Chapter 5.4 of the International Maritime Dangerous Goods Code (2012 Edition) indicates the requirements of the International Maritime Organization (IMO) for the description of a dangerous good on a shipping paper (referred to in the IMDG Code as a dangerous goods transport document) to be offered for transportation by vessel in international waters. The purpose of this article is to summarize the general requirements for a Shipper preparing a dangerous goods transport document.
- It is the responsibility of the consignor (ie. Shipper) of the dangerous good to provide the Carrier with the information required by the IMDG Code. This information must be provided on a dangerous goods transport document.
- A dangerous goods transport document may be in any form, provided it contains all of the information required by the IMDG Code. An example – not required, but an example – of a dangerous goods transport document is included as figure 5.4.5 of the IMDG Code.
- Paper documentation of the dangerous goods transport document is not required. Use of electronic data processing (EDP) or electronic data interchange (EDI) for transmission of the required information is acceptable, if agreed to by the Carrier. All references to “dangerous goods transport document” in the IMDG Code allows for the use of an EDP or EDI in place of a paper document.
- If an EDP or EDI is used instead of a paper document, the Shipper must be able to produce the required information, in the sequence mandated by the IMDG Code, without delay.
- If the initial Carrier accepts an EDP or EDI and later transfers the dangerous good to a Carrier that requires a paper document, it is the responsibility of the initial Carrier to provide a paper copy of the dangerous goods transport document and ensure it contains the statement: “Original received electronically” with the name of the certifying Shipper in UPPERCASE LETTERS.
- If both dangerous and non-dangerous goods are listed on a single document, the dangerous goods must be listed first, or otherwise emphasized.
- The name and address of the Shipper (ie consignor) and the receiving facility (ie. consignee) must be included on the dangerous goods transport document.
- The date a dangerous goods transport document was prepared or given to the initial carrier must be included on the document.
A lot more information is required on the dangerous goods transport document, and a full description of those will have to wait for another article, though a summary includes:
- A description of the dangerous good in the required sequence and using supplemental information, as applicable.
- The total quantity of dangerous goods.
- Information required in addition to the dangerous goods description, as applicable.
- A certification statement signed and dated by the Shipper. If an EDP or EDI is used instead of a paper document, the following two options are available to replace the hand-written signature of the Shipper:
- An electronic signature.
- The name of the person authorized to sign the document in UPPERCASE LETTERS.
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Is an EDP or EDI acceptable for transport of a dangerous good (HazMat within the U.S.) by vessel domestically? The answer is no. The Hazardous Material Regulations of the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the USDOT allows for an electronic shipping paper only if the transportation is by rail [49 CFR 172.201(a)(5)]. However, at 49 CFR 171.22(a) PHMSA allows for the use of international regulations – including the IMDG Code – as an alternative to compliance with the HMR, even within the U.S. Therefore, it is possible to transport a dangerous good/HazMat by vessel within the U.S. using an EDP or EDI as long as you comply fully with the IMDG Code and meet any additional requirements of the HMR indicated in 49 CFR 171.22, §171.23, and §171.25.