Amendment 34 to the International Maritime Dangerous Goods (IMDG) Code

Margaret Fitzgerald Senior Specialist Chemical Safety

Dangerous goods legislation

Dangerous goods legislation has been developed over a number of decades by various United Nations bodies to ensure that the same safety standards are applied no matter what the mode of transport We now have a harmonized system of legislation covering road, rail, air and sea transport of dangerous goods

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International Legislation

Maritime transport International Maritime Dangerous Goods Code (IMDG Code) (developed by the International Maritime Organization IMO)

Air transport Technical Instructions (developed by the International Civil Aviation Organization ICAO)

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European wide legislation

Road transport ADR (developed by the United Nations Economic Commission for Europe UN ECE) Rail RID (developed by the Intergovernmental Organization for International Carriage by Rail (OTIF) In addition, some countries have their own national legislation, e.g.CFR 49 which covers the transport of dangerous goods by road in the United States

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Why the need to amend the IMDG Code?

The IMDG Code is amended on a continuous 2-yearly cycle. This may seem excessive why the need for such a constant revision of the Regulations? The IMDG Code is revised for 2 reasons: .1 to harmonise its requirements with those of the other modal regulations which are also updated every 2 years to meet industry demand. This ensures seamless multimodal transport from one mode of transport to another; and .2 to respond to the needs of the international shipping community in addressing safety issues, political issues, commercial issues etc

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Entry into force of Amendment 34

Amendment 34 is the latest amendment to the IMDG Code In order to facilitate the multimodal transport of dangerous goods, the provisions of Amendment 34 to the IMDG Code may be applied from 1 January 2009 on a voluntary basis. Amendment 34 will become mandatory on 1 January 2010.

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The changes introduced in Amendment 34

The changes introduced in Amendment 34 may be divided into 2 categories: Political; and Technical

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The importance of land based activities in the safe transport of dangerous goods by sea
IMO has over many years expressed concern about the high rate of deficiencies and the lack of adherence to the provisions of the IMDG Code, especially in the areas of classification, placarding and marking, and documentation. Maritime transport does not exist in isolation it is fed from land transport Therefore how the goods are handled on land plays a vital role in the onward safety of the goods, particularly at sea, where any emergency has to be handled by the ships crew

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The importance of land based activities in the safe transport of dangerous goods by sea
Training of shore-based personnel 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 In the 2002 edition of the IMDG Code, training requirements for shore-side personnel were introduced for the first time These requirements were only recommendatory

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The training requirements did not go far enough

However, despite IMOs best efforts, there was growing evidence that the training requirements did not go far enough At the last dangerous goods meeting in IMO the results of container inspection programmes were submitted by Belgium, Canada, Chile, Italy, the Republic of Korea, Sweden, and the United States On the basis of the reports received, of a total of 25,284 cargo transport units inspected, 7,979 cargo transport units were found with deficiencies, i.e. about 32% A total of 8,574 deficiencies were found, i.e. a deficiency rate of 33.9%

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What was the answer?

At its 84th session in May 2008, IMOs most senior technical body, the Maritime Safety Committee took one of the most important political decisions it had ever taken with respect to the IMDG Code The existing training requirements were to become mandatory with the entry into force of Amendment 34

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Training of shore-based personnel

Let us take a look at these provisions The IMDG Code specifies 4 types of training in relation to the transport of dangerous goods: General awareness/familiarization training; Function-specific training; Safety training; and Security training.

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Training of shore-based personnel (Chapter 1.3)

General awareness/familiarization training Each person should receive training designed to provide familiarity with the general provisions of dangerous goods transport provisions

Function-specific training Each person should receive detailed training concerning specific dangerous goods transport provisions which are applicable to the function that person performs

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Training of shore-based personnel

Safety training Commensurate with the functions performed, each person should receive training on safety issues, including: methods and procedures for accident avoidance; available emergency response information; general dangers presented by the various classes of dangerous goods; and immediate procedures to be followed in the event of an unintentional release of dangerous goods

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Training of shore-based personnel (Chapter 1.4)

Security training The training of shore-side personnel shall also include elements of security training Security awareness training shall address the nature of security risks, recognising security risks, methods to address and reduce risks and actions to e taken in the event of a security breach

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Function-specific training of shore-based personnel

The training requirements recommended in the IMDG Code for shore-side personnel, take into account their responsibilities. Such training is required for those who: Classify dangerous goods and identify Proper Shipping Names of dangerous goods; Pack dangerous goods in packages; Mark, label or placard dangerous goods; Pack/unpack CTUs;

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Function-specific training of shore-based personnel

Prepare transport documents for dangerous goods; Offer dangerous goods for transport; Accept dangerous goods for transport; Handle dangerous goods for transport; Prepare dangerous goods loading or 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.

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Enforcing the new requirements

The key to ensuring that these new mandatory requirements bring about a marked improvement in safety standards is enforcement To date, there has been little response from the Flag Administrations on how they intend to enforce these requirements Co-operation with national agencies carrying out other safety enforcement activities is seen by many as key to ensuring the mandatory requirements are met and that they are effective

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Other changes introduced by Amendment 34

Let us now take a brief look at the important technical changes introduced by Amendment 34

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Chapter 2.7 Radioactive Material

The entire text of Chapter 2.7 has been replaced s a result of harmonisation with the requirements of the IAEA, the lead body on the development of legislation addressing the safe transport of radioactive material

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Chapter 2.9 - Miscellaneous dangerous substances and articles (Class 9) and environmentally hazardous substances (Marine Pollutants)
There has been a major re-write of the requirements for class 9 with respect to the criteria for defining Marine Pollutants The detail of this text is only applicable to those who actually classify Marine Pollutants and applying the criteria appears to be have become more complex rather than simplified Changes to Marine Pollutants The use of the notation P to indicate a Marine Pollutant and PP to indicate a severe Marine Pollutant has been amended. PP is no longer used and P will now denote both marine pollutants and severe marine pollutants.

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Changes to Marine Pollutants

The use of the notation P to indicate a Marine Pollutant and PP to indicate a severe Marine Pollutant has been amended. PP is no longer used and P will now denote both marine pollutants and severe marine pollutants. Changes to marking A new section 3.1.2.9 has been introduced to reflect the need to supplement the Proper Shipping Name of Marine Pollutants with the recognized chemical name of the marine pollutant

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The Marine Pollutant Mark

The Marine pollutant Mark has been changed to bring it into line with the symbol used by other modes of transport to denote pollutants, not just marine pollutants The Symbol is now a fish and tree; black on white or suitable contrasting background

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New Chapter 3.5 Excepted Quantities

As a result of harmonisation with other modes of transport, a new Chapter 3.5 has been created which covers Dangerous goods packed in excepted quantities. These are small amounts, up to 30g or 30ml per inner package, 1kg per outer package These are subject only to the rules of the new chapter 3.5, part 2 (classification) and some sections of 4.1 (packing) and 5.4 (documentation) The Dangerous Goods Form shall state the words "dangerous goods in excepted quantities" together with the description of the shipment

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New Chapter 3.5 Excepted Quantities

Excepted quantities will be labelled with an 'excepted quantity' label and the class number. Excepted quantities mark Hatching and symbol of the same colour, black or red, on white or suitable contrasting background * The class shall be shown in this location. ** The name of the consignor or of the consignee shall be shown in this location if not shown elsewhere on the package.

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Changes to column 7 of the Dangerous Goods List (DGL)

Column 7 has now been divided into two; Column 7a - Limited Quantities. This column provides the maximum quantity per inner packaging or article for transporting dangerous goods as limited quantities in accordance with chapter 3.4 Column 7b - Excepted Quantities. This column provides an alpha numeric code described in sub-section 3.5.1.2 which indicates the maximum quantity per inner and outer packaging for transporting dangerous goods as excepted quantities in accordance with chapter 3.5

Limited and Excepted quantity provisions

LQ(7a)

EQ(7b)

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Changes to column 7 of the Dangerous Goods List (DGL)

An entry E0 in column 7b indicates that a substance may not be transported in excepted quantities Codes E1 to E5 indicate different quantity limits according to a table in chapter 3.5 The total number of excepted quantity packages in a CTU shall not exceed 1000

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Changes to the Dangerous Goods List (DGL)

Column 12 - IMO tank instructions The IMO tank instruction column disappears from the Dangerous Goods List because the transitional provisions on their use will have expired by the time this amendment becomes mandatory on 1/1/2010 Column 13 UN tanks has been renamed Tanks

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Class 5.2 label Organic Peroxides

The Hazard label for class 5.2 has now changed to more clearly differentiate between class 5.1 and 5.2 Symbol (flame): black or white Background: upper half red; lower half yellow Figure 5.2 in bottom corner

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Documentation Changes

Declaring a cargo as belonging to one of the Segregation Groups Paragraph 5.4.1.5.11.1 has been amended to permit a Shipper to declare an N.O.S. entry not included in the segregation groups listed in 3.1.4.4 under a Segregation Group if, in the opinion of the consignor, the cargo belongs to one of these groups The appropriate segregation group name preceded by the phrase IMDG Code segregation group shall be included in the transport document after the dangerous goods description. For example: UN 1760 CORROSIVE LIQUID, N.O.S. (Phosphoric acid) 8 III IMDG Code segregation group 1 Acids

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Documentation requirements for dangerous goods in excepted quantities (new section 5.4.1.5.14)
The words dangerous goods in excepted quantities shall be included on the transport document (5.4.1.5.14.1)

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Other documentation changes

Facsimile signatures are acceptable where applicable laws and regulations recognize the legal validity of facsimile signatures (paragraph 5.4.2.2). If the dangerous goods documentation is presented to the carrier by means of electronic data processing (EDP) or electronic data interchange (EDI) transmission techniques, the signature(s) may be replaced by the name(s) (in capitals) of the person authorized to sign (paragraph 5.4.2.3)

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Lloyds Register Services

Lloyds Register is actively trying to protect the maritime industry from unsafe practices and costly claims by focussing on the activities of land-based personnel the clients of the shipping industry Lloyds Register is providing dangerous goods advice, consultancy & training in the requirements to assist shippers by ensuring that they are competent, fully understand the regulations governing the transport of dangerous goods and are capable of meeting these requirements

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For more information, please contact: Lloyds Register EMEA 71 Fenchurch Street London, EC3M 4BS T +44 (0)20 7709 9166 F +44 (0)20 7488 4796 E margaret.fitzgerald@lr.org

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