Poor knowledge of IMDG Code ...." I think, I know" attitude!

POOR KNOWLEDGE OF IMDG CODE…. “I THINK, I KNOW” ATTITUDE !

Capt Zarir Irani MICS , MBA MNI, MIIMS (Regional Director- Middle East)

Master Mariner, DipMarSur(MI).

This is how I plan to take away 2 precious hours of your lives.

Some of you may enjoy this time, some might get educated, but surely none will get bored...... I promise to keep you awake.

• The objective of the International Maritime Dangerous Goods (IMDG) Code.

• HOW IS IMDG CODE MANDATORY ? WHY is IMDG CODE TRAINING MANDATORY FOR THE SHORE SIDE STAFF ?

• The Amendment Cycle of the IMDG Code

• Common Documentation Violations in our region

• DISECTING THE MULTIMODAL DANGEROUS GOODS FORM

• Layout of the IMDG Code

• IMDG Code Classification System

• Identification of Dangerous Goods

• MOST PRACTICAL SOLUTIONS TO EVERY DAY HIC-UPS RELATING TO DG CARGO !





Objectives of the Code….

• The objective of the International Maritime Dangerous Goods (IMDG) Code is to:

• Enhance the safe transport of dangerous goods

• Protect the marine environment

• Facilitate the free unrestricted movement of dangerous

goods



HOW IS I.M.D.G. MANDATORY ? The International Maritime Organization (IMO) has developed two international conventions to address

these issues:

•The SOLAS Convention (covering safety of life at sea)

•The MARPOL Convention (covering pollution prevention)

To supplement the principles laid down in the SOLAS and

MARPOL Conventions, the IMO developed the International

Maritime Dangerous Goods (IMDG) Code.

The IMDG code contains detailed technical specifications to

enable dangerous goods to be transported safely by sea.

The IMDG Code became mandatory for adoption by SOLAS

signatory states from 1st January 2004. UAE is a signatory.



What are you doing here ?

• In the 2002 edition of the IMDG Code, training was introduced for the

first time.

• The IMO Member Governments recognised that the safe transport of

dangerous goods by sea is dependent upon the appreciation, by all

persons involved, of the risks involved and on a detailed

understanding of the IMDG Code requirements.

• The training requirements became mandatory with

Amendment 34-08.

Did u miss the word “Mandatory” ??





Updating the IMDG Code. Consulting old editions of IMDG is like

Consuming expired medication -OR- injecting your company and clients with used syringes.

• Each version of the Code is given an Amendment

• number to signify how many times it has been updated. This number

appears at the bottom of each page together with the year of the

Amendment.

• The current Amendment is 34-08 which will remain in force until

December 31st 2011.

• However, from 1st January 2011 Amendment 35-10 can also be used

because 2011 is a transition year which allows the use of both

Amendments in tandem.

• Let’s look at this Amendment process further.



The Amendment Cycle of the IMDG Code

• Each Amendment is valid for up to three years.

• There are alternating years for implementation.

• In January of the yellow years, a new Amendment is

published and can be used immediately, subject to the

timing of National Competent Authority adoption.

• During the yellow years, the preceding Amendment can also

be used, so it is a transition year.

• In the green years, only the current Amendment may be

used. Capt Zarir Irani MICS , MBA

MNI, MIIMS (Regional Director- Middle East) Master Mariner, DipMarSur(MI).

MANDATORY IMDG CODE TRAINING FOR THE SHORE SIDE STAFF

• CIRCULAR: EHS/PM/04/10

• Dated: 28th February 2010

• To: Port Operators, Port Users, Freight Forwarders, Clearing & Forwarding, Shipping, Survey Companies & Hazmat Handlers/Contractors

• Further to our earlier circular EHS/PM/04/09 dated 1st April 2009, please be informed that as per the mandatory requirements of IMDG Code 2008 Volume 1, Part 1, Chapter 1.3.1: Training of shore side personnel, which is already in force from 01st January 2010, all shore side personnel involved with the transportation of dangerous goods by sea are to receive training in the contents of dangerous goods provisions commensurate with their responsibilities. Training requirements specific to security of dangerous goods shall also be addressed in accordance with its requirements. Shore based personnel engaged in the following activities are required to undergo the mandatory IMDG Code training.

• 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 transport 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



Publication of New IMDG Code- 2010 Edition & EHS Requirements

• CIRCULAR: EHS/PM/01/11 • Dated: 15th February 2011 • To: All Shipping Lines, Shipping Agents, Ship Owners, Vessel Operators,

Shippers and Other Interested Parties • The new edition (2010) of the IMDG Code has been published by the

International Maritime Organization (IMO) incorporating Amendment 35-10 which was adopted by the Maritime Safety Committee (MSC) in May 2010.The new amendments to the Code are mandatory from 01st January 2012.

• There are many detailed changes to the Dangerous Goods List and to the most of the Chapters. Below are some of the significant additions and changes:

• There are 16 new UN numbers going up to 3496, with explosives going up to 0509.

• No UN Numbers were deleted



A show of hands ? These training requirements highlight the need for all shore-based

personnel involved in the shipment of dangerous goods to receive

training commensurate with their responsibilities. The IMDG Code

defines shore-based personnel as those who:

• classify dangerous goods and identify PSNs

• pack dangerous goods

• mark, label or placard dangerous goods

• load/ unload CTUS

• 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, survey or inspect for compliance with applicable rules

and regulations Capt Zarir Irani MICS , MBA MNI, MIIMS (Regional Director- Middle East)


10 Most Common Documentation Violations with DG Shipments

Did you know that 10 out of the top 19 violations that the Department of Transportation finds with Dangerous Goods shipments relate to DG

Documentation?

How certain are you that your DG Documentation is in full

compliance with the various regulatory requirements?

The 10 most common Documentation violations based on DOT statistics are as follows:

1. Failing to enter the proper description of the hazardous material

2. Failing to make or sign a "shipper’s certification/DG declaration" on

the shipping document

3. Failing to identify properly hazardous materials on a shipping paper that also contains non hazardous material entries Capt Zarir Irani MICS , MBA


4. Failing to enter the basic description of the hazardous material in the proper sequence 5. Failing to list the emergency response number for an individual who assumes responsibility for said function 6. Failing to enter the technical name in association with the proper shipping description 7. Failing to enter the total quantity of hazardous material on the shipping paper 8. Offering hazardous material without preparing a shipping paper 9. Failing to include the words "limited quantity" (or "LTD QTY") as required, improper package marking 10. Failing to enter the packing group on the shipping paper ……NOW LETS SEEK SOME ANSWERS. Capt Zarir Irani MICS , MBA


An example of a ships DOC supplements



Layout of the IMDG Code IMDG implementation is best suited to academically inclined team players.

It is known that MANAGERS are not good nor proficient with IMDG or its implementation.

The Code comprises 7 parts.

It is presented in two books; Volume 1 and Volume 2.

It is necessary to use both books to obtain the required

information when shipping dangerous goods by sea.

The Code also contains a Supplement.



Layout of the IMDG Code

Volume 1 (Parts 1-2 & 4-7 of the Code) comprises:

Part 1 General provisions, definitions and training

Part 2 Classification

Part 4 Packing and tank provisions

Part 5 Consignment procedures

Part 6 Provisions for the construction and testing of pressure

receptacles, aerosol dispensers, small receptacles

containing gas (gas cartridges) and fuel cell

cartridges containing liquefied flammable gas

Part 7 Requirements concerning transport operations



Layout of the IMDG Code

Volume 2 (Part 3 and the Appendices of the Code)

comprises: Part 3 Dangerous Goods List (DGL), Special

Provisions Limited and Excepted Quantities

Exceptions

Appendix A List of Generic and N.O.S. (Not Otherwise

Specified) Proper Shipping Names

Appendix B Glossary of terms

Alphabetical Index





Layout of the IMDG Code Supplement

The supplement contains the following texts related to

the Code:

• Emergency Response Procedures for Ships Carrying

Dangerous Goods

• Medical First Aid Guide

• Reporting Procedures

• IMO/ILO/ECE Guidelines for Packing Cargo Transport

Units

• Safe Use of Pesticides in Ships, Cargo Holds and CTUs

• International Code for the Carriage of Packaged

Irradiated Nuclear Fuel, Plutonium and High-Level

Radioactive Wastes on Board Ships Capt Zarir Irani MICS , MBA


IMDG Code Classification System

The purpose of the IMDG Code’s classification system

is:

• To distinguish between goods which are considered

to be dangerous for transport and those which are

not.

• To identify the dangers which are presented by

dangerous goods in transport.

• To ensure that the correct measure are taken to

enable these goods to be transported safely without

risk to persons or property.

IMDG Code reference: 2.0




Dangerous goods are classified into 9 classes

according to properties. The way in which different classes of dangerous goods are handled in transport

will depend upon these properties and hazards, for

example:

• The type of packaging that can be used.

• What classes of dangerous goods can be transported

together in freight containers.

• Where the goods can be stored within the port and on the

ship.

Continued…





The 9 classes: Class 1 Explosives

Class 2 Gases

Class 3 Flammable liquids

Class 4 Flammable solids

Class 5 Oxidizing substances and organic peroxides

Class 6 Toxic and infectious substances

Class 7 Radioactive material

Class 8 Corrosive substances

Class 9 Miscellaneous dangerous substances and articles

These 9 hazard classes have been established internationally by a United Nations (UN) committee to ensure that all modes of transport (road, rail, air and sea) classify dangerous goods in the same way.

Continued…




Identification of Dangerous Goods

PSN and UN Number Within each of the 9 hazard classes dangerous goods are

uniquely identified by two pieces of information:

• A four-digit number known as the UN Number which is

preceded by the letters UN.

• The corresponding Proper Shipping Name (PSN).

For example, kerosene is identified in the IMDG Code by its

UN Number UN 1223 and the PSN Kerosene.

Continued…

IMDG Code reference: 2.0.2




PSN and UN Number Together the UN Number and PSN uniquely identify

dangerous goods to:

• enable rapid and precise identification during transport to

ensure the correct handling, stowage, segregation etc,

and

• in the event of an emergency, ensure that the correct

procedures are followed.

IMDG Code reference: 2.0.2



Hazard labels Each of the hazard classes are also identified by labels:


IMDG Code reference: 5.2.2.2.2



CARRIER - LINER – NVOCC, PoV • Customer places a booking with sales guy. Say -China –JEA

• Sales informs the DG team feasibility. Consider P.O.D and transshipments

• Decide to Load on own or Partner’s vessel. HAZ , NON-HAZ (cargo) is decided.

For cargo out of India, I.P.C ( International Packing Cert.) solves some issues

• Line then approves , MT container released by liner

• For this Specialist needed – Chemist needed , to be proved it is NON-HAZ

• Acidic / Alcohol content / Neutralizing characteristics are scrutinized.

Shipper’s incorrect perspective - saves lot of money by Mis-declaring. BEWARE !

In case of a stand off between shipper and DG desk of a line

Eg: Naphthalene category LOI from shipper availed Line goes to the insurance and get an ok to load this. Considers all POT and POD.



EVERY DAY HIC-UPS .....

• Shippers generally tell your sales team, what the cargo is, in generic terms.

• Eg: Fertilizers – Ammonium Nitrate . 5000MT ( 20 Percent nitrate or more ? - can this be used as an explosive mixture ?)

• Why Should it be D.G ? Who finds this out?

• DUBAI BEING A TRADING HUB

• Traders do not have the MSDS Producing the cargo cert of origin packaging



…….HIC UPS

Consignee’s Yard stuffing; who checks ?

• Port says “You get DG in my premises and I have the right to know some more about this cargo, in fact, all about this cargo”.

• Int . Expert certifies, How its stuffed and lashed stowed etc. (typical of India)

• Lines carry out own inspection for lashing.

• Shipping line should ask for stowage and packing.



Segregation & Packing wrt PLANNING

• When 2 compatible classes loaded in the same box – additional precautions needed. This is sometimes when an Independent is needed.

• Eg: Class No 9 can mostly be loaded with any other class. Who certifies it?

• On Board cargo segregation planning –

• Eg: MSC has a procedure of every vessels every plan goes to Antwerp for approval from DG desk. This takes care of any shifting's or restows.

• POL should not just be looking at only their port , consider restrictions of ports in the process of shipment. (each port restriction and requirements)

POD & POT is to be considered.



quantity mis-match & particular port regulations

• Pkg 6 ltrs exceeding the minimum suggestive of 5ltrs in each packing unit, they put white ink and send box back. BEWARE

• What happens to liner’s responsibility?

• No substantial DG mfg nor originating form , UAE.

Direct delivery problems - an example:

B. Abbas - class 5.1 is landed as direct Deliv. Only -

• Consignee does not come, does carrier take it back to POL. (and/OR)

• Bring it back to Disch. on negotiated double freight



EHS works on the principle of collective responsibility – blame you, me and the dog 1. NO Labeling or Non- Standard labeling.

Contact CFS – for available Play cards

2. Poor storage & segregation.

Wrong declaration , drums reused - light boxes down & heavy on top tier.

3. Selection of Packing Material. Eg: poor quality flexible tank & over stowing. Expansion – due to heat.

4. Carton boxes, melting and leaking.

Tank Containers- outlet v/v leaking.

5. Fines are very low here in Dubai as

compared to International Ports, so beware.

-Are they reasonable or not? “their backyard, will they take care of it ”?



About IMDG violations ports say:

• Leakage is shippers liability. Agents generally put their

hands up when it leaks or needs reworking.

Why ? There is not that kind of money.

Second hand drums ,over stow, heat affects.

• Fexi bags, poor quality or reused ones.

• Arrive DXB leaking, DXB removes & it is removed at the side.





PLACARDS – LEAKS – T.H.C. – drop a hat and call a surveyor !

• If it looks like an original placard it will pass , but will it stay through the voyage ? Don’t know, don’t care !

• Freight is normal, but there is an IMCO surcharge is levied by the port & also the liner.

• Leakage is shippers liability. Causation of potential loss of business account.

TRANSHIPMENTS -

DG Arrives DXB leaking, DXB removes & it remains removed unless someone pays

THC (terminal handling charge) UPTO 50 - 200% EXTRA.

- some ones woes are other persons bread winnings. Get trained and be confident. NEVER SAY “I think, I know” If u do, you might make some surveying firm a couple of 1000 Dees.

Thank you – Good Night. Capt Zarir Irani MICS , MBA


A TYPICAL NOMINATION WOULD BE.............

Reference to our conversation have faxed the MSDS to your attention.

Please confirm on the same asap.

Below are the details as requested, the Class is same but UN Nos are different.

Cargo Details:

UN 1066 – Class 2.2 UN 1956 – Class 2.2

3 Drums – 51 Kgs – 24x24x36 - DG

2 Ctns- 68 Kgs – 37x37x25 – DG 1 Ctn 4 Kgs – 30x21x39 – DG

UN 1956 – Class 2.2

2 Pkgs Approx 60 Kgs

Please confirm whether these are compatible with each other.

Also further more we would be planning to load the container on Saturday and require surveyors presence at the same.

Shall keep you posted on date and time.

Looking forward for your response.

Thanx/Regards

Capt Zarir Irani MICS , MBA


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Poor knowledge of IMDG Code ...." I think, I know" attitude!