Status of the IMDG Code for 2021

2020 was not a normal year.

IMO’s meeting schedule was disrupted by the global public health crisis and the 2020 Edition of the IMDG Code is not yet available. IMO hopes to have it published in early 2021. Therefore, IMO announced a five-month delay in the mandatory compliance with the 2020 Edition of the IMDG Code.

The new mandatory date is June 1, 2022 instead of January 1, 2022.
Voluntary compliance remains January 1, 2021. (which I really don’t see the point of since the IMDG Code isn’t expected to be printed until several months into 2021!)

What this means to you:

Until the 2020 Edition of the IMDG Code is published you may continue to comply with the 2018 Edition. Even after the publication of the 2020 Edition on ??.??.21, you may continue to comply with the 2018 Edition during this transition year. And you may continue to comply with the 2018 Edition through January 1, 2022 (the normal cut-off) until June 1, 2022 which is the new date for mandatory compliance with the 2020 Edition.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Got it?

If you prepare a dangerous good for international transportation by vessel you – and perhaps other employees – must receive initial and triennial IMO Training and USDOT/PHMSA HazMat Employee Training. I can provide both.

Q&A: How do I classify a Class 3 Combustible Liquid for both international and domestic transport?

This e-mail was sent from a contact form on Daniels Training Services (https://danielstraining.com) on December 05, 2019

Hello,

I am trying to name a chemical for transport. It has a flashpoint of 81 C. It is not a US DOT marine pollutant, but it is an IMDG marine pollutant. We ship in both bulk and non-bulk packaging, both domestically and internationally. I believe the US DOT name would be NA1993, combustible liquids, n.o.s. (name), 3, III -is that correct?

I am having a hard time with the IATA and IMDG name. Would those still be the NA1993? I know that NA1993 isn’t recognized internationally, so I am little confused as how this should be named. Any help you can provide with the naming would be greatly appreciated!!

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My reply December 10th:

Thank you for contacting me. I apologize for my delay. I will review and reply. Please advise on the below.

What is the chemical? Do you have an SDS?
What makes it an IMDG marine pollutant?
What is the expected capacity of the packaging: <5 L / 5 kg? <119 gallons? >119 gallons?
Does transport begin or end in the U.S.?

Thank you and please advise.

Answer:

Hello Daniel,

Thanks for taking the time to help me with this!!

The product is a blend of basic epoxy resin (casRn 25085-99-8) and Oxirane, 2-(butoxymethyl)- (casRn 2426-08-6); flash point 81 °C
No, we do not have a SDS. We are trying to make one and the SDS author asked me to assist in the naming.
It is IMDG marine pollutant because it meets the UN model regulation criteria for classification as a Chronic Aquatic Toxicity Cat 2.
When we make a SDS, we include the names for each package type and mode of transport. We ship 1L to 20L/5 gallon samples, 55 gallon drums, and 275 gallon totes
- 1L to 5 gallon samples ship by ground or air both domestically and internationally
- 55 gallon drums and 275 gallon totes ship by ground domestically and by vessel internationally
Transport begins in the US

Thanks,

Interested in site specific training at your site that covers this topic, and more!

Ask me about my Onsite Training

It was after Christmas, (12.27.19) but I got him an answer:

I will try to answer you questions. Please see below.

Based on the flash point it is a Class 3 Combustible Liquid per USDOT regulations.
A material with a flash point higher than 60 degrees C is not subject to international regulations (IATA or IMO).
Based on your information it is not a marine pollutant per USDOT regulation but is a marine pollutant per international regulations.
A combustible liquid is not subject to USDOT regulation if transported by highway or rail within the U.S. and in a non-bulk packaging (and other conditions).
A non-bulk packaging of this material is not subject to USDOT regulations within the U.S. In a bulk packaging it is a Class 3 Combustible Liquid. NA1993, combustible liquids, n.o.s. (name), 3, III may be the proper shipping description if a more specific name is not available. There may be other shipping names that are more descriptive of the HazMat.
The material is subject to international regulation as a marine pollutant unless subject to the marine pollutant exception (packaging of less than 5 L or 5 Kg).
USDOT regulations allow a non-HazMat to be classified as a marine pollutant within the U.S. if subject to international regulation as a marine pollutant.

Also:

Section 14 of the SDS is not required to be completed within the U.S.

My suggestion:

Classify as marine pollutant for all transport.
Classify as Class 3 Combustible Liquid only when in bulk packaging within the U.S. All other transport is non-HazMat.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Read:

I hope this helps. Please don’t hesitate to contact me with any other questions.

His reply December 30th:

Thanks Daniel! This was very useful!!

Q&A: What is the proper shipping description for a limited quantity of HazMat by vessel?

Question (May 02, 2018):

I have had no official training, but I have been brokering Hazardous shipment(s) for approx 25 years.
I wanted to make sure that the BOL I prepared is correct.

UN 3208 Metallic Substance, Water-Reactive NOS (Magnesium, Class 4.3, PG II, Limited Quantity, F-G, S-N

Emergency Phone ###-###-####

My reply that same day:

Please see below.

Overall, the shipping description appears correct. Please see below for further guidance.

Note: Since you represent a trucking company within the U.S., I presume at least part of the transport to be by U.S. highway. Also, though not indicated in your question, I presume this consignment is to be transported by vessel according to the International Maritime Organization Dangerous Goods Code (IMDG Code). I’ll indicate how I came to this second conclusion while answering your question.

The sequence to the basic description is correct.
- UN/ID number: UN3208
- Proper shipping name: METALLIC SUBSTANCE, WATER-REACTIVE, N.O.S. The proper shipping name is displayed in uppercase letters in the IMDG Code. It is acceptable to be displayed in lowercase letters.
- Hazard class: Class 4.3. Class 4.3 is Dangerous When Wet. Note: Class 4.3 is how it is identified in the IMDG Code. The USDOT/PHMSA Hazardous Materials Regulations refers to it as Division 4.3.
- Packing Group: PG II. PG II is the medium / moderate level of danger for a hazardous material / dangerous good.
An additional description of the hazardous material / dangerous good is required as well:
- Since this is a generic proper shipping name, at least one technical name of a constituent of the hazardous material / dangerous good must be included with the shipping description. The technical name must be contained within parenthesis (brackets). You indicate “Magnesium” but do not have it contained within parenthesis.
- “Limited Quantity” or “Ltd Qty” is to be included as an additional description if the hazardous material / dangerous good is to offered for transport by vessel or air subject to the limited quantity exception. Both the IMDG Code and the USDOT/PHMSA Hazardous Materials Regulations have similar requirements for packaging and hazard communication of a limited quantity. Note: A shipping paper is not required for the transport of a limited quantity by highway or rail within the U.S., but is required for transport by vessel. I therefore again presume that this consignment is to be transported by vessel per the IMDG Code.
- Subject to the IMDG Code, it may be a limited quantity only if the net quantity of dangerous good in a single packaging is no more than 500 grams and if the gross package weight does not exceed 30 kg.

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“F-G, S-N” are the relevant emergency schedules for FIRE and SPILLAGE in the EmS Guide for this dangerous good. It is identified in column 15 of the IMDG Code’s Dangerous Goods List. This information – along with the emergency phone indicated – can fulfill part of your responsibility as the shipper to provide emergency response information to the carrier. Note: the EmS Guide is not identified in the USDOT/PHMSA Hazardous Materials Regulations (another indication of this consignment’s transport) but may be acceptable as a source of emergency response information it requires.
You do not indicate a total quantity of hazardous materials / dangerous goods nor a number and type of packaging. I presume you are satisfied with these aspects of the shipping description.

Please contact me with any other questions or comments.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

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Conclusion / Summary:

I did not receive confirmation from my questioner but I believe my presumptions to be correct. A question then: Is it OK to prepare and offer for transport a consignment of a hazardous material / dangerous good in compliance with the IMDG Code when some of the transport is by highway within the U.S.? Answer: yes! The Hazardous Materials Regulations of USDOT/PHMSA at 49 CFR 171.23 and §171.25 allow for the transport of a hazardous material (the IMDG Code refers to it as a dangerous good) according to the international regulations of the IMDG Code within the U.S. as long as the shipper complies with the additional requirements and limitations identified in those sections.

And wow! “I have had no official training…” just knocks me out. The regulations of both USDOT/PHMSA and the IMDG Code require any person with a direct affect on the safe transport of hazardous materials / dangerous goods to receive initial training (within 90 days) with a triennial renewal (every three years).

Q&A: Must I display the Class 9 Miscellaneous Placard on a cargo transport unit by vessel?

Question received March 26, 2018:

Mr Stoehr,

I was doing some research when I came across your website and had a question on the requirement for a Class 9 placard on an international vessel shipment via CTU (Cargo Transport Unit, a type of freight container) on the following:

UN3480, Lithium Ion Batteries, 9, II – (21kg. net) 23 kg. Gross
UN3090, Lithium Metal Batteries, 9, ll – (14 kg. net) 34.45 kg. Gross

: Lithium ion battery

: Lithium metal battery

I’m familiar with 49 CFR 172.504(f)(9) for no placard required for domestic shipping. Just not clear on international shipments via vessel.

Thank you very much for your time Sir have a great day.

My reply with a partial answer the next day:

I have a partial answer for you now but can provide a more complete answer if you are able to provide more information about your shipment. Please see below.

With a few exceptions the International Maritime Organization Dangerous Goods Code (IMDG Code) requires enlarged labels (placards) to be displayed on a cargo transport unit (CTU) for any primary and subsidiary hazard of the dangerous goods contained within.
As you indicate, the domestic regulations of USDOT/PHMSA do not require display of the Class 9 placard within the U.S. There is no such exception in the international regulations.
Therefore, under some circumstances this would require the display of the Class 9 placard on all four sides of the CTU.
However, special provision 188 allows for an exception from most of the IMDG Code for lithium batteries of a certain size. To determine the applicability of this regulation please provide the following:
- Watt-hour (Wh) rating of lithium ion batteries
- Lithium metal content (g) of lithium metal batteries.

Status	Lithium Ion Battery (Watt-hour (Wh) Rating)		Lithium Metal Battery (Lithium Content (g))
	Battery	Cell	Battery	Cell
Subject to "smaller battery exception"	Does not exceed 100 Wh	Does not exceed 20 Wh	Does not exceed 2 g	Does not exceed 1 g
Subject to full regulation	Exceeds 100 Wh	Exceeds 20 Wh	Exceeds 2 g	Exceeds 1 g
Subject to "smaller battery exception" by highway or rail	Does not exceed 300 Wh	Does not exceed 60 Wh	Does not exceed 25 g	Does not exceed 5 g

I’m happy to help you further.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

A long while later (May 1st!) I hadn’t hear from him so I followed up:

Please let me know if my answer was satisfactory or if you require further information.

I am happy to assist you!

And he came right back:

Thank you for your response very much appreciated. The total Watt Hours exceeded the limit. So I ended up putting a UN3480 class 9 placard on thank you for your assistance.

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Conclusion:

Looking at his answer now, I’m concerned by the wording of his response, “The total Watt Hours exceeded the limit”. “…total…”? My concern is that he might have tallied up the Watt hour (Wh) rating for every lithium ion battery in the consignment. He then may have found this total then exceeded the limit – actually a threshold – between a fully-regulated lithium battery and one subject to the packaging exception identified in Special Provision 188. A lithium battery (ion or metal) below the threshold value is not subject to full regulation in the IMDG Code and does not require the display of the Class 9 Lithium Battery label on the package nor the Class 9 Miscellaneous placard on the CTU. A fully-regulated lithium battery, however, does require the display of the Class 9 Lithium Battery label on the package and the Class 9 Miscellaneous placard on the CTU. And a lot more.

: Class 9 Lithium Battery label

: Class 9 Miscellaneous placard

The questioner indicated he is aware of the differing regulatory requirements for the display of the Class 9 Miscellaneous placard: required for international transportation v. not required – but allowed for domestic transportation. In this situation the CTU may – or may not – display the Class 9 Miscellaneous placard when transported within the U.S., but once it is prepared for international transportation by vessel, i.e., at the dock, it must display the Class 9 Miscellaneous placard.

The regulations for the transportation of a hazardous material can be complicated. Let me help you to navigate through them. My training can give you the knowledge necessary to access the regulations and find these answers for yourself. And, of course, you can always contact me for help.

Daniels Training Services, Inc.

815.821.1550

The Lithium Battery Test Summary

The regulations for the transportation in commerce of lithium cells and batteries requires each cell or battery to be of the type proved to meet the requirements of specific test procedures of the United Nations. Under current regulations it is the responsibility of the battery manufacturer to perform the tests, maintain a record of satisfactory completion, and make such records available to an authorized representative upon request. As of January 1, 2020, this responsibility expands (in some regulations) to include subsequent distributors of lithium cells and batteries.

The purpose of this article is to identify the regulatory requirements for applicable persons to test lithium a lithium cell or battery, maintain records of the test summary, and to provide a copy of the test summary upon request.
(more…)

Q&A: What are the the specifications in the IMDG Code and USDOT/PHMSA regulations for the Division 4.1 Flammable Solid placard?

This email came from India on February 12, 2019:

(India!)

Dear Sir,

Good Morning!

We are the manufacturer of Aluminium powder (UN1309, Aluminum powder, coated, 4.1, PG II). We request your help to know the details from the Hazardous material transportation regulation of IMDG, 2018 Edition 39 -18 Amendment or 49 CFR 172.546 (Class 4 placards specification). Please send the placard specification for class 4 details from the above latest regulations. Now we are following old regulatory placard specifications for the shipments. It is most Urgent. We are expecting your positive reply.

Thanking You.

Well, I’m just a guy from the Midwest so getting an email from India requesting my help is pretty cool. I had to reply right away.

Thank you for contacting me. I will try to answer your questions below.

Your question refers to both the International Maritime Organization and their Dangerous Goods Code (IMDG, 2018 Edition 39 -18 Amendment) and the Hazardous Materials Regulations (October 2018 Edition) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).
The required specifications for the Division 4.1 placard are almost – but not quite – the same for both the IMO and the USDOT/PHMSA.
Hazardous Materials Regulations of USDOT/PHMSA:
- 49 CFR 172.519 for general specifications and §172.546 for the Flammable Solid (Division 4.1) placard.
- Outer dimensions of 250 mm x 250 mm.
- Line inside the edge 12.5 mm from outside edge.
- Class or division symbol must be as shown at §172.546.
- Hazard class number in bottom point of placard must be at least 41 mm high.
- Any words that appear on placard must be at least 41 mm high.
IMDG Code:
- 5.3.1.2.1 for placard specifications and 5..2.2.2 for specimen labels.
- Outer dimensions of 250 mm x 250 mm.
- Line inside the edge 12.5 mm from outside edge.
- Class or division symbol shall be positioned and sized in proportion to those shown in 5.2.2.2.2.
- Hazard class or division number in bottom point of placard must be at least 25 mm high.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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There is much more information in the regulations than I am able to summarize here.

I suggest you contact ICC The Compliance Center to purchase the required placards. Indicate what you need them for and they will be able to sell you what you need.

I hope this helps. Please contact me with any other questions.

That seemed to do it!

Q&A: What is the required size of the new Class 9 Lithium Battery label?

This question came to me over a year ago (January 14, 2018). A time when the Class 9 Lithium Battery label was not yet mandatory but the question of its size was still important. Since January 1st of 2019, when use of the label became mandatory for regulated shipments of lithium batteries, it is more critical still.

Hello Daniel,

I have a query about Class 9 Lithium Battery Label that what is the Size of the label to be printed?

I found somewhere mentioned 100 mm x 100 mm, is this diagonal or edge dimension? What if the box size is smaller to print this size what is the smaller size can be printed?

The mandatory Class 9 label for regulated packages of lithium batteries after 01.01.19.

Thanks & Regards,

My reply the next day (01.14.18):

I believe I have an answer for your question. The answer depends upon the mode of transportation and the applicable regulations. Please see below.

USDOT/PHMSA for the transport of HazMat within the U.S. (usually limited to highway or rail):

The Hazardous Materials Regulations of USDOT/PHMSA at 49 CFR 172.407(c)(1) require the hazmat label to be at least 100 mm (3.9″) on each side. There are 4 sides to the label, each side must be a minimum of 100 mm (3.9″).
However, §172.407(c)(1)(i) allows the dimensions of the label and its features to be reduced proportionally if the size of the package so requires. Symbol and other elements of the label must remain clearly visible.
Also, §172.406(b)(1) allows for the display of the label on a “securely affixed tag” or other suitable means if the HazMat is not a Class 7 Radioactive and the dimensions of the package are less than those of the required label.

So, per the USDOT/PHMSA regulations a label may be reduced in size as necessary to fit on the package. There is no minimum size requirement. The label can be as small as necessary to fit on the package as long as it continues to communicate the necessary information. Or, as an option, a label may be displayed on a tag secured to the package.

International Maritime Organization (IMO) for the international transport of dangerous goods by vessel:

The IMO Dangerous Goods Code at 5.2.2.2.1.1 mandates the label to be a minimum of 100 mm on a side. The image at 5.2.2.2.1.1 clearly indicates the 100 mm minimum applies to each diagonal side of the label.
5.2.2.2.1.1.3 allows for a proportional reduction in the size of the labels if the package is too small and if the symbols and other elements of the label remain clearly visible.
Also, 5.2.2.1.6 allows the label to be displayed on a “securely affixed tag” or other suitable means if the package is too small.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

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Similar to USDOT/PHMSA, the IMDG Code sets a minimum size for the label on a package. However, the label may be smaller than this minimum if required by the size of the package. The shipper also has the option to display the label on a tag or by other means if the size of the package hinders display of a full-size label.

International Air Transport Association (IATA) for the international and domestic transport of dangerous goods by air:

7.2.2.3.2(a) of the IATA Dangerous Goods Regulations establishes a minimum dimension of 100 mm for each side of a label.
7.2.2.3.1 allows for reduced dimensions of a label’s size (labels may have dimensions that are half of the 100 mm minimum, but no less), but only for the following dangerous goods and only when displayed on a package of an infectious substance that is too small to display the full-size label:
- Class 2.1 Non-flammable, non-toxic gas
- Class 6 Infectious substance
- Class 9 Miscellaneous
7.2.6.1(d) allows for the display of the label on a “strong tag(s)” but only when the package is of such an irregular shape that a label cannot be attached or printed on its surface.
7.2.6.1(e) requires the shipper to ensure the package is of such a size that there is adequate space to affix all required labels.

It should be no surprise the regulations of IATA are more strict than any other agency. In brief, the IATA Dangerous Goods Regulations do not allow for the reduction in size of the hazard label except in very limited circumstances, and then, a reduction in size of no more than half of the minimum size. IATA goes further than either of the other agencies in specifying that the shipper must use a packaging that is big enough for all required labels – and package marks.

I hope this helps. Please contact me with any other questions.

Conclusion:

That seemed to do it! If the transport of hazardous materials (aka: dangerous goods) is required for your business, make sure you are doing it in compliance with the applicable regulations. Though similar in many ways, there are significant differences between the regulations of USDOT/PHMSA, IMO, & IATA, even when dealing with something as insignificant as the display of a hazard label on a package. Contact me to assist you with compliance.

Q&A: Is stoddard solvent a marine pollutant?

A question posted to pcjr101@yahoo.com [hazmat101] hazmat101@yahoogroups.com on November 1, 2017:

Is Stoddard Solvent a marine pollutant per DOT or IMDG Code? Under what scenarios? What about a mixture with it? References to guidance documents are appreciated.

Stoddard Solvent is sometimes referred to a White Spirit or Turbine Substitute

49 CFR Appendix B to 172.101 (List of Marine Pollutants):

Lists “White Spirit, low (15-20%) aromatic) as a Marine pollutant.
Lists “Turbine” (UN299) as a Marine Pollutant
Does not list “Turpentine Substitute” (UN1300) as a Marine Pollutant.

The IMDG Code Index:

Lists “White Spirit, low (15-20%) aromatic) (UN1300) as a Marine pollutant.
Lists “White Spirit” (UN1300) as a Marine pollutant.
Lists “Turpentine” (UN1299) as a Marine pollutant.
Lists “Turpentine Substitute” (UN1300) as a Marine pollutant.

2018 Edition of the IMDG Code

The IMDG Code Dangerous Goods List:

Lists UN1299 (Turpentine) as a marine pollutant
Does not list UN1300 (Turpentine Substitute) as a marine Pollutant.

Thanks in advance.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

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Note: this group allows its members to post questions like this one and then hope for answers from others within the group. What follows are some of those answers with mine at the end.

First to answer…

Stoddard Solvent is Mineral Spirits. UN 1268, PETROLEUM DISTILLATES , N.O.S. (Naphtha solvent), 3, PG III, combustible liquid

And…

Check the SDS for that product

And then me:

I will try to answer your question. Please see below.

General information:

White spirit or mineral spirits, also known as mineral turpentine, turpentine substitute, petroleum spirits, solvent naphtha, Varsol, Stoddard solvent, or, generically, “paint thinner”.

USDOT/PHMSA:

To be a marine pollutant per USDOT/PHMSA regulations it must be each of the following:
- Identified by name as a marine pollutants (appendix B to Hazardous Materials Table at 49 CFR 172.101).
- 10% or more in solution if marine pollutant. 1% or more in solution if a severe marine pollutant (identified by ‘PP’ in column 1 of list).
- Transported in any size packaging by vessel or transported in a bulk packaging by highway, rail, or air.
White Spirit, low (15-20%) aromatic is identified by name as a marine pollutant.
Turpentine is identified by name as a marine pollutant.
Read: What is a Marine Pollutant?

It is impossible to determine if your product is a marine pollutant per USDOT/PHMSA regulations without first identifying exactly what it is and its concentration, packaging, and mode of transport.

IMO:

To be a marine pollutant per the IMO dangerous goods code (IMDG), it must be one of the following:
- Display a ‘P’ in the ‘MP’ column for its entry in the Index.
- Display a ‘P’ in column 4 of the Dangerous Goods List (DGL) for its entry.
- Meet the criteria of the UN Recommendations (2.9.3) for an Environmentally Hazardous Substance (aquatic environment).
If identified as a marine pollutant in either the Index or the DGL it is not subject to regulation as a marine pollutant if it does not meet the UN criteria.
If not identified as a marine pollutant in either the Index or the DGL it is subject to regulation as a marine pollutant if it is proven to meet the UN criteria.
White Spirit, low (15-20%) aromatic, white spirit, & TURPENTINE are all identified as a marine pollutant in the Index.

Unless the shipper has data to indicate it does not meet the criteria for an environmentally hazardous substance (aquatic environment), then the above identified substances must be shipped as a marine pollutant when subject to the IMDG Code.

And…

49 CFR 172.101, Appendix B (4): if not listed as a marine pollutant but meets criteria for marine pollutant per IMDG, then may be transported as marine pollutant within U.S.
49 CFR 172.101, Appendix B (5): if listed as a marine pollutant but does not meet criteria for marine pollutant per IMDG, then may be excepted from transport as marine pollutant within U.S. with approval from PHMSA/USDOT.
The International Air Transport Association (IATA) uses the same UN criteria as the IMO for classifying a marine pollutant.

More information:

I hope this helps.

Please contact me with any other questions.

If you like this article, please share it using any of the social media platforms identified at the bottom of this article.

You’ll look real smart recommending my articles!

Conclusion:

The classification of a marine pollutant is complicated. It is made more so by the fact that the classification of a marine pollutant of USDOT/PHMSA within the U.S. differs from the international regulations of IATA & IMO. That means the requirements for transport of a HazMat within the U.S. may differ from those outside of the U.S. Make certain you determine the applicable regulations and them comply with them.

General Provisions for Cargo Transport Units

A person who offers a hazardous material (HazMat) for transport to, from, or through the U.S. must comply with the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). If a person offers for transport a dangerous good (dangerous good is the term used by international regulations to refer to what we in the U.S. call a hazardous material) for transport by vessel in international waters that person must also comply with the International Maritime Organization (IMO) and its Dangerous Goods Code (IMDG Code).

The challenge for a shipper is knowing when to comply with the HMR and when compliance with the IMDG Code is required. To summarize the requirements: a shipper may comply with the IMDG Code – even for transport within the U.S. if all requirements of the IMDG Code are met and the shipper complies with 49 CFR 171.22 and §171.25.

The purpose of this article is to explain the general provisions for use of cargo transport units (CTUs) to transport dangerous goods by vessel in compliance with Chapter 7.3.2 of the IMDG Code.

Before we begin…

This article is based on the 2018 edition of the IMDG Code containing amendments 39-18. This edition alone must be used to determine compliance in 2020 but is optional for use in 2019. The 2016 edition, which includes amendments 38-16, is also optional for use in 2019. It alone was mandatory in 2018. Confused? Read: The IMDG Code Amendment Cycle.

For the purposes of this article it doesn’t matter which edition is used. The effective regulations are unchanged between the two.

: 2018 Edition of the IMDG Code

: 2016 Edition of the IMDG Code

Scope:

The regulations of Chapter 7.3 of the IMDG Code apply to those persons responsible for the loading of the CTU. This may be the shipper, a freight-forwarder, the motor carrier responsible for highway transport, or shore-based personnel at the port of departure; it does not have to be the person identified as the shipper on the Dangerous Goods Transport Document.

A cargo transport unit is defined at 1.2.1 of the IMDG Code.

Cargo transport unit means a road transport tank or freight vehicle, a railway transport tank or freight wagon, a multimodal freight container or portable tank, or an MEGC.

For the purposes of this article think of a CTU as a big metal box used to contain packagings of dangerous goods.

General Provisions for Cargo Transport Units:

By their very nature “General Provisions” don’t get into specifics – that’s saved for later.

CTU must be “strong enough to withstand the shocks and loadings normally encountered during transport”. This requires a knowledge of the conditions to be expected during the anticipated journey.
CTU must be constructed so as to prevent the loss of the contents.
Where appropriate, CTU must have devices that will assist in the securing and handling of the dangerous goods it contains. In other words, whatever devices are necessary to secure the dangerous goods within the CTU must be available.
CTU must be adequately maintained.
If the CTU is a “container” per the International Convention for Safe Containers (CSC) 1972, then the applicable provisions of the CSC must be followed. However, the CSC does not apply to offshore containers handled in open seas. Those must meet requirements established by the competent authority (USDOT/PHMSA in the U.S.) An offshore container designed to be handled in open seas shall be clearly marked: “OFFSHORE CONTAINER” on the safety approval plate.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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In my next article I’ll address the Packing of Cargo Transport Units

Conclusion:

Pretty simple and pretty vague. Remember, compliance with chapter 7.3.2 is the responsibility of the person(s) who load the cargo transport unit with dangerous goods to be transported by vessel. If this is you, make certain all personnel are knowledgeable not only of these regulations but all of the IMDG Code applicable to their job – which includes training.

Packing of Cargo Transport Units for Transport by Vessel per the IMDG Code

The purpose of this article is to explain the requirements for the loading of cargo transport units (CTUs) for transport by vessel in compliance with Chapter 7.3.3 of the IMDG Code.

Before we begin…

For the purposes of this article it doesn’t matter which edition is used. The effective regulations are unchanged between the two.

: 2016 Edition of the IMDG Code

: 2018 Edition of the IMDG Code

Scope:

A cargo transport unit is defined at 1.2.1 of the IMDG Code.

Cargo transport unit means a road transport tank or freight vehicle, a railway transport tank or freight wagon, a multimodal freight container or portable tank, or an MEGC.

For the purposes of this article think of a CTU as a big metal box used to contain packagings of dangerous goods.

The general provisions for cargo transport units were addressed in an earlier article

Packing of Cargo Transport Units:

CTU must be checked prior to use to ensure it is fit for intended purpose.
Interior and exterior of CTU must be inspected prior to loading to ensure their is no damage that could affect its integrity or that of the packages it is to contain.
Condition of packages.
- Packages must be examined before loading. Packages shall not be loaded in CTU if found to be damaged, leaking, or sifting.
- Excessive water, snow, ice or foreign matter adhering to packages must be removed before packing into CTU.
- If handling provision “keep as dry as reasonably practicable” (H1) is assigned in column 16a of the Dangerous Goods List for a dangerous good to be loaded in a CTU, then the CTU must be kept as dry as reasonably practicable.
Drums of dangerous goods loaded in a CTU must always be stowed in an upright postion unless otherwise authorized by the competent authority (USDOT/PHMSA in U.S.).
More on packages.
- CTU must be loaded in compliance with 7.3.4 Segregation provisions within cargo transport units. Incompatible dangerous goods – or other non-dangerous goods must be segregated.
- Specific loading instructions such as: orientation arrows, not to be double stacked, keep dry or temperature control requirements shall be met.
- Liquid dangerous goods must be loaded below dry dangerous goods whenever possible.
Securing and restraining packages within CTUs.
- Packaged dangerous goods and unpackaged dangerous articles must be secured within the CTU to prevent any movement during transport that would change their orientation or cause them to be damaged.
- Methods of restraint may include: fastening straps, sliding slatboards, adjustable brackets, and filling any voids by the use of dunnage or by blocking and bracing.
- If dangerous goods are transported in the CTU with other goods (e.g., heavy machinery or crates), all goods must be secured to prevent the release of dangerous goods.
- If restraints such as banding or straps are used they must not be over-tightened to cause damage or deformation of the package or the securing points (such as D-rings) within the CTU.
- Packages must be packed to minimize the likelihood of damage to fittings during transport. Fittings on packages must be adequately protected.
- If restraints such as banding or straps with integral container fittings are used, packer must use care to ensure the Maximum Securing Load (MSL) of the fittings is not exceeded.

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Stacking of packages.
- Packages must not be stacked unless designed for stacking.
- Exercise caution when stacking packages of different stacking designs.
- Load bearing devices must be used to prevent a stacked package from damaging the package below.
Cargo shall be entirely contained within the CTU without overhang or projections. However, oversized machinery (e.g., tractors and vehicles) may overhang or project outside of the CTU if the dangerous goods within the machinery cannot leak or spill outside of the CTU.
Care must be taken during preparation for transport and loading of packages to prevent damage. Damaged or leaking packages shall not be transported.
If dangerous and non-dangerous goods are packed in the same CTU, dangerous goods should, whenever possible, be packed near the doors with marks and labels visible.
If the doors of a CTU are locked it shall be possible to open them without delay in an emergency.
When venting of the CTU is required venting devices shall be kept clear and operable.
CTUs containing any amount of a dangerous good shall be marked and placarded per chapter 5.3 of the IMDG Code.
Irrelevant marks, labels, placards, orange panels, signs and marine pollutant marks shall be removed, masked or removed before packing a CTU.
CTU shall be packed so that cargo (includes non-dangerous goods) is uniformly distributed consistent with the CTU Code.
If the CTU is packed with Class 1 Explosives, it must be “closed” as defined at 7.1.2 of the IMDG Code.
If the CTU is packed with Class 7 Radioactive, the transport index and, if applicable, the criticality safety index, shall be limited according to 7.1.4.5.3 of the IMDG Code.
The person(s) responsible for packing dangerous goods in a CTU shall provide a “container/vehicle packing certificate” per 5.4.2 of the IMDG Code. This document is not required for tanks.
Flexible bulk containers are not allowed to be transported in CTUs per 4.3.4 of the IMDG Code.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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Daniels Training Services, Inc.

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