Many carriers do send a fillable format of dangerous goods declarations to their shippers which contain fill in the blanks or yes/no options.

This helps the carriers in a way of getting all the mandatory information as required not only by IMDG Code but also by National Regulations such as 49 CFR and cross check the information in their internal software. These software are basically having functions to highlight mandatory fields in a DG booking such as flashpoint for class 3 or subsidiary hazard class 3, technical names for those UN Numbers assigned with special provisions 274 or 318, some of the software even prompt for technical name for special provision 220.

There is a common yes or no option in most carriers’ DGD format which is “Marine Pollutant Yes or No” where in shipper has to write either yes or no.

As per IMDG Code Marine pollutants are those assigned with symbol “P” in column 4 of dangerous goods list in chapter 3.2 or “P” in alphabetical index. Most software by default select non editable field marine pollutant as YES for these entries.

I have seen a declaration where a very honest shipper had answered the filed “Marine Pollutant Yes/No: as “MAY BE”

One shipment was penalized in a port which had error in the declaration on marine pollutant part. The declaration stated marine pollutant as “YES POISIONOUS”.

I have not seen the original declaration but I doubt this error may be come in as 49 CFR’s poison inhalation hazard (PIH) zone as a fill in the blank field is mostly below marine pollutant section on the DGD formats sent by carriers. If that was the case then also declaring YES POISNOUS for PIH Zone is wrong.

Shipper/Consignor is not a single person. There are multiple departments and many personnel involved before dangerous goods are offered for transport.

Shippers responsibility is clearly stated in the dangerous goods declaration

I hereby declare that the contents of this consignment are fully and accurately described below 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 the applicable international and national governmental regulations.

IMDG Code 39th Amendment 5.4.1.6.1

Packer’s Responsibilies

I hereby declare that the goods described above have been packed/loaded into the container/vehicle identified above in accordance with the applicable provisions.

IMDG Code 39th Amendment 5.4.2 Container/vehicle packing certificate

Those who prepare dangerous goods declaration as required by chapter 5.4 of IMDG Code and those who sign such declarations must receive function specific training on “Prepare Dangerous Goods Declaration” which should include – transport document, container/vehicle packing certificate, competent authorities’ approval, waste transport documentation,  special documentation. This training must cover chapters 1, 2.0, 3.1, 3.2, 3.3, 3.4, 3.5, 5.4, 5.5 & 7.9.

And those who pack the CTU must receive training in function Load/unload cargo transport units which includes responsibility of verifying dangerous goods declaration is received for each of the goods loaded into the CTU.

Dangerous Goods Declarations are not fill in the blanks or multiple choice questions which can be answered by untrained personnel.

By shashi kallada

25 years in Merchant Shipping, Last 13 years working on Packaged Dangerous Goods Sailor, Ex Manager Global Dangerous Goods Maersk Line * Freelance Photographer *Amateur Cyclist

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