement for Radioactive materials
5.1.5.2 Certificate issuance for Radioactive materials
5.2.2.1.9 Dispensing explosive subsidiary risk label for type B self-reactive substances
5.2.2.1.10.1 Dispensing explosive subsidiary risk label for type B organic peroxides
5.4.1.5.9.1 Assigning entries EXPLOSIVE, N.O.S.
5.4.1.5.9.2 Authorizing explosives with lesser water of phlegmatizer
5.4.1.5.15 Issuance of fireworks classification reference
5.4.2.1.4 Authorizing drums on roll
5.5.2.5.4 Determining period between fumigant application and loading of the fumigated cargo transport unit on board the ship
6.1.5.1.1 Procedure for design type of packaging
6.1.5.1.3 Intervals for testing packaging on production samples
6.1.5.1.5 Selective Testing of packaging
6.2.1.1.2 Approving pressure receptacles without UN certification marking
6.2.1.1.9 Pressure receptacle for acetylene
6.2.1.3.6.5.4 Capacity of pressure relief devices
6.2.1.4.2 Quality assurance systems for pressure receptacles
6.2.1.5.1.7 Replacing hydraulic pressure test by gas
6.2.2.1.1 Extending the usage of composite cylinders beyond 15 years
6.2.2.4 Gas cylinders – Welded carbon-steel gas cylinders – Periodic inspection and testing
6.2.2.5 Conformity assessment system and approval for manufacture of pressure receptacles
6.2.2.5.4.11 Communicate with other competent authorities about design type approval, modifications of approvals, and withdrawn approvals
6.2.2.6 Approval system for periodic inspection and testing of pressure receptacles
6.2.2.6.2.4 Approving Periodic inspection and testing body
6.2.2.6.3.2 Auditing periodic inspection and testing body and its quality system
6.2.2.6.4.3 Examine the documentation and verify the inspections on pressure receptacles
6.2.2.6.4.5 Provide details for denial of approval
6.2.2.6.4.6 Modifications to periodic inspection and testing body approvals
6.2.2.6.4.7 Communicate to any other competent authority, information concerning initial approvals, modifications of approvals, and withdrawn approvals
6.2.2.7.8 Authorizing engraving of inspection dates on acetylene cylinders
6.2.3.1 Authorizing non-UN pressure receptacles
6.2.3.5 Salvage pressure receptacles
6.2.3.5.4 Marking of salvage pressure receptacles
6.2.4.2.2 Alternative methods for testing Aerosol dispensers
6.2.4.3 Exempting water bath testing for Aerosol dispensers
6.3 Test provisions for packagings
6.4.6.4 Packages designed to contain 0.1 kg or more of uranium hexafluoride
6.4.9 Provisions for Type B(M) packages
6.4.9.2 operational controls for venting of Type B(M) packages
6.5 Various Provisions related to the construction and testing of intermediate bulk containers (IBCs)
6.6 Various Provisions related to the construction and testing of large packagings
6.7 Various provisions related to the design, construction, inspection and testing of portable tanks and multiple-element gas containers (MEGCs)
6.8 Road tank vehicles
6.9 Design, construction, inspection and testing of bulk containers
7.3.2.3 Requirement of offshore containers
7.3.3.4 Authorizing drums on roll
7.3.4.1 Approving packing of goods which require segregation away from each other in same container
7.3.7.8 Relaxing temperature control
7.6.2.1.2 Authorizing drums on roll
7.6.2.1.5 Authorizing over stowing of portable tanks
7.7.1.2 Approval of Shipborne barges
7.7.3.5 Approving packing of goods which require segregation away from each other in same barge
7.8.4.1 Special provisions for incidents involving radioactive material
7.9.1.1 Exemptions from the provisions of IMDG Code
7.9.2.1 Approvals as required by IMDG Code
Grieving for the death of Mark Antony, whom she loved most dearly, having no hope for her son Ptolemy Caesar to live, forget becoming emperor,Cleopatra foresaw her doomed future. What can be more humiliating to Cleopatra, who called herself the goddess Isis, the wife of Osiris, than being paraded in victory march in Rome by the triumphant Octavian, who later became Emperor Augustus Caesar.
Today, the 12th August 30 BCE, Cleopatra VII Philopator said her last words, as she applied the second asp (Egyptian cobra) to her arm:
“As sweet as balm, as soft as air, as gentle,
O Antony! Nay, I will take thee too.
What should I stay!”
![The Death of Cleopatra - Guido Cagnacci [Public domain], via Wikimedia Commons](https://shashikallada.files.wordpress.com/2015/08/669px-guido_cagnacci_-_the_death_of_cleopatra_-_wga03758.jpg?w=300&h=269)
Coffee, tea or cola all these beverages contain ‘caffeine’, in the second edition of “A Small Dose of Toxicology” – The Health effects of Common Chemicals- Steven G. Gilbert says “Most consumers of caffeine are well aware of the benefits of this drug as well as the consequences of consuming too much. Through trial and error, we have learned how to moderate our consumption of caffeine to avoid any undesirable effects. In regulating our consumption of caffeine we are applying the most basic principle of toxicology: dose/response”.
What dose constitute a substance as poison in transport regulations?
During transport we do not expect the Master of the vessel or her crew to open the packages and start eating or drinking the dangerous goods. The only way people on board ships or others involved in transport of goods by Rail, Road, River or Air can be exposed to chemicals are while handling the packages which carry stains of chemicals on the exterior or while dealing with a spillage or fire. Example a crew handle leaking packages and without washing hands consume food; oral route of exposure.
Paracelsus(1493-1541) said “All substances are poisons; there is none, which is not a poison. The right dose differentiates a poison from a remedy.”
In transport regulations the word “toxic” has the same meaning as “poisonous”.
Toxic Gases are placed under Class 2.3 (Toxic gases) and Toxic Liquids and Solids are placed under Class 6.1 (Toxic substances).
Class 6.1, for the purpose of packing toxic liquids and solids are grouped into three packing groups:
For making this grouping consideration from both accidental human experience and data obtained from animal experiments are taken.
The possible routes of exposures are:
– oral ingestion;
– dermal contact; and
– inhalation of dusts, mists or vapours.
Class 6.1 Grouping criteria for administration through oral ingestion, dermal contact and inhalation of dusts and mists
LD50 of Egyptian cobra (Naja haje), Cleopatra chose for her death, is Sub-
Cutaneous 1.15 mg/kg, Intra-venous 0.96 mg/kg, Intra-peritoneal 0.185 mg/kg.
For oral and dermal the dosage is calculated mg per kg body weight and for inhalation dosage is calculated by mg per litre of air we breathe. An excellent example to understand dosage is explained on coffee by Steven G. Gilbert in the second edition of “A Small Dose of Toxicology”. Below table describes same.
What is LD50 and LC50?
LD50(median lethal dose) for acute oral toxicity is the statistically derived single dose of a substance that can be expected to cause death within 14 days in 50 per cent of young adult albino rats when administered by the oral route. The LD50 value is expressed in terms of mass of test substance per mass of test animal (mg/kg).
LD50 for acute dermal toxicity is that dose of the substance which, administered by continuous contact for 24 hours with the bare skin of the albino rabbit, is most likely to cause death within 14 days in one half of the animals tested. The result is expressed in milligrams per kilogram body mass.
LC50for acute toxicity on inhalation is that concentration of vapour, mist or dust which, administered by continuous inhalation to both male and female young adult albino rats for one hour, is most likely to cause death within 14 days in one half of the animals tested. The result is expressed in milligrams per litre of air for dusts and mists or in millilitres per cubic metre of air (parts per million) for vapours.
If you are involved in transporting toxic substances, then it is your legal and moral duty to ensure that the consignment strictly meets the requirements of relevant regulations for the mode of transport.
Recommended readings:
Ever since vehicles got reinserted into IMDG Code provisions for vehicles transported by sea have undergone many amendments. The latest IMDG Code, 37-14, coming into force from 1st January 2016, has revised the special provisions for carriage of vehicles and engines.
UN 3166 covers below:
Vehicles are defined as road vehicles (cars, trucks, motorcycles, ATVs, Jet skies, buses), boats, planes, tracked or wheeled farming construction equipment and other self-propelled apparatus designed to carry one or more persons or goods.
What are the conditions laid out in the regulations for shipping vehicles by sea?
In both cases there are conditions to be met for shipping vehicles by sea.
Let us cut apart the provisions of IMDG Code to find how we can ship a car by sea as dangerous goods or as non-dangerous goods.
Before stepping into the seemingly complicated rules we will try to understand what dangers are there in a car. Yes, the car we drive, travel, and hit out for holidays! A car, when burns, leaves nothing but its Skelton and emit toxic flames. It contains flammable fluid, gas, corrosive batteries, airbags, seat belts, may be extinguisher, air-conditioning gas, pneumatic or hydraulic components. Together when they go up in flame it can result in catastrophic fire, explosion and damage, especially in confined areas or in a shipping container.
Vehicles/Engines considered not dangerous must meet the conditions laid out in Special Provision 961 of IMDG Code.
Vehicles/Engines considered dangerous must meet the conditions laid out in Special Provision 962 of IMDG Code.
Non Dangerous Engines/Vehicles (SP 961)
Can consider empty: If the tank is drained and engine cannot be started due to lack of fuel.
No need to clean or purge: Fuel tanks, fuel lines, fuel filters and injectors.
Dangerous Goods needed for the safety of the operator, passenger and operation of the engines or vehicles such as, airbags, seatbelts, battery, extinguishers, gas cylinders etc. must be properly mounted and secured. If there are other dangerous goods inside the vehicle, then such goods must meet the relevant provisions of IMDG Code. Same applies for fuel cell engines.
Dangerous Engines/Vehicles (SP962)
1.. Internal combustion engines, vehicles, fuel cell engines or battery powered equipment: No signs of leakage from batteries, engines, fuel cells, compressed gas cylinders or accumulators, or fuel tank(s);
2. Flammable liquid powered vehicles and internal combustion engines the fuel tank(s) must not be more than one fourth full and in any case the flammable liquid must not exceed 250 ℓ; if there is more fuel same must be approved by the competent authority;
3. Flammable gas powered vehicles and internal combustion engines: Fuel shut-off valve of the fuel tank(s) must be securely closed;
4. Installed batteries must be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries must be type approved as per United Nations Manual of Tests and Criteria, part III, subsection 38.3, or approved by Competent Authority;
5. Dangerous Goods needed for the safety of the operator, passenger and operation of the engines or vehicles such as, airbags, seatbelts, battery, extinguishers, gas cylinders etc. must be properly mounted and secured.
Not required to Mark, Label or Placard. Dangerous Goods Declaration is required.
Some shipping lines, for commercial reasons, may ask shippers to submit LOI while shipping hazardous or non-hazardous vehicles.
You may download sample format of LOI by clicking here
Some readers of this blog had contacted me for sample copy of “Shippers Declaration for Hazardous and/or Non-hazardous Vehicles” or asking what format it should be.
There is no specific format for this. The letter itself is not a mandatory requirement but some lines may ask as a confirmation.
You may prepare the letter in any format but the meaning of the statement shall be that the shipment meets the requirements of Special Provision 961 (for Non Hazardous Vehicle) or Special Provision 962 (for Hazardous Vehicle) of IMDG Code 37-14.
Click below for sample formats of Non Hazardous and Hazardous Vehicle declaration. In addition to this Hazardous Vehicle need Dangerous Goods Declaration as per IMDG Code.
Non- Hazardous Vehicle Hazardous Vehicle
A question lead to this website is captivating as well yearning for compliance!
I will try to answer this paraphrased.
IMDG Cargoes are Dangerous goods, which means the substances, materials and articles covered by the IMDG Code.
This is called Dangerous Goods Declaration
Above listed is shipper’s responsibility. Apart from above, for a carrier to load dangerous goods on the vessel below documents are needed:
Refer Chapter 5.4 of IMDG Code for more information.
Pressurized deodorants, insecticides, medicinal sprays, spray paint cans, cooking spray etc. are called aerosols. Norwegian engineer Erik Rotheim patented the first aerosol can way back in 1927. Over the years much modifications came however the basic principle remains same.
Transport regulations defines Aerosols or aerosol dispensers as non-refillable receptacles made of metal, glass or plastics and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as a foam, paste or powder or in a liquid state or in a gaseous state.
Aerosols is listed under UN Number 1950 with class/ division as “2”. Special Provision 63 explains the classification depending on the content and propellant.
Aerosols are flammable (Class 2.1) if the contents include 85% by mass or more flammable components and the chemical heat of combustion is 30 kJ/g or more.
Aerosols are asphyxiant (Class 2.2) if the contents contain 1% by mass or less flammable components and the heat of combustion is less than 20 kJ/g.
Aerosols are toxic (Class 6.1) or corrosive (Class8) if the contents are toxic or corrosive. However the contents of 6.1 & 8 packing group I are prohibited. Similarly, toxic gases (Class 2.3) is prohibited to be used as propellant. Flammable aerosols classification for spray aerosols and foam aerosols are different. Section 31 of United Nations Manual of Test and Criteria lays out same. Every aerosol dispenser shall be provided with protection against inadvertent discharge.
The possible classification of aerosols is as below
Aerosols can be either max 1 litre capacity or above 1 litre, the change in the capacity triggers changes in stowage and segregation rules on board ships. As long as the capacity of aerosol is maximum 1 litre, irrespective of the class and subsidiary risk, for segregation purpose it is considered as class 9. If the capacity of aerosol is above 1 litre the segregation is as per the class and subsidiary risks assigned.
IMDG Code stowage and segregation for aerosols are “Protected from sources of heat. For AEROSOLS with a maximum capacity of 1 l, Category A. Segregation as for class 9 but “Separated from” class 1 except division 1.4. For AEROSOLS with a capacity above 1 l. Category B. Segregation as for the appropriate sub-division of class 2.
It is the responsibility of shipper to indicate the capacity of aerosol in dangerous goods declaration if same is above 1 litre.
There are special provisions for transporting waste aerosols by sea and it is permitted only on short international voyages, transportation of waste aerosols on long international voyages can only be undertaken if specially approved by competent authority.
Aerosols with a capacity not exceeding 50 mℓ containing only non-toxic constituents are not subject to the provisions of IMDG Code.
Under Globally Harmonized System of Classification and Labelling (GHS) aerosols are classified into three categories.
Refer to chapter 2.3 of GHS 5th revised edition for full details.
For sea transport refer to special provisions assigned to UN Number 1950 and section 6.2.4 of IMDG Code for testing.
Deodorants can be deadly, it has caused fire, explosion, death due to improper usage. Cars have gone up in flame due to deodorant left in it. Inhaling solvents in the deodorant may cause cardiac abnormality.
Whether you transport aerosols or not, following below precautionary statements while using/storing your body sprays, insecticides sprays and other aerosols can prevent you from injury or fire.
For more information on aerosols visit European Aerosol Federation http://www.aerosol.org/ Asian Aerosol Federation – covering Australia, China, India, Japan, New Zealand & Thailand- http://aerosol-asia.org/
The unfortunate accident happened at Formosa Fun Coast, Taipei, Taiwan, has cost two lives and almost 500 injured in which 291 needing intensive care.
On 27 June 2015 revellers at Formosa Fun Coast was attending a grand party called “Colour Play Asia” inspired from festival of colours “Holi”. During the party, the organizers discharged a cloud of colourful powder over the crowd of more than 1000 people. Upon release of colour powder there was a huge explosion resulting in a massive fireball engulfing the stage. Most victims got severe burns to limbs and torso as the dust caught fire at ground level and rose up. The colour powder was starch based consisting corn starch and food colouring which is prone to fire in higher temperature.
What causes dust explosion?
For dust suspended in air to explode minimum four conditions are needed
If the space is confined, then probability of explosion is more.
On 27th June temperature at Bali District, Taiwan was low 29 deg C and high 35 deg C. ignition source is suspected to be burning cigarettes on the floor. Further investigation say two explosion happened. After the first fireball was exhausted a worker used carbon dioxide fire extinguisher to put off scattered small fire resulting in kicking a storm of dust lying on floor going up into second fiery ball.
Where dust explosions can happen?
Dust explosion can happen wherever combustible dust can rise up and suspend in the air. Example, coal mines, flourmills, sugar factory.
What types of dusts can cause explosion?
Dusts of coal, sugar, starch, grain, milk powder, cocoa, coffee etc. can cause explosion. Likewise, fine metal powders are more prone to dust explosion.
Printer toner can also cause dust explosion.
Many solid dangerous goods may cause generation of dust while in storage and more particularly during transport due to vibration caused my train, ship or road vehicle. If the concentration of suspended dust is within the lower and upper limit then possibility of explosion increased with temperature and presence of an ignition source such as smoking, naked light or sparks and arcs.
If the suspended dust concentration makes visibility of light bulb very cloudy then you can consider you are standing inside a bomb.
Watch CSB video AL Solutions Fatal Dust Explosion below
Before packing dangerous goods into container the interior and exterior of the container must be thoroughly examined. Every package of dangerous goods, drums, jerricans, boxes, bags etc. must be visually inspected for any damage. Packages leaking or damaged must not be loaded into the container. Packer must check whether the packages are marked, labelled and are having UN Performance marking on them.
Rules for securing cargo inside container is same for dangerous goods and non-dangerous goods. Improperly secured goods are prone to damage due to movement inside when exposed to acceleration. Rolling and pitching of vessel and hard braking of vehicles may cause goods to move inside the container, stacks collapsing, heavy goods to even break through the container walls.
When oversized machinery or vehicles are secured on container the dangerous goods in the machinery or vehicle must not leak or spill.
Whenever possible liquid dangerous goods must be loaded below dry dangerous goods. Similarly, while loading dangerous and non-dangerous into same container dangerous goods should be kept towards the door end when possible. The marks and labels of dangerous goods packages should face the door end.
Packages with vents, drums, and those having orientation marks must always be kept upright. IMDG Code prohibits drums on roll. If the packages are not designed for stacking the tiers must be separated with dunnage. Some shipping lines have a policy to get a letter signed by shipper stating dunnage is used while shipping liquid dangerous goods in plastic drums. This is to ensure the top tier wont crush the bottom tier and cause leakage.
Goods must be properly blocked, braced or secured or empty space between goods filled with dunnage bags or air bags. While using air bags to fill the space one must take into consideration the force on the bag from cargo. If the pressure of the air bag is low then there is possibility of bag becoming loose and if the pressure is too high there is possibility of bag breaking due to temperature variance.
When different dangerous goods are to be loaded into the container segregation rules of IMDG Code shall be met with. When combined road, rail and sea transport is involved the most stringent provisions of IMDG Code is applicable for segregation.
Steps for checking segregation according to 37th amendment of IMDG Code
Responsibility of packer: Those who pack a dangerous goods container is responsible to issue a Container Packing Certificate, CPC is not required for tanks. The declaration of this certificate must read “I hereby declare that the goods described above have been packed/ loaded into the container/vehicle identified above in accordance with the applicable provisions” and must be signed. This certifies that;
A poorly packed container exposes transport workers and ship staff to risk additionally they pose risk to other cargo, equipment and environment.
For guidance refer Code of Practice for Packing of Cargo Transport Units published by IMO, ILO and UNECE. Searchable version of same can be found at https://www2.unece.org/wiki/display/TransportSustainableCTUCode/CTU+Code
IMDG Code Training certificates, issued by Shashi Kallada, listed in alphabetical order of name of organization. Those who have not undertaken refresher training for IMDG Code 37-14 shall undertake same before 31st Dec 2015 or before handling dangerous goods according to this amendment.
IMDG Code Amendment 37-14 can be used voluntarily from 1st January 2015 and will enter into force from 1st January 2016.
If a certificate number, signed by me, is not found below scanned copy of same may be sent to self for verification.
View certificate numbers by clicking here
Rules regulating transport of Dangerous Goods by roads within India is promulgated through Hazardous Substances (Classification Packaging and Labelling) Rules, 2011 and The Central Motor Vehicles Rules, 1989.
Hazardous Substances (Classification Packaging and Labelling) Rules, 2011, gives exemption to pharmaceutical and cosmetic end products available in packages designated for consumer use and to dangerous goods required for the propulsion of the means of transport or the operation of its specialized equipment during transport.
Dangerous goods in packaged form domestically transported must be classified packaged, marked, labelled and the vehicle carrying the goods appropriately marked according to above said rules.
Salient points within The Central Motor Vehicles Rules, 1989 (CMVR, 1989)
Chapter II licensing of drivers of motor vehicles para 9 require drivers to be able to read and write at least one Indian language specified in the schedule VIII of the Constitution and English. The driver must successfully pass training from a recognized institute and his licence endorsed by the licencing authority.
As per section 129.2 Chapter V, Construction, Equipment and Maintenance of Motor Vehicles, every goods carriage carrying dangerous goods must be fitted with tachograph, (an instrument to record the lapse of running time of the motor vehicle; time speed maintained, acceleration, deceleration, etc.) confirming to the specification of the Bureau of Indian Standards
Vehicle owner’s responsibility, Section 132.2 Every owner of a goods carriage shall, before undertaking the transportation of dangerous or hazardous goods in his goods carriage, satisfy himself that the information given by the consignor is full and accurate in all respects and correspond to the classification of such goods specified in rule 137.
Information to driver, section 132.3, The owner of a goods carriage shall ensure that the driver of such carriage is given all the relevant information in writing as given in Annexure V of these rules in relation to the dangerous or hazardous goods entrusted to him for transport and satisfy himself that such driver has sufficient understanding of the nature of such goods and the nature of the risks involved in the transport of such goods and is capable of taking appropriate action in case of an emergency.
Route planning, section 132.4, The owner of the goods carriage carrying dangerous or hazardous goods, and the consignor of such goods shall lay down the route for each trip which the driver shall be bound to take unless directed or permitted otherwise by the Police Authorities. They shall also fix a time table for each trip to the destination and back with reference to the route so laid down.
Responsibility of driver, section 133 The driver of a goods carriage transporting dangerous or hazardous goods shall ensure that the information given to him in writing under sub-rule (3) of rule 132 is kept in the driver’s cabin and is available at all time while the dangerous or hazardous goods to which it relates, are being transported. Every driver of a goods carriage transporting any dangerous or hazardous goods shall observe at all times all the directions necessary for preventing fire, explosion or escape of dangerous or hazardous goods carried by him while the goods carriage is in motion, and when it is not being driven he shall ensure that the goods carriage is parked in a place which is safe from fire, explosion and any other risk, and at all times the vehicle remains under the control and supervision of the driver or some other competent person above the age of 18 years.
Emergency information panel: Every goods carriage used for transporting any dangerous or hazardous goods shall be legibly and conspicuously marked with an emergency information panel in each of the three places indicated in the Table below so that the emergency information panel faces to each side of the carriage and to its rear and such panel shall contain the following information, namely:—
(ii) the correct technical name of the dangerous or hazardous goods in letters not less than 50 millimetres high;
(i) the United Nations class number for the dangerous or hazardous goods as given in Column 1, Table 1 appended with rule 137, in numerals not less than 100 milimetres high;
(iii) the class label of the dangerous or hazardous goods of the size of not less than 250 millimetres square;
(iv) the name and telephone number of the emergency services to be contacted in the event of fire or any other accident in letters and numerals that are not less than 50 millimetres high and the name and telephone number of the consignor of the dangerous or hazardous goods or of some other person from whom expert information and advice can be obtained concerning the measures that should be taken in the event of an emergency involving such goods.
The information contained in sub-rule (1) shall also be displayed on the vehicle by means of a sticker relating to the particular dangerous or hazardous goods carried in that particular trip.
Every class label and emergency information panel shall be marked on the goods carriage and shall be kept free and clean from obstructions at all times.
Incident Report: The driver of a goods carriage transporting any dangerous or hazardous goods shall, on the occurrence of an accident involving any dangerous or hazardous goods transported by this carriage, report forthwith to the nearest police station and also inform the owner of the goods carriage or the transporter regarding the accident.
You may download following documents for reference and compliance.
In the last article, ‘Stowage and Segregation of Dangerous Goods on Container Ships’, dated 20th May, we looked at the provisions of stowage of containerized dangerous goods on container ships. Let us look at the basic stowage and segregation provisions for carriage of dangerous goods in packaged from and in solid bulk form on general cargo ships.
Flammable gases or flammable liquids having a flashpoint of less than 23°C c.c, must be stowed on deck only, unless otherwise approved by the Administration and must be stowed at least 3 m from any potential source of ignition. Here possible sources of ignition may include open fires, machinery exhausts, galley uptakes, electrical outlets and electrical equipment including those on refrigerated or heated cargo transport units unless they are of certified safe type. For interpreting what is certified type, for cargo spaces, refer to SOLAS II:2/19.3.2 and for refrigerated or heated cargo transport units refer to Recommendation published by the international Electrotechnical Commission, in particular IEC 60079.
When explosives are loaded the compartments or holds and containers must be locked to pervert unauthorized access however when in emergency access to the locked places must be able to be gained without delay. If the cargo compartment floors are not fitted with closed boarded wood the loading/unloading equipment and process must ensure no sparks can occur. If the cargo gets wet all handling operations must be stopped unless specialist advise from shipper clears same. Personnel involved in cargo operations must be briefed prior work regarding the potential risks and necessary precaution. When explosives belonging to different compatibility groups are loaded they must be stowed not less than 6 meters from each other unless mixed loading is permitted between the involved compatibility groups as per section 7.2.7 of IMDG Code.
Non containerized flammable liquids packaged in plastics jerricans, plastics drums, plastics IBCs must always be stowed on deck. There are special requirements for stowage of FISHMEAL, UNSTABILIZED (UN 1374), FISHMEAL, STABILIZED (UN 2216, class 9) and KRILL MEAL (UN3497), SEED CAKE (UN 1386), AMMONIUM NITRATE BASED FERTILIZER, UN 2071 and certain other goods.
When feeds or other edible substances intended for consumption by humans or animals, foodstuff, is loaded it will require segregation ‘separated from’ toxic, radioactive and corrosive dangerous goods and Dangerous goods in other classes which has segregation reference in column 16 (16b in 37th amendment of IMDG Code).
There are four segregation rules for dangerous goods loaded in conventional way on board ships.
Segregation rules between containerized dangerous goods and those loaded in conventional ways are different. Dangerous goods stowed in the conventional way must be segregated from goods transported in closed containers in accordance with segregation provisions showed above except that for “away from” is required, no segregation between the packages and the closed cargo transport units is required; and where “separated from” is required, the segregation between the packages and the closed cargo transport units may be as for “away from”.
Segregation between Bulk dangerous goods and packaged dangerous goods must be in accordance with the table shown in section 7.6.3.5.2 of IMDG Code where all 4 segregation terms have different rules from those listed above.
For full details of the requirements of stowage and segregation of dangerous goods loaded on general cargo ships refer to chapter 7.6 of IMDG Code, individual entries in chapter 3.2 and IMSBC Code as applicable.
Stowage of dangerous goods on board container ships are decided by two factors, Document of Compliance and IMDG Code. IMDG Code sets forth the Stowage and Segregation Rules which is executed on each vessel according to the Document of Compliance issued to her. Document of Compliance is issued to a vessel if it meets the requirements of SOLAS Regulation II-2/19, Construction – Fire protection, fire detection and fire extinction (Carriage of Dangerous Goods).
The Document of Compliance certifies that the construction and equipment of the mentioned ship have been found to comply with the provisions of regulation II-2/19 of the International Convention for the Safety of Life at Sea, 1974, as amended; and that the ship is suitable for the carriage of those classes of dangerous goods as specified in the appendix thereto, subject to any provisions in the International Maritime Dangerous Goods (IMDG) Code and the International Maritime Solid Bulk Cargoes (IMSBC) Code for individual substances, materials or articles also being complied with.
In this document the under deck spaces and on deck spaces are marked separately for carriage of Packaged Dangerous Goods, Bulk Goods and what is not permitted.
Validity of the document of compliance will not exceed 5 years and will not be extended beyond the expiry date of the valid Cargo Ship Safety Construction Certificate issued to the ship concerned under the provisions of SOLAS regulation I/12. See Maritime Safety Committee Circular MSC.1/Circ.1266 for full details.
Coming to IMDG Code stowage and Segregation rules for dangerous goods vessels are categorized into two types, Cargo Ships and Passenger Ships. This categorization further divides cargo ships and passenger ships for carriage of Class 1, Explosives, and Classes 2 to 9. The differentiation is for Class 1, Explosives, Cargo ships (up to 12 passengers) and Passenger ships. For Classes 2-9 Cargo ships or passenger ships carrying a number of passengers limited to not more than 25 or to 1 passenger per 3 m of overall length, whichever is the greater number and Other passenger ships in which the limiting number of passengers transported is exceeded.
For other than class 1 (Explosives) each dangerous goods listed in IMDG Code 36th Amendment, Dangerous Goods List column 16 specifies stowage requirement. This is indicated by Category A, B, C, D or E.
On Deck only stowage is always prescribed for cases where:
Below dangerous goods when permitted to be loaded under deck by IMDG Code will additionally require mechanical ventilation for the cargo hold.
For example, UN 2076 Class 6.1 CRESOLS, LIQUID, stowage category in column 16 of dangerous goods list is Category B. Substances, Materials or Articles assigned with stowage Category B can be loaded on deck or under deck on a cargo ship but on a passenger ship where limiting number of passengers are exceeded Category B must be loaded on deck only!
Segregation between containers carrying dangerous goods are different for containerships with closed cargo holds and hatchless containerships. Vertical and horizontal segregation, athwart ships, fore and aft is defined for Closed Versus Closed, Closed Versus Open and Open Versus Open.
In IMDG Code 37th Amendment Stowage and Handling instructions are listed separately in column 16a in Dangerous Goods List with SW and H codes and column 16b lists out segregation codes, SG.
11th September 2011 attack on U.S. threw up a new revelation and threat that terrorists can cause mass casualties without using weapons of mass destruction. The attack on oil tanker Limburg at Gulf of Aden on 6 October 2002 resulted in 90,000 barrels of oil leaking into sea, vessel catching fire, death of one crew, injuries to 12 crews, 45 million USD loss to vessel, Yemen losing 3.8 million USD in port revenues.
The International Ship and Port Facility Security (ISPS) Code is an amendment to the Safety of Life at Sea (SOLAS) Convention (1974/1988) on minimum security arrangements for ships, ports and government agencies.
International Maritime Organisation states that “The International Ship and Port Facility Security Code (ISPS Code) is a comprehensive set of measures to enhance the security of ships and port facilities, developed in response to the perceived threats to ships and port facilities in the wake of the 9/11 attacks in the United States”
In different ways terrorists may try to reach their objective of disrupting public life, attracting media coverage, targeting high value individuals, demand release of prisoners, instil fear, economic loss, etc.
RISK = Threat x Vulnerability.
Driver leaving vehicle carrying dangerous goods on the road, gap in the peripheral fence of a port or CFS, blind sectors of security cameras are some vulnerabilities.
Threat is a probability of an attack on a target which may be stationary, ports, CFS, warehouses, or on the move, road vehicles and rail cars.
Risk is the probability of threat attacking above exampled vulnerabilities.
Unauthorized access must never be allowed to facilities having dangerous goods. Any person seen loitering around the boundary of the facility must be questioned. Unauthorized photography or filming must not be permitted. While moving high consequence dangerous goods, the route used must be assessed for vulnerabilities and possible need of change in route or need of security escort must be considered.
Every goods must have security measures to prevent unauthorized access, misuse and theft. IMDG Code Chapter 1.4 deals with Security Provisions for Dangerous Goods in which Consignors and others engaged in the transport of high consequence dangerous goods are advised to adopt, implement and comply with a separate security plan. High consequence dangerous goods are those which have the potential for misuse in a terrorist event and which may, as a result, produce serious consequences such as mass casualties, mass destruction or, particularly for Class 7, Radioactive Materials, mass socio-economic disruption.
Specific Security Plan for High Consequence Dangerous Goods must have at least below elements:
It is not always terrorists who may attack, a protest rally by political parties may turn violent torching vehicles and buildings which if have dangerous goods will multiply into catastrophic damage and loss of lives.
Insider threat is more difficult to assess and identify as she/he may lie low for right time knowing the vulnerabilities of the organization. Insider can be a sleeping terrorist or a disgruntled employee who may take revenge or an imprudent employee who unknowingly give the details of vulnerabilities to his or her friend who may utilize same to attack. An organization can put in place multi-pronged approach to detect insider threat, this includes assessing cultural, social, political, economic sector and specific local factors and backgrounds. The publications “Insider Risk Evaluation and Audit” and “Ten Tales of Betrayal: The Threat to Corporate Infrastructures by Information Technology Insiders Analysis and Observations” published by Defense Personnel Security Research Center are useful guide and reference to evaluate insider threat.
For security provisions of Radioactive Material refer to chapter 1.4 of IMDG Code and IAEA publication “Convention on Physical Protection of Nuclear Material” and the IAEA circular “The Physical Protection of Nuclear Material and Nuclear Facilities” need to be applied.
SAFER shipping can only be guaranteed by SECURE shipping!
It is a continuous learning process through experience of exposures/accidents and technological advance which makes the Safety Regulations safest. Let us take a brief look at the origin of International Maritime Dangerous Goods (IMDG) Code and where it stands today protecting lives at sea and preventing marine pollutions.
Even before SOLAS came into force in 1914 concerns were raised and discussed for the need for a regulation for safe transport of dangerous goods by sea. While submitting the proposal at the “Eighth International congress of Applied Chemistry, conducted at Washington/New York, September, 1912, Dr. Julius Abby from Antwerp said;
“I have mentioned at the beginning of this report that the importance of the question of the transportation of dangerous merchandise can no longer be ignored. If I cite a few examples hereafter, it is only because nothing else would more forcibly justify the conclusions and resolutions which I desire to put before this Congress …..It is desirable that this Congress should appoint an international commission of representatives of the chemical industry, in order to establish, and keep up to date, a list of dangerous goods; to centralize all communications on this subject; to study the special literature; to collect and examine samples; and, perhaps, organize an information service for governments, shipping companies, insurance companies, etc.”.
1948 SOLAS Chapter VI came out first time with requirements for safe carriage of Grain and Dangerous Goods. Further SOLAS 1960 brought out Chapter VII dedicated for Carriage of Dangerous Goods.
Since its inception in 1965, IMDG Code has evolved revising its regulations for safety of life at sea and the provisions to prevent marine pollution. From four volumes, running through more than 10,000 pages, the Code changed the format and became more user friendly two volumes from 30th amendment published in the year 2000.
Most of the provisions of IMDG Code has to be done ashore before loading on vessel. Every step involved in Classification, Packaging, Marking, Labelling, Placarding, Documentation, Segregating incompatible goods, Packing of container has to be in accordance with the relevant provisions of IMDG Code.
Various 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.
Shipper, Carrier and Competent Authority have differing responsibilities for consigning and carrying dangerous goods and implementing the IMDG Code. Deviation from the prescribed responsibilities may jeopardize safety and endanger lives of people especially those on board vessel.
Classification of Dangerous Goods, being the first step, carries much weightage for the correctness. Assigning the Proper Shipping Name for mixtures and solutions can be confusing at times however a simple mistake can cause disaster. The explosion of an aluminium cylinder containing ethyl chloride at Dubai airport triggered amendment to mixtures and solutions classification with more clarity in wordings.
Technical names declared influences the emergency response and medical first aid. Technical names required through special provisions 220, 274 & 318 is for medical emergencies and correct extinguishing media for firefighting. A miss declaration in this can lead to administering wrong medicines or applying wrong fire extinguishing media increasing the hazard to unlimited consequences. When the security is more a concern than accidental exposure during transport, the declaration of technical names are not needed. For example MEDICINE, LIQUID, TOXIC, N.O.S. , MEDICINE, LIQUID, FLAMMABLE, TOXIC, N.O.S need not declare the name of the constituent which makes it toxic to prevent disclosing the names of controlled medicinal substances which may lead to theft and or unauthorized usage.
With total 2826 entries in 37th Amendment, IMDG Code, ensures safety of life and prevention of Marine Pollution implementing the requirements of SOLAS Chapter VII Part A and MARPOL Annex III. Though less than 3000 entries the Generic and N.O.S. entries assist the industry to correctly declare and consign more than hundred thousand different dangerous goods.
IMDG Code applicable to transport of dangerous goods and marine pollutants in packaged form limits the size of package for different goods perceiving the threat it may pose during transport. Interestingly more than 1700 entries are assigned with tank codes allowing them to be transported by Portable Tanks. That’s more than 50% of the listed entries allowed in bulk packaging. Transport of bulk liquid dangerous goods is increasing globally and the provisions for tanks and the tank industry is meeting up the safety standard with lesser incidents and accidents to their records.
IMDG Code prohibits only certain goods. These are substance or article which, as presented for transport, is liable to explode, dangerously react, produce a flame or dangerous evolution of heat or dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport and certain substances which are forbidden for transport are listed in chapter 3.3, special provisions 349, 350, 351, 352, 353 and 900. Above this carriers may have their own prohibition list to reduce the possibility of exposing themselves to risks. This may involve risks from accidents, like carrying explosives, exposure to radioactive materials and risks for causing delay to vessel schedule. A sailing schedule can be interrupted when carrying goods which are highly restricted through ports, example Cobalt-60 or waste requiring BASEL notification, and cause economical loss to carriers disproportionate to the freight charges earned.
Apart from the concerns of safety and prevention of pollutions transport of dangerous goods also need to be looked under the glasses of security. Chapter 1.4 of IMDG Code identifies High consequence dangerous goods as those
which have the potential for misuse in a terrorist event and which may, as a result, produce serious consequences such as mass casualties, mass destruction or, particularly for Class 7, mass socio-economic disruption. The indicative list in section 1.4.3.1.2 does not preclude the application of security measures when deemed fit. An example is the need of security concern for transporting potassium nitrate in non-friable prills or granules as non-dangerous goods.
Among the amplified sections of SOLAS IMDG Code stands unique in its regulations referred and applied by experts and laymen together. A trader who is not an expert in chemistry can find the requirement for authorized packaging, quantity limit per package and subsequent provisions for offering to transport dangerous goods by Sea. This at times create ambiguity in understanding and interpretation by various parties involved in transport and has cause disasters too. To ensure the appreciation of hazard involved and the details understanding of regulations IMDG Code made training of shore side personnel mandatory from 1st Jan 2010.
Today, in the year 2015, we are shipping dangerous goods where either 36th or 37th amendment can be applied.
Below are the major changes to IMDG Code 37th amendment:
* New section for Lamps containing dangerous goods in application and implementation sets out conditions for lamps which are not subject to the provisions of IMDG Code.
* Addition of International Convention for Safe Containers, 1972, as amended covering Regulations for the testing, inspection, approval and maintenance of containers.
* Changes in general provisions concerning radioactive material
* Addition of Adsorbed gas under class 2
* Changes to assignment of packing group of viscous flammable liquids
* Changes to text in Classification of solid substances of class 5.1
* Amendments to exemptions under Infectious substances
* Various changes in chapter 2.7 for radioactive materials
* Changes to proper shipping names for some goods under class 9 and clarification of absence of letter P in column 4 of dangerous goods list. ( Airbags, Seat Belts, Capacitors)
* Column 16 stowage and segregation now replaced with column 16a and 16b, Stowage and handling & segregation
* Various changes to dangerous goods entries with respect to packing instructions, marine pollutant, special provisions and complete change of column 16 being replaced by stowage, handling and segregation codes.
* Addition of new UN Numbers from 3507 to 3526
* Changes to many existing and addition of 12 new special provisions
* Amendment of limited quantity marking and placarding
* Amendment to excepted quantity marking
* Amendment to some packing instructions and addition of new packing instructions
* New size requirement of OVERPACK marking from 1st Jan 2016
* Various changes to labels and placards
* Various changes in documentation and fumigation & Coolant/conditioning warning mark
* Changes in construction and testing of packagings
Guidance in this article is applicable only for packaged dangerous goods. Segregation recommendation explained below for port areas may also be applied to CFS/ICD for safety reasons.
Correct classification, packaging, marking, labelling, segregation, securing cargo in container and documentation is the prerequisite to ensure safety of life at sea and prevention of pollution. Packaged dangerous goods whether containerized or non-containerized when kept in port areas waiting for loading on to vessel or to be taken out by consignee may require segregation from one another. Transport regulations contain mandatory segregation rules recognizing the danger involved and available/practical emergency response in each mode of transport. Segregation requirements varies from regulation to regulation; in multimodal transport the most stringent segregation rule of one mode is acceptable by other modes.
Class 1, Explosives, other than 1.4S, and Class 7, Radioactive Materials, should generally be handled direct loading and delivery. Port authorities must formulate special plans for keeping these classes when necessary under special safety, emergency response and security measures. Class 6.2, Infectious substances, must only be handled as direct loading or delivery, never be kept in port areas.
Other classes may be segregated as in below table.
Non-containerized Packages & IBCs
0 = no segregation necessary unless required by the individual schedules
A = away from – minimum 3 m separation required
S = separated from – in open areas, minimum 6 m separation required in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall
Closed containers & portable tanks
0 = no segregation necessary
A = away from – no segregation necessary
S = separated from – in open areas, longitudinally and laterally, minimum 3 m separation required, in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall
Example segregation check -“away from”
Intersection between classes 2.2 and 3 in above table is A = away from – minimum 3 m separation required.
Intersection between classes 2.2 and 3 in above table is A = away from – no segregation necessary.
In the above example non containerized packages need ‘away from’ 3 meter segregation however when the packages are in different containers no segregation is needed.
Example segregation check -“separated from”
Intersection between classes 2.1 and 3 in above table is S = separated from
– in open areas, minimum 6 m separation required
– in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall
Intersection between classes 2.1 and 3 in above table is S = separated from
– in open areas, longitudinally and laterally, minimum 3 m separation required, – – in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall
Example segregation check – “Subsidiary Risk”
Intersection between classes 2.1 and 2.2 in above table is O = no segregation necessary
Intersection between subsidiary risk of UN 1072 class 5.1 to main class of UN 1001 2.1 is S = separated from
More stringent segregation requirement is S= separated from.
– in open areas, minimum 6 m separation required
– in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall
Intersection between classes 2.1 and 2.2 in above table is O = no segregation necessary
Intersection between subsidiary risk of UN 1072 class 5.1 to main class of UN 1001 2.1 is S = separated from
– in open areas, longitudinally and laterally, minimum 3 m separation required, – in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall
Example segregation check – “Segregation Groups”
Intersection between classes 5.1 and 5.1 in above table is O= no segregation necessary unless required by the individual schedules
UN 1502’s Column 16 of IMDG Code 36-12 says “Separated from” ammonium compounds and cyanides.
UN 1512 is listed in segregation group 2 Ammonium compounds in section 3.1.4.4 hence applicable segregation is S = separated from
– in open areas, minimum 6 m separation required
– in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall
Intersection between classes 5.1 and 5.1 in above table is O= no segregation necessary unless required by the individual schedules
UN 1502’s Column 16 of IMDG Code 36-12 says “Separated from” ammonium compounds and cyanides.
UN 1512 is listed in segregation group 2 Ammonium compounds in section 3.1.4.4 hence applicable segregation is S = separated from
– in open areas, longitudinally and laterally, minimum 3 m separation required,
– in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall.
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Ports should develop their own lay out plan for keeping and segregating dangerous goods based on quantitative risk analysis and segregation requirement. For more information refer to Revised Recommendations on the safe transport of dangerous cargoes and related activities in port areas published by IMO.
A port which stack all dangerous goods containers together is not a safe port!!!
Among the model regulations for transport of Dangerous Goods, Rail, Road, River, Air and Sea, the most stringent regulations for segregation of Dangerous Goods is stipulated by IMDG Code. IMDG Code is applicable to all ships to which the International Convention for the Safety of Life at Sea, 1974 (SOLAS 74), as amended, applies and which are carrying dangerous goods as defined in regulation 1 of part A of chapter VII of that Convention.
General Segregation as per IMDG Code
Part 7, Chapter 7.2, describes every step necessary to keep “away from”, “separated from” or in different cargo holds or the requirement of intervening cargo holds for segregating dangerous goods. The provisions of segregation varies as the extend of hazard arising may vary. Any two goods must be segregated if mixing of both may result in undue hazard.
IMDG Code segregation rules, which includes, segregation table, special provisions of segregations and segregation groups deals with segregating dangerous goods from other dangerous goods.
The basic rationale applied is as below.
This is mainly addressed through segregation groups, section 7.2.5 of IMDG Code.
Consolidation of Dangerous and Non-Dangerous Goods
When it comes to consolidation of dangerous goods and non- dangerous goods, in same container, IMDG Code places the responsibility on the shoulders of consignor or the person responsible for packing the goods into a container through section 7.2.5.4 as quoted below:
It is recognized that some non-hazardous substances have similar chemical properties as substances listed in the segregation groups. A consignor or the person responsible for packing the goods into a cargo transport unit who does have knowledge of the chemical properties of such non-dangerous goods may decide to implement the segregation requirements of a related segregation group on a voluntary basis.
Some of the reactive groups
Acrylic Acids, Alcohols and Polyols Aldehydes, Alkynes, with Acetylenic Hydrogen, Alkynes, with No Acetylenic Hydrogen Amides and Imides, Amines, Aromatic, Amines, Phosphines, and Pyridines, Anhydrides, Aryl Halides, Azo, Diazo, Azido, Hydrazine, and Azide Compounds, Bases, Strong Bases, Weak Carbamates, Carbonate Salts, Chlorosilanes, Conjugated Dienes Cyanides, Inorganic Epoxides, Esters, Sulfate Esters, Phosphate Esters, Thiophosphate Esters, and Borate Esters, Ethers, Fluorinated Organic Compounds, Halogenated Organic Compounds,Halogenating Agents, Hydrocarbons, Aliphatic Saturated, Hydrocarbons, Aliphatic Unsaturated, Hydrocarbons, Isocyanates and Isothiocyanates, Ketones, Metal Hydrides, Metal Alkyls, Metal Aryls, and Silanes Metals, Alkali, Very Active Metals, Elemental and Powder, Active Metals, Less Reactive Nitrate and Nitrite Compounds, Inorganic Nitrides, Phosphides, Carbides, and Silicides Nitriles Nitro, Nitroso, Nitrate, and Nitrite Compounds, Organic Non-Redox-Active Inorganic Compounds Not Chemically Reactive, Organometallics, Oxidizing Agents Oximes Peroxides, Organic Phenolic Salts, Phenols and Cresols, Polymerizable Compounds, Quaternary Ammonium and Phosphonium Salts, Reducing Agents Salts, Acidic Salts, BasicSiloxanes, Sulfides, Inorganic Sulfides, Organic Sulfite and Thiosulfate Salts Sulfonates, Phosphonates, and Thiophosphonates, Organic Thiocarbamate Esters and Salts/Dithiocarbamate Esters and Salts, Water and Aqueous Solutions.
Carrier’s Responsibility
Those who work in Carrier’s Dangerous Goods Desk normally gets a lot of enquiries from shippers, consolidators and/or freight forwarders whether such and such dangerous goods can safely be loaded in same container with such and such non-dangerous goods. Mostly these questions are initiated by Carrier’s booking team.
What should the Carrier’s Dangerous Goods Specialist reply to above question?
Carrier’s DG expert can use their own judgement to permit loading dangerous goods and non-dangerous goods consolidation provided such a consolidation is at least as effective and safe as that required by IMDG Code. Shippers should realize that the Carrier’s DG expert is working on behalf of vessel’s Master to ensure compliance to Regulation 2(3) of SOLAS 1974, as amended, which says “The carriage of dangerous goods in packaged form is prohibited except in accordance with the provisions of Chapter VII, Part A”.
Any goods which can violently react with each other and effect the minimum safety as required by IMDG Code must not be loaded in same container. This is applicable to dangerous goods as defined by IMDG Code and non-dangerous goods.
Where the case of food is concerned IMDG Code makes sure, to protect lives, that non compatible goods are not loaded together with foodstuff. This is stipulated through section 7.3.4.2, Segregation in relation to foodstuffs, of IMDG Code. Foodstuff is defined as “foodstuffs, feeds or other edible substances intended for consumption by humans or animals”.
Case Study
While I was heading a global container line’s Dangerous Goods Department I had encountered an interesting FAK consol box. Consolidator wanted to load many different goods into a 40 FT GP box out of which there was Class 6.1, Toxic, liquids and toothpaste with less than ½ a meter separation between. I refused to accept same on my vessel. Consolidator argued as per definition of IMDG Code, Chapter 1.2, toothpaste is not food stuff as it is not made for human or animal consumption. His argument was correct in the letter and spirit. Still I refused to accept the box on the booked vessel and any vessel in my fleet stating that knowingly I will not accept toothpaste to be kept with poison and endanger the health of people.
Due Diligence needed
Carrier must always take due diligence to protect themselves so are shippers, forwarders and consolidators. The utmost is to uphold the relevant provisions of SOLAS and MARPOL. No economy or business interest can outdo Safety, Health and Environmental Protection.
Way forward
Use your knowledge, consult experts, do whatever you can, to ensure consolidation of goods will not jeopardize safety!
The International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) deals with various aspects of prevention of marine pollution by ships.
MARPOL through its six annexes promulgates mandatory regulations aimed at minimizing and preventing pollutions from ships – both accidental and from routine operations. Annex III of MARPOL, entered into force on 1st July 1992, deals with “Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form”. Today, the number of contracting parties and states to Annex III is 138, which accounts to 97.59% of the World Tonnage.
For the purpose of Annex III, “harmful substances” are (1) those substances which are identified as Marine Pollutants in the International Maritime Dangerous Goods Code (IMDG Code) or (2) which meet the criteria in the Appendix to Annex III. Regulation 1(2) of Annex III prohibits carriage of harmful substances except in accordance with the provisions of this Annex which is amplified and published in IMDG Code.
Many substances, articles and materials falling under classes 1 to 9 have the potential to cause pollution to marine environment, the index and column 4 of Dangerous Goods List indicates these substances, materials and articles with the symbol “P”. However the absence of the symbol P or the presence of a “–” in the column 4 does not preclude the application of classification criteria of Marine Pollutant when deemed necessary.
A substance, material or article which does not have the property of any classes from 1 to 8 however having the potential to pollute marine environment must be transported as Marine Pollutant under the entry: ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., UN 3077 or ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., UN 3082, as appropriate, unless there is a specific entry in class 9.
MARPOL Annex III Regulation 2 requires the packages to be adequate to minimize the hazard to marine environment. This is amplified through Packing, IBC & Tank Instructions in IMDG Code. Further every package, tank or bulk container carrying Marine Pollutant must be marked with Marine Pollutant mark.
IMDG Code 37-14 has amended the requirement of Marine pollutant mark through section 5.2.1.6.3 as below
The marking must be in the form of a square set at an angle of 45° (diamond-shaped). The symbol (fish and tree) shall be black on white or suitable contrasting background. The minimum dimensions must be 100 mm x 100 mm and the minimum width of line forming the diamond shall be 2 mm. If the size of the package so requires, the dimensions/line thickness may be reduced, provided the marking remains clearly visible. Where dimensions are not specified, all features shall be in approximate proportion to those shown.
The section 5.2.1.6.3 of IMDG Code 36-12 may be used until 31 December 2016.
Packages must be marked on one side, IBCs on two opposing sides, containers and tanks on all four sides. The size of mark on packages and IBCs must be 100mm x 100mm, containers and tanks 250mm x 250mm. Marking of packages, containers and tanks are required through Regulation 3 of MARPOL Annex III.
According to MARPOL Annex III Regulation 4, whenever a Marine Pollutant is offered for transport by sea the document must mention the words “MARINE POLLUTANT” after the description of dangerous goods. This can be supplemented with words “ENVIRONMENTALLY HAZARDOUS”. Every ship must have a special list, manifest or stowage plan showing the stowage location of Marine Pollutants loaded at each port. This must be revised at every load and discharge. These two documents must be handed over to the person or organization designated by the port authority.
Carriers while loading Marine Pollutant packages or containers/tanks, containing Marine Pollutant, will normally prefer under deck stowage, when permitted, or will stow only on well-protected decks or inboard in sheltered areas of exposed decks. (Regulation 5 – MARPOL Annex III) This is to prevent containers falling into sea due to any reason.
IMDG Code 37-14 gives relaxation from many requirements of regulations when goods which has only Marine Pollution potential, does not have property of any other classes, is packaged in single or combination packagings containing a net quantity per single or inner packaging of 5 l or less for liquids or having a net mass per single or inner packaging of 5 kg or less for solids. When packaged in this way they are not subject to any other provisions of IMDG Code relevant to Marine Pollutants provided the packagings meet the general provisions of 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8
Heads up for next year!
Following entries which were not identified as Marine Pollutant in IMDG Code 36-12 is now identified as Marine Pollutant in IMDG Code 37-14.
UN 1005 1098 1206 1262 1272 1299 1334 1547 1600 1708 1748 1840 1920 2038 2073 2208 2218 2241 2304 2325 2331 2368 2381 2672 2709 2850 2880 3318 3451 3454 3485 3486 3487.
A simple fact: If a chemical can alter the taste of seafood then it is MARINE POLLUTANT!
‘Good things come in small packages’. The provisions of Limited Quantities was introduced in IMDG Code in the 90’s. The lesser quantity Dangerous Goods packed in good, robust packaging pose lesser risks during transport than the same goods packed in larger volumes. On the basis of this, lesser risk, shippers are given some exemptions from certain other provisions of IMDG Code when shipping Dangerous Goods in Limited Quantities.
Any entry in IMDG Code Dangerous Goods List which has ‘0’ in column 7a is not permitted to be transported in accordance with the provisions of Limited Quantities, Chapter 3.4. All other entries can be shipped in Limited Quantities provided the Dangerous Goods are packed in combination packing with inner packagings containing Dangerous Goods not more than the quantity mentioned in column 7a and gross mass of package is not more than 30 kg and for shrink-wrapped or stretch-wrapped trays not more than 20 kg.
Example Limited Quantity inner packagings and outer packagings limit.
Use of intermediate packaging is an option for Dangerous Goods in Limited Quantities but it is mandatory to use intermediate packaging for Liquid goods of Class 8, packing group II in glass, porcelain or stoneware inner packagings. Inner packagings is not required for articles such as aerosols or receptacles, small, containing gas.
The packaging for shipments in Limited Quantities need not have to pass the UN performance tests, example: drop test, stack test etc., however they shall meet the provisions of 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8 and construction requirements of 6.1.4, 6.2.1.2, 6.2.4 of IMDG Code as applicable.
Segregation provisions of IMDG Code is not applicable between Dangerous Goods packed in Limited Quantities and other Dangerous Goods. However if different Dangerous Goods are packed in same outer packaging as Limited Quantities then such consolidation must meet the criteria below
2. The segregation provisions of chapter 7.2, including the segregation provisions in column 16b of the Dangerous Goods List, are taken into account. However substances in packing group III within the same class may be packed together provided they comply with point no.1 above.
3. Dangerous Goods Declaration shall include the following statement: ‘‘Transport in accordance with 3.4.4.1.2 of the IMDG Code’’
The Marking for Packages containing Limited Quantities shall be readily visible, legible and able to withstand open weather exposure without a substantial reduction in effectiveness. The marking shall be in the form of a square set at an angle of 45° (diamond-shaped). The top and bottom portions and the surrounding line shall be black. The centre area shall be white or a suitable contrasting background.
The minimum dimensions shall be 100 mm x 100 mm and the minimum width of the line forming the diamond shall be 2 mm. Where dimensions are not specified, all features shall be in approximate proportion to those shown. If the size of the package so requires, the minimum outer dimensions shown above may be reduced to be not less than 50 mm x 50 mm provided the marking remains clearly visible. The minimum width of the line forming the diamond may be reduced to a minimum of 1 mm.
Containers with Dangerous Goods and Dangerous Goods packed in Limited Quantities shall be placarded and marked according to the provisions applicable to the Dangerous Goods which are not packed in Limited Quantities. However, if no placard or mark is required for the Dangerous Goods not packed in Limited Quantities, the container shall be marked with Limited Quantities mark on each side and on each end of the container.
Example Container Marking for Dangerous Goods in Limited Quantities
The Limited Quantity marking on the container shall be readily visible, legible and it must still be identifiable surviving at least three months’ immersion in the sea.
The requirement for containers carrying Marine Pollutants in Limited Quantities to display Marine Pollutant Mark on all four sides is removed from 37th amendment of IMDG Code.
Together with the description of the shipment words ‘‘limited quantity’’ or ‘‘LTD QTY’’ must be included in the Dangerous Goods Declaration.
Shipments of Dangerous Goods in Limited Quantities by Ocean shall meet the requirements of below sections of IMDG Code.
This article is in accordance with IMDG Code 37-14. Most lines will switch over to 37th amendment of IMDG Code at least by 1st November 2015 to ensure Dangerous Goods carried in accordance with IMDG Code 36-12 is discharged at final seaport before 1st January 2016.
IMDG Code requires certain substances to be transported under temperature control due to the properties of these substances to undergo a self-accelerating decomposition, possibly of explosive violence, when the temperature exceeds a certain value.
Self-accelerating decomposition temperature (SADT) means the lowest temperature at which a self-accelerating decomposition may occur for a substance in the packaging as used in transport.
When a Self-reactive substance or an Organic Peroxide require temperature control during transport the compulsory requirement of usage of reefer container is indicated by words “Shall be transported under temperature control” in column 16 of DGL and Stowage Code SW3 in Column 16a of DGL in 36th and 37th amendment of IMDG Code respectively.
The Control Temperature and Emergency Temperature is determined basis the SADT in which the size of package plays a crucial role. For single packagings and IBCs if SADT is 20°C or less the Control Temperature and Emergency Temperature is 20°C and 10°C below SADT respectively.
Actual transport temperature can be lower than Control Temperature however it shall not be so low to form dangerous separation of phases.
Prior stuffing the reefer must be thoroughly inspected, tested and Master must be provided with operating instructions and spare parts. If the Control Temperature is less than +25°C, the reefer must be fitted with audio visual alarm independent from the power supply of the reefer.
Redundant Reefers: Certain Self-reactive substances and Organic Peroxides require dual mechanism reefer which has two independent refrigerating units with separate power supplies and able to start automatically when the running unit fails.
While packing the reefer with packages requiring temperature control and packages not requiring temperature control the packages which require temperature control must be stowed closer to the door for access in an emergency. Similarly if there are different packages with differing control and emergency temperatures the packages having lowest Emergency Temperature should be packed near the door.
Ship staff will monitor the temperature at regular intervals and if due to malfunction if the temperature rise above Control Temperature they will initiate control measures such as repairing the equipment or providing additional coolants when available. If this fails and the temperature reaches the Emergency Temperature ship staff will initiate Emergency Response Measures which may be jettisoning the cargo or rigging fire hoses and pumping copious quantity of water on to the packages inside the reefer to prevent fire or explosion when the temperature reaches SADT.
Quality Control Reefer Shipments: Some dangerous goods which do not require temperature control for safety reasons may be offered by shippers’ in reefers for commercial reasons. These goods may be flammable liquids, flammable gases, flammable solids or corrosive substances. Example: Perfumes, Safety Matches, Paint, Lithium Batteries, Phosphoric Acid, Acetic Acid etc…
When flammable liquids or gases with flashpoint less than 23°C c.c. are loaded in reefers the substance shall be precooled and transported at a temperature at least 10 Deg C below its flashpoint or a reefer with explosion proof electrical fittings is required.
During transport if the reefer fails the Master must disconnect the reefer from power supply and must not reconnect again if the temperature has risen to less than 10°C below the flashpoint. The reefer can continue its journey and discharged at destination as non-operating reefer.
Carriers’ policy: Carriers may have their own policy with respect to set temperature and humidity for dangerous goods in reefers which do not require temperature control for safety reasons as per IMDG Code. One of these is the infamous Calcium Hypochlorite. Some lines insist that they will carry calcium hypochlorite in reefers with +10 or +20 Deg C only. This is to prevent the exposure of cargo to higher temperature which may result in a thermal runaway explosion.
Carrying Calcium Hypochlorite in reefer is a good proactive step to ensure safety. However, since the reefer is a thermally insulated box the probability of equipment failure and resulting trapped heat generated by cargo inside the reefer must be borne in mind while loading on board ships. If the reefer fails the vessel should discharge the reefer at the next port or during long passages open the doors and provide ventilation. It all depends on the Masters’ decision considering the ambient temperature and distance to go to the next port.
Repositioning Empty Reefers: Reefer is a good business for carriers same time repositioning them is a bad business too. In reefer trade lanes carriers may offer non-operating reefers for general goods and dangerous goods so as to earn freight while repositioning. Most carriers do not accept flammable gases in non-operating reefers to avoid the possibility of someone switching on the reefer en route which may result in explosion if there is gas leakage. Some carriers do accept flammable gases in non-operating reefers provided the power cables are secured and blanked.
Primary function of reefer is to carry food grade products. The reefer operator takes care of the equipment avoiding possibility of contamination by not releasing the reefers for carrying goods which must be separated from foodstuff or for tainting commodity.
For goods which require temperature control during transport for safety reason, the Control and Emergency Temperatures shall be indicated on the dangerous goods declaration, as follows:
“Control Temperature: … °C Emergency temperature: … °C”.
Below sections of IMDG Code identifies the actual Control and Emergency Temperatures for certain substances:
– 2.4.2.3.2.3 List of currently assigned Self-reactive substances in packagings
– 2.5.3.2.4 List of currently assigned Organic Peroxides in packagings
– 4.1.4 IBC520 – List of currently assigned self-reactive substances and organic peroxides in IBCs
– 4.2.5.2.6 T23 – List of currently assigned self-reactive substances and organic peroxides in in tanks
For full details on temperature controlled shipments of Dangerous Goods refer to Chapter 7.3 of IMDG Code.
While shipping dangerous goods in Reefers always remember that the “Reefer is a source of ignition”!
According to news sources, during disposal of detonators, an explosion occurred which has resulted in death of two and more than thirteen burn injuries. This has happened at the Gulf Oil Corporation Ltd, in Hyderabad, India.
The operations being carried out was disposing of rejected detonators in an open ground. Four of the injured has suffered more than 36 percent burn injuries. Explosion is said to have happened while deactivating the expired detonators.
Read more news at
IMDG Code training became mandatory from 1 January 2010 for all shore-side staff involved in dangerous goods transport by sea.
Shore side staff that require IMDG Code training include shippers and forwarders, container packers and consolidators, shipping line operations and booking staff, stevedores, port staff and cargo surveyors.
IMDG Code e-learning is a cost-effective training course for shore side staff involved in dangerous goods handling and transport by sea. It was developed in collaboration with the International Maritime Organization and is used by 12 of the top 20 container lines.
The following Amendment 37-14 courses are available:
Refresher Course – provides a recap of the main IMDG Code provisions and includes an update on the latest Amendment for personnel who have already been trained online, or in the classroom, and have previous knowledge of the IMDG Code’s provisions. The price is GBP 75 for the first ten courses with a discount for 11 courses or more.
Dangerous Goods Transport General Awareness – this is a multimodal course for personnel who need a familiarisation with dangerous goods transport regulations and an awareness of the duties that arise from them. It covers the general awareness training requirements in the IMDG Code, ADR Regulations and RID Regulations and also gives an overview of air transport provisions.
The course is ideal for warehouse personnel, clerical workers, administrators, managers, customer service and/or sales personnel and others who have a very limited direct involvement in dangerous goods shipping or transport activities but need a general appreciation of the regulations. The price is GBP 55 each for the first ten courses with a discount for 11 courses or more.
A new range of role-related function specific courses will be phased in over February and March (GBP 80 each for the first ten, multiple copy discount for 11 or more):-
Advanced course – for those requiring detailed training on all the main aspects of the IMDG Code (GBP 95 each for the first ten, multiple copy discount for 11 or more).
Please fill in the form below for a quotation or further information with type and number of courses required. The courses are open book. IMDG Code access either in book or digital format is required to attend these courses.
We can offer digital IMDG Code access with the courses for GBP 35. This allows the students to automatically hyperlink to the relevant part of the IMDG Code from their course screens. Where there are 29 students or more requiring IMDG Code access we can provide a quotation.
Any space which has limited openings for entry and exit, inadequate ventilation and not designed for continuous worker occupancy is an Enclosed Space.
A Shipping container meets the definition of, and is, an enclosed space! A container may have oxygen depleted or enriched atmosphere, further, due to the presence of dangerous goods, may have, corrosive, toxic or flammable atmosphere.
There are many cases involving workers dying in sewage duct or enclosed spaces on board ships. Co-workers go in to rescue those fallen without realizing the danger or low oxygen or presence of toxic or flammable atmosphere and fall victim themselves. More than 50% of death in enclosed spaces occur while attempting to rescue others.
Master’s Guide published by Standard P&I Club identifies the common factors as
Oxygen Depleted Atmosphere: Earth’s atmosphere contains 20.8% of oxygen, if the percentage goes up or down then we are in a dangerous situation. First let us look at reduction of oxygen.
There are many cargoes which can cause depletion of oxygen, corroding scrap metals can deplete oxygen in a closed container or cargo hold of a ship. Oil Seeds, Copra, Fishmeal, Dry Ice, Charcoal etc. may cause serious depletion in oxygen level.
Any atmosphere which has less than 19.5% oxygen is oxygen depleted atmosphere however one shall not enter any place where oxygen level is less than 20.8%!!
Oxygen Enriched atmosphere : Oxygen enrichment can be caused by various sources like, leaking oxygen cylinders, chemical reactions, inadvertent or accidental activation of oxygen generators carried as cargo etc. If the atmosphere is enriched with oxygen combustible materials can catch fire more easily and will burn more vigorously.
Oxygen enriched, depleted or containers having toxic or flammable atmosphere are too dangerous to enter and have resulted in fatalities in the past.
A fumigated container even after loaded as ventilated may have toxic fumigant gas present in it. Either natural or forced ventilation must be employed prior entering for devanning.
IMDG Code 36th amendment section 7.3.6.1 warns the possibility of unsafe condition, concentration of toxic or flammable vapours, or an oxygen-enriched or oxygen-depleted atmosphere and advise to take necessary caution prior opening the doors of a container.
Prior devanning an import container the risk factor can be placed into three levels.
Level 1 – High Risk – The container contains dangerous gases (example fumigated)
Level 2 – Medium Risk – The container may contain dangerous gases, enriched or depleted level of oxygen (example ventilated fumigated containers, volatile liquids, oxygen depleting goods or gas as cargo)
Level 3 – Low Risk – Probability of oxygen enriched, depleted or hazardous atmosphere is remote.
Ventilation methods: Ventilation prior entering can be either natural ventilation or mechanical. Various factors must be borne in mind while carrying out ventilation and entering the unit. Some gases may take longer to dissipate than others. 1,2-dichloroethane and methyl bromide are less volatile and may adhere to the goods. The time required for natural ventilation must be ascertained depending on the nature of gas, ambient temperature and wind speed. A near zero wind speed may have little or no ventilation effect and the dangerous gases may linger at the door end. Lower the ambient temperature slower evaporation of fumigant gases. Similarly goods which absorb gases such as cotton bales, mattresses, cloths etc. can take longer time for complete ventilation.
A 40 ft container will take twice as much time for ventilating a 20 ft container with similar levels of gas.
For carbon dioxide, carbon monoxide or oxygen ventilation time needed is lesser due to faster degasing properties of these gases. Minimum 2 hours ventilation may be sufficient, for other gases best recommended practice is 24 hours ventilation.
Forced ventilation can be achieved with either using powerful fans or degassing door. Forced ventilation has an advantage of minimizing time required for ventilation.
Never enter the unit while ventilation is in progress. The unit must be clearly marked with warning signs or approach restricted. For highly toxic gases such as sulfuryl fluoride, phosphine and methyl bromide a minimum safe distance of 20 meters must be maintained. Prior entering, after ventilation, presence of toxic, flammable, corrosive gas and oxygen level must be measured. When in doubt contact a specialist or company who has expertise in degassing containers.
Common fumigants: Acrylonitrile, Carbon disulphide, Carbon tetrachloride, Chloropicrin, Dichlorvos (DDVP),Ethylene dibromide, Ethylene dichloride, Ethylene oxide, Ethyl formate, Hydrogen cyanide, Methyl bromide, Methyl formate, Paradichlorobenzene, Phosphine, Sulphuryl fluoride, Trichloroethylene.
An ISO tank is an enclosed space, it may have presence of dangerous gases or oxygen depleted condition. Those who are entering an ISO tank for any purpose must be trained and aware of the procedures for safe entry into enclosed spaces.
On board ships enclosed spaces are cargo spaces, double bottoms, fuel tanks, ballast tanks, cargo pump-rooms, cargo compressor rooms, cofferdams, chain lockers, void spaces, duct keels, inter-barrier spaces, boilers, engine crankcases, engine scavenge air receivers, sewage tanks, and adjacent connected spaces etc. From 1st January 2015 amendment of SOLAS regulation III/19, on emergency training and drills, mandate enclosed-space entry and rescue drills, which will require crew members with enclosed-space entry or rescue responsibilities to participate in an enclosed-space entry and rescue drill at least once every two months.
The wall of the sludge storage tank filled with toxic mix of chemicals such as chromium sulphate, sulphuric acid, ammonia, sodium chloride breached flooding the area where workers were asleep.
The disaster happened at Ranipet, Tamil Nadu, India.
Further reading
http://www.deccanherald.com/content/456985/ten-labourers-buried-alive-tn.html
In the last article we looked at hazard communication through marks and labels on packages. This type of visual communication, marks, labels on packages and placards on containers, is addressing only those who are in the vicinity of packages/containers or handling them. More detailed communication throughout the transport chain takes place through “Dangerous Goods Declaration”, here in after referred as DGD.
For every consignment of Dangerous Goods, ‘Dangerous Goods Transport Information’ must be provided. This is a requirement as per Regulation 4 of SOLAS Chapter VII Part A and Regulation 4 of MARPOL 73/78, Annex III. There are exceptions for certain goods.
The most important function of transport document is to convey the information about hazardous goods consigned. Shipper can submit this document/information either as a hard copy or through electronic data processing (EDP) and electronic data interchange (EDI) transmission techniques.
Five Elements of Dangerous Goods description:
The sequence of above 5 elements must always be written in the order 1, 2, 3, 4 and 5, it must never be scattered or placed here and there in the DGD.
In order to provide exact nature of the dangerous goods Proper Shipping Name must be supplemented as below.
Examples
UN 1098 ALLYL ALCOHOL 6.1 (3) I (21°C c.c.)
UN 1098, ALLYL ALCOHOL, class 6.1, (class 3), PG I, (21°C c.c.)
UN 1092, Acrolein, stabilized, class 6.1 (3), PG I, (–24°C c.c.) MARINE POLLUTANT/ENVIRONMENTALLY HAZARDOUS
UN 2761, Organochlorine pesticide, solid, toxic, (Aldrin 19%), class 6.1, PG III, MARINE POLLUTANT
The total quantity of Dangerous Goods must be declared in mass or volume as appropriate. This must be declared separately for each Proper Shipping Name with different UN Number or Packaging Group. The number and type of packages must also be declared, however, no need to declare the quantity by mass or volume for empty uncleaned packaging. Estimated quantity need to be declared for salvage packaging. For dangerous goods in tanks the gross mass does not include the tare weight. Package type can be declared as drums or boxes but most carriers insist to declare full description. Example; Steel non removable head drums.
In the multimodal transport the goods need to comply with regulations applicable to all modes of transport it goes through as well the country specific requirements. The certification by consignor acknowledges same.
“I hereby declare that the contents of this consignment are fully and accurately described above by the Proper Shipping Name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable international and national government regulations.”
By certifying above, a consignment is guaranteed to meet all international and national regulatory norms.
When goods are packed in a container the packer need to issue a container packing certificate. This can be together with the Dangerous Goods Declaration in the same form or separate.
Signature of the persons responsible can be replaced by name in capital letters when DGD is submitted through electronic medium (EDI or EDP). Language of the DGD can be Swahili, Bhojpuri, Mandarin, or any other language, however, the carrier demand the DGD in a language they prefer.
Together with DGD additional documents also may be required which is prompted by individual entries and other requirements of IMDG Code. To correctly fill up a DGD one must be trained to do so. It is illegal for anyone to prepare a DGD without receiving training.
Above is just the basic information, there are many more requirements as applicable to various goods which can be found in chapter 5.4 of IMDG Code and individual schedules.
You may download the DGD format from http://tinyurl.com/m4wcvhg
Further reading: Documentary Aspects of the International Transport of Dangerous Goods, Revised Recommendation No. 11, ECE/TRADE/C/CEFACT/2008/8
For Dangerous Goods acceptance, in general, main ports will be closed from 18-Feb to 24-Feb while inland/barge ports will be closed earlier on 13-Feb and will reopen on 2-Mar.
For dry cargo, port operations will be slowed down, meanwhile some mother vessels will cancel sailing or omit Chinese ports due to Lunar New Year Holiday impact.
Consignment procedures of dangerous goods is nothing but procedures for communicating hazard involved in dangerous goods while in transport. The potential hazard, specific nature of goods requiring segregation, stowage conditions etc. are communicated through marks, labels, placards and document.
A dangerous goods which is correctly classified, identified with proper shipping name and appropriately packed but not consigned as per part 5 of IMDG Code will fail to meet the objective of IMDG Code, ‘enhance the safe carriage of dangerous goods while facilitating the free unrestricted movement of such goods and prevent pollution to the environment’.
Apart from risking lives at sea and those who handle such goods, a wrongly consigned dangerous goods may also experience delays and detentions at ports.
Part 5 of IMDG Code starts with the two most important aspects of consignment procedures
Above two requirements are directly evolved from the application and regulations of SOLAS 1974, as amended, Chapter VII Part A and MARPOL, 1973/78, Annex III; the two most important conventions of International Maritime Organisation for enhancing safety of life at sea and prevention of marine pollution.
However there are exceptions, all dangerous goods need not require labeling, placarding or document. What is required and when not required can only be determined by referring to part 5 and the individual entries in part 3, chapter 3.2.
Example
Marking and Labeling of packages including IBCs
A package must be marked with UN Number, Proper Shipping name and technical name when assigned with special provisions 274 or 318. Example” UN 2902 PESTICIDE, LIQUID, TOXIC, N.O.S. (drazoxolon). The letters “UN” shall be at least 12 mm high, for packagings of 30 ℓ or 30 kg capacity or less at least 6 mm in height.
IBCs of more than 450 ℓ capacity and large packagings shall be marked on two opposing sides.
When a substance, material or article is identified as Marine Pollutant by IMDG Code or when it possesses the properties that meet the criteria of MARPOL Annex III but not identified as a Marine Pollutant by IMDG Code the same must be consigned as Marine Pollutant. Document must identify this with words MARINE POLLUTANT or MARINE POLLUTANT / ENVIRONMENTALLY HAZARDOUS.
Additionally the package must bear the Marine Pollutant Mark which shall be at least 100 mm × 100 mm unless the package size can only bear smaller marks.
Exception – single packagings and combination packagings where such single packings or inner packagings of such combination packagings have a net quantity of 5 ℓ or less for liquids; or a net mass of 5 kg or less for solids need not require a Marine Pollutant mark however the container carrying this package must display Marine Pollutant Mark one on each side and one on each end of the unit.
Specification of Labels
In terms of colour, symbols, numbers and general format the labels must meet the specifications mentioned in section 5.2.2.2.2 of IMDG Code.
Colour of the label is very important as the colour together with the symbols directly communicate the type of hazard involved. Those who are printing their own label may use PANTONE ® formula guide for accurate colour.
While using PANTONE ® formula guide following colour standards may be used.
Or refer to corresponding Munsell notations or International Commission of Illumination standards. A spectrophotometer or other instrumentation may be used to check whether the colour of printed labels match the standards.
Durability
Durability of Marking and Labeling shall be such that this information will still be identifiable on packages surviving at least three months’ immersion in the sea. British standard BS 5609 for printed pressure-sensitive, adhesive-coated labels meets this requirement. This standard tests the labels for print permanence, adhesive performance, abrasion resistance etc.
Mixed Packages
When a package is containing more than one dangerous goods it shall be marked and labelled for all the dangerous goods contained within.
An overpack must additionally be marked with word OVERPACK and the size of this marking must be at least 12 mm high from 1st January 2016.
The Amendment 37-14 digital IMDG Code products (Windows, Web, Intranet and e-reader) are now available to purchase from the IMDG Support website:
http://www.imdgsupport.com/imdg_code_for_windows.asp?mode=buy.
They can be purchased at the Amdt 36-12 price if the order is placed for delivery before 1 March 2015.
Amendment 37-14 of the IMDG Code can be used from 1 January 2015 and is mandatory from 1 January 2016.. Exis Technologies has produced a free comprehensive summary of the Amendment 37-14 changes which is available here: www.imdgsupport.com.
Exis is also pleased to announce that they will be launching two of their new 37-14 IMDG Code e-learning courses shortly:
Refresher Course (Amdt 37-14) – provides a recap of the main IMDG Code provisions and includes an update on the latest Amendment for personnel who have already been trained online, or in the classroom, and have previous knowledge of the IMDG Code. Price is GBP 75 for the first ten courses with a discount for 11 courses or more.
Dangerous Goods Transport General Awareness (Amdt 37-14) – for personnel who need a familiarisation with dangerous goods transport regulations and an awareness of the duties that arise from them. It covers the general awareness training requirements in the IMDG Code, ADR Regulations and RID Regulations and also gives an overview of air transport provisions. It is ideal for warehouse personnel, clerical workers, administrators, managers, customer service and/or sales personnel and others who have a very limited direct involvement in dangerous goods shipping or transport activities but need a general appreciation of the regulations. Price is GBP 55 for the first ten courses with a discount for 11 courses or more.
37-14 Function Specific courses will be available in January 2015. For more information see: http://hazcheck.existec.com/hazcheck-systems/imdg-code-e-learning-37-14.aspx
Available from the mobile app stores in January – Hazcheck DGL Lite FREE mobile app (Amdt 37-14) http://hazcheck.existec.com/hazcheck-systems/hazcheck-dgl-lite-mobile-app.aspx
If you are looking to purchase IMDG Code 37th amendment or any other IMO publication you may look for authorized distributors in below link
IMDG Code 36th / 37th Amendment Basic and Advanced level of Training scheduled for end January 2015 and mid February 2015 respectively at Navi Mumbai.
Target Audience: Sales and Booking staff of Shippers, Freight Forwarders and Shipping Lines, Operation Teams of Shippers, Freight Forwarders, CFS & Ports
For enquiry and Registration fill up below form or mail to shashi@shashikallada.com
Today much is been discussed about tumbling Brent crude price and its effect on global economy. While Indians will hail the falling price Venezuelans & Russians will look gloomy. Crumbling Russian rubles and many crying not being translated to cheaper fuel for their cars and bikes is filling the limited pages of newsprint.
Let’s look at what is Brent benchmark, API Gravity and Safety in transport of Crude Oil (packaged form). Light and low in sulphur is a better property of crude. There are many benchmarks in international trade of crude such as West Texas Intermediate (WTI), Brent Blend, Dubai Crude, Tapis Crude, Bonny Light etc.
Brent crude with its low sulphur content, sweet, low density is being used as bench mark as oil price around the globe.
Comparing to water, how heavy or light petroleum liquid to water, is API Gravity. The math works as API Gravity = 141.5/Specific Gravity – 131.5. Those who works in oil industry and who sailed on oil tankers will remember this formula.
However the economy goes up or down on crude oil trade, the safety concerns remains same. Due to various development and lessons learned from accidents, today, the latest amendment of Regulations for Transport of Dangerous Goods in Packaged Form list Crude Oil as below.
UN 1267 PETROLEUM CRUDE OIL, Class 3 (Flammable Liquid)
UN 3494 PETROLEUM SOUR CRUDE OIL, FLAMMABLE, TOXIC. Class 3, Subsidiary Risk 6.1 (Flammable, Toxic Liquid)
Sour Crude has higher content of sulphur and it evolves hydrogen sulphide gas which is highly toxic and may cause death in minutes.
Recent accidents involving Bakken Crude has prompted the authorities to look into and issue new guidelines for testing the characteristics of Crude oil and its vapour pressure for safe transport.
We need to learn from accidents, history, and advance of technology for a safer and better tomorrow.
A question which comes to many of us while marking dangerous goods packages is, ‘how and where technical name is to be marked on these packages’.
Packages of Dangerous Goods assigned with special provision 274 shall be marked with technical name together with UN Number and proper shipping name.
See example marking of drum UN 1993 FLAMMABLE LIQUID N.O.S. (Contains Acetone)
IBCs of more than 450 ℓ capacity and large packagings shall be marked on two opposing sides.
Today, 25th September, is observed as World Maritime day. The theme for this year is “IMO conventions: effective implementation”
I take this opportunity to encourage the stake holders who are involved in transport of Dangerous Goods in Packaged from by Sea to adopt and implement two of the most important conventions of IMO, International Convention for the Safety of Life at Sea (SOLAS), 1974 as amended & International Convention for the Prevention of Pollution from Ships (MARPOL) 73/78 as amended.
Through Chapter VII Part A and Annex III respectively of above two conventions IMO promulgate the regulations for carriage of Dangerous Goods in Packaged from by Sea with the below objective.
“Enhance the safe carriage of dangerous goods while facilitating the free unrestricted movement of such goods and prevent pollution to the environment.”
Watch the video message by IMO Secretary-General, Koji Sekimizu
The April 2014 issue of Inbound Logistics Thought Leaders features Labelmaster’s Vice-President of Software & Services, Forest Himmelfarb discussing Efficient and Compliant Hazmat Shipping. To learn more visit: http://www.inboundlogistics.com/cms/article/efficient-and-compliant-hazmat-shipping-today-you-can-have-both/
The Nairobi International Convention on the Removal Wrecks will enter into force on 14 April 2015 following the deposit, on 14 April 2014, of an instrument of ratification by Denmark, with the International Maritime Organization (IMO).
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The biggest blasts took place as police and fire fighters arrived at the scene in the town of Tultepec. Emergency workers are among the casualties.
Every Sunday night, millions of people worldwide gather to watch a show about kings, queens, dragons and Class 3 hazmat. Yes, it’s Game of Thrones, and it’s the greatest show about Dangerous Goods ever created. What’s that? You don’t think Game of Thrones is about hazmat shipping? Here are seven uncanny similarities that will prove…
via 7 clues that Game of Thrones is really about hazmat shipping — Labelmaster Blog
IMDG Code Compliance Centre 