International Maritime Organization (IMO)

Q&A: Segregation of Limited Quantities

A question from a customer of my ONSITE TRAINING on October 15th, 2015:

Hey Daniel,

I just had a quick question regarding limited quantities.  If I have 2 different hazmat items that normally could not be shipped together per the shipping regs but one qualifies under the limited quantities provision then are they able to be shipped together?  The way I interpret the regulations is that if an item is being shipped as a limited quantity it no longer has to be segregated due to the amount since we are also not having to label it as the hazardous material.

Thank you for your input.

(10.15.15)  I was certain he was right about the segregation requirements for a Limited Quantity but I wanted a little more information:

What mode of transportation?  What is the HazMat?

I believe you are right, but I’d like a little more information to be certain.
Dan
And the next day (10.16.15) I got it:

Hey Dan,

So the items are being shipped via ocean.  The 2 hazmat items that I am wanting to put on the same pallet are Nitric Acid(UN2031) and a limited quantity of Silver Nitrate (UN1493).  They will be in their own boxes but on the same pallet.

The International Maritime Organization

The International Maritime Organization regulates the international transportation of dangerous goods by vessel.

Thanks,

With that information I replied with “The Big Answer” on October 17th:

Sorry for the delay, I hope I’m not too late, but my answer confirms yours:

  • Nitric Acid UN2031 may not be shipped as a limited quantity or any other exception under the HMR.
  • Silver Nitrate UN1493 may be shipped as a limited quantity according to 49 CFR 173.152.
  • Interestingly, there is no mention in 49 CFR 173.152 of a limited quantity not being subject to the HazMat segregation requirements.
  • However, 49 CFR 176.80(b) contains an exception for limited quantities from the segregation requirements of the HMR.
  • Nitric Acid UN2031 may or may not be shipped as a limited quantity per the IMDG Code depending on its concentration.
  • Silver Nitrate UN1493 may be shipped as a limited quantity per the IMDG Code.
  • Per 3.4.4.2 of the IMDG Code, the segregation provisions of chapter 7.2 do not apply to packagings of limited quantities.
Therefore, I believe you are correct that the Silver Nitrate UN1493 as a limited quantity is not subject to the segregation requirements of the HMR or the IMDG Code.  However, Nitric Acid UN2031 may not be shipped as a limited quantity within the U.S. (though it may outside of the U.S in some situations) and will be subject to the segregation requirements of the HMR and the IMDG Code.
Non-bulk packaging of HazMat - Limited Quantity

The Limited Quantity marking

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

His final reply:
Thanks.  I’m only shipping the Silver Nitrate as the limited quantity with the acid which will be classified as hazardous.
Conclusion/Summary:
Notice from my answer on the 17th that I first determined compliance with the domestic regulations of PHMSA and then those of the International Maritime Organization in the IMDG Code.  The transportation to, from, or through the U.S. is subject to the Hazardous Material Regulations of PHMSA.  If it will also be shipped internationally – in this case on a vessel – then it will be subject to international regulations as well.  Here, the regulations of both PHMSA and the IMO were similar but that may not always be the case.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

It’s not uncommon that person who have received my Onsite Training follow-up with questions once they begin to apply the information from the training on their job.

Contact me to schedule Onsite Training required by the International Maritime Organization (IMO) every three years, the International Air Transport Association (IATA) every two years, or the Pipeline and Hazardous Materials Safety Administration (PHMSA) every three years.

Significant Changes to the International Maritime Dangerous Goods Code for 2016

Significant Changes to the International Maritime Dangerous Goods Code for 2016

December 31, 2015 is the end of the transition year for the 2012 Edition (36-12 Amendment) of the IMDG Code of the International Maritime Organization.  The code is updated every two years but is optional for its first and last year and mandatory for a third year that falls between the two voluntary compliance years.  Confused?  Check out the infographic contained in this short article and I think it will make more sense:  The IMDG Code Amendment Cycle.

The result is that as of midnight on December 31, 2015 the 2012 Edition of the IMDG Code is worthless and must be replaced with the 2014 Edition, Incorporating Amendments 37-14.

I bought my 2014 Edition of the International Maritime Dangerous Goods Code from Air Sea Container, Inc.  If - like me - you can't get the spiral bound copy, take it to a printer who can cut the spine and place it in a spiral binder.  It lies flat and is easier to work with.

There are many changes from the 2012 Edition to the 2014.  Significant changes are summarized below and explained further at this IMO publication:  Summary of Significant Changes to the Code 2014 Edition.  Or, if you wish to see all 217 pages of amendments:  IMDG Code Amendments 37-14.

  • Caution Radioactive MaterialsProvisions regarding the transportation by vessel of Class 7 Radioactive Materials have been revised to reflect the IAEA Regulations for the Safe Transport of Radioactive Material – 2012 Edition (IAEA Safety Standards Series SSR-6), which supersedes the IAEA 2009 Edition.
  • The format of the 4.2 Dangerous Goods List has been modified to replace column 16 Stowage and Segregation with two new columns:  16a Stowage and Handling and 16b Segregation.  Instead of descriptive text, the new columns now contain codes that are defined in Chapter 7 of the IMDG Code.
  • There are significant changes in Chapter 7.2, including more stringent segregation and stowage requirements for Class 4.3 and other water-reactive materials.
  • Updates of the Dangerous Goods List in 4.2 include:
    • The proper shipping name for UN 3268 has been changed from AIR BAG MODULES, AIR BAG INFLATORS or SEAT-BELT PRETENSIONERS to SAFETY DEVICES.
    • Asbestos is now to be shipped as UN 2212 ASBESTOS AMPHIBOLE or UN 2590 ASBESTOS, CHRYSOTILE.
    • The entry for CAPACITORS has been divided into CAPACITOR, ELECTRIC DOUBLE LAYER (UN 3499) and CAPACITOR, ASYMMETRIC (UN 3508).
    • PACKAGING DISCARDED, EMPTY UNCLEANED (UN 3509) has been added but can’t be used for sea transport (!?!).
    • A series of shipping names for various adsorbed gases have been assigned between UN 3510 and UN 3526.
  • The following Special Provisions have been added:
    • SP 367 through 376 (excluding 374, 375).
    • SP 968 through 970
  • Special Provisions for shipping certain common items have been added or Transportation of dangerous goods by vesselrevised:
    • SP 376 through 377 for lithium batteries damaged/defective or for recycling/disposal.
    • SP 961, 962 for vehicles or internal combustion engines (see also SP 970).
The IMDG Code Amendment Cycle – 2010 thru 2019

The IMDG Code Amendment Cycle – 2010 thru 2019

If you ship HazMat/Dangerous Goods by vessel in international waters, then you must comply with the regulations of the International Maritime Organization (IMO) and its International Maritime Dangerous Goods Code (IMDG Code).  But to comply you must make certain that you are using only the latest approved edition of the IMDG Code which is updated every two years.

From the above graphic you can see that the 2012 Edition of the IMDG Code acceptable for use through the end of 2015 must be replaced by the 2014 Edition which is then acceptable through the end of 2017.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

 

 

General Requirements for the Shipping Paper When Transporting Dangerous Goods by Vessel

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. (more…)

Changes to the International Maritime Dangerous Goods Code – 2014 Edition

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:Vessel transporting dangerous goods

  • 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.

More Questions?

An Overview of New Regulations in the 56th Edition (2015) of the IATA Dangerous Goods Regulations

The transportation of hazardous materials (aka: Dangerous Goods) by air will likely have to comply with the Dangerous Goods Regulations of the International Air Transport Association.  I say “likely” because compliance with the DGR of IATA is a requirement of most air carriers – though not all.

If you must comply with the IATA DGR, subsection 1.5 requires you to provide training for applicable personnel initially and every two years thereafter.

Please contact me for a free consultation on the HazMat/Dangerous Goods regulations of the PHMSA/USDOT, IATA, or the International Maritime Organization.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Significant Changes and Amendments to the 55th Edition (2014) of the IATA DGR

The Dangerous Goods Regulations of the International Air Transportation Association (IATA) are the standards used by most of the airline industry throughout the world.  If you intend to ship hazardous materials (aka: Dangerous Goods), either domestically (within the US) or internationally by air, you will likely be required to comply with the IATA DGR.  A challenge to compliance is that it is updated annually; therefore the 54th Edition, in use in 2013, is no longer acceptable for compliance in 2014.  So, throw out your 2013 version of the International Air Transportation Association Dangerous Goods Regulations and replace it with the 55th Edition.  Each new Edition includes changes from the previous, and it is up to you to ensure you are in compliance with the latest Edition.  The purpose of this article is to summarize the main changes to the 2014 IATA DGR and direct you to a more thorough evaluation of the changes. (more…)