UN 3166 VEHICLE

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 be more than one-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 batteries shall be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries 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 securely mounted 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!

Dangerous Goods Transport Regulations

Below are various regulations concerning Dangerous Goods transport and chemicals

This is not an exhaustive list but a simple guidance to readers about some regulations currently in force.

Mode

Regulation

Description

Road

ADR

European Agreement concerning the International Carriage of Dangerous Goods by Road

Rail

RID

(Reglement concernant le transport International ferroviare des merchandises Dangereuses par chemin de fer (RID)  ) The regulations concerning the international carriage of dangerous goods by rail

River

ADN

European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways

River

ADNR

Rhine River

River

ADND

Danube River

Air

IATA TI

International Air Transport ( Technical Instructions )

U.S.A

CFR 49

Code of Federal Regulations 49 ( U.S.A. Road, Rail, Water, Air)

Canada

TDG

Transport of Dangerous Goods Canada

Australia

ADG

Australian Dangerous goods, Code Australia

Argentina, Brazil, Paraguay, and Uruguay + Venezuela going to become full member

MERCOSUR

 

Agreement on the Transport of Dangerous Goods in MERCOSUR

SEA

IMDG Code

International Maritime Dangerous Goods Code

GHS

Harmonizing all Regulations

The Globally Harmonized System of Classification and Labelling of Chemicals

China

 

Regulations  on safe management on hazardous chemicals China 2011

Other Conventions and Protocols

Montreal Protocol

 

Ozone Depleting Substances

The Montreal Protocol on Substances That Deplete the Ozone Layer (a protocol to the Vienna Convention for the Protection of the Ozone Layer) is an international treaty designed to protect the ozone layer by phasing out the production of numerous substances believed to be responsible for ozone depletion.

Bamako Convention

 

Hazardous Wastes within Africa 

Bamako Convention on the ban on the Import into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes within Africa  is a treaty of African nations prohibiting the import of any hazardous (including radioactive) waste

Rotterdam Convention

 

Hazardous Chemicals and Pesticides

The Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, more commonly known simply as the Rotterdam Convention, is a multilateral treaty to promote shared responsibilities in relation to importation of hazardous chemicals.

Stockholm Convention

 

Persistent Organic Pollutants

Stockholm Convention on Persistent Organic Pollutants is an international environmental treaty that aims to eliminate or restrict the production and use of persistent organic pollutants (POPs).

Basel Convention

 

Waste

The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, usually known simply as the Basel Convention, is an international treaty that was designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries (LDCs).

Australia Group

Dual Use Chemicals

The Australia Group is an informal group of countries (now joined by the European Commission) established in 1985 (after the use of chemical weapons by Iraq in 1984) to help member countries to identify those of their exports which need to be controlled so as not to contribute to the spread of chemical and biological weapons

WHO

Pesticides

The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification 2009

Dangerous Goods Classes, Divisions, Marine Pollutants, Packing Groups and Wastes

Parties to the MARPOL 73/78 convention on mari...
Parties to MARPOL 73/78 Convention on marine pollution - Image via Wikipedia

In dangerous goods transport regulations+ of sea, IMDG Code, substances (including mixtures and solutions) and articles are assigned to one of the classes 1 to 9 according to the hazard or the most predominant of the hazards they present. Some of these classes are subdivided into divisions.

These classes or divisions are as listed below:

Class 1: Explosives

Division 1.1: substances and articles which have a mass explosion hazard

Division 1.2: substances and articles which have a projection hazard but not a mass

explosion hazard

Division 1.3: substances and articles which have a fire hazard and either a minor

blast hazard or a minor projection hazard or both, but not a mass

explosion hazard

Division 1.4: substances and articles which present no significant hazard

Division 1.5: very insensitive substances which have a mass explosion hazard

Division 1.6: extremely insensitive articles which do not have a mass explosion

Hazard

Class 2: Gases

Class 2.1: flammable gases

Class 2.2: non-flammable, non-toxic gases

Class 2.3: toxic gases

Class 3: Flammable liquids

Class 4: Flammable solids; substances liable to spontaneous combustion; substances which, in contact with water, emit flammable gases

Class 4.1: flammable solids, self-reactive substances and solid desensitized

Explosives

Class 4.2: substances liable to spontaneous combustion

Class 4.3: substances which, in contact with water, emit flammable gases

Class 5: Oxidizing substances and organic peroxides

Class 5.1: oxidizing substances

Class 5.2: organic peroxides

Class 6: Toxic and infectious substances

Class 6.1: toxic substances

Class 6.2: infectious substances

Class 7: Radioactive material

Class 8: Corrosive substances

Class 9: Miscellaneous dangerous substances and articles

The numerical order of the classes and divisions is not that of the degree of danger.

Marine Pollutants

As per IMDG Code any substance which are subject to the provisions of Annex III of

MARPOL 73/78, as amended is a MARINE POLLUTANT. These substances or articles are identified as such in column 4 of Dangerous Goods List in Volume 2 of the said Code.

Packing Groups

For packing purposes, substances* are assigned to three packing groups in accordance with the degree of danger they present:

Packing group I: substances presenting high danger;

Packing group II: substances presenting medium danger; and

Packing group III: substances presenting low danger.

*classes 1, 2, 5.2, 6.2 and 7, and self-reactive substances of class 4.1 are not assigned with Packing Groups

Wastes

While transporting wastes by sea the goods shall be assigned to the class or division considering their properties and shall be consigned as per the relevant rules. However when wastes not subject to any criteria of IMDG Code but belonging to the notification requirement of BASEL Convention may be transported as Class 9

+ Based on UN Model Regulations, for latest edition click here