Frequently Asked Questions on Dangerous

Goods by Sea
(IMDG Code 37-14 / 38-16)

101 Questions answered by Shashi kallada

pg. 1
 Did you know cricket balls are not
dangerous goods but table tennis balls
are dangerous goods?

This book contains questions raised by Shippers, Consolidators, Ports, Tank

Operators, Forwarders, and Carriers, related to transporting dangerous goods in
packaged from by Sea, answered by interpreting relevant provisions of IMDG Code and
other regulations, where mentioned.

Readers are reminded that IMDG Code is the only legal document for compliance to safe transport of
dangerous goods in packaged form by sea and must refer to IMDG Code and apply all the applicable
provisions while offering to or transporting dangerous goods by sea.

All the questions are answered by Shashi Kallada.

Shashi started his career in merchant ships and sailed for more than a decade. Leaving
the sea in 2003, he joined P&O Nedlloyd as a Specialist in Dangerous Goods and later
worked with Maersk Line as Manager, Global Dangerous Goods. He was responsible for
the more than 500+ships carrying DG Maersk Line, MCC Transport, Mercosul Line and
Safmarine B/L and tonnage.

Shashi left Maersk Line in October 2010, and since then he has been conducting training,
seminars and providing consultancy in dangerous goods by Rail, Road, River and Sea.

Shashi has written 450+ articles on dangerous Goods and his articles are being
published in leading shipping newspaper. With monthly average 10,000+ page views
www.shashikallada.com is one of the top websites in the shipping industry.

Visit and subscribe to www.shashikallada.com for updates on IMDG Code and

other related information on dangerous goods regulations.

pg. 1
Contents
Introduction ............................................................................................................................................ 7
Objective ................................................................................................................................................. 7
Training ................................................................................................................................................... 7
Crack the Code ........................................................................................................................................ 7
Regulations ............................................................................................................................................. 8
1. Which Regulations govern transport of dangerous goods throughout the world? ............... 8
2. If an import dangerous goods container while on Indian road is caught for noncompliance
by transport authority who will be penalised? ............................................................................... 8
3. Does a ship carrying dangerous good in solid Bulk form require to comply with IMDG code
or IMSBC code? ............................................................................................................................... 8
4. If a bulk carrier is loading UN grade Sulphur which sections need to be checked in IMDG
Code by Ship staff?.......................................................................................................................... 8
5. Where can I purchase IMDG Code? ........................................................................................ 9
6. Who all are the parties involved in transporting dangerous goods in multimodal transport?
9
7. What is the difference between IMDG Code and 49 CFR? ................................................... 10
Responsibilities ..................................................................................................................................... 10
8. What are the responsibilities of shipper for dangerous goods?........................................... 10
Training ................................................................................................................................................. 11
9. Who needs to be trained in IMDG Code? Is it compulsory? ................................................. 11
10. Is it mentioned anywhere in IMDG Code that each person involved in packing/stuffing of
hazardous container require general as well as periodic training? .............................................. 11
Classification ......................................................................................................................................... 11
11. How do I know whether the Goods shipped are dangerous? .......................................... 11
12. How can we know & decide the applicability of special provisions for our products? .... 12
13. As per special provision SP277 of UN 1950 the limited quantity value is 120 mL for
receptacles containing toxic substances, why this is not applicable for corrosive sub risk? ....... 12
14. What is the criteria for assigning packing group to dangerous goods? ............................ 12
15. What is marine pollutant? How do we identify whether a dangerous goods is marine
pollutant or not? ........................................................................................................................... 13
16. Special provision 965 for carriage of UN 2211 POLYMERIC BEADS, EXPANDABLE & UN
3314 PLASTICS MOULDING COMPOUND has various requirements, which of these must be met
with? 13
17. Are UN Numbers UN 3077 and 3082 always Marine Pollutant? Why there is no letter P
in dangerous goods list identifying these entries as marine pollutant? ....................................... 13

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 18. What possibilities are there for UN 3077 and UN 3082 to be assigned to any segregation
group as per section 7.2.5.4 of IMDG Code? ................................................................................ 14
19. We have a mixture of chemical having more than one hazard properties and is not listed
by name in IMDG Code. How do we assign proper shipping name, UN Number and Packing
group for this mixture? ................................................................................................................. 14
20. Why do carriers ask for correct technical name? What is the requirement of IMDG Code
and why this is required? .............................................................................................................. 14
21. We are freight forwarders, shipper offered a liquid as non-dangerous but the flashpoint
is 56 Deg C, carrier rejected and we know from IMDG Code that any liquid with flashpoint 60
Deg C or below is considered as Class 3 Flammable Liquids, shipper insisted the cargo as non-
dangerous liquid. What are the regulatory aspects for this? ....................................................... 16
22. Where can we find the list of forbidden chemicals in the IMDG code? ........................... 17
23. Is technical name required to be declared when a generic entry is consigned as marine
Pollutant? ...................................................................................................................................... 17
24. Why Ammonium permanganate has no UN number but it is prohibited for transport? . 17
25. UN 1910: What does SP 960 by other modes. Does this mean UN 1910 is Non-hazardous
for sea transport? ......................................................................................................................... 17
26. Why is the net weight for UNNO 3363 should be in Limited quantity? ........................... 18
27. What should be the combustible material content for UN 1942? ................................... 18
28. For UN 1779, Formic Acid, why the flashpoint varies to different shippers or
consignments? .............................................................................................................................. 19
29. I am working in ocean carrier’s dangerous goods department, how to explain to other
shipping partners about the flashpoint criteria of UN 1779 if they are not ready to accept the
cargo when flashpoint declared by shipper is above 60 Deg C.c.c.? ............................................ 19
30. Why only organic peroxides listed in section 2.5.3.2.4 and self-reactive substances listed
in section 2.4.2.3.2.3 of the IMDG code is acceptable?................................................................ 19
31. Can shipper declare batteries which are installed in machinery such as generator under
UN2794 or any other battery UN? ................................................................................................ 19
32. UN3481 can be shipped as NON-HAZ as per SP188? ........................................................ 19
33. Can UN 3269 POLYESTER RESIN KIT and UN 3108 ORGANIC PEROXIDE TYPE E, SOLID be
acceptable to load in the same unit as per SP340 of UN 3269? ................................................... 20
34. What is Reportable Quantities in 49 CFR, is this applicable to both export and import
shipments from/to U.S.A? ............................................................................................................ 20
Packagings ............................................................................................................................................. 20
35. Packing should be different for DG cargo, if yes then how should I get it? ...................... 20
36. Who is the certifying body for packaging? ....................................................................... 20
37. We use 210 litres MS Composite drums for variety of products falling under packing
group I, II & III. Can we apply for a single UN Certification under “X” Category? ........................ 20
38. What will happen if we load the cargo with expired packing certificate?........................ 21
39. What will happen if the packing certificate expire after sailing? ..................................... 21

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 40. What is the procedure to get rejected material back when packing certificate is expired?
21
41. How can we calculate the quantity of hazardous material to be filled in the primary
pack? 21
42. One of our product we export in combination pack i.e. class 2.2 gas filled in disposable
cylinder and the filled cylinder packed in Corrugated box. In this case do we require to have UN
Certificate of package? If yes, then UN certificate require for which pack, inner or outer pack? 21
43. For UN 2794, BATTERIES, WET, FILLED WITH ACID, 2795, BATTERIES, WET, FILLED WITH
ALKALI and 3028, BATTERIES, DRY, CONTAINING POTASSIUM HYDROXIDE, SOLID are the
packagings having specific weight limits....................................................................................... 22
Limited Quantities & Excepted Quantities............................................................................................ 23
49. As per MSDS Section 14 Special precautions for user Limited Quantity shows 5L. When
we dispatch 80 MS Composite Drums of 200 kg each in one container do we need to mention
the words “limited quantity” in DGD as mention in 3.4.6(Documentation)? .............................. 23
50. Is there any segregation rule applicable to dangerous goods in limited quantities? ....... 23
51. What are the segregation rules applicable for dangerous goods in excepted quantities?
24
Marking, Labelling and Placarding ........................................................................................................ 24
52. What type of labels we need to affix on dangerous goods packages? ............................. 24
53. How to determine the quality of labels? .......................................................................... 24
54. As mentioned in 5.3.2.0.2 of IMDG Code, Proper Shipping Name shall be displayed in
contrasting colour with the background. Which background? Is it required to mention Proper
Shipping Name having solid border line? If yes, what should be border size & colour? .............. 25
55. What is the correct size and specification for labels on dangerous goods packages? ..... 25
56. Is it required to mention Technical, Chemical Name of Product, with proper shipping
name display on ISO Tank Container (As per 5.3.2.0.2 of IMDG Code)? If yes, what should be the
size of Technical/Chemical Name? ............................................................................................... 26
57. Are both methods of Example of display of UN numbers on container mentioned in
5.3.2.1.3 of IMDG Code valid globally? ......................................................................................... 26
58. One of our product has hazard class 8 and subsidiary risk 6.1 In that case if we use class
placard having UN No. within it as mentioned in 5.3.2.1.2.1 of IMDG Code should the UN
number be displayed inside class 8 or class 6.1 placard? ............................................................. 26
59. What is the meaning of hazard identification number? As in below image, “33”, our
consignee asked us to mark our tank with hazard identification number 268, what does this
mean? 26
60. We dispatch refrigerant gases class 2.2 in disposable cylinders & ISO Tank container in
that case do we require to affix orientation arrow marking as mentioned in IMDG Code 5.2.1.7?
27
61. What is the correlation between GHS Label & NFPA Labels with IMDG Code? ............... 27
62. Where do I place the technical name on packages when shipping Dangerous Goods? .. 27
Packing of container ............................................................................................................................. 28

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 63. How many dangerous goods packages can be loaded into a single container? ............... 28
64. We manufacture 1950 class 2.1 and 2.2 products that require heat protection for
shipping during winter months. We ship limited quantity against POs that also call for non-DG
items needed heat protect in winter. Can we use reefer container for class 2.1 and 2.2
products? ...................................................................................................................................... 28
65. What is the correct size and specification for placards on dangerous goods containers
and tanks? ..................................................................................................................................... 28
66. Which is the exact place to affix placard on a container? Is it the centre of side, end walls
and doors or towards top end? .................................................................................................... 28
67. What is segregation group? .............................................................................................. 29
68. In FAK consol what are the requirement of segregation between dangerous goods and
non-dangerous goods and dangerous goods and foodstuff? ....................................................... 29
69. What are the changes associated with Column 16b Segregation? .................................. 30
70. Should Shippers provide Segregation Group Name to Carrier? ....................................... 30
71. UN 3089 is assigned to two segregation groups: 7 Heavy metals and their salts (including
their organometallic compounds) & 15 " Powdered metals ". Which group must be considered
as segregation group? ................................................................................................................... 31
72. If we have dangerous goods and non-dangerous goods in same container is there any
special requirement of packing of the container? ........................................................................ 31
73. How to determine the segregation group of a specific cargo? ........................................ 31
74. We are operating a CFS, Container Freight Station, we handle export and import
containers which include stuffing and stripping. Some of the goods are dangerous. Which is the
best way to segregate different dangerous goods in our premises? ........................................... 32
75. What are the segregation requirement for dangerous goods in excepted quantities? ... 33
76. Section 7.2.6 Special segregation provisions and exemptions, overrules segregation
table. While checking segregation requirement how do the packer know when to apply section
7.2.6 of IMDG Code. Is there a full systematic guidance for checking segregation?.................... 33
77. Section 7.2.6.4 of IMDG Code gives exemption from the segregation requirement of
“away from” or “separated from” “acids” or “away from” or “separated from” “alkalis” for
substances falling under class 8, packing group II or III. Does shipper need to provide
documentary evidence to carrier while offering to load under this clause?................................ 34
Tank Container ...................................................................................................................................... 34
78. At what intervals, a portable tank shall be inspected? ..................................................... 34
79. Can we transport a tank beyond the 2.5 or 5 yearly inspection? ..................................... 34
80. Can we transport a tank which is filled half of its volume? .............................................. 35
81. How do we know which type of tank is permitted for a dangerous goods? .................... 35
82. What reason are there for Dangerous Goods tanks not to be offered to load on a ship?
35
83. What will be the residue weight for tank in return uncleaned movement? .................... 36

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 84. Interpreting special provision 274, do we need to display technical name on the exterior
or tank? ......................................................................................................................................... 36
Misdeclared or Undeclared Dangerous Goods ..................................................................................... 36
85. What is Undeclared and Misdeclared Dangerous Goods? ............................................... 36
86. What may happen or must be done in case of misdeclaration? ...................................... 36
Dangerous Goods Declaration .............................................................................................................. 36
87. What are the important parameters in a Dangerous Goods Declaration? ...................... 36
88. If we have same UN Number packed in different types of packages should we declare
separately? .................................................................................................................................... 37
89. Is it valid if we fill Dangerous Goods Declaration form completely in soft copy and then
convert into PDF and forward it to shipping line? If yes, is there any specific criteria to be
followed in submitting soft copy of DGD form? ........................................................................... 38
90. Who is shipper?................................................................................................................. 38
91. Do the signatory need to be certified from anybody to sign the D.G. declarations or
anyone from shipper’s company can sign?................................................................................... 39
92. Why emergency contact number is required? ................................................................. 39
93. As per 49 CFR, emergency response telephone number is not required for dangerous
goods in limited quantities, why this is exempted?...................................................................... 39
94. What are the basic documents required for shipment of Waste shipment? ................... 40
Fire fighting ........................................................................................................................................... 40
95. Water is not allowed as extinguishing media for class 3 in reefer container then what
should be the course of action?.................................................................................................... 40
Carriers’ Policy ...................................................................................................................................... 40
96. Sometimes carrier reject our dangerous goods booking stating not acceptable on vessel.
What reasons are common for a carrier to reject a booking?...................................................... 40
Safety Data Sheets ................................................................................................................................ 41
97. What is the importance of MSDS? .................................................................................... 41
98. If SDS does not mention reference to section 2.10.2.7 of IMDG Code exempting marine
pollutants requirement is it still acceptable to load under such exemption? .............................. 41
99. Is it permitted for SDS of NAPHTHALENE to have two transport classification such as UN
2304 (molten) & UN1334 (Solid)? ................................................................................................. 41
100. What are the differences between GHS and IMDG Code? ............................................... 41
101. Which countries have adapted GHS into their national legislation? ................................ 43

pg. 6
Introduction
Dangerous Goods are those goods which by its inherent nature can cause harm to
humans, animals, property, or environment. Various goods fall into the category of
dangerous goods and pose different nature of hazard while being transported such as
radioactivity, acid burns, explosion, fire, dangerous generation of explosive, corrosive,
toxic, or flammable gases, depletion of oxygen etc.

In response to the sinking of RMS Titanic on 14 April 1912 International Convention for
the Safety of Life at Sea (SOLAS) was passed in 1914. Chapter VII of SOLAS Convention
contains the mandatory provisions governing the carriage of dangerous goods in
packaged form or in solid form in bulk.

Carriage of dangerous goods and marine pollutants in packaged form by sea is regulated
order to reasonably prevent injury to persons or damage to ships and their cargoes and
to prevent harm to the marine environment.

Objective
The objective of the IMDG Code is to enhance the safe carriage of dangerous goods
while facilitating the free unrestricted movement of such goods and prevent pollution to
the environment. IMDG Code attained mandatory status from 1 January 2004. From 1 st
January 2017 IMDG Code amendment 38 (38-16) will run parallel with amendment 37-
14.

Training
Success of the application of IMDG Code for transport of dangerous goods by sea is
greatly depending on the appreciation by all persons concerned in the risks involved and
detailed understanding of the Code. This can only be achieved by properly planned and
maintained initial and retraining programmes.

From 1st January 2010, onwards, it is mandatory that all Shore-based personnel engaged
in transport of dangerous goods by sea be trained in the contents of dangerous goods
provisions commensurate with their responsibilities. It is illegal to preform duties related
to dangerous goods by sea without receiving appropriate training.

Crack the Code

Though IMDG Code has come through various modifications, through the years, thus
becoming increasingly user-friendly, for many users it remains a tough Code to crack.

pg. 7
Regulations

1. Which Regulations govern transport of dangerous goods throughout the world?

a) There are International, Regional and National Regulations for transporting

dangerous goods by Road, Rail, River, Sea and Air, some of which are listed
below:

- IMDG Code (Sea Transport)

- ADR (European Agreement concerning the International Carriage of
Dangerous Goods by Road)
- ADN (European Agreement concerning the International Carriage of
Dangerous Goods by Inland Waterways)
- RID: (The regulations concerning the international carriage of dangerous
goods by rail)
- ICAO/TI (Technical Instructions for The Safe Transport of Dangerous Goods
by Air)
- 49 CFR (Code of Federal Regulations 49, U.S.A)
- TDG Clear Language (Canada)
- ADG (Australia)
- South America (Agreement on the Transport of Dangerous Goods in
MERCOSUR countries)

2. If an import dangerous goods container while on Indian road is caught for

noncompliance by transport authority who will be penalised?

The transporter, and the penalty will finally come to importer whose cargo is being
moved.

3. Does a ship carrying dangerous good in solid Bulk form require to comply with IMDG
code or IMSBC code?

IMDG Code is for dangerous goods in packaged form. IMSBC Code is for solid bulk cargo
including solid dangerous goods in bulk form.

IMSBC Code refers to IMDG Code on various sections, example IMSBC Code Section
9.2.2 Classification of dangerous goods, IMSBC Code Section 9.3.3.1 Segregation
between bulk materials possessing chemical hazards and dangerous goods in packaged
form, Appendix to COAL, Segregation, and stowage requirements, point no. 2.

IMDG Code is a mandatory publication on bulk carriers.

4. If a bulk carrier is loading UN grade Sulphur which sections need to be checked in IMDG
Code by Ship staff?

Partly the answer to question no. 3 answers the cross applications and reference of
IMDG Code on bulk carriers together with IMSBC Code.

pg. 8
Sulphur is listed in IMSBC Code as SULPHUR UN 1350, (lump and coarse grained) with
note Fine grained sulphur (flowers of sulphur) shall not be transported in bulk. There is
no specific requirement of guidance in IMDG Code for carriage of sulphur in bulk.
However, in the case of coal and certain other goods IMSBC Code refers to IMDG Code
for segregation from other solid bulk materials and packaged dangerous goods.

5. Where can I purchase IMDG Code?

IMDG Code can be purchased from distributors of IMO publications, you may find the
details at http://www.imo.org/en/Publications/Distributors/Pages/default.aspx

6. Who all are the parties involved in transporting dangerous goods in multimodal
transport?

There are multiple parties involved in multimodal transport chain which is similar for
both dangerous goods and non-dangerous goods. The parties are:

Carrier

the party who, in a contract of carriage, undertakes to perform or to procure the

performance of carriage by rail, road, sea, inland waterway or by a combination of such
modes can be further classified as:

- road haulier;
- rail operator;
- shipping line.

Consignee

the party to whom a cargo is consigned under a contract of carriage or a transport

document or electronic transport record. Also known as the receiver.

Consignor

the party who prepares a consignment for transport. If the consignor contracts the
transport operation with the carrier, the consignor will undertake the function of the
shipper and may also be known as:

- the shipper (maritime);

- the sender (road transport).

Freight forwarder

the party who organizes shipments for individuals or other companies and may also act
as a carrier. When the freight forwarder is not active as a carrier, it acts only as an
agent, in other words as a third-party (non-asset-based) logistics provider who
dispatches shipments via asset-based carriers and that books or otherwise arranges
space for these shipments.

Packer

pg. 9
the party that places the goods within the CTU; the packer may be contracted either by
the consignor, by the shipper or by the carrier; if the consignor or the shipper packs a
CTU within his own premises, the consignor or the shipper is also the packer.

Shipper

the party named on the bill of lading or waybill as shipper and/or who (or in whose name
or on whose behalf) a contract of carriage has been concluded with a carrier; also known
as the sender.

Intermodal operator

the party who provides a service to transfer and/or stow CTUs. May be subdivided into:

- Maritime terminal operator;

- Rail terminal;
- Inland waterway port.

CTU Operator

The party who owns or operates the CTU and provides empty CTUs to the
consignor/shipper/packer.

7. What is the difference between IMDG Code and 49 CFR?

The provisions in IMDG Code are applicable to all ships to which the International
Convention for the Safety of Life at Sea, 1974 (SOLAS), as amended, applies and which
are carrying dangerous goods as defined in regulation 1 of part A of chapter VII of that
Convention.

49 CFR is applicable for transportation of a hazardous material in commerce within the

jurisdiction of United States of America.

Responsibilities
8. What are the responsibilities of shipper for dangerous goods?

Most of the sections in IMDG Code prescribes the action but does not specifically
point out the party or person who is responsible for that action. The shoulder(s)
which need to bear the responsibilities of actions set out in IMDG Code may vary
according to the individual countries laws. It remains the prerogative of each
government to assign the respective responsibilities.
However, regarding Classification of dangerous goods IMDG Code specifically
states it is the responsibility of shipper or the competent authority where
specified in the IMDG Code.

Further shipper’s declaration in dangerous goods note, quoted below, identifies

certain duties by name.

“I hereby declare that the contents of this consignment are fully and accurately
described below by the Proper Shipping Name, and are classified, packaged,

pg. 10
 marked and labelled/placarded and are in all respects in proper condition
for transport according to the applicable international and national governmental
regulations.”

Training
9. Who needs to be trained in IMDG Code? Is it compulsory?

Since 2010 January 1st training is mandatory for shore side personnel. IMDG
Code, chapter 1.3, section 1.3.1.2 has given an indicative list of category of
people ashore to be trained when involved in transporting dangerous goods by
sea which includes Shore-based personnel such as those who:

- classify dangerous goods and identify Proper Shipping Names of

dangerous goods;
- pack dangerous goods;
- mark, label, or placard dangerous goods;
- load/unload Cargo Transport Units;
- prepare transport documents for dangerous goods;
- 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 in transport;
- enforce or survey or inspect for compliance with applicable rules and
regulations; or
- are otherwise involved in the transport of dangerous goods as determined
by the competent authority

All above category personnel and any others who is involved in transporting dangerous
goods by sea must be trained in;
- General awareness/familiarization training:
- Function-specific training
- Security Training
- Safety training.

10. Is it mentioned anywhere in IMDG Code that each person involved in packing/stuffing
of hazardous container require general as well as periodic training?

Refer previous question and its answer, also refer to section 1.3.1 of IMDG Code which
includes those who Load/unload cargo transport units.

Classification

11. How do I know whether the Goods shipped are dangerous?

a) Dangerous Goods are;

- Those listed by name in IMDG Code, or
- Those meet the classification criteria of IMDG Code, or
- Those identified by Competent Authority as dangerous goods.

pg. 11
 If your goods meet any one or more of the above points, then it is dangerous
goods.
Refer IMDG Code Alphabetical index, chapters 2.0, 2.x & dangerous goods list for
more information.

12. How can we know & decide the applicability of special provisions for our products?

Every special provision assigned to a product need to be referred to check if applicable

for the particular shipment. Some special provisions may not be applicable for a given
case.

Example UN 1869, MAGNESIUM or MAGNESIUM ALLOYS Class 4.1 Special Provisions 59

and 920

SP 59 These substances, when they contain not more than 50% magnesium, are not
subject to the provisions of this Code.

SP 920 Bars, ingots or sticks are not subject to the provisions of this Code.

If your product is containing less than 50% magnesium or consists of bars or ingots or
sticks, then it is not subject to dangerous goods regulations of IMDG Code. If not, then it
has to be shipped under applicable provisions of UN 1869.

13. As per special provision SP277 of UN 1950 the limited quantity value is 120 mL for
receptacles containing toxic substances, why this is not applicable for corrosive sub
risk?
Toxicity is more dangerous than corrosivity

14. What is the criteria for assigning packing group to dangerous goods?

For packing purposes, substances other than those of classes 1, 2, 5.2, 6.2 and 7, and
other than self-reactive substances of class 4.1, are assigned to three packing groups in
accordance with the degree of danger they present:

Packing group I : substances presenting high danger;

Packing group II : substances presenting medium danger; and
Packing group III : substances presenting low danger.

The packing group to which a substance is assigned is indicated in the Dangerous Goods
List in chapter 3.2. Packing group indicate level of danger and assist shipper to select
authorized package as per packing, IBC or tank instructions in dangerous goods list of
IMDG Code chapter 3.2.

The criteria for assigning packing group differ from class to class, below are some
examples;

- Class 3 Flammable liquids – basis flashpoint and initial boiling point

- Class 4.1 Flammable solids – basis burning rate

pg. 12
 - Class 4.3 Substances which, in contact with water, emit flammable gases –
volume of flammable gas produced within a given time
- Class 6.1 Toxic Substances – Dosage required to meet LD50 toxicity
- Class 8 Corrosive substances – exposure and observation time to cause
complete destruction of intact human tissue.

It is the shipper’s responsibility to assign correct packing group either by analogy

or by laboratory test in accordance with UN Manual for Test and Criteria in
conjunction to IMDG Code chapter 2.x

15. What is marine pollutant? How do we identify whether a dangerous goods is marine
pollutant or not?

Many substances, articles and materials falling under classes 1 to 9 have the
potential to cause pollution to marine environment, the index and column 4 of
Dangerous Goods List in IMDG Code indicates these substances, materials and
articles with the symbol “P”. However, the absence of the symbol P or the
presence of a “–” in the column 4 does not preclude the application of
classification criteria of Marine Pollutant when deemed necessary.

A substance, material or article which does not have the property of any classes
from 1 to 8 however having the potential to pollute marine environment must be
transported as Marine Pollutant under the entry: ENVIRONMENTALLY
HAZARDOUS SUBSTANCE, SOLID, N.O.S., UN 3077 or ENVIRONMENTALLY
HAZARDOUS SUBSTANCE, LIQUID, N.O.S., UN 3082, as appropriate, unless there
is a specific entry in class 9.

16. Special provision 965 for carriage of UN 2211 POLYMERIC BEADS, EXPANDABLE & UN
3314 PLASTICS MOULDING COMPOUND has various requirements, which of these must
be met with?

Depending on the package type and type of container the respective provision
must be met with. You may visit below link for breakdown of the requirement of
SP 965 for easy understanding.

http://www.shashikallada.com/special-provision-965-for-plastics-moulding-compound-polymeric-
beads-expandable-2/

17. Are UN Numbers UN 3077 and 3082 always Marine Pollutant? Why there is no letter P
in dangerous goods list identifying these entries as marine pollutant?

If a substance meets the provisions of section 2.9.3, of IMDG Code, then it is a

marine pollutant. If a substance does not meet the provisions of section 2.9.3, of
IMDG Code, but transported under 3077 or 3082 then it is not a marine pollutant.
If a substance is identified as marine pollutant by IMDG Code but no longer meets
the provisions of classification as per section 2.9.3, of IMDG Code, then it can be
transported as non-marine pollutant with the approval of competent authority.

pg. 13
 Basel waste which does not meet any criteria of IMDG Code can also be
transported under UN 3077 or 3082.

18. What possibilities are there for UN 3077 and UN 3082 to be assigned to any
segregation group as per section 7.2.5.4 of IMDG Code?

Nil, because UN 3077 and 3082 are two entries which are listed in the Code for
the purpose of transporting substances and mixtures which are dangerous to the
aquatic environment that do not meet the classification criteria of any other class
or another substance within class 9 and also for wastes not otherwise subject to
the provisions of this Code but which are covered under the Basel Convention on
the Control of Transboundary Movements of Hazardous Wastes and their Disposal
and for substances designated to be environmentally hazardous substances by
the competent authority of the country of origin, transit or destination which do
not meet the criteria for an environmentally hazardous substance according to
the provisions of this Code or for any other hazard class.

If shipper feel UN goods classified by him/her under UN 3077 or 3082 to be

assigned to a segregation group, then according to the properties of the
substance classification may change to another UN Number or class.

19. We have a mixture of chemical having more than one hazard properties and is not
listed by name in IMDG Code. How do we assign proper shipping name, UN Number
and Packing group for this mixture?

Classification of mixtures and solutions having multiple hazards must be in

accordance with section 2.0.3 “Classification of substances, mixtures and
solutions with multiple hazards (precedence of hazard characteristics)” of IMDG
Code. The Proper Shipping Name (see 3.1.2 of IMDG Code) of a substance,
mixture or solution when classified in accordance with 2.0.3.1 and 2.0.3.2 of
IMDG Code must be the most appropriate N.O.S. (“not otherwise specified”) entry
in this Code for the class shown as the primary hazard. The packing groups for
each of the hazards associated with the substance, mixture or solution must be
determined by reference to the appropriate criteria. The most stringent of the
groups so indicated must then become the packing group of the substance,
mixture or solution.

20. Why do carriers ask for correct technical name? What is the requirement of IMDG Code
and why this is required?

Special Provision 274 assigned to Generic and Not Otherwise Specified (N.O.S.)
entries in Model Regulations requires the shipper to supplement the Proper
Shipping Name (PSN) with Technical Name on the Packages (marking) and in
shipping papers (Dangerous Goods Declaration).

What must supplement the proper shipping name and ‘Why’ this is required?

What?

The Generic and N.O.S. entries assigned with SP 274 shall be supplemented with
Technical or Chemical group names shall be a recognized chemical or other name
currently used in scientific and technical handbooks, journals and texts.

pg. 14
Technical names shall be entered in brackets immediately following the Proper
Shipping Name. Modifier, such as “contains” or “containing” or other qualifying
words such as “mixture”, “solution”, etc., and the percentage of the technical
constituent may also be used, Trade names shall not be used for this purpose.

For Pesticides below may be used:

 ISO common name(s),
 other name(s) in the WHO Recommended Classification of Pesticides by
Hazard and Guidelines to Classification
 the name(s) of the active substance(s)

When not required?

When a national law or international convention prohibits disclosing the name of a

controlled substance.

Why Technical name is required?

Below table shows some of the reasons for the requirement of technical names
through special provision 274

pg. 15
Example of technical name: UN 1993 Flammable liquid, n.o.s. (contains xylene and
benzene)

21. We are freight forwarders, shipper offered a liquid as non-dangerous but the flashpoint
is 56 Deg C, carrier rejected and we know from IMDG Code that any liquid with
flashpoint 60 Deg C or below is considered as Class 3 Flammable Liquids, shipper
insisted the cargo as non-dangerous liquid. What are the regulatory aspects for this?

Liquids with a flashpoint of more than 35°C which do not sustain combustion are not
considered as dangerous goods under class 3, flammable liquids. Liquids are considered
to be unable to sustain combustion for the purposes of IMDG Code if:

pg. 16
 1. they have passed the suitable combustibility test (see the Sustained
Combustibility Test prescribed in part III, 32.5.2 of the United Nations Manual of
Tests and Criteria); or
2. their fire point according to ISO 2592:1973 is greater than 100°C; or
3. they are water-miscible solutions with a water content of more than 90%, by
mass.

You may check with your shipper whether his cargo meets above criteria and ask for
proof.

22. Where can we find the list of forbidden chemicals in the IMDG code?

In chapter 3.3, special provisions 349, 350, 351, 352, 353 and 900 list certain
substances which are forbidden for transport.

Further below sections prohibits transport of substances liable to dangerously polymerize

 2.2.4 Gases not accepted for transport

 2.3.5 Flammable Liquid Substances not accepted for transport
 2.6.2.5 Toxic Substances not accepted for transport
 2.8.3 Corrosive Substances not accepted for transport
 For Class 4.1 Polymerizing substances and mixtures refer to section 2.4.2.5 of
IMDG Code

23. Is technical name required to be declared when a generic entry is consigned as marine
Pollutant?

Yes, as per section 3.1.2.9.1 of IMDG Code, it is required, example: UN 1263 PAINT
(triethylbenzene) class 3 PG III (27°C c.c.) MARINE POLLUTANT

24. Why Ammonium permanganate has no UN number but it is prohibited for transport?

No UN Number is assigned because ammonium permanganate is prohibited from

transport. Those goods which are totally forbidden from transport will not be assigned to
any UN Number. In other words, UN Number is assigned to only those goods which are
permitted to be transported under conditions laid down IMDG Code.

25. UN 1910: What does SP 960 by other modes. Does this mean UN 1910 is Non-
hazardous for sea transport?

The question answers itself. Sea transport does not regulate UN 1910. Below are the
entries in IMDG Code which are not regulated for sea transport through SP 960.

pg. 17
 UN NO. CLASS PROPER SHIPPING NAME

1910 8 CALCIUM OXIDE

2807 9 MAGNETIZED MATERIAL

2812 8 SODIUM ALUMINATE, SOLID

3334 9 AVIATION REGULATED LIQUID, N.O.S.

3335 9 AVIATION REGULATED SOLID, N.O.S.

26. Why is the net weight for UNNO 3363 should be in Limited quantity?

UN 3363 is DANGEROUS GOODS IN MACHINERY or DANGEROUS GOODS IN APPARATUS,

Class 9 and as per special provision SP301 This entry only applies to machinery or
apparatus containing dangerous substances as a residue or an integral element of the
machinery or apparatus.

Machinery and apparatus transported under this entry shall only contain dangerous
goods which are authorized to be transported in accordance with the provisions in
chapter 3.4 (Limited quantities).

The quantity of dangerous goods in machinery or apparatus shall not exceed the
quantity specified in column 7a of the Dangerous Goods List for each item of dangerous
goods contained.

In case if the dangerous goods contained in the machinery or apparatus exceeds the
value of column 7a of dangerous goods list then a special approval from competent
authority is required for transport except when special provision 363 applies to engines
or machinery, powered by fuels classified as dangerous goods via internal combustion
systems or fuel cells (e.g. combustion engines, generators, compressors, turbines,
heating units, etc.), except those which are assigned under UN 3166 or UN 3363.

27. What should be the combustible material content for UN 1942?

UN 1942, Class 5.1, Proper Shipping Name: AMMONIUM NITRATE with not more than
0.2% combustible substances, including any organic substance calculated as carbon, to
the exclusion of any other added substance. The proper shipping name underlined above
sets the maximum limit of combustible substances to 0.2%. If the percentage of
combustible substances increases above 0.2% then classification changes to Class 1.1.

pg. 18
 28. For UN 1779, Formic Acid, why the flashpoint varies to different shippers or
consignments?

UN No. 1779 is assigned to FORMIC ACID with more than 85% acid, by mass. Pure
formic acid (100% concentration) flashpoint is 42°C c.c. as the concentration reduces
from 100% flashpoint increases, see below table.

29. I am working in ocean carrier’s dangerous goods department, how to explain to other
shipping partners about the flashpoint criteria of UN 1779 if they are not ready to
accept the cargo when flashpoint declared by shipper is above 60 Deg C.c.c.?

Quote the above table and inform them that proper shipping name of Formic Acid sets
maximum concentration 85% hence decrease in concentration increases flashpoint
however the most appropriate UN Number and proper shipping name for formic acid is
UN 1779 hence acceptable even if flashpoint is above 60 Deg C.c.c. as subsidiary risk
class 3 if it is not reducing the minimum required safety standard of SOLAS Convention.

30. Why only organic peroxides listed in section 2.5.3.2.4 and self-reactive substances
listed in section 2.4.2.3.2.3 of the IMDG code is acceptable?

Self-reactive substances and Organic peroxides listed in sections mentioned in the

question and IBC520 and Tank Instruction T23 is tested and authorized in packagings as
per OP instructions and IBC520 and T23 tank instructions. Any self-reactive substance or
organic peroxide not listed in above sections need competent authority approval for
transport.

31. Can shipper declare batteries which are installed in machinery such as generator under
UN2794 or any other battery UN?

If the batteries are not integral part of the machinery, then it has to be shipped
separately.

32. UN3481 can be shipped as NON-HAZ as per SP188?

UN 3090, UN 3091, UN 3480, and UN 3481, when consigned according to IMDG Code
special provision 188 must not be declared as dangerous goods however must meet all
provisions of SP 188 including marking as per section 5.2.1.10 of IMDG Code.

pg. 19
 33. Can UN 3269 POLYESTER RESIN KIT and UN 3108 ORGANIC PEROXIDE TYPE E, SOLID be
acceptable to load in the same unit as per SP340 of UN 3269?

NO! UN 3269 Polyester resin kits consist of two components: a base material (either
class 3 or class 4.1, packing group II or III) and an activator (organic peroxide). Both
are packed in same package separated by inner packing. The entire kit is classified as
UN 3269.

Special provision 340 is only for authorizing to transport the polyester resin kit as
excepted quantities even though organic peroxides are not individually authorized in
excepted quantities.

34. What is Reportable Quantities in 49 CFR, is this applicable to both export and import
shipments from/to U.S.A?

Appendix A to section 172.101 of 49 CFR is materials and their corresponding reportable quantities
(RQ's) that are listed or designated as "hazardous substances'' under section 101(14) of the
Comprehensive Environmental Response, Compensation, and Liability Act. If we are shipping within
or from or into the USA materials listed in appendix A to 172.101 having quantities exceeding per
package than listed there in, then letters “RQ” must be entered before or after the basic description
of dangerous goods.

Packagings
35. Packing should be different for DG cargo, if yes then how should I get it?

IMDG Code authorizes different types of packagings and quantity limitations for
each dangerous good, differing in packing groups or not, through packing, IBC or
tank instructions. These packagings, IBCs and tanks need to meet the UN
Performance criteria. It is the shipper’s responsibility to identify which type of
packaging is authorized by IMDG Code for his or her cargo and arrange such
packagings from package suppliers.

36. Who is the certifying body for packaging?

Competent authority of a country or a designated body is the authority who tests and certify
packagings for dangerous goods.

37. We use 210 litres MS Composite drums for variety of products falling under packing
group I, II & III. Can we apply for a single UN Certification under “X” Category?

UN Packing Marking X, Y, Z represents for which packing group the package is tested, namely
packing group I, II or III.

pg. 20
You may get a package tested for packing group I (X) and pack other goods of packing groups II and
III in same package provided each of your dangerous goods in packing groups II and II are permitted
in the packing group I certified packaging.

38. What will happen if we load the cargo with expired packing certificate?

Nothing. Certificate issued for UN Performance testing of packaging may have a

validity period for manufacturing the type of packagings certified.
Example a Steel drum certificate issued on 1st January 2016 with validity of 1
year enable manufacturer to manufacture similar drums during this period and
the drums can be used beyond expiry of package certificate. A drum will not
collapse on the night of expiry of package certificate.

39. What will happen if the packing certificate expire after sailing?
Refer answer to previous question.

40. What is the procedure to get rejected material back when packing certificate is
expired?

In case consignee rejects the shipment due to packing certificate expired shipment can
be returned as normal return shipment.

41. How can we calculate the quantity of hazardous material to be filled in the primary
pack?

The maximum quantities permitted in an inner or outer package is listed in the

respective packing instruction of each dangerous goods entry in IMDG Code.

For example, UN 2732, packing instruction is P001, in P001 inner packing limit for glass
bottle is 10l and single packaging for steel, non-removable head (1A1) is 450l and steel,
removable head (1A2) is 250l.

42. One of our product we export in combination pack i.e. class 2.2 gas filled in disposable
cylinder and the filled cylinder packed in Corrugated box. In this case do we require to
have UN Certificate of package? If yes, then UN certificate require for which pack, inner
or outer pack?

Design and construction of Non-refillable gas cylinders must be in accordance with

section 6.2.2.1.1. of IMDG Code / ISO 11118:1999. Non-refillable gas cylinder valves
must meet the design standard of IMDG Code section 6.2.2.3 / ISO 13340:2001. Non-
refillable cylinder must be marked “DO NOT REFILL” in 5 mm size. Such a cylinder does
not require a UN Performance tested corrugated box for transport, shippers may or may
not use corrugated boxes. Cylinder must be certified type.

Let us simplify more, does the packing instruction of gas include corrugated box? No,
then the cylinders in packing instruction for gas must be certified type.

pg. 21
 43. For UN 2794, BATTERIES, WET, FILLED WITH ACID, 2795, BATTERIES, WET, FILLED WITH
ALKALI and 3028, BATTERIES, DRY, CONTAINING POTASSIUM HYDROXIDE, SOLID are the
packagings having specific weight limits.

Packagings are authorized, provided the general provisions of 4.1.1, except 4.1.1.3, and
4.1.3 are met, except that packagings need not conform to the provisions of part 6.
Part 6 relates to the weight limitations which are set for each packaging.

44. For UN 1950 what will be the max capacity for fibreboard boxes in terms of weight?

When fibreboard boxes are used as Rigid outer packagings as in P207 point no.2 then 55
kg max net mass.

45. Any Gas Cylinder containing Residue can be Shipped as non-hazardous?

Empty uncleaned packages must be shipped with all marks, labels, placards and
document however in the case of gas cylinders carrying residual gas of class 2.2 with
pressure less than 200 KPa are not liquefied or refrigerated liquefied gases can be
considered as non-hazardous.

46. What must be the full UN Packing Code for UN 2809 Class 8, Mercury? Shipper’s
declaration mention package as 25 Flasks.

According to packing instruction P800 Steel flasks or bottles with threaded closures with
a capacity not exceeding 3.0 L is acceptable. There is no UN Package code for steel
flasks.

47. For UN 3358 and UN 2857 - REFRIGERATING MACHINES -can we consider net weight
and gross weight same?

The dangerous goods in question is the machine itself hence there is no difference
between gross and net mass.

48. What should be the ideal packaging as per P203 for UN 1963 if going in standard
container?

UN 1963, HELIUM, REFRIGERATED LIQUID when packed according to packing instruction

P203 is to be contained in closed cryogenic receptacles or open cryogenic receptacles
with conditions laid down therein.

pg. 22
Limited Quantities & Excepted Quantities

49. As per MSDS Section 14 Special precautions for user Limited Quantity shows 5L. When
we dispatch 80 MS Composite Drums of 200 kg each in one container do we need to
mention the words “limited quantity” in DGD as mention in 3.4.6(Documentation)?

Limited quantities in column 7a and in dangerous goods list of chapter 3.2 of IMDG Code
is an option for shipper to pack and mark the packages in accordance with chapter 3.4 of
IMDG Code. Column 7a of dangerous goods list the maximum quantity per inner packing
and chapter 3.4 of IMDG Code sets maximum gross mass to 30 kg per outer packaging
and 20 kg for shrink or stretch wrapped packagings. Only the consignment packed
according to column 7a and chapter 3.4 meets the limited quantities requirement and
such a consignment need to mention words “limited quantities” in dangerous goods
declaration.

A drum of 200 kg is a single packaging which does not meet the above requirement of
limited quantities and hence no need to mention words limited quantities for your
shipment. If you mention you will be violating the law and may result in increase of
magnitude of accidents out at sea.

50. Is there any segregation rule applicable to dangerous goods in limited quantities?

A package of dangerous goods consigned as per column 7a and chapter 3.4 of IMDG
Code has no segregation applicable with another package of dangerous goods not in
limited quantities or packed in limited quantities.

However, there are segregation rules for mixed packing of different dangerous goods in
limited quantities within the same outer packaging. These rules are slightly different
from general segregation rules laid out in chapter 7.2 of IMDG Code with exemption as
below.

What is permitted?

Mixed packing of different dangerous goods in limited quantities are permitted within
same outer packaging provided;

1. that the substances do not react dangerously with each other and cause

a) combustion and/or evolution of considerable heat;

b) evolution of flammable, toxic or asphyxiant gases;

c) the formation of corrosive substances; or

d) the formation of unstable substances.

and

2. notwithstanding the individual provisions specified in the Dangerous Goods List,

column 16b, substances in same class in packing group III may be packed
together subject to compliance with point no. 1 above

What is not permitted?

pg. 23
Any two dangerous goods within same class which has specific segregation requirement
between each other and are in Packing groups I or II and those which conflict as per
general segregation rules in chapter 7.2

Any two dangerous goods which may react with each other and result in one or more
dangerous situation as listed in points a to d above

In the case of mixed packing according to point no. 2 a statement reading ‘‘Transport in
accordance with 3.4.4.1.2 of the IMDG Code’’ must be included in the dangerous goods
declaration.

Refer Chapter 3.4 of IMDG Code 37-14 for full details.

51. What are the segregation rules applicable for dangerous goods in excepted quantities?

There is no segregation requirement between dangerous goods packed in Excepted

Quantities with other dangerous goods however if we pack two dangerous goods in
excepted quantities in same packaging then we must ensure that these goods will not
react dangerously with each other and cause:

- 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.

Marking, Labelling and Placarding

52. What type of labels we need to affix on dangerous goods packages?

Dangerous Goods packages must be marked and labelled according to chapters

5.1, 5.2 of IMDG Code. Marking includes, UN Number, Proper Shipping Name,
Technical Name when required, Marine Pollutant mark and Labels are of
hazardous class and subsidiary risks in column 3 and 4 of dangerous goods list in
chapter 3.2 of IMDG Code. Special provisions in column 6 of dangerous goods list
may require additional label or dispense a subsidiary risks label or give exemption
to marking and labeling for certain goods.

53. How to determine the quality of labels?

IMDG Code states the marks and labels shall be such that this information will
still be identifiable on packages surviving at least three months’ immersion in the
sea. There is no ISO standard for above quality but British Standard BS 5609
meets this quality of IMDG Code requirement.

pg. 24
 54. As mentioned in 5.3.2.0.2 of IMDG Code, Proper Shipping Name shall be displayed in
contrasting colour with the background. Which background? Is it required to mention
Proper Shipping Name having solid border line? If yes, what should be border size &
colour?

IMDG Code require tank containers, bulk containers and any other cargo transport unit
containing packaged dangerous goods of a single commodity for which no placard, UN
Number or marine pollutant mark is required to display the Proper Shipping Name for
the goods in characters not less than 65 mm high and the Proper Shipping Name shall be
of contrasting colour with the background.

If the background of printed proper shipping name is orange and the font is also shade
of orange, then it will not be clearly visible hence the contrast required can be black font
on white or orange or any font colour contrasting to the background colour in which it is
printed.

55. What is the correct size and specification for labels on dangerous goods packages?

Specimen labels are published in section 5.2.2.2.2 of IMDG Code and specification
for the size and other aspects of the label is published in section 5.2.2.2 of IMDG
Code.

Labels shall be configured as shown in the figure below

* The class or, for divisions 5.1 and 5.2, the

Division number shall be shown in the bottom
corner

** Additional text/numbers/letters shall (if

mandatory) or may (if optional) be shown in this
bottom half

*** The class or division symbol or, for divisions

1.4, 1.5 and 1.6, the division number and for
Model No 7E the word "FISSILE" shall be shown in
this top half".

Labels shall be displayed on a background of

contrasting colour, or shall have either a dotted or solid outer boundary line.

The label shall be in the form of a square set at an angle of 45° (diamond-shaped).

The minimum dimensions shall be 100 mm x 100 mm and the minimum width of the line
inside the edge forming the diamond shall be 2 mm.

The line inside the edge shall be parallel and 5 mm from the outside of that line to the
edge of the label.

The line inside the edge on the upper half of the label shall be the same colour as the
symbol and the line inside the edge on the lower half of the label shall be the same
colour as the class or division number in the bottom corner.

pg. 25
Where dimensions are not specified, all features shall be in approximate proportion to
those shown.

If the size of the package so requires the dimensions may be reduced, provided the
symbols and other elements of the label remain clearly visible.

The line inside the edge shall remain 5 mm to the edge of the label. The minimum width
of the line inside the edge shall remain 2 mm.

56. Is it required to mention Technical, Chemical Name of Product, with proper shipping
name display on ISO Tank Container (As per 5.3.2.0.2 of IMDG Code)? If yes, what
should be the size of Technical/Chemical Name?

Marking of cargo transport units, section 5.3.2 of IMDG Code, stipulate marking of
Proper Shipping name in section 5.3.2.0 and marking of UN Number in section 5.3.2.1.
There is no requirement of marking of technical name on tank container in these
sections or any other sections of IMDG Code. Hence it is not required to mark the
technical name. If technical names are displayed it must be separated from proper
shipping name, within brackets, and must not cause confusion while reading UN Number
and proper shipping name.

57. Are both methods of Example of display of UN numbers on container mentioned in

5.3.2.1.3 of IMDG Code valid globally?

Yes, IMDG Code is international regulations for carriage of dangerous goods in packaged
form and the method of displaying UN Number either inside the placard or in a separate
orange panel is acceptable throughout the globe.

58. One of our product has hazard class 8 and subsidiary risk 6.1 In that case if we use class
placard having UN No. within it as mentioned in 5.3.2.1.2.1 of IMDG Code should the
UN number be displayed inside class 8 or class 6.1 placard?

For a product having multiple hazards the UN Number when displayed inside the placard it must be
displayed in the class placard not the subsidiary risk placard. Otherwise display UN Number in an
orange panel separately.

59. What is the meaning of hazard identification number? As in below image, “33”, our
consignee asked us to mark our tank with hazard identification number 268, what does
this mean?

pg. 26
In the above image 1088 is the UN Number and 33 is hazard identification number or
HIN. This is in accordance with ADR section 5.3.2.1.

33 means highly flammable liquid (flashpoint below 23 °C)

268 means toxic gas, corrosive

60. We dispatch refrigerant gases class 2.2 in disposable cylinders & ISO Tank container in
that case do we require to affix orientation arrow marking as mentioned in IMDG Code
5.2.1.7?

No, orientation arrows are required only for below packagings, gas cylinders and tank
containers does not require orientation arrows.

- combination packagings having inner packagings containing liquid dangerous

goods;
- single packagings fitted with vents; and
- cryogenic receptacles intended for the transport of refrigerated liquefied gases.

61. What is the correlation between GHS Label & NFPA Labels with IMDG Code?

There is no correlation between GHS, NFPA and IMDG Code labels. IMDG Code labels are
required for transport by sea, GHS labels as per GHS for consumer or end user
awareness. NFPA labels are in accordance with U.S. based National Fire Protection
Association.

62. Where do I place the technical name on packages when shipping Dangerous Goods?

Packages of Dangerous Goods assigned with special provision 274 or 318 in column 6 of
dangerous goods list in chapter 3.2 of IMDG Code shall be marked with technical name
together with UN Number and proper shipping name.

See example marking of drum UN 1993 FLAMMABLE LIQUID N.O.S. (Contains Acetone)

IBCs of more than 450 ℓ capacity and large packagings

shall be marked on two opposing sides.

pg. 27
Packing of container
63. How many dangerous goods packages can be loaded into a single container?

As many packages carrying different dangerous goods which can be packed into a
container is permitted however the consolidation must meet the segregation requirement
of chapter 7.2 of IMDG Code.
In the case of excepted quantities, as per chapter 3.5 of IMDG Code, maximum number
of excepted quantities packages in a container is limited to 1000.

64. We manufacture 1950 class 2.1 and 2.2 products that require heat protection for
shipping during winter months. We ship limited quantity against POs that also call for
non-DG items needed heat protect in winter. Can we use reefer container for class 2.1
and 2.2 products?

Class 2.1 (flammable gases) is not permitted in reefer (live or non-live) container by any
ocean liners. Class 2.2 is permitted.

65. What is the correct size and specification for placards on dangerous goods containers
and tanks?

Specification of Placard is published in IMDG Code section 5.3.1.2.1 and must be as

below

1. be not less than 250 mm by 250 mm, with a

line running 12.5 mm inside the edge and parallel
with it. In the upper half of the placard the line
shall have the same colour as the symbol and in
the lower half it shall have the same colour as the
figure in the bottom corner;

2. correspond to the label for the class of the

dangerous goods in question with respect to
colour and symbol; and

3. display the number of the class or division

(and, for goods in class 1, the compatibility group
letter) of the dangerous goods in question in the
manner prescribed in section 5.2.2.2 of IMDG
Code for the corresponding label, in digits not less than 25 mm high.

66. Which is the exact place to affix placard on a container? Is it the centre of side, end
walls and doors or towards top end?

IMDG Code section 5.3.1.1.4.1 states “A cargo transport unit containing dangerous
goods or residues of dangerous goods shall clearly display placards as follows:
1. a freight container, semi-trailer or portable tank: one on each side and one on
each end of the unit;

pg. 28
 2. a railway wagon: at least on each side;
3. a multiple-compartment tank containing more than one dangerous substance or
their residues: along each side at the positions of the relevant compartments;
and
4. any other cargo transport unit: at least on both sides and on the back of the unit.

Above section of IMDG Code does not specify exact location however, it is prudent to
affix in area between 5 feet from bottom and 1 feet from top. The line of sight area of an
average height human being. Never too close to door end as doors when opened my
block the visibility of placards.
Never stand on the ground and affix placard when container is sitting on a trailer as this
will make the placard to ground end when container is placed on ground.

67. What is segregation group?

Dangerous goods having similar chemical properties are grouped together to correctly
segregate incompatible materials. There are total 18 groups of Segregation in IMDG
Code starting with 1. Acids till 18. Alkalis.

For example, if an entry in dangerous goods list indicates segregation requirement like
to be “away” or “separated from” ‘bromates’ that substance, material or article must be
segregated from all those listed under segregation group “bromates”.

Below are the segregation groups listed in IMDG Code

- acids
- ammonium compounds
- bromates
- chlorates
- chlorites
- cyanides
- heavy metals and their salts (including their organometallic compounds)
- hypochlorites
- lead and its compounds
- liquid halogenated hydrocarbons
- mercury and mercury compounds
- nitrites and their mixtures
- perchlorates
- permanganates
- powdered metals
- peroxides
- azides
- alkalis

Refer section 7.2.5 of IMDG Code for further details.

68. In FAK consol what are the requirement of segregation between dangerous goods and
non-dangerous goods and dangerous goods and foodstuff?

Segregation between dangerous goods and non-dangerous goods and dangerous goods
and foodstuff is laid out IMDG Code provisions listed below.

pg. 29
IMDG Code Section 7.2.5.4 – Segregation between dangerous goods and non-
dangerous goods.
The segregation groups in this Code do not cover substances which fall outside the
classification criteria of this Code. It is recognized that some non-hazardous substances
have similar chemical properties as substances listed in the segregation groups. A
consignor or the person responsible for packing the goods into a cargo transport unit
who does have knowledge of the chemical properties of such non-dangerous goods may
decide to implement the segregation requirements of a related segregation group on a
voluntary basis.

7.3.4.2 Segregation in relation to foodstuffs - Dangerous goods having a primary or

subsidiary risk of classes 2.3, 6.1, 6.2, 7 (with the exception of UN 2908,2909, 2910 and
2911), 8 and dangerous goods having a reference to 7.3.4.2.1 of IMDG Code in column
16b of the Dangerous Goods List shall not be transported together with foodstuffs (see
1.2.1 of IMDG Code) in the same cargo transport unit.

Further section 7.3.4.2.2. permit the following dangerous goods may be transported with
foodstuffs provided that they are not loaded within 3 m from foodstuffs:
 dangerous goods of packing group III of classes 6.1 and 8;
 dangerous goods of packing group II of class 8; and
 any other dangerous goods of packing group III with a subsidiary risk of classes
6.1 or 8; and
 dangerous goods having a reference to 7.3.4.2.2 in column 16b of the Dangerous
Goods List.

69. What are the changes associated with Column 16b Segregation?

37th amendment of IMDG Code replaced the column 16, Stowage and Segregation with
Column 16a and 16b.

16a contains stowage categories, stowage codes and handling codes.

16b contains segregation codes.

Stowage and handling codes are listed with meanings in sections 7.1.5 Stowage codes
and 7.1.6 Handling codes.

Segregation Codes with meaning is listed in section 7.2.8 Segregation codes.

This is done for consistency in the rules and ease during changes or additions to the
dangerous goods list in future.

70. Should Shippers provide Segregation Group Name to Carrier?

Shipper need not provide segregation group names for single entries & specific N.O.S.
entries already listed under segregation groups in section 3.1.4.4 of IMDG Code.

Carrier may ask segregation group name for goods declared under general N.O.S.
entries which are not assigned to any segregation group in IMDG Code.

pg. 30
If shipper assign a segregation group for goods declared under general N.O.S. entry
which is not assigned to segregation group in IMDG Code, then it is shipper’s
responsibility to mentioned the group name in transport document in accordance with
section 5.4.1.5.11.1 of IMDG Code.

Example: “UN 1760 CORROSIVE LIQUID, N.O.S. (Phosphoric acid, acetic acid) 8 III
IMDG Code segregation group 1 – Acids”

71. UN 3089 is assigned to two segregation groups: 7 Heavy metals and their salts
(including their organometallic compounds) & 15 " Powdered metals ". Which group
must be considered as segregation group?

If a UN Number is assigned with more than 1 segregation group then all of the
segregation group provisions must be taken in to consideration.

Taking example of UN 3089 in question, any UN number intended to be loaded in same

container with UN 3089 for which below SG codes assigned must not be loaded;

SG30 Stow "away from" heavy metals and their salts

SG33 Stow "away from" powdered metals
SG61 Stow "separated from" powdered metals

72. If we have dangerous goods and non-dangerous goods in same container is there any
special requirement of packing of the container?

If dangerous goods packages and non-dangerous goods packages are being loaded into
same container dangerous goods packages should be, when possible, loaded towards the
door end. This is for easy access during emergency response. It is recognized that some
non-hazardous substances have similar chemical properties as substances listed in the
segregation groups. A consignor or the person responsible for packing the goods into a
cargo transport unit who does have knowledge of the chemical properties of such non-
dangerous goods may decide to implement the segregation requirements of a related
segregation group on a voluntary basis.

73. How to determine the segregation group of a specific cargo?

UN Numbers of the named substances and specific N.O.S. entries which are falling under
similar chemical families are already assigned to 1 or more of the segregation groups 1
to 18, see section 7.2.5 of IMDG Code. Goods shipped under N.O.S. entries not assigned
to a segregation group must be assigned to appropriate segregation group by shipper if
he/she knows the properties of the chemical demands such an assignment. See section
7.2.5.3 of IMDG Code.

pg. 31
 74. We are operating a CFS, Container Freight Station, we handle export and import
containers which include stuffing and stripping. Some of the goods are dangerous.
Which is the best way to segregate different dangerous goods in our premises?

At a CFS or port you can follow the segregation rules of IMDG Code for packages and
containers as stipulated in Chapter 7.1 General stowage provisions, Chapter 7.2 General
segregation provisions and Chapter 7.4 Stowage and segregation on containerships. But
this may cause constrains in space utility as these stowage and segregation rules are
very stringent keeping in view of sailing in high seas. The best method is to follow IMO’s
recommendation for port areas handling dangerous goods. Under which you may follow
below rules for segregating dangerous goods packages and containers.

Segregation Table

Class 1, Explosives, Class 6.2 Infectious Substances and Class 7 Radioactive materials
must be handled as direct delivery, no storage in your facility. In case storage is
required appropriate risk evaluation should be done prior taking custody of the cargo.

Packages stored in yard

0 = No segregation needed unless required by the individual substance Over stowing of

packages not allowed unless same class and no segregation required by individual
substances
A = Away from: minimum 3 meters separation required. Over stowing of packages not
allowed
S = Separated from – Open areas: 6 meters Sheds: 12 meters unless separated by fire
walls Over stowing of packages not allowed
Containers in yard

0 = No segregation needed
A = Away from: minimum 3 meters separation required
S = Separated from – Open areas: longitudinally and laterally minimum 6 meters

Over stowing of containers not allowed unless same class and no segregation required
by individual Substances (refer column 16b of IMDG Code chapter 3.2)

3M = Width of standard container.

Secondary Hazard = If applicable then same shall be taken into consideration where it

pg. 32
 is more stringent.
Consolidated boxes = Containers having dangerous goods of more than one class – most
stringent requirement shall be applied.

Over stacking = Only containers belonging to same class may be over stacked,
however, some of the class 8 substances shall not be over
stacked.

Generally, over stacking shall be avoided; preferably containers shall be so stacked that doors and
sides are accessible.

Toxic = Containers carrying toxic substances shall be separated from those

carrying animal feed or foodstuffs.

75. What are the segregation requirement for dangerous goods in excepted quantities?

Segregation provisions for dangerous goods in excepted quantities are laid down in
sections 3.5.8.1 and 3.5.8.2 of IMDG Code.

Section 3.5.8.1 deals with segregation between two or more packages of dangerous
goods in excepted quantities or other packages containing dangerous goods, which has
no segregation reqrueiments.

Section 3.5.8.2 deals with segregation of different dangerous goods within the same
outer packaging which again does not have any segregation requirement provided that
the different dangerous goods in inner packings does not dangerously react with each
other and cause

a) combustion and/or evolution of considerable heat;

b) evolution of flammable, toxic or asphyxiant gases;
c) the formation of corrosive substances; or
d) the formation of unstable substances.

76. Section 7.2.6 Special segregation provisions and exemptions, overrules segregation
table. While checking segregation requirement how do the packer know when to apply
section 7.2.6 of IMDG Code. Is there a full systematic guidance for checking
segregation?

Segregation table is the general provisions for segregation between different classes of
dangerous goods. Since the properties of substances, materials or articles within each
class may vary greatly, the Dangerous Goods List shall always be consulted for particular
provisions for segregation as, in the case of conflicting provisions, these take precedence
over the general provisions. Segregation shall also take account of a single subsidiary
risk label.

Specific requirement of segregation is dealt with SG codes assigned in column 16b of

dangerous goods list in chapter 3.2 of IMDG Code.

As a guidance IMDG Code as published a flow chart and examples on how to check
segregation between different dangerous goods packages.

pg. 33
See segregation flow chart in annex in chapter 7.2. However, this flow chart is not
mandatory since it is too cumbersome to prepare a flowchart or step by step guidance to
check segregation between all goods.

Packer of the container or the person responsible deciding which packages to be loaded
in same container need to be trained in depth on segregation provisions to carry out
his/her duties.

77. Section 7.2.6.4 of IMDG Code gives exemption from the segregation requirement of
“away from” or “separated from” “acids” or “away from” or “separated from” “alkalis”
for substances falling under class 8, packing group II or III. Does shipper need to provide
documentary evidence to carrier while offering to load under this clause?

Point no. 4 of section 7.2.6.4 demands producing copy of test report when asked by
competent authority. Hence it is prudent for the carrier to ascertain the availability of
same prior loading.

Tank Container

78. At what intervals, a portable tank shall be inspected?

Every portable tank must be subject to below inspections

- Initial inspection
- 2.5-year inspection, and
- 5-year inspection

79. Can we transport a tank beyond the 2.5 or 5 yearly inspection?

A portable tank may not be filled and offered for transport after the date of expiry of the
last 5-year or 2.5-year periodic inspection and test as required by 6.7.2.19.2. However,
a portable tank filled prior to the date of expiry of the last periodic inspection and test
may be transported for a period not to exceed three months beyond the date of expiry of
the last periodic test or inspection. In addition, a portable tank may be transported after
the date of expiry of the last periodic test and inspection:

1. after emptying but before cleaning, for purposes of performing the next required
test or inspection prior to refilling; and
2. unless otherwise approved by the competent authority, for a period not to
exceed six months beyond the date of expiry of the last periodic test or
inspection, in order to allow the return of dangerous goods for proper disposal or
recycling. Reference to this exemption shall be mentioned in the transport
document.

pg. 34
 80. Can we transport a tank which is filled half of its volume?

For liquid cargo, the rule is either the tank is filled above 80% or below 20%, this is to
avoid dangerous surge of cargo jeopardizing the safety of vehicle. This rule is applicable
only to tanks having a volume of 7,500 litres or more.

Portable tanks shall not be offered for transport with a degree of filling, for liquids having
a viscosity less than 2,680 mm2/s at 20°C or at the maximum temperature of the
substance during transport in the case of a heated substance, of more than 20% but less
than 80% unless the shells of portable tanks are divided, by partitions or surge plates,
into sections of not more than 7,500 ℓ capacity;

81. How do we know which type of tank is permitted for a dangerous goods?

For each entry, UN No., IMDG Code Dangerous Goods List column 13 indicates with a T
code whether the substance or material can be carried in tanks by type of tank. If there
is no T code in column 13, substance or material shall not be carried in tank unless
specifically approved by competent authority. Column 14 of IMDG Code Dangerous
Goods List contains TP notes applicable to portable tanks.

Example T code and permitted other types of tanks

UN 2282 is assigned with T code T2, which means this substance shall be accepted in a
tank meeting the requirements of T2.

However as per table 4.2.5.2.5, Tank type T4, T5 and T7 to T22 are also permitted to
carry UN 2282

82. What reason are there for Dangerous Goods tanks not to be offered to load on a ship?

Portable tanks shall not be offered for transport:

1. with a degree of filling, for liquids having a viscosity less than 2,680 mm2/s at 20
°C or at the maximum temperature of the substance during transport in the case
of a heated substance, of more than 20% but less than 80% unless the shells of
portable tanks are divided, by partitions or surge plates, into sections of not more
than 7,500 L capacity;
2. with residue of substances previously transported adhering to the outside of the
shell or service equipment;
3. when leaking or damaged to such an extent that the integrity of the portable tank
or its lifting or securing arrangements may be affected; and
4. unless the service equipment has been examined and found to be in good
working order.

And can be more reasons, refer individual entry of dangerous goods to be offered in tank
and applicable provisions for compliance.

pg. 35
 83. What will be the residue weight for tank in return uncleaned movement?

When shipped as empty uncleaned the mass of the cargo need not be declared, refer
section 5.4.1.5.1 of IMDG Code.

84. Interpreting special provision 274, do we need to display technical name on the
exterior or tank?

No. Under section 5.3.2.0.1.1 of IMDG Code proper shipping name of the contents shall
be durably marked on at least both sides tank container together with UN Number as
mentioned in section 5.3.2.1.1.1.

Misdeclared or Undeclared Dangerous Goods

85. What is Undeclared and Misdeclared Dangerous Goods?

Undeclared dangerous goods mean any goods which are listed in the IMDG Code by
name or meeting the classification criteria of the IMDG Code but not declared by the
shipper as dangerous goods.

Misdeclared dangerous goods means any dangerous goods not declared correctly as per
the requirement of IMDG Code. Which may include incorrect or misleading description of
dangerous goods in dangerous goods declaration, misleading Marking, Labeling and
placarding.

86. What may happen or must be done in case of misdeclaration?

When a shipper realizes after loading of the container that the said unit contain
one or more dangerous goods which is not previously declared correctly or
misdeclared to the carrier then it becomes shipper’s immediate responsibility to
inform the carrier full details of such misdeclared or undeclared dangerous goods.
When dangerous goods are not declared or misdeclared the unit may be stowed
on board ship next to other containers conflicting the segregation requirement or
wrongly stowed next to living quarters or near to sources of heat or ignition which
can result in catastrophic accidents on board ships.

Dangerous Goods Declaration

87. What are the important parameters in a Dangerous Goods Declaration?

a) The most important information in Dangerous Goods Declaration is ‘Dangerous

goods description’ which consist of;
- The UN Number preceded by the letters “UN”;
- The Proper Shipping Name

pg. 36
 - The primary hazard class
- Subsidiary hazard class, when assigned
- Packing Group, when assigned

Examples of dangerous goods descriptions:

o UN 1098 ALLYL ALCOHOL 6.1 (3) I (21°C c.c.)

o UN 1098, ALLYL ALCOHOL, class 6.1, (class 3), PG I, (21°C c.c.)
o UN 1092, Acrolein, stabilized, class 6.1 (3), PG I, (–24°C c.c.) MARINE
POLLUTANT/ENVIRONMENTALLY HAZARDOUS
o UN 2761, Organochlorine pesticide, solid, toxic, (Aldrin 19%), class 6.1,
PG III, MARINE POLLUTANT

Apart from above, proper shipping name may require information to be

supplemented such as, Technical Names, Empty Uncleaned Packagings, Waste,
Elevated Temperature information, Marine Pollutants, Flashpoint.

The next information consists of total quantity and packagings, limited or

excepted quantities and temperature control details.
For full information refer to chapter 5.4 of IMDG Code.

88. If we have same UN Number packed in different types of packages should we declare
separately?

Section 5.4.1.5.1 of IMDG Code stipulates the way total quantities of dangerous
goods to be declared in document which says ‘the total quantity of dangerous
goods covered by the description (by volume or mass as appropriate) of each
item of dangerous goods bearing a different Proper Shipping Name, UN Number
or packing group shall be included…... For class 1 dangerous goods, the quantity
shall be the net explosive mass. The number and kind (e.g. drum, box, etc.) of
packages shall also be indicated’.

If the dangerous goods description does not have any difference, then only
package difference can be listed.

Example – difference in packaging type only

UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums
100 50 litres jerry cans

If the dangerous goods description differs then separate declaration is required.

Example – difference in packing group and flashpoint

UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums

UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG II (-24 Deg C.c.c.)

100 50 litres jerry cans

Example – difference in Technical name

UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums

pg. 37
 UN 1993 FLAMMABLE LIQUID N.O.S (XYZ) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums

89. Is it valid if we fill Dangerous Goods Declaration form completely in soft copy and then
convert into PDF and forward it to shipping line? If yes, is there any specific criteria to
be followed in submitting soft copy of DGD form?

Electronic declaration of dangerous goods is permitted by IMDG Code. This can be in PDF
or any other format such as .JPEG or .TIFF etc. In this case signature of shipper and
packer can be done by digital signature or replaced by name of the signatory shown in
capital letters.

After submitting original dangerous goods declaration electronically if carrier ask for hard
copy then the hard copy must contain the words “Original received electronically”.

Refer section 5.4.1.6 of IMDG Code.

90. Who is shipper?

tThe definition in IMDG Code says “Shipper, for the purpose of this Code, has the same
meaning as consignor.” and “Consignor means any person, organization or Government
which prepares a consignment for transport”

The shipper is the shipper mentioned in bill of lading. This is the same shipper who offer
to load to first carrier in multimodal transport chain. When shipper sign in box no. 22 of
MDGF (Multimodal Dangerous Goods Form) s(h)he abides by the applicable international
and national governmental regulations which also includes individual countries road, rail
or river regulations when applicable.

A Shipper is a person, company or entity that is shown in all the shipping documents (bill
of lading, commercial invoice, packing list) as the party responsible for procuring and/or
placing the order for shipment and maybe also for arranging the freight payment etc.

Shipper shown on the bill of lading need not necessarily be a registered exporter (there
is a difference between shipper and exporter) and may or may not be the seller of the
goods. A Freight Forwarder can also be shown as the shipper on a lines bill of lading.

The shipper is responsible for all the declarations made for the shipment whether it is
cargo info on the bill of lading, hazardous info on the dangerous goods declaration or the
VGM information on the VGM declaration.

IMO defines Shipper as the legal entity or person named on the bill of lading or sea
waybill or equivalent multimodal transport document (e.g. “through” bill of lading) as
shipper and/or who (or in whose name or on whose behalf) a contract of carriage has
been concluded with a shipping company (see paragraph 2.1.12 of the Guidelines
regarding the verified gross mass of a container carrying cargo (MSC.1/Circ.1475)).

pg. 38
 91. Do the signatory need to be certified from anybody to sign the D.G. declarations or
anyone from shipper’s company can sign?

As per IMDG Code chapter 5.4 it is the shipper who must sign the dangerous goods
declaration and shipper must receive training as per chapter 1.3 of IMDG Code. An
untrained shipper signing dangerous goods declaration may result in civil/criminal
penalties if the shipment meets an accident or the entire claim may be written off.
Regarding being certified, it depends on country to country. Certain countries have
authorized training schools who are only legally approved to deliver training and
certification. As per IMDG Code only training and record of training is mandatory, this is
to show the proof of training if an audit takes place.

92. Why emergency contact number is required?

IMDG Code does not ask for emergency contact name or number however certain
countries’ national law asks same. Example, USA, Canada. Emergency response
telephone number must be 24 hours answering number and the person who
answer the call must have sufficient knowledge about the goods to advise initial
emergency response in case of spillage, fire or first aid.

93. As per 49 CFR, emergency response telephone number is not required for dangerous
goods in limited quantities, why this is exempted?

According to section 172.604(d) of 49 CFR, below listed dangerous goods need

not have an emergency response telephone number in shipper papers (because
they do not pose high hazard in an event which may require manufacturer’s
advice to deal with)

 Hazardous materials that are offered for transportation under the provisions
applicable to limited quantities; or
 Materials properly described under the following shipping names:
 Battery powered equipment.
 Battery powered vehicle.
 Carbon dioxide, solid.
 Castor bean.
 Castor flake.
 Castor meal.
 Castor pomace.
 Consumer commodity.
 Dry ice.
 Engines, internal combustion.
 Fish meal, stabilized.
 Fish scrap, stabilized.
 Krill Meal, PG III.
 Refrigerating machine.
 Vehicle, flammable gas powered.
 Vehicle, flammable liquid powered.
 Wheelchair, electric.
o Transportation vehicles or freight containers containing lading that has
been fumigated and displaying the FUMIGANT marking (see §172.302(g))

pg. 39
 as required by §173.9 of this subchapter, unless other hazardous
materials are present in the cargo transport unit.

94. What are the basic documents required for shipment of Waste shipment?

In addition to the transport document required in chapter 5.4, all transboundary

movements of wastes shall be accompanied by a waste movement document from the
point at which a transboundary movement commences to the point of disposal. This
document shall be available at all times to the competent authorities and to all persons
involved in the management of waste transport operations.

Fire fighting
95. Water is not allowed as extinguishing media for class 3 in reefer container then what
should be the course of action?

Firefighting must be in accordance with Fire schedule listed in column 15 of dangerous

goods list and EmS published in supplement of IMDG Code.

Carriers’ Policy

96. Sometimes carrier reject our dangerous goods booking stating not acceptable on
vessel. What reasons are common for a carrier to reject a booking?

There can be multiple reasons for rejection of dangerous goods shipment in multimodal
transport as each carrier may have different policy on said goods and the way ports may
have differing port rules. Some of the common reasons for carrier to reject a dangerous
goods booking is listed below.

- Goods involved are prohibited by the line’s in-house rules

- Goods involved are prohibited by Vessel owner / VSA
- Transit port prohibition
- Transhipment port prohibition
- Discharge port prohibition
- Quantity limit of transit port increase if this shipment is accepted
- Quantity limit of transhipment port increase if this shipment is accepted
- Quantity limit of discharge port increase if this shipment is accepted
- Direct delivery confirmation needed from consignee
- Import/Export permit required (UN Drug Control or CWC requirement)
- Special documents such as analysis report or competent authority report
needed
- Technical name missing or not matching the proper shipping name
- Insufficient or non-appropriate packing details
- Segregation needed with other goods in same container

pg. 40
 - Reefer temperature not as per regulations for said dangerous goods
- Flashpoint and Packing Group not matching
- Flashpoint variation from pure substance is too large
- Information in dangerous goods declaration not matching the details
submitted in booking
- Segregation or stowage restriction on vessel
- Draft constrains at a port when loading DG on deck

Above is not an exhaustive list. There can be other reasons also; it is always prudent to
place the booking well advance of cut-off to avoid last minute rejection.

Safety Data Sheets

97. What is the importance of MSDS?

MSDS is now called SDS, Safety Data Sheet. SDS is required by law to inform the
audience the hazards of a substance or a mixture and provide information on the safe
storage, handling and disposal of the substance or a mixture. SDS contains information
on the potential health effects of exposure and how to work safely with the substance or
mixture. It also contains hazard information derived from physicochemical properties or
environmental effects, on the use, storage, handling and emergency response measures
related to that substance or mixture.

SDS is important and required to the end user not the carrier. IMDG Code does not ask
for SDS except as an optional document for emergency response.

98. If SDS does not mention reference to section 2.10.2.7 of IMDG Code exempting marine
pollutants requirement is it still acceptable to load under such exemption?

Yes, any marine pollutant which is packed according to 2.10.2.7 of IMDG Code does not
need to meet the requirement of the provisions related to marine pollutant. This need
not be mentioned in SDS as the requirement of SDS carrying this exemption is not
demanded by IMDG Code.

99. Is it permitted for SDS of NAPHTHALENE to have two transport classification such as UN
2304 (molten) & UN1334 (Solid)?

Yes, the safety issues related to product is already addressed, changes in transport
classification of solid and molten under different UN Numbers does not contradict other
information as required by SDS.

100. What are the differences between GHS and IMDG Code?

GHS and IMDG Code are entirely different. The purpose itself makes each to differ
from other. The origin of Globally Harmonized System of Classification and
Labelling of Chemicals (GHS) is from Rio Conference of in 1992 by coordinated
work with International Labour Organization (ILO), the Organization for Economic

pg. 41
 Co-operation and Development (OECD), various governments and other
stakeholders to align and harmonize the criteria for classification and standard for
labelling of dangerous goods and hazardous substances. 1st edition of GHS
(Purple Book), was published in 2005, the latest edition is Revision 6 published in
the year 2015.

Transport regulations are harmonized with GHS standard for classification of

dangerous goods. Latest Transport Regulations such as ADR 2017 & IMDG Code
2016 is aligned with GHS Revision 6 published in the year 2015.

IMDG Code
38-16

GHS Rev.6 UN Model Regulations ICAO – TI

Rev.19 2017/18

ADR/AND/RID
2017

Transport Regulations Classifies Dangerous Goods into 9 Classes and

Environmentally hazardous substances. Some of these classes are subdivided into
divisions. GHS identifies substances, materials and articles into three groups,
Physical Hazard, Health Hazard and Environmental Hazards.

Transport regulations, like IMDG Code, consider hazard only during transport. Not
doing storage or end use.

GHS does not cover following Hazards

- Infectious Substances;
- Radioactive Materials;
- Other dangerous substances (such as: elevated temperature substances,
genetically modified microorganism, lithium batteries, etc.).
-

Transport Regulations does not cover following hazards

- Eye damage/eye irritation

- Respiratory or skin sensitization,
- Germ cell mutagenicity
- Carcinogenicity
- Reproductive toxicity
- Hazardous to the ozone layer

pg. 42
 Communication in Transport Regulations & GHS

101. Which countries have adapted GHS into their national legislation?

In the below link you may find the status of implementation of GHS in various
countries in alphabetical order
https://www.unece.org/trans/danger/publi/ghs/implementation_e.html

pg. 43