MARPOL 73/78 – IMDG Code Compliance Centre

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

IMDG Code 36^th 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 1^st Jan 2015 & 1^st 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 37^th 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 35^th 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!

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MARINE POLLUTANTS

IMDG Code identifies a substance, material or article as MARINE POLLUTANT with the criteria based on those developed by the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), as amended. This criteria is listed in Appendix to Annex III of MARPOL.

Marine pollutants are identified with letter “P” in column 4 of dangerous goods list in chapter 3.2

MARPOL Annex III deals with ‘Regulations for the Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form’. This regulation deals with Application, Packing, Marking and labelling, Documentation, Stowage, Quantity limitations, Exceptions & Port State control on operational requirements. In this article we will look at Annex III requirement for, Marking and labelling and Documentation; regulations 3 & 4 respectively.

Marking and labelling

Every package containing marine pollutant shall be marked with correct technical name and marine pollutant mark. These marks and label shall be so durable that information will still be identifiable on packages surviving at least three months’ immersion in the sea.

Symbol (fish and tree): black on white or suitable contrasting background

Dimensions at least 100 mm × 100 mm

Exception: for packages, single packagings and inner packagings of combination packagings containing

– a net quantity of 5 l or less for liquids; or a net mass of 5 kg or less for solids.

Documentation

If the cargo is a marine pollutant Dangerous Goods Declaration must indicate this with words ““MARINE POLLUTANT”. Also if the cargo is under a generic or N.O.S. entry then proper shipping name shall be supplemented with technical name.

Examples for technical name supplementing proper shipping name for N.O.S. and Generic entries:-

“UN 1993, FLAMMABLE LIQUID, N.O.S. (propyl acetate, di-n-butyltin-di-2-ethylhexanoate), class 3 PG III (50 °C c.c.) MARINE POLLUTANT”

“UN 1263, PAINT (triethylbenzene), class 3 PG III (27 °C c.c.) MARINE POLLUTANT”

Globally Harmonized System of Classification a... — Globally Harmonized System of Classification and Labelling of Chemicals (GHS) pictogram for environmentally hazardous substances (Photo credit: Wikipedia)

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World Oceans Day & MARPOL ANNEX III

June 08^th is observed as World Oceans Day. 2011 & 2012 theme is Youth: the Next Wave for Change.

On this occasion let us look at Annex III of International Convention for the Prevention of Pollution from Ships, 1973/78.

Annex III of the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78), deals with the prevention of pollution by harmful substances carried by sea in packaged form.

Annex III of MARPOL has 8 regulations, below are the explanation of each.

For full details refer MARPOL or part 1.1.2.2. of IMDG Code 35-10

1. Application

This regulation identifies harmful substances as those identified as marine pollutant by IMDG Code or any substance which meets the criteria laid down in appendix to annex III.

Packaged form means the forms of containment specified for harmful substances in the IMDG Code.

It further states carriage of substances is prohibited except in accordance with the provisions of this annex. And ask to treat the empty packages used for carriage of harmful substances themselves as harmful substances unless adequate precautions have been taken to ensure that they contain no residue that is harmful to the marine environment. Further states that the provisions of this annex do not apply to ship’s stores.

2. Packing

Regulation 2 requires the packages to be adequate to minimize the hazard to the marine environment.

3. Marking and labelling

Regulation 3 requires the packages to be marked with correct technical names and marked or labelled to identify the substance is a marine pollutant. Trade names alone shall not be used. The regulation requires the durability of marking to be such that it survives minimum three months immersion in sea.

4. Documentation

Documentation of harmful substances shall contain correct technical names and the words “MARINE POLLUTANT”. Each ship carrying harmful substances shall carry a special list of manifest identifying the goods and its stowage locations thereof. This list must be revised at any port where loading and or discharging of harmful substances takes place.

5. Stowage

Harmful substances are to be stowed on board vessels in such a way to minimize the hazard to the marine environment without jeopardizing safety of the persons on board or ship.

6. Quantity limitations

Certain harmful substances may need to be prohibited for carriage or limited by quantity which may be carried aboard any one ship. In limiting the quantity consideration shall be given to size, construction and equipment of the ship, as well as the packaging and the inherent nature of the substances.

7. Exceptions

Jettisoning of harmful substances are prohibited except when it is needed to secure the safety of life on board vessels or for securing the safety of the vessel.

8. Port State control on operational requirements

IMO PUBLICATIONS ON BOARD VESSELS

Which IMO publications a vessel must carry? There are various publications which is to be carried mandatory and many are recommended and encouraged to carry.

SOLAS, MARPOL, LL, COLREG, and STCW Conventions deal with operational aspects, navigational responsibilities, safety related trainings/drills on board, safe cargo handling, oil spill prevention, collision avoidance activities and watchkeeping standards hence these publications though not mandatory, need to be carried on board in order to improve the crew’s knowledge.

The publications may be carried in electronic form, like CD-ROM. However publications for emergency use, such as the International Code of Signals and the IAMSAR Manual should always be available in the form of hard copies since such publications need to be readily available for use in case of emergency without any restrictions such as only available on a computer at specific place.

Publications Required on board Vessels

All publications must be latest edition.

Dangerous Goods in Packaged form and in Solid Bulk form

Refer to MSC-MEPC.2/Circ.2 of 1 June 2006 for full details

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

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

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