“book it right & pack it tight” - uk p&i · “book it right & pack it tight” •...

“Book it right & pack it tight”

• Revised guidebooks to the IMDG Code operational rules

for preparing dangerous goods for carriage by sea

• Book 1: Shippers & Forwarders

• Book 2: Shipping lines and freight

booking agencies

• Book 3: Consolidators – managers

and supervisors

• Book 4: Fork lift operators

and cargo handlers

Subjects covered in this presentation

• Purpose & content of the Guidebooks

• Classification of dangerous goods

• Creation of Shipper‟s Declaration

• Packaging & labelling

• Limited quantities, mixed loads, aerosols & security

• IMDG Code training

• Provision of information to shipping line

• Summary & source of further information

1 - Purpose & content of the Guidebooks

What is in the Guidebooks?

• Clear guidance on what you must do to comply

with the IMDG Code

• Explanation of your legal duties

• Practical examples

• Sample documents

• Photographs

• Illustrations

Format of the guidebooks

• The Guidebooks all have a Part A & Part B:

• Part A identifies the key operational duties – what you

must do and how to do it

• Part B is a common reference section explaining

requirements of the IMDG Code

What is the purpose of the Guidebooks?

1. To provide practical operational guidance to the

complex requirements of the IMDG Code

2. To provide a quick reference to the relevant

IMDG Code text

A fundamental question: What are dangerous goods?

Answer: Substances or articles that may:

– kill or injure people

– damage ships or transport equipment

– damage cargo

– damage the environment (marine pollutants)

Are there rules for shipping

dangerous goods by sea?

YES – there are strict rules for shippers,

container packers and shipping lines

The rules are contained in the

International Maritime

Dangerous Goods Code

Failure to comply with

dangerous goods rules causes severe maritime incidents …….

.

..… and heavy losses

Known as the IMDG Code

A complete instruction

manual for documentation,

packaging and carriage of

dangerous goods by sea

The International Maritime Dangerous Goods Code

What is the IMDG Code?

• Two volumes & a Supplement (over 800 pages)

• Rules for every stage of the carriage of

dangerous goods by sea

• The international UN system for classification,

listing, documentation, packaging & packing of

dangerous goods

• Specific legal duties for all parties arising from the

SOLAS (Safety of Life at Sea) Convention

Where does the IMDG Code come from?

• The IMDG Code is produced by the International Maritime Organisation (IMO)

• The IMO is a United Nations agency

• The IMDG Code is based on the UN inter-modal dangerous goods system and is used world-wide

Who has duties under the IMDG Code?

• Shippers & forwarders

• Shipping line booking agents

• Consolidators (supervisor/manager)

• Fork lift drivers/container packers

• Ships and shipping lines

Must I comply with the IMDG Code rules?

YES!

• Since 2004 the IMDG Code has been mandatory

in all countries by government signature at the

SOLAS Conference and through the IMO

• It is also mandatory to train your employees in

aspects of the Code applicable to their jobs

1. Classification & identification

2. Documentation

3. Packaging & labelling

Practical operational guidance on the Shipper’s IMDG Code duties regarding:

Book 1: Shippers & Forwarder

References in this presentation

• References to sections in Guidebook 1 are

always shown in yellow at bottom left hand corner

e.g.

• References to text in the IMDG Code are shown

in blue: See IMDG 3.2

See Guidebook Part B section 4

See Guidebook Part B section 4

The guidebook is your quick guide to the IMDG Code

Your quick reference to …

…. the 800 pages of the IMDG Code

How to use your guidebook

Identify your operational duties, and see examples. Use the IMDG references to ….

…. take you directly to the relevant text in IMDG Code for full details

Guidebook 1 identifies shipper‟s key IMDG Code duties:

1. Classification of dangerous goods

2. Creation of shipper‟s declaration

3. Packaging & labelling

4. Provision of information to the shipping line

2 - Classification of dangerous goods

What does “classification” mean?

• Classification means your duty as a shipper to describe your product and its hazard according to the rules of the IMDG Code

e.g.

- UN Number

- Proper Shipping Name of product

- Class and type of hazard(s)

- Description in terms used in the IMDG Code (see examples below)

Where can classification details be found?

In the columns of the Dangerous Goods List in

Part 3 of the IMDG Code –

What is the Dangerous Goods List?

• A list containing an entry for all dangerous goods

(it takes up 169 pages of Volume 2 of the IMDG

Code)

• It is the first point of reference for all enquiries

about classification or technical details of a

substance or article

Dangerous

Goods List (diagrammatic display)

Each substance entry has

18 columns of classification &

other information

Substances are listed under their

UN Number in Column 1

Why does the shipper need the classification details?

1. He must add the classification details to a signed

document (Shipper‟s Declaration) that

accompanies the dangerous goods

2. He must display the classification details

on each package

Classification factors: mandatory & conditional

There are a number of classification details shippers

must provide for each dangerous substance:

1. UN Number

2. Proper Shipping Name

3. Class

4. Plus a number of “conditional” details such as degree of hazard (Packing Group), flashpoint, marine pollutant, etc, depending upon the substance

UN classification system

• The IMDG Code uses the UN intermodal system

to classify and identify dangerous goods

• Classification details for each substance are listed

in the columns of the Dangerous Goods List

See Guidebook Part B sections 1-8

Class 1 - Explosives

Class 2 - Gases

Class 3 - Flammable Liquids

Class 4 - Flammable Solids

Class 5 - Oxidising Substances

Class 6 - Toxic Substances

Class 7 - Radioactive Substances

Class 8 - Corrosives

Class 9 - Miscellaneous

Dangerous

goods are put into one

of 9 categories,

depending

upon the type of hazard.

These are called

‘Classes’

There are 9 hazard Classes

Hazard classes are represented by symbols: e.g.

CLASS 3

Flammable liquids are liquids that have a flashpoint of below 60°C

CLASS 8

Corrosive substances and their vapours destroy living tissue on contact and can damage many other materials

CLASS 6.1

Toxic substances cause injury or death to humans by inhalation, swallowing or skin contact

Some classes are sub-divided into “divisions”

Class 2.1 – Flammable gas

Class 2.2 – Non-flammable non-toxic gas

Class 2.3 – Toxic gas

See Guidebook Part B Section 4 for an explanation of all the classes and sub-divisions

Multiple hazards (Class + Sub-risk)

• Some substances have more than one hazard –

They have a main class and a “sub-risk” e.g. a substance classed as a flammable liquid may also be toxic:

CARBON DISULPHIDE

Class 3 + Sub-risk of

class 6.1

See Guidebook Part B section 5

UN Number

• Every dangerous substance has a UN Number

• This is a unique number allocated by the UN

• The UN Number is used to locate the dangerous

substance entry in the IMDG Dangerous Goods

List

e.g. UN 1170

See Guidebook Part B section 6

All dangerous goods have a mandatory UN

Number, Proper Shipping Name & Class

Example: ETHANOL

• UN Number - UN 1170

• Proper Shipping Name - ETHANOL

• Class - 3

What name shall I give to my dangerous goods?

• Every dangerous substance and article is listed in the IMDG Dangerous Goods List under its Proper Shipping Name

See Guidebook Part B section 7

E.g. Substance name: SULPHURIC ACID E.g. Article name: ROCKET MOTORS

Proper Shipping Name

Common substances & articles:

• The Proper Shipping Name is the only name you are permitted to use on your documentation and package labelling

• It is the name by which a dangerous substance is listed in the IMDG Dangerous Goods List alphabetical index

• This is the only name internationally recognised by the United Nations dangerous goods system

Proper Shipping Names (N.O.S. Names)

Mixtures & uncommon substances & articles:

• Mixtures of dangerous substances and

uncommon dangerous substances are not listed

in the Dangerous Goods List

• They are shipped under generic names called

“Not Otherwise Specified” (N.O.S.) names

How N.O.S Proper Shipping Names

are determined for mixtures

• A mixture is subjected to classification tests to

determine if it should be assigned to any hazard

class and sub-risk

• If so, the mixture is allocated a generic name that

describes the hazard e.g. FLAMMABLE LIQUID

N.O.S.

• Each generic name is assigned a UN Number

e.g. UN 1993, FLAMMABLE LIQUID N.O.S.

See Guidebook Part B section 7

Completing N.O.S. names

• To complete an N.O.S. name the identity of the dangerous substance(s) must be added in brackets after the generic name e.g.

• UN 1993, FLAMMABLE LIQUID N.O.S. (contains glycol and acetone)

• The IMDG Code has a list containing N.O.S. generic

names that cover all combinations of hazard class and sub-risk – the IMDG Code Dangerous Goods List Appendix A has a comprehensive list

There are other classification details that are “conditional”

• “Conditional” classification details are those that

depend upon the class nature of specific

dangerous goods

• To find what details are required for a particular

substance, refer to the substance entry in the

Dangerous Goods List

See Part B sections 5, 8, 10, 11, 14, 15, 16, 17 & 19 for full details

The most common conditional classification details:

1. Sub-risk

2. Packing group

3. Flashpoint (Class 3 substances only)

4. Marine pollutant

Packing Groups: an indication of danger

• Some hazard classes require the documentation to

show a Packing Group to indicate degree of hazard

• “Packing Group” is usually shortened to “PG”

• PG I Great danger

• PG II Medium danger

• PG III Low danger

See Guidebook Part B section 8

Flashpoint

• The flashpoint must be provided for:

– Class 3 substances (Flammable Liquids)

– Or any substance with a class 3 sub-risk

CLASS 3 - flammable liquids are liquids that have a flashpoint of less than 60°C.

See Guidebook Part B section 10

Marine Pollutants

• Substances that bio-accumulate in the marine

food chain, or are highly destructive to the marine

environment

• Document must state “Marine Pollutant” and

packages and cargo transport units display the

marine pollutant mark.

See Guidebook Part B section 11

Less common variable details

• Some classes require other less common conditional classification details eg:

– Solid or liquid form

– Control & emergency temperature

– Radioactivity details

– Explosives details

• Refer to the substance entry in the Dangerous Goods List and IMDG 5.4 to see what details may be required

Reminder: How to find classification details

• All classification details are found in the various

columns of the Dangerous Goods List in Part 3.2

of the IMDG Code

3 – Creation of shipper‟s declaration

Provision of dangerous goods

information from shipper to shipping line

• The shipper or forwarder must provide the line with full

classification details at the initial booking stage – you will

usually be requested to complete a shipping line internal

booking request form

• Later, when you despatch the goods, they must be

accompanied by a formal dangerous goods declaration

that complies with IMDG Code requirements – details in

the following section

:

Shipper’s dangerous goods declaration

This example of a shipper’s declaration is taken from page 20 of Guidebook 2

Shipper’s dangerous goods declaration

• All dangerous goods

consignments must be

accompanied by a

dangerous goods

declaration that includes

all classification details

and is signed by the

shipper

Details required for the dangerous goods declaration

• Shipper’s address

• Consignee’s address

• Ship & voyage details

• Classification & identification

• Packaging description

• Quantity

• Leading marks

• Shipper’s signature

• Place & date of signature

See Guidebook Part A sections 3 & 4

Shipper’s name & address

Consignee’s name & address

Voyage details

Number & type of packaging

Leading marks

Classification & identification

Container details

Packing certificate details: not to be completed by the shipper, to be completed only by the container packer

Details of the packaging, classification and substance identification must all

be entered on the declaration

See IMDG 5.4

See Guidebook Part A sections 3 & 4

Classification details are vital

Classification details

Proper Shipping name Mandatory

Class Mandatory

UN Number Mandatory

Sub-risk (conditional)

Packing Group (conditional)

Marine Pollutant (conditional)

Flashpoint (conditional

Control & emergency temperature (conditional)

Fumigation details (conditional)

Radiation details (Mandatory for Class 7)

Explosives details (Mandatory for Class 1)

Shipper’s declaration: This text confirms that the shipper has accurately described his dangerous goods and they are correctly classified, packaged and labelled according to all national and international legislation.

This is a mandatory text from the IMDG Code.

This is where the document is signed and dated by the shipper

Net & gross quantity of dangerous goods

4 – Packaging & labelling

Packaging for dangerous goods

• Three principles apply to packages:

• They must be made to a UN approved design

standard

• The design type and size must be permitted by

the IMDG Code

• Each package must be marked and labelled with

details of the dangerous goods

UN-approved packaging design

• Packages used for carriage of dangerous goods

must be built to a UN–approved design standard

that is stamped with an appropriate packaging

design code

• As the shipper, it is your duty to ensure that you

select suitable UN–approved packaging for your

product

See Guidebook Part A section 6

Packaging codes for UN-approved designs

Example of a UN code marked on a drum head

Package design and size permitted by the IMDG Code

• The IMDG Code specifies different package

designs and maximum safe package sizes for

different dangerous goods

• These specifications are found in the individual

substance entries in the Dangerous Goods List

Column numbers 8 to 11

Package marking & labelling

Each package must

display warnings about

the dangerous goods

inside:

– Proper Shipping Name

– UN Number

– Class (& sub-risk if applicable)

– Marine Pollutant mark (marine pollutants only)

See Guidebook Part A section 7

There are rules for unit loads and overpacks

Each individual package in a unit load must be marked and labelled

Overpacks must be marked and labelled and an “OVERPACK” mark must be added

See Guidebook Part A section 7

Packaging: Summary of shipper’s duties

• Select suitable packaging coded with the UN-

approval mark

• Only use package designs and sizes allowed by

the IMDG Code (see Dangerous Goods List)

• Apply warning marks & label(s)

5 - Limited quantities, mixed loads, aerosols

& security

Limited quantities

• Dangerous goods shipped as “limited quantities”

are exempted some of the land and sea transport

rules

• By sea the main concession is that no segregation

is required from other dangerous goods

• Another concession is that UN-coded packaging is

not required

Limited quantities

In principle limited quantities means shipping in small receptacles protected by outer packaging

Rules for limited quantities

• Weight/capacity of inner and outer packaging for

each substance is specified by the IMDG Code

(see column 7 of Dangerous Goods List)

• Amended shipper‟s declaration required

• Marks & labels replaced by limited quantities

mark

• UN-tested packaging not required

See Guidebook Part A section 8 & Part B section 9

Segregation: Rules for controlling mixed hazard loads

• „Mixed loading‟ means loading different types of dangerous goods together in the same container

• Mixed loading creates the possibility of dangerous chemical reaction

• Mixed loading is prohibited unless permitted by the IMDG Code segregation rules in IMDG section 7.2

The rules of segregation are complex - see IMDG chapter 7.2

Be aware that different types of dangerous goods may have to be packed into different containers

See Guidebook 1 Part A section 9

See Guidebook 3 (Consolidators) Part A section 12 for full details of segregation in containers

Aerosols: special rules

• Aerosols are a commonly-shipped commodity that

often cause problems

• Usually shipped as Limited Quantities (note limited quantities mark)

• Aerosols have special rules for

classification, documentation

and packaging

See Guidebook Part B section 19

6 – IMDG Code Training

IMDG Code training for shippers

• The IMDG Code requires that staff preparing

dangerous goods documents and cargo must be

trained to understand the rules of the IMDG Code

• Shippers and packers may expect to be given

advice on classification, package marking &

labelling, documentation and segregation from the

line

Key training areas for shippers & forwarders

1. Classification of dangerous goods

2. Use of the Code Dangerous Goods List

3. Documentation requirements

4. Packaging selection, marking & labelling

See Guidebook Part A section 1

Have you given your staff proper IMDG Code training?

The IMDG Code requires that employers train their employees in both:

– general dangerous goods awareness

– job-specific functions

Refer to the IMDG Code training schedule in section 1.3 to check the functions in which shippers and forwarders are expected to be competent

Security awareness

• Some dangerous goods can be used to create

explosions, fires and toxic releases in a terrorist

context

• All personnel should be aware of such hazards

and keep information confidential

• IMDG Code Chapter 1.4 has provisions for

security of dangerous goods in transit

• Ports are high security zones

See Guidebook Part A section 2

7 – Provision of information to the shipping line

It is your legal duty to correctly declare all

dangerous goods to the shipping line

Shippers & forwarders take note!

• Shipper or forwarder must provide full classification details to the line in advance of shipment

• The information will be the same as that required on the shipper’s dangerous goods declaration (IMDG 5.4)

• Details will normally be required on a special dangerous goods booking form

8 – Summary of presentation & source of further

information

What has been covered in this presentation

• This presentation has looked briefly at key duties of the

shipper including:

• Classification

• Packaging & labelling

• Shipper’s declaration

• Greater detail on these and related topics will be found in

Guidebook 3.

• Other Guidebooks in the series provide detailed coverage of

other topics including:

• Segregation

• Packing certificates

• Container packing & securing

• Container marking and placarding

Important Notice

The Guidebooks are a practical operational aid and

should be used alongside the IMDG Code

They are not a substitute for IMDG Code training –

employees should be trained as appropriate for their job

and responsibility

Technical issues should always be checked against the

legal text of the IMDG Code

The end

This presentation is to introduce the “Book it

Right and Pack it Tight” guidebooks to a wide

audience and to promote understanding and

use of the IMDG Code. Please modify to

your own requirements

Published by:

Thomas Miller P&I Ltd, 90 Fenchurch Street, London EC3A 5BA

Tel: +44 (0)20 7283 4646. Fax: +44 (0)20 7283 5614

http://www.ukpandi.com

For more information contact:

Email: karl.lumbers@thomasmiller.com