IMDG CODE TRAINING INDIA – IMDG Code Compliance Centre

Three Steps to Segregation – IMDG Code 37-14

From 1^st January 2016 the 37^th 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;

280 intersections in Segregation Table with 56 conclusions
18 Segregation Groups
72 Segregation Codes
2820 entries in IMDG Code
761 entries assigned with Segregation Codes which may over rule the segregation table
Additional Special Segregation provisions and exemptions
Different Segregation Provisions for Class 1 Explosives
And more
To know whether two or more goods are permitted in the same container submit UN Numbers in below form

Dangerous Goods Workshop – UASC, India

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 11^th to 12^th 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.

UASC IMDG Workshop Participants From Right to Left: Shashi Kallada, Harshala Singh, Dinesh Ramane, Pravin Daunde, Avinash Bhandary, Aditya Shivnekar

The workshop was conducted by www.shashikallada.com

NISAA Dangerous Goods Workshop at Delhi

The Northern India Steamer Agents Association or NISAA organized a two days Workshop on Dangerous Goods at Delhi on 20^th 21^st 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.

NISAA IMDG Code Workshop - Delhi November 2015 — NISAA IMDG Code Workshop – Delhi November 2015

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.

Capt Ajay Kaura & Shashi Kallada @ NISAA Dangerous Goods Workshop at Delhi, November 2015

NISAA, took another major step in their continuous support to industry by organizing this event.

Organisations attended the workshop:

Class 4.2: Pyrophoric and Self-Heating Substances

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.

"Separated longitudinally by an intervening complete compartment or hold from — “Separated longitudinally by an intervening complete compartment or hold from

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.

Volume of Cargo
Rate of Self-heating
Presence of moisture
Ambient temperature and heat dissipation.

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.

Competent Authority’s Responsibilities in IMDG Code 37th Amendment

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

IMDG Code Training Certificates Issued

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 31^st Dec 2015 or before handling dangerous goods according to this amendment.

IMDG Code Amendment 37-14 can be used voluntarily from 1^st January 2015 and will enter into force from 1^st 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

IMDG Code Training @ Mumbai Jan/Feb 2015

IMDG Code 36^th / 37^th 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

Cochin Port conducted Dangerous Goods Training

Dec 3^rd – 4^th 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
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 ? (shashikallada.com)
Time to Change IMDG Code (shashikallada.com)

Time to Change IMDG Code

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

IMDG Code (Amdt. 36-12) will come into force from 1^st 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 1^st 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 (Photo credit: L2F1)

IMDG Code e-learning (shashikallada.com)
Detailed guide: Driving dangerous goods and special loads (gov.uk)

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