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 and Labelling of Chemicals (GHS) pictogram for environmentally hazardous substances (Photo credit: Wikipedia)
IMDG Code through part 5.4 requires shipper to submit duly filled and signed Dangerous Goods Declaration and container packing certificate ( DGD/CPC) for all shipments except for a few.
Apart from Dangerous goods Declaration there may be requirement of additional documents such as
a weathering certificate;
a certificate exempting a substance, material or article from the provisions of the IMDG Code
for new self-reactive substances and organic peroxides or new formulation of currently assigned self-reactive substances and organic peroxides
For documents required on board vessels IMDG Code states each ship to carry a special list or manifest showing the details of dangerous goods and marine pollutants with stowage location.
The Code does not ask for the UN Performance test certificate of packaging to accompany every shipment however there are increasing cases of shipping lines asking for this certificate for dangerous goods export ex India.
The institute authorized to carry out the UN Performance test for packaging in India is ‘Indian Institute of Packaging’ located in Mumbai, Chennai and Kolkata. The UN Performance test certificates issued by this institute are called as IIP Certificate by the shipping industry out here.
These days most of the lines ask for IIP certificate for every dangerous goods shipment out of India. This results in delay or sometimes unnecessary rejection as certificates are issued with 1 year validity and if shipment is booked at 11th month line rejects saying package certificate will expire before shipment reach final destination. Or IIP certificate is issued to a particular company who manufactures the packaging and the shippers name is different in the DGD.
Even lines are asking for IIP certificates for shipments in LIMITED QUANTITIES!!!!
Yes, shipper must confirm to the provisions of IMDG Code by jot and iota however asking for too many documents and formalities will cause much delay in supply chain. One must not be over verifying what is not needed.
IN the past self has handled dangerous goods export shipment safety approval of global export for large container lines. Working with other lines and various countries self never saw package performance test certificate being asked for verification unless for certain cases where there was misunderstanding about type of packaging or quantity being filled in a particular package.
Hope lines will not start asking who authorized Indian Institute of Packaging and who authorized them who authorized Indian Institute of Packaging
Hermetically sealed means vapour-tight closure. For certain substances IMDG Code packing provisions require package to be hermetically sealed.
For example Packing provision PP31 under instruction P400 states “For UN Nos 2870, packagings shall be hermetically sealed”
Unless otherwise specified for a particular substance in IMDG Code, packages containing dangerous goods which evolve flammable gases or vapour, may become explosive if allowed to dry, evolve toxic gases or vapour, evolve corrosive gases or vapour or may react dangerously with the atmosphere should be hermetically sealed.
Musk Xylene (5-tert-BUTYL-2,4,6-TRINITRO-m- XYLENE ) is a chemical having the smell of natural musk. Musk Xylene has explosive properties if kept under confinement. Transport regulations classify Musk Xylene under Class 4.1, Flammable Solids.
Listed in IMDG Code under UN 2956 Musk Xylene’s packing instructions only allows packages which do not create confinement. IMDG Code authorized packages are Fibre drums max net mass 50 Kg or Fibreboard box with an inner plastic bag max net mass 50 Kg or Fibreboard box or fibre drum with inner plastic packaging each containing 5 Kg and total net mass not more than 25 Kg.
If any other package is used other than what is permitted in packing instructions then the product must display a subsidiary risk label of explosives however this requirement may be removed provided competent authority of the country of origin permits so basis test data showing there is no explosive behaviour in the packaging used.
During transport packages containing Musk Xylene shall be protected from direct sunshine and stored (or kept) in a cool and well ventilated place, away from all sources of heat.
Packaging means one or more receptacles and any other components or materials necessary
for the receptacles to perform their containment and other safety functions.
Package means the complete product of the packing operation, consisting of the packaging and its contents prepared for transport.
Below is for beginners to understand what do Packing Codes means and why do some shipping lines or freight forwarders ask for it.
As per IMDG Code the design of each packaging used for carriage of Dangerous Goods shall pass UN Performance testing. (Consignments of Dangerous goods in limited quantities does not require this ) Details of performance test for various types of packaging are laid out in Chapter 6 of IMDG Code.
After the performance test a unique marking will be issued by the testing authority which shall be durable and legible.
If the packaging is intended to carry gross mass of more than 30 Kg of then this marking is required to be on the top or on the side of the packaging.
For Packaging of more than 30 kg the letters, numerals and symbols shall be at least 12mm high.
For Packaging of 30 kg, 30 l or less the letters, numerals and symbols shall be at least 6mm high.
For Packaging of 5kg, 5 l or less the letters, numerals and symbols shall be of appropriate size.
Packaging Marks
Each package design type is tested and issued with a unique mark from which we can understand the type of package and certain other details.
The code consists of:
.1 an Arabic numeral indicating the kind of packaging, such as drum, jerrican, etc.,
followed by
.2 one or more capital letters in Latin characters indicating the nature of the material,
such as steel, wood, etc., followed where necessary by
.3 an Arabic numeral indicating the category of packaging within the type to which the
packaging belongs.
Types of material:
A Steel (all types and surface treatments)
B Aluminium
C Natural wood
D Plywood
F Reconstituted wood
G Fibreboard
H Plastics material
L Textile
M Paper, multiwall
N Metal (other than steel or aluminium)
Lets look at an example package marking and interpret same to understand how this works
Letters UN = United Nations Symbol
4G = Packaging Code ( 4= box , G = Fibreboard )
Y = Tested for packing group II
145 = Maximum gross mass in Kilogram
S = Packing intended to carry solids or inner packing
02 = Last two digits of the year in which packaging was manufactured
NL = The country authorizing the allocation of this mark
VL823 = Manufacturer’s details
Testing
These design types of packaging undergo various types of test as required by the IMDG Code. Lets look at some of the test requirements
Drop test for Bag
Packaging
No. of test samples
Drop orientation
Bags – single-ply with a side seam
Three
(three drops per
bag)
First drop: flat on a wide face
Second drop: flat on a narrow face
Third drop: on the end of the bag
Bags – single-ply without a side
seam or multi-ply
Three
(two drops per bag)
First drop: flat on a wide face
Second drop: on an end of the bag
Drop height
Packing group I
Packing group II
Packing group III
1.8m
1.2m
0.8m
if the substance to be carried have a relative density more than 1.2 then the drop height is calculated as
dx1.5m , dx1.0m & dx0.67m for packing groups I,II and III respectively.
Leakproofness test
Any packaging intended to carry liquids shall undergo leakproofness test. These packaging will be kept under water and internal air pressure is applied
Packing group I
Packing group II
Packing group III
Not less than
30 kPa (0.3 bar)
Not less than
20 kPa (0.2 bar)
Not less than
20 kPa (0.2 bar)
After conducting various test, as specified in chapter 6 of IMDG Code on successful pass a certificate will be issued by the testing authority to the manufacturer of packaging with below mandatory details
name and address of the test facility;
name and address of applicant (where applicable);
a unique test report identification;
date of the test report;
manufacturer of the packaging;
description of the packaging design type (such as dimensions, materials, closures,
thickness, etc.), including method of manufacture (such as blow-moulding), and which
may include drawing(s) and/or photograph(s);
maximum capacity;
characteristics of test contents, such as viscosity and relative density for liquids and
particle size for solids;
test descriptions and results;
signature, with the name and status of the signatory.
This mark on the packaging does not necessarily confirm that the packaging may be used for any substance. For type of packaging and quantity of dangerous goods in packaging one must look into specific entry in chapter 3 and find out what type of packaging is allowed and what is the max allowed mass or quantity per package.
IMDG Code Compliance Centre 