Dangerous goods is not something to be taken serious only because of “hazardous surcharge”, sorry to say this but many believe delay in getting acceptance and hazardous surcharge for dangerous goods as a nuisance and some believe this can be bypassed by manipulation of cargo information. Dangerous goods transport regulations are here to promote safety of the personnel, protection of environment and to facilitate the free unrestricted movement of such goods.

The first Model Regulations was published in 1956. Later Rail, Road, River, Sea & Air regulations were published taking the guidance from model regulations. IMDG Code became mandatory regulations under SOLAS and MARPOL conventions for transport of dangerous goods and marine pollutants in packaged form from 1^st January 2004.

Lessons learnt from accidents, technological advance and research are the basis on which transport regulations are being update periodically.  I remember reading somewhere that experiences gathered during Berlin Blockade was also used while framing cargo by air regulations.

The recent past has plagued the container industry with many catastrophic fires at sea some including loss of lives, loss of property worth billions of dollars and damage to environment. Most of them resulted from misdeclared or undeclared dangerous goods.

IMDG Code 2008 edition made training mandatory to shoreside personnel from 1^st January 2010 onwards.

Shoreside personnel involve those who classify dangerous goods, pack dangerous goods into packages, mark and label dangerous goods, prepare dangerous goods declarations, load/unload dangerous goods into/from cargo transport units(CTU), placard cargo transport units(CTU), offer for transport, carry in transport and also in any other ways connected to transport of dangerous goods by sea.

If we look closely, we can notice that many are working without being trained with no access to IMDG Code and some are trained but no access to IMDG Code.

Due Diligence Checklist In Identifying Providers Of CTU-Related Services issued by Maritime Safety Committee of IMO states “Companies causing CTUs to be transported would want to be assured that the activities undertaken by a service provider are carried out in compliance with international and national regulatory frameworks, and conform with the CTU Code.”

Service providers include

• Shipper
• Consignor
• Consolidator
• Freight Forwarder
• Packer
• CTU Operator
• Carrier
• Inspectors
• Surveyors

When the goods involved is dangerous the checklist has three questions .

1. Does the Provider have a copy of a currently valid amendment to the IMDG Code?
2. Are employees and any subcontractors of the Provider trained in accordance with chapter 1.3 of the IMDG Code?
3. Does the Provider maintain training records? In what form are the records maintained and accessible?

If the answer is NO then stop dangerous goods transport!