Stowage and Segregation of Dangerous Goods on General Cargo Ships

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.

  1. Away from: Effectively segregated so that the incompatible goods cannot interact dangerously in the event of an accident but may be transported in the same compartment or hold or on deck, provided a minimum horizontal separation of 3 metres, projected vertically is obtained.
  2. Separated from: In different compartments or holds when stowed under deck. Provided the intervening deck is resistant to fire and liquid, a vertical separation, i.e. in different compartments, may be accepted as equivalent to this segregation. For on deck stowage, this segregation means a separation by a distance of at least 6 metres horizontally.
  3. Separated by a complete compartment or hold from: Either a vertical or a horizontal separation. If the intervening decks are not resistant to fire and liquid, then only a longitudinal separation, i.e. by an intervening complete compartment or hold, is acceptable. For on deck stowage, this segregation means a separation by a distance of at least 12 metres horizontally. The same distance has to be applied if one package is stowed on deck, and the other one in an upper compartment.
  4. Separated longitudinally by an intervening complete compartment or hold from: Vertical separation alone does not meet this requirement. Between a package under deck and one on deck, a minimum distance of 24 m, including a complete compartment, must be maintained longitudinally. For on deck stowage, this segregation means a separation by a distance of at least 24 metres longitudinally.

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.

 

 

Segregation of Dangerous Goods in Port Areas

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.

Segregation of Dangerous Goods in Port Areas
Segregation of Dangerous Goods in Port Areas

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

DPP_0372

 Example segregation check -“away from”

 

  1. Non containerized packages class 2.2 and 3

 Intersection between classes 2.2 and 3 in above table is A = away from – minimum 3 m separation required.

 

  1. Container one carrying class 2.2, container two carrying class 3

 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”

 

  1. Non containerized packages class 2.1 and 3

 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

 

  1. Container one carrying class 2.2, container two carrying class 3

 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”

 

  1. Non containerized packages UN 1072 OXYGEN, COMPRESSED Class 2.2 Subsidiary Risk 5.1 and UN 1001 ACETYLENE, DISSOLVED Class 2.1

 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

 

  1. Container one carrying UN 1072 OXYGEN, COMPRESSED Class 2.2 Subsidiary Risk 5.1 and container two carrying UN 1001 ACETYLENE, DISSOLVED Class 2.1

 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”

 

  1. Non containerized packages of UN 1502 SODIUM PERCHLORATE, Class 5.1 and UN 1512 ZINC AMMONIUM NITRITE, Class 5.1

 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

 

  1. Container one carrying UN 1502 SODIUM PERCHLORATE, Class 5.1 and Container two UN 1512 ZINC AMMONIUM NITRITE, Class 5.1

 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.

—-

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!!!

Dangerous Goods in Reefers

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.

Reefer

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.

DSCN0645

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”!

Bulk Liquids – Think Tank, do the Math!

One of the most efficient ways to transport liquid dangerous goods in packaged form is by tanks. IMDG Code, by giving options of varying sizes of packages, permits many Dangerous Goods in Liquid Form to be transported in tanks on board ships.

ISO TANKS
ISO TANKS

Advantages of using tanks, instead of drums, are numerous, however, tank is a specialized equipment and care by all parties at all time is necessary for an event less journey. Tank Provider, Shipper, Transporter, Carrier and all others involved in its transport may have different roles to play.

From 1st January 2010, the transport of dangerous goods in IMO type portable tanks and road tank vehicles will be permitted in accordance with columns (13) and (14) of IMDG Code only. For full details on IMO tanks refer to IMO Circular “Dsc/Circ.12 Guidance on The Continued Use of Existing IMO Type Portable Tanks and Road Tank Vehicles for the Transport of Dangerous Goods.

When a particular liquid Dangerous Goods is allowed to be transported in UN Type tanks a Tank Code is assigned to the entry in Dangerous Goods List. Tank codes T1 to T22 are for liquid and solid substances of classes 3 to 9, T23 is for substances of class 4.1 and class 5.2, organic peroxides. The differences between T codes are based on Minimum test pressure (bar), Minimum shell thickness, Pressure relief and Bottom opening provisions.

A liquid assigned with a specific T Code in Dangerous Goods List may be filled in higher T Codes as permitted by IMDG Code. Example: HYDROGEN FLUORIDE, ANHYDROUS, UN 1052, assigned with T Code T10 may also be filled in Tanks under T Codes T14, T19, T20 & T22.

For shipping liquid dangerous Goods, if you think tank, then do the math!

For stability during transport the rule for liquids is either the tank be filled above 80% or below 20%. The most dangerous surge of liquid effecting the stability of vehicles on road is when liquid level is between 40 to 60%. To transport liquids between 20 to 80% baffle tanks need to be used. Baffle tanks have transverse surge plates fitted inside for longitudinal stability.

In a rough way we can say that the degree of filling for tank containers shall be greater than 80% and not more than 97% for general dangerous goods and 95% for Class 6.1 and 8 Liquids PG I and II.

However the actual value for each liquid shall be calculated with below formulas

1. for general use maximum degree of filling (in %) is

DEGREE OF FILLING 97

DEGREE OF FILLING 97

2. for class 6.1 and class 8 PG I & II, Liquids with an absolute vapour pressure of more than 175 kPa (1.75 bar) at 65°C or for marine pollutants maximum degree of filling (in %) is

DEGREE OF FILLING  95
DEGREE OF FILLING 95

 

 

 

 

a is the mean coefficient of cubical expansion of the liquid between the mean temperature of the liquid during filling (tf) and the maximum mean bulk temperature during transport (tr).

Liquids transported under ambient conditions, α could be calculated by the formula

mean coefficient of cubical expansion of the liquid
mean coefficient of cubical expansion of the liquid

 

 

 

 

d15 and d50 are the densities of the liquid at 15°C and 50°C, respectively.

The maximum mean bulk temperature (tr) shall be taken as 50°C except that, for journeys under temperate or extreme climatic conditions, the competent authorities concerned may agree to a lower or require a higher temperature, as appropriate.

Example Calculation -Cargo Details and properties

CARGO DETAILS

Calculation to find ‘a’ and degree of filling

CALCULATION TO FIND DOF
CALCULATION TO FIND DOF

 

 

 

 

 

 

Both cargo shall be filled above 80% in which Cargo 1 & 2 shall not be filled above 91.98% and 88.12% respectively.

Certain shipping lines, while accepting Class 6.1 & 8, Packing Group I or II, demand from shipper a signed statement that the degree of filling meets the respective provisions of IMDG Code applicable to the liquid filled in tank. This declaration guarantees the shipper’s compliance to degree of filling and indemnify the line from non-compliance.

Further a portable tanks shall not be offered for transport:

  1. With a degree of filling, for liquids having a viscosity less than 2,680 mm2/s at 20°C or at the maximum temperature of the substance during transport in the case of a heated substance, of more than 20% but less than 80% unless the shells of portable tanks are divided, by partitions or surge plates, into sections of not more than 7,500 ℓ capacity;

2. With residue of substances previously transported adhering to the outside of the shell or service equipment;

3, When leaking or damaged to such an extent that the integrity of the portable tank or its lifting or securing arrangements may be affected; and

4. Unless the service equipment has been examined and found to be in good working order.

Before tanking do the math!

I wish all the readers “A Very Happy New Year 2015!”

Consequences of including Non-Dangerous Goods in Dangerous Goods Manifest

For enabling effective Emergency Response Measures in the event of spillage and fire involving dangerous goods on board ships, regulation VII/ 4.2 of SOLAS 1974, as amended, and regulation 4.2 of Annex III of MARPOL 73/78 and section 5.4.3.1 of IMDG Code requires a special list, manifest or stowage plan with information of Dangerous Goods, Marine Pollutants and the locations of these goods on board the vessel.

 Section 5.4.3.2.1 of IMDG Code requires appropriate information, immediately available, at all times for use in emergency response to accidents; methods of this can be:

  • appropriate entries in the special list, manifest or dangerous goods declaration; or
  • provision of a separate document such as a safety data sheet; or
  • provision of separate documentation, such as the Emergency Response Procedures for Ships Carrying Dangerous Goods (EmS Guide) for use in conjunction with the transport document and the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods (MFAG).

 In general most shipping lines submit Dangerous Goods Declarations and Dangerous Goods Manifest to vessels. Some lines provide only Dangerous Goods Manifest, IMO FAL Form 7.

 

FAL Form 7 Dangerous Goods Manifest
FAL Form 7 Dangerous Goods Manifest

 

What may be the consequences if non-dangerous Goods are included in this manifest?

UN Numbers UN 1910, UN 2807, UN 2812, UN 3334 and  UN 3335 are assigned with Special Provision 960 which states “Not subject to the provisions of this Code but may be subject to provisions governing the transport of dangerous goods by other modes.”

Even though not dangerous for sea transport IMDG Code included these UN Numbers for harmonization purpose as they may be dangerous for other mode(s) of transport ( e.g. Air ).

In Dangerous Goods List (chapter 3.2 of IMDG Code)  there are no EmS Codes assigned for Emergency Response Measures in column 15  for these UN Numbers as they are  not dangerous goods for Sea transport and there are no specific requirement or guidance for handling spillage or firefighting involving these goods.

If a vessel operator includes any of these UN Numbers in the Dangerous Goods Manifest and if there is an emergency on board involving fire to containers including  these said non-dangerous UN Number(s) the Master and crew may look for emergency response measures in IMDG Code and will not find any information.

This may cause delay in effective firefighting and or other consequences due to loss of vital time spent for looking for EmS of non-dangerous goods.

 Keeping above in view we must urge the industry not to include NON Dangerous Goods in DG Manifest as it may cause delay in firefighting on board ships at sea.

Dangerous Goods – Rejection by Shipping Lines

 

Shippers across the globe has sometimes experienced rejection of their dangerous goods bookings with different shipping lines.

What are the reasons for a shipping line to reject a dangerous goods booking submitted to it or at the time of loading?

There may be varying reasons for a shipping line to reject a booking. This rejection can be immediately after placing the booking or after giving a formal acceptance the goods can be rejected from loading.

CMA CGM Marco Polo © Hans Hillewaert / CC-BY-SA-3.0
CMA CGM Marco Polo © Hans Hillewaert / CC-BY-SA-3.0

Some of the common reasons resulting in rejection by a line are:

  • Goods involved are prohibited by the line’s in-house rules
  • Goods involved are prohibited by Vessel owner / VSA
  • Transit port prohibition
  • Transshipment port prohibition
  • Discharge port prohibition
  • Quantity limit of transit port increase if this shipment is accepted
  • Quantity limit of transhipment port increase if this shipment is accepted
  • Quantity limit of discharge port increase if this shipment is accepted
  • Direct delivery confirmation needed from consignee
  • Import/Export permit required (UN Drug Control or CWC requirement)
  • Special documents such as analysis report or competent authority report needed
  • Technical name missing or not matching the proper shipping name
  • Insufficient or non-appropriate packing details
  • Segregation needed with other goods in same container
  • Reefer temperature not as per regulations for said dangerous goods
  • Flashpoint and Packing Group not matching
  • Flashpoint variation from pure substance is too large
  • Information in dangerous goods declaration not matching the details submitted in booking
  • Segregation or stowage restriction on vessel
  • Draft constrains at a port when loading DG on deck

 

Above is not an exhaustive list. There can be other reasons also; it is always prudent to place the booking well advance of cut off date for materializing a dangerous goods shipment. For more information on the process of line accepting Dangerous Goods, Reefer and OOG please refer to article Booking Validation .

 

What is Undeclared and Misdeclared Dangerous Goods?

Undeclared and Misdeclared dangerous goods is a growing concern in maritime industry. What do these terms mean?

Undeclared dangerous goods means any goods which are listed in the IMDG Code by name or meeting any of the classification criteria of the IMDG Code but not declared by the shipper as dangerous goods.

Misdeclared dangerous goods means any dangerous goods not declared correctly as per the requirement of IMDG Code. Which may include incorrect or misleading description of dangerous goods in dangerous goods declaration, misleading Marking, Labeling and placarding.

 

Cochin Port conducted Dangerous Goods Training

Dec 3rd – 4th 2013, Indian Maritime University conducted a two days workshop on Handling Of Dangerous Goods at Cochin Port, India. Workshop was inaugurated by Capt. Paul N. Joseph, Deputy Conservator, and conducted by Shashi Kallada. Capt. Paul N. Joseph spoke about the dangers involved with hazardous cargo to ports, ships and other users handling such goods.

Two days session covered over view of IMDG Code, dangerous goods declaration, placarding of containers, segregation in containers and segregation between containers.

Storage and handling of dangerous goods at port was covered in depth as per International Maritime Organisation’s “Revised Recommendations On The Safe Transport Of Dangerous Cargoes And Related Activities In Port Areas”

Dr. B. Swaminathan highlighted the importance of training and human element factor in maritime industry.

Sitting 3rd from left: Dr. Dr.B.Swaminathan, Faculty-PortManagement, Indian Maritime University
Sitting 3rd from left: Dr. Dr.B.Swaminathan, Faculty-PortManagement, Indian Maritime University
4th from left: Capt. Paul N. Joseph Deputy Conservator, Cochin Port
4th from right: Shashi kallada, Dangerous Goods Specialist.

How informed are you in changes to IMDG Code ?

IMDG Code, the mandatory instrument under SOLAS and MARPOL conventions of International Maritime Organisation for carriage of dangerous goods in packaged form by sea, undergoes biennial revisions. The latest amendment is 36th amendment published in 2012. With amendment number and year of publication this edition is called as IMDG Code 36-12.

IMDG Code 36-12 came into voluntary usage from 1st January 2013 and will come into force from 1st January 2014. Click here to see IMDG Code Amendment cycle 2010-2019.

IMDG Code 36th amendment (36-12) brought out many revisions and additions including total reshuffling of provisions concerning transport operations in chapter 7.x. Click here to see changes to IMDG Code 36-12 or search ’36-12′ in search box on top right hand side of this page.

October 2014 new IMDG Code will be published which will come into voluntary and mandatory application from 1st Jan 2015 & 1st Jan 2016 respectively.  This edition will be called as 37-14.

Time flies by before we realize seasons changing. Similarly regulations for transport of dangerous goods by sea continuously gets revised and modified. If we do not keep up with regulatory changes we will fall short on compliance which may pose risk to personnel and property or environment with deadly consequences.

IMDG Code 37th amendment (37-14) is about to bring out revolutionary revisions in stowage and segregation requirements by replacing stowage segregation rules by codes and various other changes including but not limited to tank  hazard communications, marine pollutant communications, vehicle shipments clarifications and exemptions etc.

Training is the first step to Compliance and Safety. Timeline for training for dangerous goods by sea is as below;

  • From 1st January 2008 – Recommendatory
  • From 1st January 2010 – Mandatory

Since training became mandatory in 35th amendment of IMDG Code (34-08) four years have passed. There are still a great lot of personnel in shore side who are either not trained or not undertaken mandatory refresher training.

It is the organization’s responsibility to ensure all personnel are trained commensurate with their responsibilities and timely refresher training is provided. Training can be provided either as classroom training, in house training or eLearning. The requirement of IMDG Code is ‘you SHALL  be trained to handle dangerous goods’.

Click here to see details of classroom training and ELearning.

Be safe and ensure safety!

Time to Change IMDG Code

If you haven’t done, it’s time to change your IMO books to 36th amendment.

IMDG Code (Amdt. 36-12) will come into force from 1st January 2014. Almost all shipping lines have already switched over to IMDG Code 36-12 to ensure compliance for dangerous goods being carried and or delivered on or after 1st January 2014.

Chapter 1.3 of IMDG Code makes it mandatory for shore side personnel engaged in transport of dangerous goods by sea to receive training commensurate with their responsibilities.

Competent Authority of India, Directorate General of Shipping, through its circular M.S. Notice No. 6 of 2010 reiterates the mandatory requirement of training of shore based personnel.

Click here to read more about IMDG Code 36-12 training.

Click here for classroom training

Click here for IMDG Code e-learning

Container ship Bahia Laura
Container ship Bahia Laura (Photo credit: L2F1)