Ever since entry for Formic Acid came into IMDG Code as UN 1779, Class 8 subsidiary risk Class 3, FORMIC ACID with more than 85% acid, by mass, the confusion on flash point is tagging along.
Formic acid, 85% lab reagent grade. Appr. 25 ml of acid. Author W. Oelen
Some Shippers offer UN 1779 8/3 FORMIC ACID with flash point above 60 Deg C.c.c. and Shipping Line’s Dangerous Goods Safety Approvers reject the request to load asking clarification.
Some Dangerous Goods Safety Approvers do accept to load UN 1779 with flash point above 60 Deg C.c.c considering the fact though FP is above 60 it is not deteriorating safety as per Document of Compliance and SOLAS Chapter II-2., (CONSTRUCTION – FIRE PROTECTION, FIRE DETECTION AND FIRE EXTINCTION).
As per classification of IMDG Code upper limit of flash point for liquids which are to be classified as Class 3 or Subsidiary Risk 3 stops at 60 Deg C.c.c. and shippers offer UN 1779 Class 8/3 with FP above 80 Deg C.c.c.
Table for Formic Acid Concentration v/s Flashpoint
formic acid concentration and flashpoint table
Adding to confusion is missing special provision 223 for UN 1779; however using UN 3412 depending on the concentration, flash point and applying chapter 2 of model regulation for selection of Proper Shipping Name shippers can reach to correct classification for their product.
World over most shippers are in dark wondering what makes the delay for a shipping line to revert with acceptance of a dangerous goods shipment request or what checks are being done at shipping lines’ dangerous goods approval desk.
This article is an overview of information flow of dangerous goods shipments for ocean carriage and checks done at Line’s approval desk of big shipping companies who has global presence.
Geographical Desks
Generally global lines have three separate DG desks (Dangerous Goods Department) for handling dangerous goods shipment requests. These desks handle booking requests for loading within a defined geographical area.
Below table is representative geographical distribution areas of each DG desk within a Shipping Line.
Geographical Desks
These regional desks will be situated in said regions. Example Asia DG desk in Singapore or Hong Kong, Europe DG Desk in London, Hamburg or Marseille, America DG desk in New York or Charleston.
Some Lines have consolidated these three DG desks into one single office however working in same manner 24 hours x 5 days. Example offshored DG desk situated in India.
Within the same office DG approvers (Person who verify shipper’s declaration for compliance to regulations) may be looking after certain trade lanes not the entire area. Example: One DG approver handling Asia Europe and Asia North America, another handling Asia South America and Asia/Africa.
Information Flow
Below is the standard information/process flow of dangerous goods shipments for ocean transport (not in exact sequential order), there may be minor variations for different lines or when shipper uses his own equipment etc.
Shipper submit details to local booking desk
Booking Desk submit DG details to respective DG Approval desk (as in above table)
DG Approval desk verifies booking details against IMDG Code, Port Rules and send requests, when needed, to transit Transshipment ports
DG Approval desk send request to other lines when loading on their ships ( VSA- Vessel Sharing Agreements)
DG Approval desk checks with stowage planners ( only for certain commodities and or smaller vessels)
DG Approval desk flags each acceptances received ( form ports, vessel partners and stowage planners)
DG Approval desk approves the booking when all acceptances are in hand
Booking desk Informs shipper about acceptance
Booking Desk make request to local transporters (trucks/railway/barge operators) for export pickup and delivery at first load port
Equipment yard delivers empty container
Transporter Picks up empty container to shipper
Unit stuffed and shipper submit final DG Declaration Form to booking desk
Booking desk submit DG declaration to vessel for loading
Container moved to first ocean load port for loading
Stowage Planner plan the vessel as per Document of Compliance, IMDG Code and in house restrictions.
Unit loads when vessel arrives
Import Desk make request to local transporters (trucks/railway/barge operators) for delivery based on import manifest.
Flow map of Dangerous Goods
Above looks very straight forward and simple but in reality information flows back and forth for clarification and correctness with compliance to IMDG Code, National Regulations etc. and may be rejected too.
DG Approval Desk – Activities
Cross checking details submitted by shipper with respect to IMDG Code requirements
This is generally done like a proof reader’s job. Example: Shipper submitted details of packaging as Plastics non-removable drum, IMDG Code packing instruction for said UN Number allows same, if not booking is rejected.
Similar way DG approver checks compliance with IMDG Code for
– Type of packaging ( drums, boxes, bags, jerrycan, IBCs, tanks, cylinders, MEGCs)
– Material of packaging ( Plastics, Steel, Aluminium, Wooden, etc)
– Quantity per package
– Some lines look into inner packing details too ( though not mandatory by IMDG Code on declaration)
– Type of container ( Example: Reefer for flammable liquids, flashpoint, reefer setting, temperature controlled cargo control and emergency temperatures)
Port Approvals
DG Approver checks the UN Number in the booking against the policy of each port involved in the route through which the cargo will move from origin to destination. This will include Load, Transit, Transshipment and Discharge ports.
Port policies may vary from port to port and cargo to cargo. Some of the common restrictions are as below, however these restrictions are only applicable to certain UN Number or UN Class as per particular port’s restrictions:
port restriction matrix
First load port also may have restrictions, DG approver will check same.
Let us see an example how a DG approver checks the port rules. In order to keep it short we will check one commodity at Transshipment port Singapore.
Cargo: Ammonium Nitrate UN 1942 Class 5.1
Quantity: 5 x 20 ft container each having 20 tons net weight
Port or Loading: Hamburg
Transhipment : Singapore (PSA Terminal B01)
Port of Discharge: Busan
Singapore port regulations for Ammonium Nitrate (Click here for more details)
Singapore restrictions
– DG Approver, through booking desk, ask Shipper for Certificate of Analysis
– Booking has 100 tons,
– Singapore limit is 400 tons
– DG Approver extracts a report from his/her computer application for all bookings made on the voyage and filter down ammonium nitrate bookings already accepted and pending through Singapore.
– If quantity of this booking will increase the total quantity more than 400 tons or certificate of analysis is not received said booking will be rejected.
Vessel Approval
There are three categories of vessels
Own vessel
Chartered Vessel
VSA Vessel
Own Vessel Restrictions
Line’s own vessel the restrictions applicable are company’s house rule
Chartered Vessel Restrictions
When a shipping line is loading on chartered vessel charter party restrictions will be applicable.
Generally Charter Party restrictions are applicable for below commodities
– Ammonium Nitrate
– Calcium hypochlorite
– Explosives
– Fireworks
– Radioactive substances
If restricted by vessel owner the line need to submit each booking to vessel owner and await their go ahead before giving acceptance to Shipper.
VSA Vessel Restrictions
In VSA (Vessel Sharing Agreement) Dangerous Goods are divided into three groups:
Embargoed Dangerous goods which will not be carried;
Dangerous goods that require special requirement by Vessel Operator;
General dangerous goods which involves standard application and approval procedure
When loading on VSA vessel approver will check Line’s own house rule and VSA’s house rule. The agreement is that a Line shall not offer to load a cargo which it restricts on own vessels to VSA or which is restricted on VSA vessel.
Below matrix is an example which restrictions are applicable if Hapag Lloyd and Hamburg Sud is in Vessel Sharing Agreement (VSA) and are loading DG on each other’s vessels
VSA MATRIX
Turn Around Time (TAT)
How much time does it may take for a dangerous goods shipment request to get accepted?
This is a million dollar question debated by entire shipping community over decades with most still banging their heads on walls.
Sales and Customer Service team, without knowing how a DG request is processed by DG approvers, may give guarantee to shipper that they can get approval within 2 hours from the time of submission of request.
Shipper is overjoyed, he/she submit the booking expecting acceptance within promised 2 hours and may end up waiting and sending reminders for next two weeks.
What makes a booking to take so long to get accepted?
It all depends on the cargo, route, vessels involved etc. If the booking is of PAINT it may get accepted within an hour. If it is Ammonium Nitrate or Explosives it may take 15 days, sometimes more.
Port acceptance may take 1 – 5 days due to time zone difference and their work load
VSA vessel approval may take similar time
Charted Vessel Owner’s Approval may take 5 – 15 days
Reference Books and Publications used for DG Acceptance
IMDG Code
49 CFR
TDG Canada
ADR
RID
Other National Regulations when needed
Hawley’s Condensed Chemical Dictionary (or similar)
Chemical Weapon Convention ( Australia Group)
UN Convention Against Illicit Traffic In Narcotic Drugs And Psychotropic Substances
Bamaco, Basel, Rotterdam, Stockholm Conventions
Montreal Protocol
US Embargo
EU Embargo
Conclusion
On a daily basis, for each geographical region, a vessel operator may have approximately 500 -800 bookings, including new bookings submitted by shippers on that particular day and bookings from previous days and older pending for ports, VSA or Charter Party Approval.
Some shipping lines prioritize the bookings as per earliest sailing date.
Some lines work like hens picking worms from ground, randomly. A booking which is sailing after 20 days may be accepted without delay but another booking which is scheduled to load in same week may remain pending with them.
Overall all shipping lines’ approval desks do an excellent job ensuring compliance to IMDG Code, National, International Regulations, Port Regulations, other applicable International Protocols and Conventions such as Basel, Rotterdam, Stockholm, Bamako Conventions, Montreal Protocol, Chemical Weapon Convention, United Nations Convention Against Illicit Traffic In Narcotic Drugs And Psychotropic Substances, EU/US Embargo to ensure safety of life at sea, prevention of pollution & legitimate business.
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Above is an overview of work done at shipping lines approval desk, it actually involves more complicated process such as segregation checks (E.g. segregation and port restrictions for consol box “180 or more different UN Numbers in a single container”) and time consuming verification of various other criteria depending on FAK, Consoles, special cargoes, shippers, origin/ destination/trade route, in house rule, charter party agreement, VSA rules, Truck, Barge or Rail operator restrictions etc.
Shipper can never contact DG desk directly, communication is always routed through Booking Desk (Customer Service Team)
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.
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’.
A particular Gas may be incompatible with the cylinder or any packaging in which it is stored or with the pipelines through which it passes. For example Acetylene will react with zinc and copper, hydrogen sulphide will react with brass..
English: Gas cilinder (Photo credit: Wikipedia)
There was an incident in which an aluminium cylinder containing ethyl chloride and helium with trace amounts of 1,1,1-trichloroethane and trichloroethylene exploded in a cargo warehouse in the Dubai Airport. This was due to non-compatibility of the mixture of gases and the material of cylinder.
Two different gases may react with each other, example Acetylene, which is a highly flammable gas will dangerously react with Chlorine which is a strong oxidizing agent; water-reactive gas.
In transport regulations gases are classified as below
Class 2: Gases
Class 2.1: flammable gases
Class 2.2: non-flammable, non-toxic gases
Class 2.3: toxic gases
According to physical state transport condition of gases are divided in to four;
Compressed gas
Liquefied gas
Refrigerated liquefied gas
Dissolved gas.
While storing gas in cylinders or any pressure receptacles or while transporting or storing different gases together, one must take into consideration of below;
Compatibility of gas with the storage device (materials of the cylinder made of).
Compatibility of gases stored or transported together (chemical reactions between the gases in case of leakage of both or when involved together in fire what may be the consequences).
Compatibility of gas with other goods
Any other safety concerns
Below is the segregation table for gases as per IMDG Code, in this we can see the different clauses for transporting gas by ocean going vessels.
SEGREGATION OF CLASS 2
For sea transport one must look in to the individual provisions in IMDG Code for each gas before deciding whether it can be stored together on a ship.
Diwali is one of the biggest festivals in India celebrated by lighting numerous oil lamps and use of fireworks. After every Diwali celebration newspapers reports many accidents involving fireworks injuries, some grievous.
English: An oil lamp made of clay used for the diwali festival in India (Haryana). Deutsch: Eine indische Öllampe aus Ton während des Diwali-Festes in Haryana. (Photo credit: Wikipedia)
Below are some safety tips while handling fireworks
Never try to modify or make your own fireworks
Do not use fireworks in doors
Do not use fireworks in crowded streets
Never light fireworks in metal containers or glass containers
Kids shall not be allowed to use fireworks other than sparklers or similar products and only under watch.
Do not keep fireworks in your pocket
Do hold sparklers and other hand held articles well away from body
Point fireworks away from home, other buildings and check the area where residue of rockets may fall
Keep available fire extinguishing media, water or extinguisher, at ready disposal
List of cautions can be endless, always use common sense and check possibility of fire and injury while using fireworks.
A last word; pets and other animals are not amused with your fireworks, they in fact hate it!
In transport regulations fireworks are classified as explosives with below entries
Class UN Number
1.1G 0333
1.2G 0334
1.3G 0335
1.4G 0336
1.4S 0337
Below image, courtesy U.S. Consumer Protection Safety Commission, Fireworks Injuries infographic, highlight the risks.
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.
We all know mercury is a silvery metal in liquid form. Probably most of us first saw it in childhood at the mirror like shining bulb end of thermometer when doctor pushed the thermometer in to our mouth .
In ancient days mercury was thought to have medicinal properties which will prolong life !! 🙂 Qín Shǐ Huáng Dì, Emperor of China, died due to drinking a mercury and powdered jade mixture formulated by Qin alchemists thinking he will attain immortality. The Emperor’s tomb contained flowing mercury models of rivers in china. Ancient Egyptians and Greeks used mercury in cosmetics and other ointments.
Mercury is highly corrosive to aluminium and is classified as Corrosive Substances (Class 8) in model regulations. Recent study of corrosive effect of Mercury on Aluminium states that heavy and sudden corrosion will take place leading to pitting and cracking which increases by presence of humidity. On mild steel the corrosion rate is.25mm/year.
Mercury is traditionally sold in flasks measuring about 2.5 litres (34.5 kg or 76 lb.). This weight is equal to one Spanish quintals; Spain was one of the biggest producers of mercury. Mercury is having high density of 13.54562 g/cm3
For sea transportIMDG Code list mercury under UN 2809 MERCURY Class 8 with special instruction prohibiting transport by hovercraft and other ships constructed of aluminium. IMDG Code allows flasks up to 3L for transporting Mercury by sea, including the empty flask the total gross mass per flask may be around 45-50 kg.
There is a new convention by United Nations named Minamata Convention for protecting human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds.
Mercury FlaskOverpack containing Mercury
If you are shipping Mercury or any article containing Mercury by Sea it is a mandatory requirement that you receive training to handle same as per IMDG Code.
IMDG Code training became mandatory from 1 January 2010 for all shore-side staff involved in dangerous goods transport by sea.
Shore side staff requiring IMDG Code training include: – shippers and forwarders, container packers and consolidators, shipping line operations and booking staff, stevedores and port staff. IMDG Code e-learning is a cost-effective training course for shore side staff involved in dangerous goods handling and transport by sea.
IMDG Code is applicable to any to ship which SOLAS 74, as amended, applies and are carrying dangerous goods. Dangerous Goods is defined in Regulation 1 of SOLAS Chapter VII Part A as the substances, materials and articles covered by the IMDG Code.
Document of compliance with the special requirements for ships carrying dangerous goods as per the provisions of regulation II-2/19 of the SOLAS 1974, as amended is applicable to
a) Passenger ships and Cargo ships constructed on or after 1st July 2002
b) 1. For passenger ships constructed on or after 1st Sept 1984 but before 1st July 2002
2. a cargo ship of 500 gross tons or over constructed on or after 1st Sept 1984 but before 1st July 2002
3. a cargo ships of less than 500 gross tons constructed on or after 1st Feb 1992 but before 1st July 2002
the requirements of regulation II-2/54 of SOLAS 1974, as amended by MSC.1(XLV), MSC.6(48), MSC.13(57), MSC.22(59), MSC.24(60), MSC.27(61), MSC.31(63) and MSC.57(67), apply.
Member governments to SOLAS Convention is recommended to apply, as far as possible, IMDG Code to cargo ships of less than 500 gross tons constructed on or after 1st Sept 1984 and before 1st Feb 1992.
Any ship irrespective of size and type which carries substances, materials or articles identified as Marine Pollutants in IMDG Code are subject to the provisions of the said code.
IMDG Code Compliance Centre 