GUIDELINES TO SHIPPING PACKAGED DANGEROUS · PDF fileinternational safety panel general series #1 guidelines to shipping packaged dangerous goods by sea advice to consignors and shippers

INTERNATIONAL SAFETY PANEL

GENERAL SERIES #1

GUIDELINES TO SHIPPING PACKAGED

DANGEROUS GOODS BY SEA ADVICE TO CONSIGNORS AND

SHIPPERS

By

Margaret Fitzgerald

ICHCA INTERNATIONAL PREMIUM MEMBERS:

ICHCA International Safety Panel General Series #1

ICHCA INTERNATIONAL LIMITED is an independent, non-political international membership organisation, whose membership comprises corporations, individuals, academic institutions and other organisations involved in, or concerned with, the international transport and cargo handling industry. With an influential membership in numerous countries, ICHCA International’s objective is the improvement of efficiency in cargo handling by all modes of transport, at all stages of the transport chain and in all regions of the world. This object is achieved inter-alia by the dissemination of information on cargo handling to its membership and their international industry. ICHCA International enjoys consultative status with a number of inter-governmental organisations. It also maintains a close liaison and association with many non-governmental organisations. ICHCA International has an Honorary President, a nine person Board and National Sections in various countries, together with an International Registered Office in the U.K. The office’s primary role is to co-ordinate the activities of the organisation. It has an International Safety Panel and an International Research Panel. The Registered Office maintains a unique and comprehensive database of cargo handling information, publishes bi-monthly electronic newsletters, an annual hard copy report and operates a dedicated technical enquiry service, which is available to members. It also organises a biennial Conference. Studies are undertaken and reports are periodically issued on a wide range of subjects of interest and concern to members and their industry. ICHCA International Limited Tel: +44 (0) 1708 735295 Suite 2, 85 Western Road, Fax: +44 (0) 1708 735225 Romford, Essex, RM1 3LS Email: [email protected] United Kingdom Website: www.ichcainternational.co.uk

© ICHCA International Limited

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This publication is one of a series being developed by the International Safety Panel of ICHCA International Limited. The purpose of the series is to inform and advise those involved in the cargo-handling field of various practical issues and needs concerning relevant health and safety matters. The aim is to encourage the growing interest in port safety, reduction in accidents in port work and the protection of port workers' health. The International Safety Panel prepares its publications according to the latest information available at the time of publication. No responsibility is accepted by ICHCA International Limited or by any member of the International Safety Panel for the manner in which the information may be construed or applied by any party and any consequence that may arise therefrom. This publication should always be read in conjunction with the relevant national and international regulations, standards, codes of practice, etc., and should not be considered as an all-inclusive manual or handbook on any particular aspect of the subject matter to which the publication refers. The International Safety Panel Briefing Pamphlet series consists of the following pamphlets: No. 1 International Labour Office (ILO) Convention No. 152 Occupational

Safety and Health in Dockwork (revised) No. 2 Ships Lifting Plant (revised) No. 3 The International Maritime Dangerous Goods (IMDG) Code (revised)) No. 4 Classification Societies (Revised) No. 5 Container Terminal Safety No. 6 Guidance on the Preparation of Emergency Plans (under revision) No. 7 Safe Cleaning of Freight Containers (under revision) No. 8 Safe Working on Container Ships No. 9 Safe Use of Flexible Intermediate Bulk Containers (FIBCs) (Revised) No. 10 Safe Working at Ro-Ro Terminals No. 11 The International Convention for Safe Containers (CSC) No. 12 Safety Audit System for Ports No. 13 The Loading and Unloading of Solid Bulk Cargoes No. 14 The Role of the Independent Marine Surveyor in Assisting Claims

Handling No. 15 Substance Abuse No. 16 Safe Use of Textile Slings No. 17 Shore Ramps and Walkways No. 18 Port State Control No. 19 Safe Handling of Interlocked Flats No. 20 Unseen Dangers in Containers No. 21 Stow it right No. 22 Suspension Trauma No. 23 Safe handling of Forest Products The International Safety Panel Research Paper series consists of the following research papers: No. 1 Semi-Automatic Twistlocks (under revision) No. 2 Fumes in Ships Holds (revised) No. 3 Health & Safety Assessments in Ports (under revision) No. 4 Container Top Safety, Lashing and Other Related Matters No. 5 Port & Terminal Accident Statistics (under revision) No. 6 Safe Handling of Radioactive Materials in Ports and Harbour Areas

(under revision)



No. 7 Ship Design Considerations for Stevedore Safety (under revision No. 8 Safe Walkways in Port & Terminal Areas No. 9 Personal Protective Equipment & Clothing No. 10 Back Pain No. 11 Lifting Persons at Work for Cargo Handling Purposes in the Port Industry The International Safety Panel Technical/Operational Advice series consists of the following:

No. 1 Vertical Tandem Lifting of Freight Containers No. 1A Vertical Tandem Lifting – Operations Checklist Plasticised Pocket Cards IIL/1 Dangerous Goods by Sea Documentation IIL/2 Dangerous Goods by Sea: The IMDG Code Labels, Placards, Marks

and Signs IIL/3 Confined Spaces on Board Dry Cargo Ships Other titles in many of the series are in preparation This publication is one of a series developed by the International Safety Panel ("Safety Panel") of ICHCA International Limited ("ICHCA"). The series is designed to inform those involved in the cargo-handling field of various practical health and safety issues. ICHCA aims to encourage port safety, the reduction of accidents in port work and the protection of port workers' health.

ICHCA prepares its publications according to the information available at the time of publication. This publication does not constitute professional advice nor is it an exhaustive summary of the information available on the subject matter to which the publication refers. The publication should always be read in conjunction with the relevant national and international legislation and any applicable regulations, standards and codes of practice. Every effort is made to ensure the accuracy of the information but neither ICHCA nor any member of the Safety Panel is responsible for any loss, damage, costs or expenses incurred (whether or not in negligence) arising from reliance on or interpretation of the publication.

The comments set out in this publication are not necessarily the views of ICHCA or any member of the Safety Panel All rights reserved. No part of this publication may be reproduced or copied without ICHCA's prior written permission. For information, contact ICHCA's registered office.



ICHCA International Limited - INTERNATIONAL SAFETY PANEL

The International Safety Panel is composed of safety and training officers and directors, transport consultants, representatives from leading safety and training organisations, enforcement agencies, trade unions, insurance interests, institutions and leading authorities on the subject area from around the world.

Mike Compton (Chairman), Circlechief AP, UK John Alexander, UK Martin Anderson, DP World. DUBAI Paul Auston, Checkmate UK Limited, UK David Avery, Firefly Limited, UK Peter Bamford, CANADA Bob Barnes, UK Jan Boermans, P&O Ports, THE NETHERLANDS Mike Bohlman, Horizon Lines, USA (Deputy Chairman) Roy Boneham, UK Bill Brassington, GeSeaCo, UK Jim Chubb, BMT Murray Fenton Limited, UK Gary Danback, IICL, USA Steve Durham, Trinity House, UK Patricia Esquival, OPCSA, SPAIN Margaret Fitzgerald, IRELAND Pamela Fry, P&O Ports, CANADA Fabian Guerra, Fabian Guerra Associates, EQUADOR Harri Halme, Min. of Social Affairs & Health, Dept for Occupational Health & Safety, FINLAND Daragh Henry, APM Terminals, THE NETHERLANDS Jeff Hurst, UK Peter van der Kluit, THE NETHERLANDS Fer van der Laar, IAPH, THE NETHERLANDS Larry Liberatore, OSHA, USA Kate Linley, Australian Maritime Safety Authority, AUSTRALIA Shimon Lior, Israel Ports, Development and Assets, ISRAEL Eric Luca, ECT, THE NETHERLANDS Kees Marges, THE NETHERLANDS Richard Marks, Royal Haskoning, UK Joachim Meifort, Hamburger Hafen-u Lagerhaus A-G, GERMANY Marios Meletiou, ILO, SWITZERLAND John Miller, Mersey Docks & Harbour Company, UK Al le Monnier, ILWU, CANADA Pedro J. Roman Nunez, Puertos del Estado, SPAIN John Nicholls, UK Nic Paines, Gordon, Giles & Coy Ltd, UK Benoit Passard, PEMA, SWEDEN Mick Payze, AUSTRALIA Irfan Rahim, International Maritime Organization, UK Captain Peter Lundahl Rasmussen, BIMCO, DENMARK Risto Repo, Accident Investigation Bureau of Finland, FINLAND Capt. Hans-Jürgen Roos, Gauss, GERMANY Raymond van Rooyan, SAPO, SOUTH AFRICA Ron Signorino, The Blueoceana Company, Inc., USA Armin Steinhoff, Behörde für Arbeit, Hamburg, GERMANY Bala Subramaniam, INDIA



Andrew Synnott, Patrick Stevedoring, AUSTRALIA Markus Theuerholz, MacGregor-Conver, GERMANY Raoul de Troije, Confidence Shipmanagement Company BV, THE NETHERLANDS Hubert Vanleenhove, Hessanatie, BELGIUM Andrew Webster, TT Club, UK (Deputy Chairman) Evert Wijdeveld, Environmental & Safety Affairs, Deltalinqs, THE NETHERLANDS (Deputy Chairman) Bill Williams, Maersk Inc. USA Dave Wilson, Hutchison Ports (UK) Limited, UK OBSERVERS:

Capt. Jim McNamara, National Cargo Bureau, Inc., USA Charles Visconti, International Cargo Gear Bureau, Inc., USA CORRESPONDING/ASSOCIATED MEMBERS: Gerrit Laubscher, Estivar pty, SOUTH AFRICA Paul Ho, HIT, HONG KONG Paul Rossi, OSHA, USA

Richard Day, Transport Canada, CANADA Samuel Ng, Maritime Department, HONG KONG

The above lists those persons who were members of the Panel when the pamphlet was published. However, membership does change and a list of current members can always be obtained from the ICHCA International Secretariat.



About the Author MARGARET FITZGERALD BSc (Hons), CChem, MRSC, MSc, MIOSH, DGSA Margaret holds an Honours degree in Chemistry and a Masters in Occupational Safety & Health. She has more than 15 years experience in risk management in relation to maritime and road transportation of hazardous materials, chemicals, oil, etc, storage and environmental protection. Having spent 4 years in private industry for a risk management company specialising in chemical safety, Margaret joined the Secretariat of the International Maritime Organization, where she was responsible for Dangerous Goods legislation and related environmental protection matters. She oversaw the ongoing development of the International Maritime Dangerous Goods (IMDG) Code and its harmonization with other modal regulations and the UN Orange Book. She was IMO’s representative at the UN Committee of Experts on the Transport of Dangerous Goods. Margaret subsequently joined the Irish Government's Health & Safety Authority as an inspector in the Dangerous Substances/ADR Group, responsible for drafting, implementing and enforcing dangerous goods legislation under the ADR and DGSA Directives. She was Ireland’s representative at transport meetings of the European Commission in Brussels and the United Nations in Geneva. Margaret is a member of the International Safety Panel and is now working as an independent consultant/trainer covering all aspects of dangerous goods transport, storage and safety.



Contents Page 1 Introduction 1 2 Legal Requirements 1 3 Principles of the IMDG Code 2 4 Detailed guidance 3

(a) Classification 3 (b) Product Containment – Packaging 5

(c) Hazard Identification – Marking, Labelling and Placarding 8 (d) Documentation 12 (e) Segregation 14 (f) Requirements relating to the use of CTUs 16 (g) Packing and Securing Dangerous Goods within a CTU 17 (h) Handling 20 (i) Training and Competency 20 5 Security 22 List of relevant publications 22

ISBN: 1 85330 119 1 978-1-85330-119-3 First Published: July 2006



GUIDELINES FOR SHIPPING PACKAGED DANGEROUS GOODS BY SEA

ADVICE TO CONSIGNORS AND SHIPPERS 1 INTRODUCTION

Millions of tons of packaged dangerous goods are handled and conveyed by sea year on year and the majority of such movements are carried out in complete safety. However, despite this fact, national surveys by maritime administrations as well as high profile accidents have indicated that there are unacceptable levels of non-compliance with the international requirements governing the transport of dangerous goods by sea. If the relevant legal provisions are not followed, any movement of dangerous goods will be illegal and this could result in them being refused by a port or a ship. If an accident occurs, it could lead to action under criminal law as well as extensive civil liabilities. A recent court case has underlined the fact that shippers who are negligent in fully and properly complying with the IMDG Code can be held completely liable if an accident happens that arose from their non compliance. The purpose of this guidance is to explain to consignors and shippers the main details of the international requirements, to raise awareness of the need to comply with these requirements and thereby increase the level of compliance and so reduce accidents. The references to chapters and paragraphs in these guidelines are references to chapters and paragraphs in the IMDG Code edition 32-04.

2 LEGAL REQUIREMENTS

Q What are the international requirements governing the transport of dangerous goods by sea?

A The international transport of dangerous goods by sea is regulated by the

‘International Maritime Dangerous Goods (IMDG) Code’. The IMDG Code is produced by the International Maritime Organisation; a United Nations agency which is made up of 166 Member States. With some very small exceptions, the IMDG Code is legally a mandatory document which must be followed when shipping dangerous goods by sea internationally. Accordingly, most IMO Member States have incorporated the IMDG Code into their national legislation which means that it applies to both national and international transport of dangerous goods by sea.

Q Do any other national regulations apply? A Each Member State will have in place national legislation governing the

transport of dangerous goods by air*, road**, rail*** and inland waterway**** which must be complied with in order to safely transport dangerous goods to the port. Port regulations and restrictions will also apply and it is essential that the consignor is aware of these and also complies with them when offering dangerous goods for transport by sea. The requirements of the IMDG Code only come into effect from the time dangerous goods are loaded onto the ship, although some principles of the IMDG Code are applied by Member States in port areas (e.g. segregation requirements).



* The ICAO Technical Instructions (TIs) are applicable internationally and are the air transport equivalent of the IMDG Code.

Note: There are no fully international regulations governing the transport of dangerous goods by road, rail and inland waterway. However, European legislation is used by a number of countries in other parts of the world.

** The ADR is the applicable legislation in Europe. *** The RID is the applicable legislation in Europe. ****The ADN is the applicable legislation in Europe. Countries which do not apply the ADR, RID or ADN will have equivalent

national legislation in place. When offering dangerous goods for transport, consignors must ensure that they are familiar with the national legislation which applies in the countries of origin, transit and destination.

3 PRINCIPLES OF THE IMDG CODE

The IMDG Code is based on an internationally agreed system which: .1 Groups dangerous goods together based on the hazards they present in

transport (classification); .2 Contains the dangerous goods in packagings/tanks which are of appropriate

strength and which will prevent the goods escaping; .3 Uses hazard warning labels and other identifying marks to identify

dangerous goods in transport; .4 Requires standard documentation to be provided when dangerous goods

are being transported; .5 Lays down principles for ensuring that incompatible dangerous goods are

kept apart; .6 Lays down principles for where to place dangerous goods on board ship to

ensure safe transport; .7 Provides emergency response advice for dangerous goods involved in a fire

or spillage on board ship. Q What should a consignor or shipper know before considering shipping

dangerous goods? A Before deciding to ship dangerous goods by sea a consigner or shipper

should be aware of:

.1 The International transport requirements relating to the safe transport of dangerous goods;

.2 The national requirements which will apply in transporting the dangerous goods to the port;

and be confident that the transport requirements can be interpreted and can

meet the legal obligations to ensure that the dangerous goods arrive safely at their destination without endangering the lives of those handling or carrying the goods during their journey and without endangering the environment.

Q Have the main factors affecting the safe transport of dangerous goods

by sea been identified? A The main factors affecting the safe transport of dangerous goods by sea are :



.1 Ensuring that the dangerous goods are correctly classified, as this will determine the transport requirements which are applied throughout the transport chain;

.2 Having correctly classified the goods, ensuring that the correct type of containment is utilised (i.e. conventional packagings, IBCs, large packagings and cargo transport units (CTUs);

.3 Ensuring that the hazards presented by the dangerous goods in transport are adequately conveyed by means of appropriate hazard diamond labels or placards, marks and signs on packagings and CTUs;

.4 Ensuring that the correct documentation is provided & is correctly completed to ensure that those in the transport chain, who do not see the dangerous goods moving, are fully informed of the dangers they present;

.5 Ensuring that incompatible dangerous goods are adequately segregated;

.6 Ensuring that the requirements relating to the use of CTUs are met; .7 Ensuring that dangerous goods are correctly packed and secured

within CTUs; .8 Ensuring that dangerous goods are correctly handled in transport; and .9 Ensuring that those involved in the transport of dangerous goods are

adequately trained and competent in carrying out their responsibilities.

These issues are addressed in the next part of this guidance which highlights specific details from the IMDG Code. Note: The term ‘CTU’ includes freight containers, ro-ro vehicles, portable tanks, tank containers, road tank vehicles and railway wagons Q Does the company have an up-to-date copy of the IMDG Code? A In order to work with the IMDG Code, a consignor or shipper or his

company must ensure that they have an up-to-date copy of the IMDG Code to work from. This is an essential point to check, as the IMDG Code, together with the other modal Regulations (the ICAO TIs, ADR, RID and ADN) are updated on a two-yearly cycle and the requirements may change from one edition to the next.

The consignor will know what edition of the IMDG Code he is working from by checking the reference at the bottom of each page. There he will find a reference to the Amendment Number and the year that that Amendment has been approved. For example, Amdt 32-04 at the bottom of the page means that the 2004 edition is incorporating the 32nd Amendment.

4 DETAILED GUIDANCE (a) CLASSIFICATION

Q What packaged goods are considered to be dangerous for transport by sea?

A The IMDG Code divides packaged dangerous goods into 9 hazard

classes according to the danger they present in transport, as follows:-



Class 1 Explosives

Class 2 Gases, which are sub-divided as follows:

Class 2.1 Flammable gases

Class 2.2 Non-flammable gases

Class 2.3 Toxic gases

Class 3 Flammable liquids

Class 4 Flammable solids, substances liable to spontaneous combustion and substances which, in contact with water, emit flammable gases, which are sub-divided as follows:

Class 4.1 Flammable solids

Class 4.2 Spontaneously combustible substances

Class 4.3 Substances which, in contact with water, emit flammable gases

Class 5 Oxidizing substances and organic peroxides, which are sub-divided as follows:

Class 5.1 Oxidizing substances

Class 5.2 Organic peroxides

Class 6 Toxic and infectious substances, which are sub-divided as follows:

Class 6.1 Toxic substances

Class 6.2 Infectious substances

Class 7 Radioactive material

Class 8 Corrosives

Class 9 Miscellaneous dangerous substances and articles

Dangerous goods are assigned to one or more of the 9 hazard classes on the basis of internationally accepted UN test procedures and classification criteria.

Packaged dangerous goods falling within the classification criteria of any one of these 9 classes (or a maximum combination of 3 hazards),



including dangerous goods classified as ‘marine pollutants’ are considered to be dangerous for transport by sea.

Q Can the consignor or shipper look up all dangerous goods in the

IMDG Code? A The IMDG Code lists a large number of dangerous goods and marine

pollutants, which are classified under the 9 hazard classes and are considered dangerous for transport. However, as many of the chemicals produced today are mixtures, solutions, formulations, etc., containing a number of different hazardous constituents, it is not possible for these to be listed individually in the IMDG Code. However, some dangerous goods may be shipped under generic classifications (see .3 of next question). It is the shipper’s responsibility to classify the cargo according to the established UN classification criteria and to decide whether his cargo must be declared as ‘dangerous goods’.

Q Have the dangerous goods been correctly classified for transport

by sea? A The shipper must check that the cargo has been correctly classified in

accordance with the IMDG Code either:

.1 By checking the classification listed against the product in the Dangerous Goods List (DGL) for known products

.2 By having the product tested, in accordance with the established UN classification criteria referred to in the IMDG Code to establish whether the product meets the criteria of one or more of the 9 hazard classes. Details of the test procedures and the classification criteria are found in the UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria

.3 If the product is not listed in the DGL and all the hazards are known, it is possible to use an N.O.S. (not otherwise specified entry) details of which can be found in Appendix A in Volume 2 of the IMDG Code. For example, Flammable Liquid, NOS (plus the name of product in brackets) is a perfectly acceptable proper shipping name and will have the UN number 1993.

(b) PRODUCT CONTAINMENT - PACKAGING

Dangerous goods are considered to be ‘packaged’ if they are contained in:

.1 Conventional packagings (e.g. drums, bags, fibreboard boxes, gas cylinders, etc.);

.2 Intermediate Bulk Containers (IBCs); .3 Large Packagings; .4 Bulk Containers; .5 Portable tanks and road tank vehicles; or .6 Limited quantities (i.e. small quantities).

Q Do any special requirements apply to packagings used for the

transport of DG by sea? A Conventional packagings, IBCs and large packagings are required to

meet established design standards, pass specified performance tests,



and bear UN packaging codes, in accordance with Chapter 6 of the IMDG Code. The shipper must check that the intended packagings meet the required test standards and bear the appropriate UN packaging code confirming that the packagings have been tested in accordance with the IMDG Code requirements.

The IMDG Code indicates a range of possible packagings for every substance. The permitted packagings reflect the degree of hazard presented by the dangerous goods. Packagings used to transport very hazardous (Packing Group I or PG I) dangerous goods must be manufactured and tested to a higher standard than packagings used to transport medium hazard goods (PG II) which in turn are of a higher standard than for the less hazardous (PG III) dangerous goods. The shipper must check that his intended packagings are appropriate to contain the hazard presented by his dangerous goods in transport. For example, a PG I product (high hazard) cannot be shipped in a packaging only manufactured and tested to contain PG III (low hazard) products.

However, all the permitted packagings are subject to the prime requirement that the packaging materials must be compatible with the proposed contents and suitable for use.

Q How will the shipper know that the proposed packagings are

permitted to be used for the particular dangerous goods in question?

A The packagings permitted to be used for all dangerous goods are

coded in the Dangerous Goods List, as indicated below. If a code does not appear against a particular product, then that type of packaging may not be used. For example, if there is no IBC packaging code listed for a particular product, then IBCs may not be used for the transport of that product by sea.

.1 The conventional packagings which may be used are indicated in a packing instructions (P code) in column 8 of the DGL. Any special packing provisions which apply are coded (PP codes) in column 9 of the DGL. Full details of the Packaging Instructions and Special Packing provisions are found in Chapter 4.1.4.1 of Volume I of the IMDG Code.

.2 If IBCs may be used, this is indicated by an IBC packing instructions (IBC code) in column 10 of the DGL. Any special IBC packing provisions which apply are coded (B codes) in column 11 of the DGL. Full details of the packaging instructions and special packing provisions are found in Chapter 4.1.4.2 of Volume I of the IMDG Code.

.3 If large packagings may be used, this is indicated in a large packing instruction (LP code) in column 8 of the DGL. Any special large packing provisions which apply are coded (LP codes) in column 9 of the DGL. Full details of the large packaging instructions and special packing provisions are found in Chapter 4.1.4.3 of Volume I of the IMDG Code.

Q Is the use of bulk containers permitted?



A Closed bulk containers may be used for some dangerous goods, if so, this will be indicated by the code ‘BK2’ in column 13 of the DGL. Closed bulk containers include freight containers, skips, offshore bulk containers, bulk bins, swap bodies, trough-shaped containers, roller containers and the load compartment of vehicles. Details on the use of bulk containers are given in chapter 4.3.

Note: sheeted bulk containers may not be used for sea transport. Q Is the use of portable tanks permitted?

A Where portable tanks may be used, the tank requirements are coded

into a tank instruction (T code) which is listed in columns 12 or 13 or both of the DGL.

● A T code in column 12 indicates that an IMO portable tank or

road tank vehicle constructed in accordance with an earlier version of the IMDG Code (Amendment 29) is authorised.

● A T code in column 13 indicates that a UN portable tank or

road tank is authorised for use. If a T code is not listed in column 13, then the dangerous goods are not authorised for carriage in UN portable tanks or road tank vehicles unless specifically approved by the competent authority.

● A full interpretation of the T codes is found in 4.2.5.2.6. ● If there is no T code listed in column 12 but there is a T code

listed in column 13, then the requirements indicated by the T code in column 13 apply. If a T code is listed in both columns 12 and 13, then the provisions of column 12 may be used instead of those of column 13 until 2010.

● Any Tank special provisions which apply are coded (TP codes)

in column 14 of the DGL. Full details of the TP codes are found in 4.2.5.3 of Volume I of the IMDG Code.

● Full details on the constructional requirements of portable tanks

are found in Chapter 6.7 of the IMDG Code.

Q Do any special requirements apply to road tank vehicles? There are special requirements applicable to road tank vehicles –

● Road tank vehicles are required to be designed and manufactured with supports to provide a secure base for the tank during transport and with suitable tie-down attachments.

● Tanks may only be carried on vehicles whose fastenings are capable, in conditions of maximum permissible loading of the

tanks, of absorbing the forces specified in Chapter 6.7 of the IMDG Code.

● The vehicle of a road tank vehicle is required to be tested and



inspected in accordance with the road transport provisions of the competent authority of the country in which the vehicle is operated.

● A road tank vehicle must be driven on board on its own wheels and be fitted with permanent tie-down attachments for securing on board the ship.

● Road tank vehicles may not be filled or discharged while they remain on board ship.

● Road tank vehicles must comply with the provisions of Chapter 6.8 of the IMDG Code.

Q Are there any relaxations of the requirements when dangerous

goods are transported in limited quantities?

A When certain less hazardous dangerous goods are packed in small (limited) quantities (i.e. not exceeding the amount specified in column 7 of the DGL) and the package gross mass does not exceed 30 kg, certain relaxations of the requirements apply, provided the shipments meet the requirements given in Chapter 3.4.

For more hazardous dangerous goods, including all PG I dangerous

goods, this exemption does not apply and the word ‘None’ appears in column 7 of the DGL. This indicates that the full requirements of the IMDG Code apply and there is no exemption quantity

(c) HAZARD IDENTIFICATION - MARKING, LABELLING AND PLACARDING

Q Are the individual packages correctly marked and labelled?

Unless provided otherwise in the IMDG Code, all packages and cargo transport units must be correctly marked. The following notes give guidance on what is required -

• Marking of packages

Unless provided otherwise in the IMDG Code, all packaged dangerous goods are required to be ‘marked’ with the Proper Shipping Name and the corresponding UN Number, preceded by the letters ‘UN’, as listed in columns 1 and 2 of the DGL.

Note: IBCs of more than 450 l require this marking on two opposite sites.

The requirements of 5.2.1 of the IMDG Code relating to marking must be met.

• Marking of marine pollutants

In addition, packages containing marine pollutants must also be marked with the marine pollutant mark unless the quantity of marine pollutants being carried is small enough to be exempted (see 5.2.1.6).



• Labelling of packages Each of the 9 hazard classes is assigned a specific diamond shaped label or labels indicating the main hazard pictorially and showing the class number in the bottom corner.

Each package containing dangerous goods must bear the

appropriate label(s) to warn of all the hazards (both primary and any subsidiary hazards) presented by the dangerous goods. Details of the labels which must be applied can be found in columns 3 and 4 of the DGL.

The requirements of 5.2.2 of the IMDG Code relating to labelling

must be met.

Some very low hazard dangerous goods are not required to be labelled (e.g. baled hay carried in cargo transport units). This is indicated by a special provision in column 6 of the DGL. Any other labelling requirements which may apply are also indicated by a special provision in column 6 of the DGL.

Orientation labels (indicating which way is considered to be upright) are also required for certain dangerous goods (see 5.2.2.1.13).

Q What marking and labelling requirements apply to mixed

dangerous goods in the same packaging?

A Where two or more dangerous goods are packed within the same outer packaging, the packaging must be marked and labelled as required for each of the dangerous goods contained within.

Q Are the correct marks, placards and signs on the cargo transport

unit?

The following notes are intended to give guidance on what are the correct marks, placards and signs to be used

• Marking a CTU with the proper shipping name

The proper shipping name of the dangerous goods, as indicated in column 2 of the DGL, must be marked on at least both sides of:

.1 Tank transport units; .2 Bulk containers; and

.3 Any other CTU containing packaged dangerous goods of a single commodity where no class placard, UN Number or marine pollutant mark is required. However, the UN Number may be displayed as an alternative.

• Marking a CTU with the UN Number

The IMDG Code requires the UN Number, as indicated in column 1 of the DGL, to be applied to a CTU as follows:

.1 Solids, liquids or gases transported in tank cargo

transport units, including on each compartment of a multi-compartment tank cargo transport unit;



.2 Packaged dangerous goods loaded in excess of 4000 kg gross mass, to which only one UN Number has been assigned;

.3 Unpackaged LSA-I or SCO-I material of class 7; .4 Unpackaged radioactive material with a single UN

Number; and .5 Solid dangerous goods in bulk containers.

• Marking a CTU with the marine pollutant mark

A cargo transport unit containing marine pollutants must display the marine pollutant mark as indicated in the table below:

Type of CTU Location of marine pollutant marks Freight container, semi-trailer or portable tank

One on each side and one on each end

Railway wagon At least on each side Multiple-compartment tank containing more than one dangerous substance

Along each side at the positions of the relevant compartments

Any other CTU At least on both sides and on the back

• Placarding of a CTU A cargo transport unit containing packaged dangerous goods

must bear enlarged class labels, known as placards to warn of all the hazards (both primary and any subsidiary hazards) presented by the dangerous goods. Details of the placards which must be applied can be found in columns 3 & 4 of the DGL.

In addition to the class placards, there are also additional

marks and signs, which must be shown on the exterior of a cargo transport unit in certain circumstances. These include the Fumigation Warning Sign to be displayed on units carrying dangerous goods under fumigation (see 5.3.2.5) and the Elevated Temperature Mark to be displayed on tanks carrying dangerous goods which are carried hot (see 5.3.2.2).

Vehicles carrying dangerous goods to and from a port may,

additionally, be required to display orange plates in accordance with the applicable road regulations.

A cargo transport unit carrying dangerous goods in limited

quantities is not required to bear class placards but must be suitably marked as ‘LIMITED QUANTITIES’ or ‘LTD QTY’.

The requirements of Chapter 5.3 of the IMDG Code relating to

placarding and marking of a CTU must be met.

Q How many placards must be applied to a cargo transport unit? A The number of placards that must be applied depends upon the type

of CTU in which the dangerous goods are carried.



Type of CTU Number of placards Freight container, semi-trailer or portable tank

One on each side and one on each end

Railway wagon At least on each side Multiple-compartment tank containing more than one dangerous substance

Along each side at the positions of the relevant compartments

Any other CTU At least on both sides and on the back

Q Are empty, uncleaned packagings and cargo transport units still

required to display marks, signs, labels and placards? A Empty, uncleaned packagings and CTUs that previously contained

dangerous goods are still required to display the relevant marks, signs, labels and placards relating to the dangerous goods last contained within, until the necessary steps have been taken to ensure that no further hazard remains.

Q Have all irrelevant placards, marks and signs been removed or

masked? A Before filling a packaging or loading a CTU, the shipper must ensure

that all irrelevant marks, signs, labels and placards are removed or masked to ensure that false and misleading information is not conveyed about a shipment, especially to the emergency services responding to an accident or incident.

Q Do any special marking requirements apply to overpacks and unit

loads? A Overpacks and unit loads are required to be marked with the Proper

Shipping Name and corresponding UN Number, as indicated in columns 1 and 2 of the DGL and labelled as indicated in columns 3 and 4 of the DGL for each item contained within unless these marks and labels are visible from the outside.

In addition, overpacks must be marked with the word ‘OVERPACK’. Note: “unit loads” in this context means that a number of packages are

either - • Placed or stacked on and secured by strapping, shrink-

wrapping or other suitable means to a load board such as a pallet

• Placed in a protective outer enclosure, such as a pallet box • Permanently secured together in a sling

“overpack” in this context means an enclosure used by a single consignor to contain one or more packages and to form one unit for the convenience of handling and stowage during transport. Examples of overpacks are a number of packages either – • Placed or stacked on the load board such as a pallet and

secured by strapping, stretch-wrapping or other suitable means or



• Placed in a protective outer packaging, such as a box or crate

(d) DOCUMENTATION Q Is there an established form for the dangerous goods transport

document? A The IMDG Code contains an example of a multimodal dangerous

goods form in 5.4.5 which meets all the requirements for the international transport of dangerous goods by all modes of transport. This form may be used as the basis for a company’s transport document. However, the transport document may be in any format provided it contains all the information required by the IMDG Code.

The dangerous goods transport document is the key source of

information when dangerous goods are being transported by any form of transport. This document provides essential information on the classification of the dangerous goods being shipped (proper shipping name, UN Number, class, subsidiary risk(s), if applicable and marine pollutant status) and the quantities. If there are any errors in the transport document, misleading information may be conveyed to the ship and to those further down the transport chain in the destination country.

Q Who will complete the Dangerous Goods declaration? A The consignor of the dangerous goods is responsible for completing

the Dangerous Goods Transport Document declaring that the consignment is acceptable for transport and that the dangerous goods are properly packaged, marked and labelled and in the proper condition for transport.

In order to comply with the requirements of the IMDG code, this

declaration must be signed and dated by the consignor.

Q Has a container/ vehicle packing certificate been completed and signed?

A Where dangerous goods are packed or loaded into a container or

vehicle, those responsible for packing the container or loading the vehicle are required to prepare a container/vehicle packing certificate declaring that the packing or loading operation has been carried out in accordance with the requirements specified in 5.4.2.1.

In order to comply with the requirements of the IMDG code, this

declaration must be signed and dated by the person responsible for loading the container /vehicle.

Where several separate consignments have been consolidated into

one CTU, the company who is responsible for the final loading, before the CTU embarks on its sea voyage, must prepare a consolidated container/vehicle packing certificate and the person who is responsible for the final loading of the CTU is the person who is required to sign and date the consolidated packing certificate.



Q Can the Dangerous Goods Transport Document & Container/Vehicle Packing Certificate be incorporated into a single document?

A To assist the consignor, the information required by both documents

may be incorporated into a single document as shown in the Multimodal Dangerous Goods Form in 5.4.5. However, if this is not done, the two documents must be attached to each other during transport to ensure that the essential information required by each is not lost.

Q Are there any other documentary requirements that must be met?

A There are various other documentary requirements that may apply

when certain dangerous goods are being transported, e.g. competent authority approvals giving permission for certain provisions to be used in certain cases. Where these apply, they are mentioned throughout the IMDG Code (see also 5.4.4).

Q Are there any specific documentary requirements that apply on

board the ship? A Each ship carrying dangerous goods and marine pollutants must have

a special list or manifest indicating which dangerous goods are on board and their exact locations. This list is usually compiled by the shipping agent on the basis of the dangerous goods transport document which has been provided by the consignor. If there are any errors in the transport document, misleading information may be conveyed to the ship and to those further down the transport chain in the destination country.

Q How is the ship informed of the necessary emergency action to

take in the event of an emergency? For consignments of dangerous goods, appropriate information must

be available at all times for use in an emergency. This information must be provided by the consignor to the forwarder or shipping agent by indicating the EmS Code* from column 15 of the DGL on the dangerous goods transport document or by providing a separate document containing emergency response information, such as a material safety data sheet.

*The EmS Code in column 15 of the DGL contains two references to

schedules which are contained in the EmS Guide in the Supplement to the IMDG Code (i.e. the Emergency Response Procedures for Ships Carrying Dangerous Goods).

● The first reference is to a Schedule which gives advice on what to do in the event of a fire involving that particular dangerous substance; and

● The second reference is to a Schedule which gives advice on what to do in the event of a spillage involving that particular dangerous substance.



(e) SEGREGATION Q Can a number of different DGs to be transported in the same

package or CTU? A Yes, in some circumstances it is possible for different DGs to be

transported in the same package or CTU. In some cases a consignor may wish to transport a number of different dangerous goods within the same packaging or CTU. This is permitted as long as the dangerous goods are considered ‘compatible’ i.e. will not interact dangerously with each other.

Dangerous goods are considered to be ‘incompatible’ if a leakage,

spillage or accident could result in a hazardous reaction between them, when they are stowed together causing:

• Combustion and/or evolution of considerable heat; • Evolution of flammable, toxic or asphyxiant gases; • The formation of corrosive substances; or • The formation of unstable substances.

The segregation requirements aim to ensure that adequate separation

is maintained between incompatible dangerous goods to ensure that they do not interact dangerously: e.g.

• Dangerous goods from different classes (class 1 explosives

must be segregated from class 3 flammable liquids); • Dangerous goods in the same class (corrosive acids must be

segregated from corrosive alkalis); • Dangerous goods from non-dangerous goods (toxics must be

segregated from foodstuffs).

Segregation between substances of the same class In general, substances of the same class may be stowed together, regardless

of any segregation required by subsidiary risk label(s), provided the substances do not react dangerously with each other. However, it is important to always check the DGL first for additional segregation requirements which may apply (see below), as not all substances of the same class may be stowed together, eg alkalis and acids.

Segregation between substances of different classes The general provisions for segregation between different classes of

dangerous goods are shown in the Segregation Table in 7.2.1.16. This table is consulted to ascertain the general segregation requirements between different classes of dangerous goods. The table is read by finding the intersection between any two classes in question. However, always check the DGL first as information in column 16 will over-ride the table. Only consult the table if column 16 of the DGL for both substances has no advice on segregation

Mixed dangerous goods within the same packaging



Mixed dangerous goods within the same packaging is only permitted if the intersection between the two classes on the Segregation Table results in an ‘X’ and there is no segregation advice in column 16 of the DGL.

Mixed packing within the same CTU If the intersection between the two classes results in a ‘2’, ‘3’ or ‘4’, this

implies a separation distance of ‘6m’, ‘12m’ and ‘24m’ respectively and is not possible to achieve within a CTU and is not permitted.

If the intersection between the 2 classes results in a ‘1’, this implies a

separation distance of ‘3m’ which, in theory is possible if one of the dangerous goods is packed at the far wall of the CTU and the other is packed immediately adjacent to the door. However, in order to carry such dangerous goods in the same CTU, competent authority approval is required and, in practice, most competent authorities will not issue such approvals.

If such permission is given, it will have to be in writing and a copy of

that document should be attached to the dangerous goods note Additional Segregation Requirements While the Segregation Table provides general advice on segregating

different classes of dangerous goods, for some specific dangerous goods, additional segregation requirements may apply and these take precedence over the general provisions. When deciding upon the segregation requirements, column 16 of the DGL should always be checked first before applying the general segregation requirements of Table 7.2.1.16.

If additional segregation requirements apply, they may involve either -

• A separation distance such as ‘away from’, ‘separated from’* etc, which ALWAYS appear in the DGL in quotes; or

• Another segregation requirement, e.g. ‘Separated from’ powdered metals, ammonium compounds and cyanides.

How will the shipper know what dangerous goods are, for

example, powdered metals, ammonium compounds and cyanides?

For the purposes of segregation, dangerous groups having similar

chemical properties have been grouped together into segregation groups (see 3.1.4.4) as follows –

• Acids • Ammonium compounds • Bromates • Chlorates • Chlorites • Cyanides • Heavy metals and their salts



• Hypochlorites • Lead and lead compounds • Liquid halogenated hydrocarbons • Mercury and mercury compounds • Nitrites and nitrite mixtures • Perchlorates • Permanganates • Powdered metals • Peroxides • Azides • Alkalis

To assist in applying the segregation requirements, the dangerous

goods allocated to each of these segregation groups are listed in 3.1.4.4.

(f) REQUIREMENTS RELATING TO THE USE OF A CARGO TRANSPORT

UNIT Q Are there any special requirements applicable to the use of a

cargo transport unit? A A CTU used for the transport of dangerous goods must be –

● of adequate strength to resist the possible stress imposed by the conditions of the services in which they are employed; and

● adequately maintained. Containers must comply with the requirements of the 1972

International Convention for Safe Containers (CSC 1972). The Convention sets out procedures whereby containers used in international transport must be safety-approved by the Administration of a Contracting Party or by an organisation acting on its behalf.

The Administration, or an organisation authorised by it, will then

authorise the manufacturer to affix a Safety Approval Plate containing the relevant technical data to approved containers. When using a freight container to transport dangerous goods, the shipper must ensure that the container displays a valid Safety Approval Plate.

Q What information must be displayed on the Safety Approval

Plate? The plate must contain the following information in at least English or

French:

• ‘CSC SAFETY APPROVAL’; ● Country of approval and approval reference; ● Date (month and year) of manufacture; ● Manufacturer's identification number of the container; ● The number allotted by the Administration in the case of

existing containers where the manufacturer’s identification number is unknown;

● Maximum operating gross weight (kg and lb);



● Allowable stacking weight for 1.8g (kg and lb); and ● Transverse racking test load value (kg and lb).

Q How often does a container have to be examined? A Under the CSC Convention, two systems of re-examination are

permitted, either: ● Periodic re-examination at intervals of not more than 30

months after its first 5 years; or ● Re-examination under an Approved Continuous Examination

Programme (ACEP) which must be started within the first 30 months and performed in no case less than every 30 months.

To indicate that a container is operated under an approved continuous

examination programme (ACEP), a decal showing the letters ‘ACEP’ and the identification of the Contracting Party which has granted approval of the programme must be displayed on the container on or as close as practicable to the Safety Approval Plate. The decal is colour coded to show the year in which it was examined.

Q How will the shipper know when the container next has to be

examined? A Under a PES scheme, the date (month and year) before which the

container has to be re-examined must be clearly marked on the container on or as close as practicable to the Safety Approval Plate. The shipper has no way of knowing the situation under an ACEP scheme.

(g) PACKING AND SECURING DANGEROUS GOODS WITHIN A CARGO

TRANSPORT UNIT

Q What factors must be borne in mind when packing and securing dangerous goods into/onto a cargo transport unit?

A freight container or vehicle should –

• Be suitable for the load • Be clean • Be dry • Have no residues from previous cargoes • Have no residual fumigant • Have no irrelevant placards, markings or signs

The following should be taken into account –

.1 Weather conditions Sea voyages are made in a variety of weather

conditions which are likely to exert a combination of forces upon the ship and its cargo over a prolonged period.



Such forces may arise from pitching, rolling, heaving, surging, yawing or swaying or a combination of any two or more.

Note: It should never be assumed that the weather will be calm and the sea smooth or that securing methods used for land transport will always be adequate at sea.

.2 Climatic conditions

During longer voyages, climatic conditions (temperature, humidity, etc.) are likely to vary considerably. These may affect the internal conditions in a CTU which may give rise to condensation (sweating) on cargo or internal surfaces. Where the shipper is aware that the dangerous goods are susceptible to damage from condensation, expert advice should be sought.

.3 Conditions encountered during handling in

terminals Container movements by terminal tractors may be

subject to differing forces as terminal trailers are not equipped with suspension. Additionally, ramps can be very steep, causing badly stowed cargo inside a CTU to be thrown forward or backward.

Considerable forces may also be exerted on a CTU and its cargo during terminal transfer. At sea ports containers are transferred by shore-side gantry cranes that lift and lower containers, applying considerable acceleration forces and creating pressure on the packages in containers. Lift trucks and straddle carriers may take containers, lift them, tip them and move them across the terminal ground.

Packing and securing of cargo into/onto a CTU should be carried out with these conditions in mind.

Q What requirements should be met before packing a cargo

transport unit? . A CTU should be thoroughly inspected, both internally and externally,

before it is packed with cargo. Before loading, check that it has a current safety approval plate. A CTU used for the transport of dangerous goods must be examined for external signs of damage, leakage or sifting of contents. Any CTU found to be damaged, leaking or sifting must not be accepted for shipment until repairs have been effected or damaged packages have been removed (Section 2 of the Guidelines for Packing CTUs, contained in the Supplement to the IMDG Code, contains advice on what to look for during an inspection of the CTU).

The CTU should be suitable for the intended dangerous goods. It

should be clean, dry and in good structural condition with fittings in full working order. It should also have securely closing doors.



Information should be provided by the shipper about the hazards of

the dangerous goods to be handled and their quantities.

Other items of information may be required, depending on the mode of transport (flashpoint for transport by sea, instructions to be followed in case of incident for road transport under the ADR regime, special certificates, e.g. for radioactive materials, etc.). The various items of information required by each regulation and applicable during combined transport operations should be provided so that appropriate documentation may be prepared for each shipment.

The shipper should ensure that all the individual dangerous goods are

packaged, marked and labelled and that the CTU is placarded in accordance with the IMDG Code requirements. Packages of dangerous goods should be examined and any found to be damaged, leaking or sifting should not be packed into a CTU. Packages showing evidence of staining, etc. should not be packed without first determining that it is safe and acceptable to do so.

Detailed advice on the safe handling and securing of CTUs is given in Section 6 of the IMO/ILO/UN ECE Guidelines for Packing CTUs (contained in the Supplement to the IMDG Code).

Q Are the goods properly secured in the cargo transport unit? A The key to the safe transport of dangerous goods in CTUs lies in the

standard of the packing and securing. Once the packing operation is completed, the next person to see inside the CTU will usually be the consignee on arrival of the CTU at its destination. Consequently, the following precautions should be taken:

● The packing and method of securing of dangerous goods in a

CTU should be planned before packing is started; ● Packaged dangerous goods and any other goods within the

same cargo transport unit must be tightly packed and adequately braced and secured for the voyage; and

● The packages must be packed in such a way that there will be a minimum likelihood of damage to fittings during transport.

Detailed advice on how to pack and secure cargo within a CTU is

given in Section 3 of the IMO/ILO/UN ECE Guidelines for Packing CTUs (contained in the Supplement to the IMDG Code).

Q Is the weight uniformly distributed within the cargo transport

unit? A A CTU must be loaded so that, as far as practicable, the cargo is

uniformly distributed over the floor. In no case should more than 60% of the load be concentrated in less than half the length of the CTU.

Q Do any special requirements apply if dangerous goods form only

part of the load within the CTU?



A Dangerous goods consignments which form only part of the load of a CTU should, whenever possible, be packed adjacent to the doors with markings and labels visible.

For further advice, refer to section 3.3.1 of the IMO/ILO/UN ECE

Guidelines for Packing CTUs for information on securing of cargo by the doors of a unit.

(h) HANDLING

Q Are appropriate precautions taken before opening consignments received from elsewhere?

A If a CTU has travelled by sea, it may well have been subjected to

conditions which have caused some of the cargo to move, particularly if it was inadequately secured at the point of origin. Precautions should be taken when opening doors, not only against the hazards from the dangerous goods contained within which may be leaking from damaged packages, but also any part of the cargo having moved against a door and so being likely to fall on a person opening it.

Q Have CTUs which have carried dangerous goods been properly

cleaned after unloading? A The cleaning should include the removal of any residual dangerous

goods, discarded packagings and securing materials. Once the CTU is completely clean, all hazard warning placards, marks and signs should be removed or else masked.

(i) TRAINING & COMPETENCY

Q Are all personnel involved with the transport of dangerous goods

by sea adequately trained? A The IMDG Code recommends that all shore-based personnel involved

in the transport of dangerous goods by sea should be adequately trained in the requirements of the IMDG Code, commensurate with their responsibilities. The training which is required will vary depending upon the level of involvement of individuals and the nature and number of dangerous goods to be handled.

Shore-based personnel include those who – ● Classify dangerous goods;

● Pack dangerous goods in packagings; ● Mark, label or placard dangerous goods; ● Pack/unpack CTUs; ● Prepare transport documents; ● Offer dangerous goods for transport; ● Accept dangerous goods for transport; ● Handle dangerous goods in transport; ● Prepare dangerous goods loading/stowage plans; ● Load/unload dangerous goods into/from ships; ● Carry dangerous goods; ● Enforce, survey or inspect for compliance with the legislation;



● Are otherwise involved in the transport of dangerous goods. The training should include – ● General awareness/familiarisation training; ● Function-specific training relating to the actual responsibilities

and work carried out; ● Safety training, including the general dangers of the 9 hazard

classes, safe systems of work when handling dangerous goods and the actions to be taken in the event of an accident or an emergency; and

● Security training in relation to dangerous goods. Training should be provided or checked upon first employment and

supplemented by periodic updating or re-training, as necessary.

Further information on the training requirements is given in Chapter 1.3 and on security provisions in Chapter 1.4.

Q Will the cargo transport unit be packed/loaded by a ‘competent

person’?

A The IMO/ILO/EN ECE Guidelines for Packing CTUs require each regulatory authority to establish –

● Minimum requirements for training; and ● Where appropriate, qualifications, for each person involved,

directly or indirectly, in the packing of cargo in CTUs, particularly in relation to dangerous goods

● The shipper should ensure that those packing/loading a CTU on his behalf, whether employed directly or indirectly, are suitably and adequately trained

● Further information on the training requirements is given in section 7 of the Guidelines for Packing CTUs

Q Will the dangerous goods be taken to the port by a competent

vehicle operator with appropriately trained drivers?

A Some regional requirements, such as the European road transport legislation (the ADR), and most national road transport legislation requires that dangerous goods are only transported by competent vehicle operators employing appropriately trained drivers. The drivers are usually required to undergo a specific training programme and pass an exam in order to be certified as ‘competent’.

Q Who can the organisation turn to for advice? A Every company that is involved in shipping dangerous goods by sea

should have access to a person with the relevant knowledge of the requirements either on the staff or available to give advice. His/her knowledge must include not only properties of individual substances but also transport requirements and this may also need to extend to imports coming into the country. If copies of individual legislation and guidance are not held, specialists should know where to consult them and/or seek specialist advice themselves. When consulting such



documents, it is important that only the latest up-to-date copies are used.

5 SECURITY Q What does the IMDG Code say about security? A It recommends that shoreside personnel engaged in transport of

dangerous goods by sea should be trained in security awareness and that they should consider security provisions for that transport commensurate with their responsibilities. Certain dangerous goods within the various classes are considered to be high consequence goods and consignors and others engaged in their transport are recommended to adopt, implement and comply with a security plan that includes as a minimum certain elements. The high consequence goods are listed in the Code at 1.4.3.1 in volume one and the elements that should be included in the plan are listed in 1.4.3.4.



International Maritime Dangerous Goods Code Recommendations on the Safe Transport of Dangerous Cargoes in Port Areas International Maritime Organisation, 4 Albert Embankment, London SE1 7SR

www.imo.org. The International Maritime Dangerous Goods (IMDG) Code, Safety Briefing

Pamphlet #3 Dangerous Goods by Sea Documentation, Plasticised pocket card IIL/1 Dangerous Goods by Sea – the IMDG Code: labels, placards, marks and signs,

plasticised pocket card IIL/2 ICHCA International Ltd, Suite 2, 85 Western Road, Romford, Essex, RM1 3LS,

UK [email protected]. Book it right and pack it tight, four volume set of guidebooks plus DVD UK P&I Club package available from www.marisec,org.


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