The International Maritime Organization (IMO) is a specialized agency of the United Nations responsible for the safety and security of international shipping and to prevent pollution from ships. Just one of its responsibilities is the development of the International Maritime Dangerous Goods Code (IMDG Code). Shore-based personnel who prepare dangerous goods for international transport by vessel must comply with the IMDG Code.
The IMDG Code is updated every two years in a standard amendment cycle. This is what that cycle should have looked like if 2020 was a normal year:
In the 4th quarter of an even-number year a new edition of the Code is published incorporating amendments added by IMO. So, in the Fall of 2020 the 2020 Edition, incorporating Amendment 40-20 should have been published.
On January 1 of the following odd-numbered year voluntary compliance with the new edition begins. The regulations of the previous edition remain valid in this transition year. So, as of January 1, 2021 both the 2020 Edition, incorporating Amendment 40-20 and the 2018 Edition, incorporating Amendment 39-18 should have been valid.
On January 1 of the following even-numbered year the new Edition comes into force, compliance with its regulations is mandatory and the previous Edition is obsolete. So, on January 1, 2022 compliance with the 2020 Edition, incorporating Amendment 40-20 should be mandatory and the 2018 Edition, incorporating Amendment 39-18 should be obsolete.
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.
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.
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.
“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
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).
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.
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
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.
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.
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
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.
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 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…
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.
2016 Edition of the IMDG Code
2018 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.
CTU must be checkedprior to use to ensure it is fit for intended purpose.
Interior and exterior of CTU must be inspectedprior 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.
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
Sometimes the regulations defy any attempts at summation and simplification and I wind up listing them almost verbatim; that is the case here. Remember, compliance with chapter 7.3.3 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 persons receive initial and triennial training as required by the USDOT/PHMSA and the IMDG Code.
The international transportation of a dangerous good by vessel – over water – is subject to the dangerous goods code of the International Maritime Organization (IMO).
The IMDG Code is published by the IMO every two years. In effect until the end of 2017 is the 2014 Edition which includes the 37-14 amendments. It will be replaced on January 1, 2018 with the 2016 Edition which includes the 38-16 amendments (read: The IMDG Code Amendment Cycle – 2016 thru 2025). The important thing to realize is this: as of January 1, 2018, if you offer a dangerous good for international transportation by vessel you must comply with the 2016 Edition of the IMDG Code. Therefore, as a shipper of dangerous goods you must be aware of any changes to the 2016 Edition from the 2014 Edition. The purpose of this article is to summarize the significant changes to the 2016 Edition of the IMDG Code. (more…)
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.
Provisions 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 revised:
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).
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
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…)
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
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.
