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.
Some confusion is there in the industry whether containers or trailers loaded with vehicles ( UN 3166) need to be placarded or not. NO! no placard need to be affixed on them.
Those who had been handling shipments of vehicles in the past to/from USA according to 49 CFR wont have this confusion.
However while making consignments you need to look at the correct regulations ( for mode of transport) for latest rules ,exemptions and limitations applicable if any.
Example: Magnetized Material (Speakers) is hazardous only by air transport. Batteries may be exempted from the requirement if it is non spillable passing the test criteria according to Model regulations. Airbags fitted in steering columns or door panels does not meet the criteria of dangerous goods.
From 1st Jan 2012 Vehicles with internal combustion engines are regulated by IMDG Code (35-10) for sea transport. Depending on certain factors vehicles may become hazardous or non-hazardous consignment. Special Provisions 961 & 962 assigned to UN 3166 specifies this.
Vehicle on flatrack - Photo by shashi kallada
Special Provisions 961 and 962 are shown below in tabular format so we can compare the differences easily
Special Provision 961 ( Non Hazardous Vehicles )
Special Provision 962 ( Hazardous Vehicles )
The fuel tank(s) of the vehicle or equipment powered by a flammable liquid fuel is empty and installed batteries are protected from short circuit;
Vehicles and equipment shall not show signs of leakage from batteries, engines, fuel cells, compressed gas cylinders or accumulators, or fuel tank(s) when applicable;
The fuel tank(s) of the vehicle or equipment powered by a flammable gas is emptied of liquefied or compressed gas, the positive pressure in the tank does not exceed 2 bar, the fuel shut-off or isolation valve is closed and secured, and installed batteries are protected from short circuit; or
for flammable liquid powered vehicles and equipment, the fuel tank(s) containing the flammable liquid shall not bemore thanone-fourth full and in any case the flammable liquid shall not exceed 250 l;
The vehicle or equipment is solely powered by a wet or dry electric storage battery or a sodium battery, and the battery is protected from short circuit.
for flammable gas powered vehicles and equipment, the fuel shut-off valve of the fuel tank(s) shall be securely closed;
installed batteriesshall be protected from damage, short circuit, and accidental activation during transport.Lithium ion or lithium metalbatteries shall meet the requirements of the United Nations Manual of Tests and Criteria, Part III,subsection 38.3, unless otherwise approved by the competent authority; and
dangerous goods required for the operation of the vehicle or equipment such as fire extinguishers, compressed gas accumulators, airbag inflators, etc., shall be securelymounted in the vehicle or equipment.
The marking, labelling and placarding provisions of IMDG Code shall not apply.
For non-hazardous consignments Shipping Lines may ask shipper to give a statement in writing stating his/her consignment meets the requirement of SP 961.
Sample Statement:
“We confirm that the vehicle meets the requirements of IMDG code Special Provision 961, the fuel tank is empty and batteries are protected from short circuit”
Lines should proactively educate the shippers that to make vehicles as non-hazardous consignment must meet conditions laid down in SP 961 (see above).
Just writing a letter won’t make haz into non-haz!
IMDG Code Compliance Centre 