The International Maritime Organization (IMO) publishes a new edition of its International Maritime Dangerous Goods Code (IMDG Code) every two years, with the current edition (2012, incorporating amendment 36-12) published in the Fall of 2012. Each new edition of the IMDG Code has an interesting life-cycle as indicated below:
- The first calendar year after its publishing (2013 for the 2012 edition) is a transition year where either the current edition or its predecessor is valid.
- The second calendar year after its publishing (2014 for the 2012 edition) is the year when only that edition is valid.
- The third calendar year after its publishing (2015 for the 2012 edition) is a transition year again where either the current edition or its replacement (2014, incorporating amendment 37-14) is valid.
- The end of the third calendar year after its publishing (December 31, 2015 for the 2012 edition) is the end of the validity of the edition.
If you’re confused by the amendment cycle of the IMDG Code and unsure if you are referring to the correct edition to determine compliance, refer to this simple infographic: The IMDG Code Amendment Cycle
The 2014 edition of the IMDG Code is expected to be published soon, below are some of the significant changes from the 2012 edition it contains:
- Updates have been made to provisions reflecting the regulations of the International Atomic Energy Agency for the safe transport of radioactive material.
- Column 16 “Stowage and Segregation”of the Dangerous Goods List has been split into two new columns: 16a “Stowage and Handling” and 16b “Segregation”. Instead of descriptive text, these two columns now contain codes that are defined in Chapter 7 of the IMDG Code.
- Significant changes to Chapter 7.2, including more stringent segregation and stowage requirements for Class 4.3 Dangerous when wet and other water-reactive materials.
- Updates to the Dangerous Goods List include:
- Proper shipping name for UN3268 has been changed from “AIR BAG MODULES, AIR BAG INFLATORS or SEAT-BELT PRETENSIONERS” to “SAFETY DEVICES”.
- Proper shipping name and UN Number for asbestos is now UN2212 “ASBESTOS, AMPHIBOLE” or UN2590 “ASBESTOS, CHRYSOTILE”.
- The entry for “CAPACITORS” has been divided into “CAPACITOR, ELECTRIC DOUBLE LAYER” UN3499 and “CAPACITOR, ASYMMETRIC” UN3508.
- “PACKAGING DISCARDED, EMPTY, UNCLEANED” un3509 HAS BEEN ADDED BUT CAN NOT BE USED FOR TRANSPORT BY VESSEL.
- A series of shipping names for various adsorbed gases have been assigned UN Numbers between UN3510 and UN3526.
- Special Provisions have been aded:
- SP 367 through SP 376 (excluding SP 374 and SP 375).
- SP 968 through SP 970.
- Special Provisions for shipping certain common items have been added or revised:
- SP 376 through SP 377 for lithium batteries damaged/defective or for recycling or disposal.
- SP 961, SP 962 (Vehicles or Internal Combustion Engines; see also SP 970).
The transportation of dangerous goods by vessel outside of the US and its territorial waters must comply with the IMDG Code. It is possible that a carrier transporting dangerous goods by vessel within the US will comply with the IMDG Code as well, thus requiring your understanding and use of it. Of course, any transportation of dangerous goods (referred to as hazardous materials by US regulations) within the US must comply with the Hazardous Material Regulations of the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Regulations, both international and domestic require that you train all personnel who are involved in the transportation of the dangerous good/HazMat. Contact me for this training.