Segregation of Dangerous Goods in Port Areas

Guidance in this article is applicable only for packaged dangerous goods. Segregation recommendation explained below for port areas may also be applied to CFS/ICD for safety reasons.

 Correct classification, packaging, marking, labelling, segregation, securing cargo in container and documentation is the prerequisite to ensure safety of life at sea and prevention of pollution. Packaged dangerous goods whether containerized or non-containerized when kept in port areas waiting for loading on to vessel or to be taken out by consignee may require segregation from one another. Transport regulations contain mandatory segregation rules recognizing the danger involved and available/practical emergency response in each mode of transport. Segregation requirements varies from regulation to regulation; in multimodal transport the most stringent segregation rule of one mode is acceptable by other modes.

Class 1, Explosives, other than 1.4S, and Class 7, Radioactive Materials, should generally be handled direct loading and delivery. Port authorities must formulate special plans for keeping these classes when necessary under special safety, emergency response and security measures. Class 6.2, Infectious substances, must only be handled as direct loading or delivery, never be kept in port areas.

Other classes may be segregated as in below table.

Segregation of Dangerous Goods in Port Areas
Segregation of Dangerous Goods in Port Areas

Non-containerized Packages & IBCs

0 = no segregation necessary unless required by the individual schedules

A = away from – minimum 3 m separation required

S = separated from – in open areas, minimum 6 m separation required in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall

 

Closed containers & portable tanks

 0 = no segregation necessary

A = away from – no segregation necessary

S = separated from – in open areas, longitudinally and laterally, minimum 3 m separation required, in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall

DPP_0372

 Example segregation check -“away from”

 

  1. Non containerized packages class 2.2 and 3

 Intersection between classes 2.2 and 3 in above table is A = away from – minimum 3 m separation required.

 

  1. Container one carrying class 2.2, container two carrying class 3

 Intersection between classes 2.2 and 3 in above table is A = away from – no segregation necessary.

 In the above example non containerized packages need ‘away from’ 3 meter segregation however when the packages are in different containers no segregation is needed.

 Example segregation check -“separated from”

 

  1. Non containerized packages class 2.1 and 3

 Intersection between classes 2.1 and 3 in above table is S = separated from

– in open areas, minimum 6 m separation required

– in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall

 

  1. Container one carrying class 2.2, container two carrying class 3

 Intersection between classes 2.1 and 3 in above table is S = separated from

– in open areas, longitudinally and laterally, minimum 3 m separation required, – – in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall

  Example segregation check – “Subsidiary Risk”

 

  1. Non containerized packages UN 1072 OXYGEN, COMPRESSED Class 2.2 Subsidiary Risk 5.1 and UN 1001 ACETYLENE, DISSOLVED Class 2.1

 Intersection between classes 2.1 and 2.2 in above table is O = no segregation necessary

Intersection between subsidiary risk of UN 1072 class 5.1 to main class of UN 1001 2.1 is S = separated from

More stringent segregation requirement is S= separated from.

 – in open areas, minimum 6 m separation required

– in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall

 

  1. Container one carrying UN 1072 OXYGEN, COMPRESSED Class 2.2 Subsidiary Risk 5.1 and container two carrying UN 1001 ACETYLENE, DISSOLVED Class 2.1

 Intersection between classes 2.1 and 2.2 in above table is O = no segregation necessary

Intersection between subsidiary risk of UN 1072 class 5.1 to main class of UN 1001 2.1 is S = separated from

 – in open areas, longitudinally and laterally, minimum 3 m separation required, – in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall

 Example segregation check – “Segregation Groups”

 

  1. Non containerized packages of UN 1502 SODIUM PERCHLORATE, Class 5.1 and UN 1512 ZINC AMMONIUM NITRITE, Class 5.1

 Intersection between classes 5.1 and 5.1 in above table is O= no segregation necessary unless required by the individual schedules

 UN 1502’s Column 16 of IMDG Code 36-12 says “Separated from” ammonium compounds and cyanides.

UN 1512 is listed in segregation group 2 Ammonium compounds in section 3.1.4.4 hence applicable segregation is S = separated from

– in open areas, minimum 6 m separation required

– in sheds or warehouses, minimum 12 m separation required unless separated by an approved fire wall

 

  1. Container one carrying UN 1502 SODIUM PERCHLORATE, Class 5.1 and Container two UN 1512 ZINC AMMONIUM NITRITE, Class 5.1

 Intersection between classes 5.1 and 5.1 in above table is O= no segregation necessary unless required by the individual schedules

 UN 1502’s Column 16 of IMDG Code 36-12 says “Separated from” ammonium compounds and cyanides.

UN 1512 is listed in segregation group 2 Ammonium compounds in section 3.1.4.4 hence applicable segregation is S = separated from

 – in open areas, longitudinally and laterally, minimum 3 m separation required,

– in sheds or warehouses longitudinally and laterally, minimum 6 m separation required unless separated by an approved fire wall.

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Ports should develop their own lay out plan for keeping and segregating dangerous goods based on quantitative risk analysis and segregation requirement. For more information refer to Revised Recommendations on the safe transport of dangerous cargoes and related activities in port areas published by IMO.

A port which stack all dangerous goods containers together is not a safe port!!!

IMDG Code 36-12 Overview of changes

IMDG Amendment 36-12 can be used voluntarily from 1 January 2013 ; will become mandatory from 1 January 2014.

List of UN numbers are up to 3506 and there are significant changes to Stowage and segregation, Sources of heat, Foodstuffs, Limited quantities and Explosives.

Part 7 has gone through a major shuffling by changing the order of  subsections and chapters.

You may visit http://www.imdgsupport.com/ to get details of changes highlighted by Exis Technologies.

Update on Amsterdam Bridge Fire -1

Fire is believed to be contained.Vessel was near Prongs Reef light house when fire started. Seat of fire is believed to be in hold no. 3.
Coast Guard , Indian Navy  and ONGC vessels are engaged in fire fighting.

According to Truthdive.com Deputy Inspector General, Coast Guard (West), Manoj Vasant Baadkar stated “Some containers carry dangerous cargo, we call them HNS, hazardous noxious substances. The master of the vessel did not know the exact nature of the cargo, but we found that the ship was carrying petrol, inflammable gas and turpentine. There was an explosion deep in the cargo hold that caused the fire,”

Wonder how Master is not aware of Dangerous goods Containers and locations. No Manifest given to vessel after JNPT cargo operations??

IMDG Code requires each ship to carry a special list or manifest showing the details of dangerous goods and marine pollutants with stowage location. This is the requirement of SOLAS Chapter VII Part A Regulation 4.5   quoted below

Each ship carrying dangerous goods in packaged form shall have a special list or manifest setting forth, in accordance with the classification set out in the IMDG Code, the dangerous goods on board and the location thereof. A detailed stowage plan, which identifies by class and sets out the location of all dangerous goods on board, may be used in place of such a special list or manifest. A copy of one of these documents shall be made available before departure to the person or organization designated by the port State authority.

Who was the responsible person or organization having possession of above mentioned manifest? Why that was not immediately available to those involved in Emergency Response Measures? Why Master was not knowing the exact nature of cargo when vessel is required to have hazardous manifest and IMDG Code?

Many questions need answer to learn from this accident ;to take measures to prevent such accidents in future.

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)

Amendment to SOLAS chapter VII – Regulation 4

At 90thsession held from 16 to 25 May 2012 Maritime Safety Committee (MSC) adopted amendment to SOLAS chapter VII – Regulation 4. The new text will replace the existing text and will come in force from 1 January 2014.

PSC inspection of motor vessel Union Anton
PSC inspection of motor vessel Union Anton (Photo credit: U.S. Coast Guard)

New text is as below

Regulation 4 –   Documentation

 1 Transport information relating to the carriage of dangerous goods in packaged form and the container/vehicle packing certificate shall be in accordance with the relevant provisions of the IMDG Code and shall be made available to the person or organization designated by the port State authority.

2 Each ship carrying dangerous goods in packaged form shall have a special list, manifest or stowage

plan setting forth, in accordance with the relevant provisions of the IMDG Code, the dangerous goods on board and the location thereof. A copy of one of these documents shall be made available before departure to the person or organization designated by the port State authority.

Regulation 4 is envisaged entry-into-force date of 1 January 2014, in order to align the entry-into-force date of the aforementioned SOLAS amendments with that of the amendments to the IMDG Code scheduled to be adopted in 2012

World Oceans Day & MARPOL ANNEX III

June 08th 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

MARPOL

International Convention for the Prevention of Pollution from Ships (MARPOL), 73/78, is a combination of two treaties adopted in 1973 and 1978 by International Maritime Organisation.

This convention includes regulations to prevent and minimize pollution from ships. It has six annexes as below.

Annex I   

Regulations for the Prevention of   Pollution    by Oil

Annex II    

Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk

Annex III   

Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form

Annex IV   

Prevention of Pollution by Sewage from Ships

Annex V 

Prevention of Pollution by Garbage from Ships

Annex VI    

Prevention of Air Pollution from Ships

IMDG Code 35-10 & MARPOL

MARPOL Annex III , Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form,  is reproduced in IMDG Code 35-10 section 1.1.2.2.  Annex III has 8 regulations and an Appendix as below

Regulation 1       = Application

Regulation 2       = Packing

Regulation 3       = Marking and Labelling

Regulation 4       = Documentation

Regulation 5       = Stowage

Regulation 6       = Quantity Limitation

Regulation 7       = Exceptions

Regulation 8       = Port State control and operational  requirements

Appendix

CRITERIA FOR THE IDENTIFICATION OF HARMFUL SUBSTANCES IN PACKAGED FORM

For the purposes of this Annex, substances identified by any one of the following criteria are harmful substances:

Section 2.9.3 of IMDG Code 35-10 sets out the classification criteria for Environmentally hazardous substances (aquatic environment)

Chapter 2.10 defines Marine pollutants as “substances which are subject to the provisions of Annex III of MARPOL 73/78, as amended”

Index of IMDG Code 35-10 and Column 4 in Dangerous Goods Lists in chapter 3.2 identifies Marine Pollutants with symbol P.

However when a substance, material or article possess the properties of  marine pollutant but not identified in IMDG Code as such it shall be transported according to the relevant provisions for carriage of marine pollutants.

Packages containing marine pollutants must be marked with the recognized chemical name of the marine pollutant and bear the Marine Pollutant mark set out in section 5.2.1.6.3 of IMDG Code 35-10 which is shown below

dimensions shall be at least 100 mm × 100 mm, except in the case of packages of such dimensions that they can only bear smaller marks.

However single packagings and combination packagings  having :
– a net quantity of 5 l or less for liquids; or
– a net mass of 5 kg or less for solids

need not be marked.

Containers containing marine pollutants must be marked with marine pollutant mark having minimum dimensions of 250 mm x 250 mm one on each side and one on each end of the container even if the container contains packages not required to bear the marine pollutant mark