The Northern India Steamer Agents Association or NISAA organized a two days Workshop on Dangerous Goods at Delhi on 20th 21st of November 2015. The organizers, NISAA, gathered 45+ delegates from various sectors of shipping industry, which included, Liners, CFSs, ICDs, Rail Operators & Forwarders under one roof deliberating latest Rules and Regulations for safe handling of Dangerous Goods in Multimodal Transport.
NISAA IMDG Code Workshop – Delhi November 2015
The workshop on IMDG Code, attended by 20 organizations under NISAA’s umbrella, was conducted by Shashi Kallada who explained basic regulatory frameworks of IMDG Code, International Rail, Road, River transport of packaged dangerous goods from shipper to consignee through rail, road, river haulage and carriage by sea under SOLAS, 1974, as amended & MARPOL 73/78 conventions of IMO and country specific differences of India’s Major trading partners such as U.S., U.K., EU, CIS, Japan, Korea, OECD & more.
Participants actively took part in discussions, deliberations and raised questions on day to day practice v/s regulatory norms for enhancing safety and simplifying the process for shipping, handling and temporary keeping of dangerous goods in their custody.
Shridhar Subramaniam, EC Member of NISAA together with Atul Sachdev Secretary of NISAA kick-started the program. The two days action packed event was concluded by certification of attendance hosted by Capt. Ajay Kaura, President of NISAA, who reiterated the importance of safe handling of dangerous goods in multimodal transport.
Capt Ajay Kaura & Shashi Kallada @ NISAA Dangerous Goods Workshop at Delhi, November 2015
NISAA, took another major step in their continuous support to industry by organizing this event.
Dec 3rd – 4th 2013, Indian Maritime University conducted a two days workshop on Handling Of Dangerous Goods at Cochin Port, India. Workshop was inaugurated by Capt. Paul N. Joseph, Deputy Conservator, and conducted by Shashi Kallada. Capt. Paul N. Joseph spoke about the dangers involved with hazardous cargo to ports, ships and other users handling such goods.
Two days session covered over view of IMDG Code, dangerous goods declaration, placarding of containers, segregation in containers and segregation between containers.
Storage and handling of dangerous goods at port was covered in depth as per International Maritime Organisation’s “Revised Recommendations On The Safe Transport Of Dangerous Cargoes And Related Activities In Port Areas”
Dr. B. Swaminathan highlighted the importance of training and human element factor in maritime industry.
Sitting 3rd from left: Dr. Dr.B.Swaminathan, Faculty-PortManagement, Indian Maritime University 4th from left: Capt. Paul N. Joseph Deputy Conservator, Cochin Port 4th from right: Shashi kallada, Dangerous Goods Specialist.
A long international voyage of an unknown sailor and his small occasion to celebrate.
Anno Domini 15th October 2010 evening I shutdown my office workstation (at Maersk) and walked off to the retired life at the age of 40. I didn’t had much plans in my life other than relaxing in my home town, a small city, Calicut, fanned by gentle breeze from Arabian Sea.
Back at home, Bombay, on that evening I made a blog account thinking I will narrate my long journey in life.
Why long journey in life by 40, because I always followed my heart. A life’s journey followed by heart is much longer than a scheduled journey, because the true happiness is in journeying not in the destination.
That's Me
I always followed my heart, where I loved to stay I stayed long, where I didn’t love to stay I moved on. When I was sailing on long voyages I loved the staying in the going. When I stayed long during breaks in sailing or worked on storage tankers moored to SPM many nautical miles off the shore I loved the going in the staying.
In between sailing I took a break of 2 years and lived in West Africa, Tema and Abidjan mainly, involving myself into various aspects of port operations related to MPVs. It was one of the best days in my life spent in gold coast and ivory coast. Once I sat Hours and hours at Cape Coast Castle where 100s and 1000s of slaves were held captive before their fateful voyage across Atlantic commenced.
Cape Coast Castle
I was also involved in transporting ECOWAS Soldiers to Liberia for peace keeping mission, a life time experience of loading and discharging armored cars, ammunition and heavy artillery into and out of the cargo holds. Arranging the logistics for 1000 plus soldiers to sail on ship, installing their military radio station and antenna ,testing their radio. Communication was HF SSB Radio Telephony and Morse code. I felt am a soldier without uniform. Oops! I felt a soldier in Merchant Marine uniform 😉
Later during 1999 coup in Ivory Coast I had to save myself from looting, arson, gunshots and finally flee the country with nothing but the cloths I wore and my passport. Of course when I got out of then Sahar airport I had the stub of the air ticket additionally together with cloths I wore, passport and a one rupee coin which had hid itself in my jeans pocket. I walked from Sahar airport (Mumbai) , some 20 odd kilometers, to D.N. Road and borrowed a pen to fill up withdrawal form at my bank. The meal I had then at a restaurant is the best I ever had in life though cockroaches were playing on the table. I lost many of my documents and a box full of old photographs and negatives I had with me. I hadn’t changed to digital camera then, technologically less savvy I am. But those memories I still cherish in my heart.
Remembering those good old days I still some time test my ability to key Morse code.
My dusty old Morse Key
Coming back to the immediate days after leaving my last job and opening blog account, I sat in front of my laptop thinking what to write and where to start. I entered some small notes on dangerous goods; a topic very fresh in my mind after working 8 years in P& O Nedlloyd and Maersk dangerous goods department.
My blog entry was very infrequent through the months. Later one day I received an email from Microsoft stating that they are stopping the blog service and it will be automatically transferred to WordPress. I obliged and moved all my previous ‘rare’ entries on to WordPress.com
My entries during September and October 2011
13 entries in Sept 2011 is accumulated figure from Oct 2010.
Then at home town I bought a mountain bike and started cycling. Hitting out on the road before sunrise coasting Calicut’s beach road and turn back home from Beypore port some 17 kilometers one way.
Beypore port entry
Ability to read is a real gift, with this gift we can immerse ourselves into the world of literature. I indulge myself into reading any book I come across be it political, historical, religious or atheist. When I look back at my working days and now the graph of reading hasn’t changed much as reading was always part of me.
My Bookshelf
From Milton’s Paradise Lost , through Dostoyevsky’s Crime and Punishment or Tolstoy’s Anna Karenina or Khayyam’s Rubaiyat one can spent his life journeying through letters. Need not mention Don Quixote of Miguel De Cervantes which makes me feel am another Ingenious Gentleman Don Quixote of Calicut 🙂
Back at blog, during my interaction with various people in industry I realized there is definitely a lack of general understanding in dangerous goods transportation. How to rectify it? Training, already made mandatory by IMO. Yes training is mandatory and is undertaken by many.
But training starts and ends within a scheduled timetable. What happens if the trainee had any doubt many days, weeks or months after training? This was the question pondering my mind. Who will answer him or her? Whom the trainee can approach post training with a specific question?
Then late in November 2011 I decided to write on blog again. But what to write? I started recalling what I used to ask myself during my initial days in dangerous goods safety department and on those topics I started writing on blog.
How much more I wrote? In November 2011 I wrote one more entry
End November my blog entry status looked like this.
Watching the visitor status I felt I am the most frequent visitor reading my blog through admin panel but later the number of visitors started growing. The topics they read made me understand what information they are looking for. This encouraged me to write more and more.
End December my blog entry status looked like this.
Then I got a Class 1.4S fireworks email from WordPress.com celebrating my blog status 😉
Blog Visitor Status – Months and Years
I realized that when I write more number of visitors are increasing, compare no. of entries and visitors for Oct, Nov and Dec below.
This encouraged me to write more about what readers are looking for and my status went on to end of March 31st as below
Across the globe there are dedicated people ensuring compliance to SOLAS, 1974, as amended, and MARPOL 73/78 for safety and environmental protection during transport of dangerous goods.
I am happy to serve those who are looking for information about safe transport of dangerous goods by Road, Rail, River and Sea. Its my duty to give back to the industry what it taught me!
Today I will celebrate passing the milestone of 10,00th reading of my safety blog with “BEER”, because
“An aqueous solution containing not more than 24% alcohol by volume is not subject to the provisions of IMDG Code.” 😉
There are plenty of brands in market with face wipes (wet wipes); some for oily skin some for moisturizing etc. In this article we will look at two of these products and their transport classification as per IMDG Code.
Hydrogen Peroxide, Ethanol, Salicylic Acid, and other inert ingredients.
Product 1Clearasil Daily Care Deep Cleansing Wipes–
All the ingredients combined with the percentage does not have any properties of danger according to IMDG Code classification. This product does not have properties of explosives, flammable liquids or solids, oxidizing substances, toxicity, radioactivity or corrosive effect hence product one when offered as cargo by sea goes as non-hazardous.
Product 2Clearasil Ultra Deep Pore Face Wipes–
The main ingredient is Ethanol which is a flammable liquid. The wipe has absorbed the liquid ethanol without any free flowing liquid visible. The product is solid and is readily flammable due to the presence of ethanol. Due to the flammability of the absorbed liquid this is classified under SOLIDS CONTAINING FLAMMABLE LIQUID, N.O.S. UN 3175, Packing Group II.
If we have above two products as cargo by Sea product 1 will go as non –hazardous and product 2 will go as hazardous with dangerous goods declaration, marking, labelling, placarding and other related provisions applicable.
Above details of ingredients and classification are taken from the manufacturer’s website which may be modified by the manufacturer. The writer does not promote any product for their usage or suggest advantage of one product over other but has only given an example that certain products which we use in daily life may be considered as dangerous goods as per transport regulations. To check applicability, limitations and or exemptions for each mode of transport responsible person shall refer the respective regulations.
For some dangerous goods together withDangerous Goods Declaration IMDG Code require additional document(s). One of which is a “Weathering Certificate”
Let’s look at what is a weathering certificate and when this is required.
Weathering is required for goods to reduce the moisture content, if any.
Example UN 1408 FERROSILICON with 30% or more but less than 90% silicon, Class 4.3.
Ferrosilicon when moist will generate hydrogen which is highly flammable.
The entry in DG list UN 1403 is assigned with special provision 932 which states “Requires a certificate from the maker or shipper, stating that the shipment was stored under cover, but in the open air, in the size in which it was packaged, for not less than 3 days prior to shipment.“
For IRON OXIDE, SPENT – UN 1376 Class 4.2: IMDG Code recommends through observation column in DG List that weathering of at least 8 weeks before shipment is needed if not packed in metal drums.
So which substance require a weathering certificate?
A substance require a weathering certificate when same is asked for in the individual entry in Dangerous Goods List.
Expandable polymeric beads or Expandable Polystyrene beads are moulding materials which come in the form of beads. The composition is polystyrene and a blowing agent which is hydrocarbon . (blowing agent is n-pentane, i-pentane and c-pentane).
Expandable polymeric beads containing blowing agent will expand when exposed to heat. These expandable polymeric beads are used for many applications like insulation, thermal packing, trays, toys, coffee cups food containers etc.
Hazards of Expandable Polymeric Beads
Fire! Fire is the hazard associated with this. Since this product contains hydrocarbon blowing agent (typically pentane) handling and storing of this product must take into consideration of any possible source of ignition. While stored Expandable polymeric beads will keep releasing a small amount of hydrocarbon vapors and the rate of release will increase when exposed to heat. Pentane vapors are heavier than air hence storage area must have good ventilation to remove any vapor trapped in low areas. Recommended storage is below 20 deg C in a well-ventilated area.
Shipping
Generally Expandable Polymeric Beads are transported in fibreboard boxes or flexible IBCs. IMDG Code list this under UN 2211 , POLYMERIC BEADS, EXPANDABLE , Class 9 with instruction for segregation as for Class 3 ( Flammable Liquids )*. IMDG Code 36th Amendment which will be published in 2012 may contain the requirement of hermetically sealed packaging and IBCs which meet certain performance standards when transported in Closed Cargo Transport unit as proposed by European Chemical Industry Council to IMO.
Some shipping lines may require additional warning label apart from Placards. This label should be placed on the door and may read “ WARNING : MAY CONTAIN EXPLOSIVE ATMOSPHERE, KEEP IGNITION SOURCES AWAY” or may even ask to ship it as one-door-off. However one-door-off operation will require additional approval for the said container as per CSC ( International Convention for Safe Containers) as one-door-off on normal containers will change allowable stacking load and transverse racking test force.
* Category E. Shaded from radiant heat and protected from sparks and open flame. When stowed under-deck, mechanical ventilation shall be in accordance with SOLAS regulation II-2/19 (II-2/54) for flammable liquids with flashpoint below 23°C c.c. Segregation as for class 3 but “Separated from” class 1 except division 1.4S.
We all know that every consignment of dangerous goods, barring a few, needs a Dangerous Goods Declaration (DGD). This can be submitted as a printed or electronic copy.
If no declaration (DGD) is submitted carrier will reject the consignment or refuse to load.
Also some of us have experienced even after submitting document container failed to load or carrier returned the document due to missing or wrong information.
Internationally when port state authorities conducted random inspection on deficiencies in Dangerous Goods consignments a major percentage was wrong documentation. Missing or wrong DGD may lead to accidents, death, loss of property of damage to environment.
When we encounter any difficulty in preparing a DGD or when DGD is rejected or questioned for missing or ambiguous information we do think How to prepare a correct completed Dangerous Goods Declaration?
Then answer is simple “Be familiar and thorough in Chapter 5.4 of IMDG Code“
Since this Chapter 5.4 is linking to other sections of IMDG code and have some exceptions let’s not go into full details but learn the basic steps of preparing a DGD.
Page Numbers
If the DGD has more than one page then same must be numbered consecutively. Example page numbers for a 3 page DGD: 1 of 3, 2 of 3, 3 of 3.
The idea is if a one or more pages of a multipage DGD is missing above way of numbering will exactly inform the referrer which page is missing.
DGD must include the name and address of the shipper and consignee.
Date
Must have a date and this can be either the date of preparing the DGD or date on which DGD is given to the initial carrier.
Dangerous Goods part
Every item of dangerous goods under the respective shipment shall be mentioned here and the IMDG Code require this information to be in a particular sequence which is as below
This information shall always be in this sequence and never shall be re arranged when preparing the document. Below are some examples of correctly sequenced dangerous information on DGD
UN1098 ALLYL ALCOHOL 6.1 (3) I (21oC c.c.)
UN1098, ALLYL ALCOHOL, class 6.1, (class 3), PG I, (21oC c.c.)
UN 1092, Acrolein, stabilized, class 6.1 (3), PG I, (-24oC c.c.) MARINE POLLUTANT
We must declare the total number and type of packages and the quantity of dangerous goods. For Explosives the quantity is the net explosive weight, for other dangerous goods its volume or mass. Here I am not writing about shipments of radioactive substances which may require activity level also on documentation.
Number and type of packages such as drums or jerricans can be written as say, 10 drums or ten drums.
One shipment which does not require total quantity of dangerous goods to be written on DGD is empty uncleaned shipment.
If the shipment offered is limited quantities then same must be mentioned on the DGD
Excepted Quantities
If the shipment offered is excepted quantities then same must be mentioned on the DGD.
Temperature controlled
Self-reactive substances and organic peroxide which require temperature control need to be mentioned with Control and Emergency Temperature this is applicable also to other substances if they are stabilized by means of temperature control.
There are much more information required on DGD which is depending on the dangerous goods being offered for carriage by sea. Also some substances may require additional documentation such as a weathering certificate or exemption certificate.
Also other than tanks DG shipments need a packing Certificate also.
Now let’s see what are the legally binding parts of documentation (DGD).
Signature
Shipper and packer must sign the document, in an electronic form this can be replaced by NAME in capital letters.
Declaration or Certification
To certify that the shipment meets the applicable regulations below text shall be in the DGD
“I hereby declare that the contents of this consignment are fully and accurately described above by the Proper Shipping Name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable international and national government regulations.”
Format of DGD can be found here including continuation page and container packing certificate points. The format of the form can be anyhow but the information required by Chapter 5.4 of IMDG Code must be there clear and legible.
Retention of DGD
Both Shipper and Carrier shall retain a copy of DGD and any other additional document as required by IMDG Code for a minimum period of 3 months.
Above is the basic of preparing DGD for full details refer to chapter 5.4 and respective entry of UNNO in chapter 3.2 of IMDG Code (35-10)
Additional Documents
For some dangerous goods together with Dangerous Goods Declaration IMDG Code require additional document(s). They are
(1) Weathering Certificate
(2) a certificate exempting a substance, material or article from the provisions of the IMDG Code
(3) a statement by the competent authority of the country of origin of the approved classification and conditions of transport for a new self-reactive substances and organic peroxides or new formulation of currently assigned self-reactive substances and organic peroxides
IMDG Code Compliance Centre 