Book it rightand pack it tight
Guidance on packing dangerous goods for carriage
by sea – IMDG Code Amendment 39-18

A Carefully to Carry publication
Jointly published by:Thomas Miller P&I Ltd
90 Fenchurch Street, London EC3M 4ST
Tel: +44 (0)20 7283 4646
email: lossprevention.ukclub@thomasmiller.com
www.ukpandi.com
Through Transport Mutual Services (UK) Ltd
90 Fenchurch Street, London EC3M 4ST
Tel: +44 (0)20 7204 2626
Email: riskmanagement@ttclub.com
www.ttclub.com
Paperback: ISBN 978-0-9562704-6-7
PDF: ISBN 978-0-9562704-7-4

Acknowledgements
UK P&I Club and TT Club would like to thankRichard Masters for putting together thisdetailed guide, and Will Bartle from Exis
Technologies for reviewing it and contributing
additional material.

Disclaimer
This guide is to assist supply chain stakeholders to understand their key duties under the International Maritime Dangerous Goods (IMDG) Code, but does not
attempt to provide comprehensive information on all subject matter in the Code. While we believe the information to be accurate, the publishers will accept nolegal liability for any conclusions drawn by any person from the contents. In all operational matters referred to in this guide, the IMDG Code must always be thesource of information, as the Code is the legal document. Nor is this guide a substitute for IMDG Code training, which is itself a requirement of the Code.
Copyright © 2020 jointly held by Thomas Miller P&I Ltd and Through Transport Mutual Services (UK) Ltd. All rights reserved. Users of this guide may reproduce ortransmit it verbatim only. Any other use, including derivative guidance based on this guide, in any form or by any means is subject to prior permission in writingfrom the copyright holders.

Foreword

I am pleased to introduce an update on the“Book it right and pack it tight” publication, whichreflects the mandatory application of the latest
amendment to the International Maritime
Dangerous Goods (IMDG) Code from 1 January
2020. In doing so, I acknowledge the continuing
efforts of the UK P&I Club and TT Club toprovide useful and practical guides to thesevital rules for the carriage of packaged
dangerous goods by sea.
While the IMDG Code has existed for over five decades and training has been
mandatory since 2004, the consequences of poor understanding and practices
continue to reverberate through the maritime supply chain. In particular, thefrequency of major ship fires shows little sign of abating and the resultant costs tolife, assets and the environment are devastating.
The global freight supply chain comprises a large number of diverse actors; theobligations and responsibilities resting on those who enter cargo into this supply
chain, in general terms shippers and packers, are substantial. The IMDG Code is
mandatory – forming the maritime element of the overall international dangerous
goods regime which is applying to all modes of transport. This is supported by otherguidance materials, key amongst which is the IMO/ILO/UNECE Code of Practicefor Packing of Cargo Transport Units (CTU Code).
The scale of unitised operations globally is such that great reliance has to be placedon the competence and integrity of each of the actors involved; the system is based
upon trust, which has been sorely strained through the incidents incurred aboard
ships and in port areas. The multitude of Vessel Sharing Agreements across the
Carriers merely underlines the need for a common and practical understanding of
the requirements involved in transport of dangerous goods.
Regardless how sophisticated electronic tools become, it is vital that the people
involved at each stage of the process have appropriate understanding and expertisein order not just to carry out their immediate function but also to be able to validate
what is presented on a screen. Such diligence is necessary to manage theunforgiving laws of physics and chemistry that govern the nature of the goods
carried in ships and stacked in container terminals in ports.
This guidance reflects Amendment 39-18 of the IMDG Code. It follows the full rangeof processes of a dangerous goods consignment being carried by sea.
Dangerous Goods problems at sea start on land, so I urge all supply chain actors –shippers, forwarders, logistics operators, shipping lines – to distribute this publication
widely to their own staff, and their counterparties who prepare consignments formariners to carry.

Uffe Ernst-Frederiksen
Head of Cargo Management, Maersk Line
Chairman of Cargo Incident Notification System (CINS) Organisation
December 2019

Guidance on packing dangerous goods for carriage by sea

3

Contents

Introduction
Using this guide
The International Maritime Dangerous Goods Code
The CTU Code – International standard for safe packing of cargotransport units
A reminder to those who pack dangerous goods into cargotransport units
IMDG code training for shore-based personnel
Security of dangerous goods
General and non-IMDG restrictions on dangerous goods cargo

7
8
8
9
10
12
13
13

Part A: Processing a dangerous goods consignment

A1
A1.1
A1.2
A1.3

15
15
16
16

A2
A2.1
A2.2
A2.3
A2.4
A2.5
A2.6
A2.7

Step 2: Selection of packaging
Importance of appropriate packagings
Packaging choice and selection
Packing Instructions
The Packing Instructions tables
Packing Provisions
Packaging for articles classified as dangerous goods
Types of packagings
UN testing, approval and marking of packagings

17
17
18
18
18
19
19
21

A3

Step 3: Marking and labelling of packages
Marking and labelling of packages

24

Step 4: Preparing the transport document for booking withthe shipping line
Information the shipper is required to present when booking adangerous goods consignment with a shipping line
Identification and display of dangerous goods details
Universal details required in a dangerous goods booking
Variable cargo details
The dangerous goods transport document
Additional certification

26
26
26
29
32
34

A4
A4.1
A4.2
A4.3
A4.4
A4.5

A5.3
A5.4
A5.5
A5.6

Step 5: IMDG segregation
Segregation of incompatible dangerous goods
Introduction
Segregation checks when preparing a mixed load dangerous
shipment for transport
Methods for checking the segregation
The IMDG Code segregation check process
Segregation group allocation for N.O.S. substances
Special segregation provisions and exemptions

35
35
36
40
41

A6
A6.1

Step 6: Packing the cargo transport unit
Packing the cargo transport unit
Pre-packing assessment

42
42

A5
A5.1
A5.2

4

Step 1: Classification of dangerous goods
Classification
Identifying the hazard by classification
Summary of the UN classification information in this guide
Level of chemical knowledge required to produce an IMDG compliant
consignment and use of safety data sheets

Guidance on packing dangerous goods for carriage by sea

35
35

A6.2
A6.3
A6.4
A6.5
A6.6
A6.7
A6.8
A6.9
A6.10
A6.11
A6.12
A6.13

A7
A7.1
A7.2
A7.3
A7.4
A7.5

Creating a stow plan for the packers
Checking the condition of the cargo transport unit
Packing the cargo transport unit
Stacking capacity of packages – 20' versus 40' cargo transport unit
Gap stacking for air circulation
Packing drummed cargo into cargo transport units
Packing dangerous goods on pallets
Solid frame Intermediate Bulk Containers (IBCs)
Securing the cargo inside the cargo transport unit
Lashing cargo inside cargo transport units
The packer’s documentation – the packing certificate
Placarding and marking cargo transport units

Step 7: The packing certificate
The purpose of the packing certificate
Who signs the packing certificate?
Packing certificate on a combined document
Legal status of the packing certificate
Legally binding statement by the cargo consolidator / cargo transport
unit packer
Summary of the provisions of the packing certificate

The final objective: Safely loading containers to the ship
Loading the ship – the role of the cargo planner
Precise and comprehensive information is vital to the planCalculating stowage and segregation
Stowage on the ship
Segregation of dangerous goods on the ship
Protecting temperature-sensitive substances from sources of heat
Areas that ship planners must avoid when stowing heatsensitive cargoes
Ship planners depend on the shipper’s information to load a safe ship
Conclusion

42
44
45
48
49
49
52
54
56
58
58
58

61
61
61
61
62
63

64
64
65
65
65
65
66
66
67

Part B: Reference and Classification

B1
B2
B2.1
B2.2
B2.3
B3
B3.1
B3.2
B3.3
B4
B5
B5.1
B6
B7
B8
B9
B10
B11
B11.1
B11.2
B11.3

Introduction
What are dangerous goods and how are they identified?
Structure of the International Maritime Dangerous Goods (IMDG) CodeFormat of the IMDG CodeThe Dangerous Goods List (numerical index)
The Alphabetical Index
Classification of dangerous goods for transport
What is classification of dangerous goods?
Classification by hazard class (IMDG Part 2 – Classes 1 to 9)
Marine pollutants
Subsidiary hazards (sub-hazards)
Entries in the Dangerous Goods List: UN numbering system andProper Shipping Names
The four types of Proper Shipping Name entries in the Dangerous
Goods List
Packing groups
Articles containing dangerous goods N.O.S.
Determination of flashpoints for flammable liquids
Special controls for polymerizing and unstable substances stabilized
for transport
Dangerous goods forbidden for transport
Additional certification that may be required from the shipper
Weathering certificate
Exemption certificate
Letter of indemnity

Guidance on packing dangerous goods for carriage by sea

70
70
71
71
72
72
73
73
83
83
84
84
85
86
86
87
87
88
88
88
88

5

B11.4
B11.5
B12
B13
B13.1
B13.2
B13.3
B13.4
B13.5
B13.6
B13.7
B13.8
B13.9
B14
B14.1
B15
B15.1
B15.2
B15.3
B15.4
B15.5
B15.6
B15.7
B15.8

6

Competent authority approval
Tank inspection certificates
Provisions for empty uncleaned tank containers
Provisions for shipping dangerous goods in Limited Quantities
General advantages of shipping in Limited Quantities
IMDG advantages of shipping in Limited Quantities
Rationality of allowing relaxed rules for Limited Quantities
Rule variations for dangerous goods in Limited Quantities
Packaging for Limited Quantities
Package marking requirements for Limited Quantities
Documentation requirements for Limited Quantities
Marking requirements for cargo transport units carrying dangerous
goods in Limited Quantities
Summary of criteria for shipping Limited Quantities
Excepted Quantities
Marking requirements for Excepted Quantities
Fumigated cargo transport units UN 3359
Purpose of fumigation
Hazards of fumigation
Definition of “fumigated cargo transport unit”
IMDG operational requirements for fumigated cargo transport units
Applying the fumigant to the cargo transport unit
Marking of fumigated cargo transport units
Documentation for fumigated cargo transport units
Loading fumigated cargo transport units to ships

88
89
89
89
89
89
90
90
90
91
91
91
91
92
93
93
93
94
94
94
94
95
95
96

Case study
Liability judgment in ‘MSC Flaminia’97

References
IMDG Code, CTU Code and fumigation guidance

100

Checklists
Shipper’s dangerous goods declaration checklist
Consolidator’s dangerous goods training and procedure checklist
Dangerous goods container packer’s checklist

101
102
103
104

About us
UK P&I ClubTT Club
Thomas Miller

105
105
105

Guidance on packing dangerous goods for carriage by sea

Introduction

As years go by, serious incidents caused by or
involving dangerous goods continue to occur,
not only on ships but also in ports. Errors,
misunderstandings, misdeclarations andinadequate packing and securing lie at theheart of many of these incidents. As ultra-large
container ships and the marine terminals theycall at increase in size and capacity, thepotential for economic, human andenvironmental accidents rise in proportion.
This guide is intended to support shippers, forwarders, shipping line booking staff
and those who pack dangerous goods into cargo transport units for carriage by sea
in the technical aspects of the IMDG Code.
It is projected that by assisting parties to understand their own duties and theduties of other actors in the transport chain, both communications and compliancecan be enhanced.
This edition reflects the position in the IMDG Code Amendment 39-18 which ismandatory for two years from 1 January 2020, and follows all the steps required
when booking and packing a consignment of dangerous goods with a shipping line.
The guide presents the operational steps in Part A, supported by a general reference
section in Part B.
Part A of the guide breaks down the process of preparing and booking the cargo
into the following steps, and looks at the roles and requirements for the parties
involved in each step:
Step 1:

Classification of dangerous goods

Step 2:

Selection of packaging

Step 3:Marking and labelling the packages

Step 4:

Preparing the transport document for booking with the shipping line

Step 5:

Applying the segregation rules

Step 6:

Packing the cargo transport unit

Step 7:

Producing the cargo transport unit packing certificate

Part B provides background to the IMDG Code and references to further materials.
The IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units(CTU Code) has been adopted as non-mandatory international law and is areferenced from the IMDG Code. This guide will refer to the CTU Code as thedefinitive industry guidance document on how to pack and secure cargo of all types
in cargo transport units.

Guidance on packing dangerous goods for carriage by sea

7

Using this guideThis guide is intended to help shippers, shipping line booking staff, and those
who pack dangerous goods into cargo transport units to get an overview of their
key practical duties under the IMDG Code and does not seek to meet the mandatory
training requirements.
This guide consists of Part A and Part B
Part AThis covers the operational processes and documentation involved in preparing andpresenting a consignment of dangerous goods for shipment. Part A uses terms fromthe IMDG Code that are explained in the reference section, Part B.
Part B
This is a reference section that explains the basic principles of the UN classification
system, the technical terms used in the IMDG Code, and provides useful backgroundinformation on common IMDG issues such as Limited Quantities procedures.
The IMDG Code is a lengthy manual set out in the same UN intermodal documentary
format as other UN transport model regulations based on part, chapter, section, andsub-section numbers to identify the location of information within the document.
IMDG Code text references appear in this guide to take readers to the relevant placein the IMDG Code text where the full details will be found. For example, reference
IMDG 5.4.1.4. refers to Part 5, Chapter 4, Section 1, Sub-section 4, titled “Information
required on the dangerous goods transport document.”

The International Maritime Dangerous Goods (IMDG) Code governs the processes
Internationalby which dangerous cargoes may be transported by sea. It was first published by theInternational Maritime Organization (IMO) in 1965. Since January 2004 the CodeMaritime
has been mandatory for SOLAS (Safety of Life at Sea Convention) signatory states,
Dangerous Goods effectively making it a global rulebook for the sea transport of dangerous goods.
Although it is directed primarily at sea transport, the provisions of the Code affect a(IMDG) Codebroader range of industries and services – manufacturers, packers, shippers, inlandtransport operators (road, rail and inland waterway), port authorities and terminal
operators. The IMDG Code is based on the same ‘Orange book’ (UNRecommendations on the Transport of Dangerous Goods – Model Regulations) as
other modal dangerous goods regulations. IMDG provides authoritative advice onclassification, stowage, segregation, packing, labelling, terminology and emergency
response action.
Unfortunately, the number of incidents involving dangerous goods worldwide tells usthat the rules are not universally followed. Factors such as desire to save cost, lack ofknowledge and training, and failure in communications between geographicallydistant actors in the transport chain, conspire to create the potential for errors.
This guide provides an overview on the key provisions and considerations of the
IMDG Code when shipping dangerous goods by sea, and is essential knowledge if
common errors are to be avoided. Much depends on the skill and awareness of thepersonnel packing the shipping containers – skills that are often under-rated andunder-valued.
Any person or organisation offering dangerous goods or packing cargo transportunits that do not comply with the IMDG Code, and now also the CTU Code, is in aprecarious position if that non-compliance leads to an incident. It can put lives at risk,
and lead to property and environmental damage. The party responsible will be liable
to prosecution, fines by national maritime enforcement agencies and to civil court
actions to compensate other actors for costs incurred arising from damage to theship, cargo and environment, injury and loss of earnings, etc. See the case study from
‘MSC Flaminia’ incident – pages 97-98.

8

Guidance on packing dangerous goods for carriage by sea

The CTU CodeInternational standard for safe packing of cargo transport units
Properly known as “The 2014 IMO/ILO/UNECE Code of Practice for Packing ofCargo Transport Units”, the CTU Code was developed by the IMO (International
Maritime Organization), the ILO (International Labour Organization) and UNECE(United Nations Economic Commission for Europe) to provide global non-mandatory
recommendations on best practice for handling and packing cargo transport units fortransport by road and sea. The CTU Code and accompanying materials wereapproved by the UN agencies during 2014.
Poor packing practices and improperly secured loads give rise to a majority ofincidents along the international transport supply chain, resulting in damage, loss andinjuries on land and at sea.
It is recognised that there has been a lack of guidance and training materials for
personnel at the “sharp end” of the cargo handling industry, and the CTU Code sets
out to address this.
Within the CTU Code, comprehensive information and references on all aspects ofpacking and securing of cargo in containers and other intermodal transport units areprovided, taking account of the requirements of sea and land transport modes. The
CTU Code applies to transport operations throughout the entire intermodal transport
chain and provides guidance not only to those responsible for packing and securingcargo, but also to those who receive and unpack such units. The Code of Practicealso addresses issues such as training and the packing of dangerous goods.
The CTU Code is freely available on the internet.
The UNECE maintains a searchable website athttps://wiki.unece.org/display/TransportSustainableCTUCode/CTU+Code
The IMO site includes further related documents at
www.imo.org/en/OurWork/Safety/Cargoes/CargoSecuring/Pages/CTU-Code.aspx

Guidance on packing dangerous goods for carriage by sea

9A reminder tothose who packdangerous goods
into cargotransport units

If you are responsible for classifying, packaging, declaring and documenting
dangerous goods, or packing them into a cargo transport unit, you have a legallybinding duty to do so in accordance with the rules of the IMDG Code.
To assist with packing and securing all types of cargo into cargo transport units
extensive practical guidance is now freely available in the CTU Code.
If you are the packer it is your responsibility to ensure that any dangerous goods
dispatched by you for maritime transport are correctly identified, labelled andsegregated, and secured inside the cargo transport unit so that they cannot move,that packages will not collapse or otherwise be damaged, allowing product to leak orescape from the packaging during carriage, and you must certify that you havecomplied with this responsibility by issue of a signed packing certificate.
Failure by packers to carry out this safety critical operation in compliance with the
IMDG Code will have serious financial and legal consequences for those responsible
in the event of that non-compliance being the cause of an incident.

10

Guidance on packing dangerous goods for carriage by sea

IMDG Codetraining forshore-based
personnel

Duties to train employees
If your organisation is involved in packaging or shipping dangerous goods, preparing
or processing dangerous goods transport documents, or packing dangerous goods
into cargo transport units, your personnel must understand the procedures to befollowed in the International Maritime Dangerous Goods (IMDG) Code. To follow
these procedures your personnel need to be trained to understand them and thereasons for them. Chapter 1.3 of the IMDG Code has detailed guidance on what
training is required for specific job-holders.
In addition to specific IMDG Code requirements, most countries also have domestic
legislation that creates an employer’s duty of care to provide training in safety criticaloperations for the safety of their employees and others, which of course includes thehandling and packing of dangerous goods for maritime and other modes of transport.

Training is a key
requirement of the IMDG
Code (see IMDG
Chapter 1.3 for the
training schedule)

Depending on their role, your staff may be required to understand the following:• The legal responsibility to identify dangerous goods accurately• Where to locate required information in the IMDG Code• How to identify different classes of dangerous goods• How dangerous goods data is presented on a transport document and what it means• How packages should be marked and labelled• How to make up, mark and label dangerous goods in palletised unit loads• The IMDG Code segregation rules for the separate packing of different types ofdangerous goods• How to stow and secure packages of different types and sizes in cargo transportunits so the packages will not slide, roll or collapse under the weight of over-stowed
cargo during the sea journey• The rules for placarding and labelling shipping containers• The legal responsibility accepted by the packer by signing a packing certificate.

Guidance on packing dangerous goods for carriage by sea

11Full operational competence can only be achieved by providing appropriate training
consistent with the employee’s level of control and responsibility in the transport
chain. It is essential that supervisory employees are trained to understand the IMDG
Code rules, and have access to the rules for reference, as different substances
require different handling; that those with the responsibility for compliance must be
given the knowledge and authority to maintain procedures that ensure the provisionsof the IMDG Code are carried out operationally.
IMDG Code dangerous goods training guide for shore-based staff
IMDG Chapter 1.3 indicates that shore-based personnel involved with dangerous
goods should have training appropriate to their job role and level of responsibility in
one or more key areas. Records of all training should be kept by the employer.
1. General awareness/familiarisation training1 – all persons should be trained to
be familiar with the general provisions of the transport of dangerous goods,
including the classes, labelling, marking, placarding, packing, segregation andcompatibility, the purpose of the dangerous goods transport document and thecontainer/vehicle packing certificate.
2. Function-specific training2 – persons must be trained in the specific dangerous
goods transport provisions that are applicable to the function(s). A guide towhat provisions are applicable to specific job functions is provided in the table in
IMDG 1.3.1.6.
3. Safety training3 – commensurate to the risk of exposure in the event of a releaseof dangerous substances and the functions involved, persons involved in thehandling of dangerous goods, or located in the vicinity of where they are handled,should be trained in:• Procedures for accident avoidance such as proper control of cargo handlingequipment and appropriate stowage of packages• Available emergency response information and how to obtain it• General dangers presented by the various classes of dangerous goods, how to
avoid exposure and where applicable, how to use or wear appropriate PersonalProtective Equipment (PPE)• Immediate procedures to be followed in the event of an unintentional releaseof dangerous goods to protect self and others.
IMDG Recommendations for training shore-based personnel
The IMDG 1.3.1.5 has a useful table that identifies the functions that shore-based
personnel carry out, and provides specific training recommendations for thoseengaged in that function.

IMDG Code, 2018 Edition Amendment 39-18, Section 1.3.1.2.1
IMDG Code, 2018 Edition Amendment 39-18, Section 1.3.1.2.2
3 IMDG Code, 2018 Edition Amendment 39-18, Section 1.3.1.4
1
2

12

Guidance on packing dangerous goods for carriage by sea

Security ofdangerous goods

4

Shippers and shipping line staff should be aware that ships, ports and container
terminals are key infrastructure elements and are potential terrorist targets. They are
subject to the provisions of the International Ship and Port Facility Security (ISPS)
Code that requires ship and port operators to take precautionary measures to defend
against acts of terrorism.
High Consequence Dangerous Goods (HCDG)
Certain types of dangerous goods have been identified as having significant
potential for misuse by terrorists intending to instigate an event leading to masscasualties or mass destruction.
Shore-based staff employed by organisations handling HCDG should be aware of
the increased risk factor, and maintain a security plan to defend against terrorists
taking advantage of the destructive potential of such dangerous goods.
The security plan should include security training to ensure employees adopt
practical measures to identify, report and reduce security risks, and to keep criticaltransport information confidential.
High consequence dangerous goods include some of the higher risk substances andarticles in Classes 1, 2, 3, 4, 5.1, 6 and 8. The list of specific items and details of thetype of defensive measures to be taken are found in IMDG 1.4.3.

General andnon-IMDG
restrictions on
dangerous
goods cargo

Not all bookings for all dangerous goods can be accepted for all ships and all routes.
Full details will be required from the shipper in the first instance.
Many ships are restricted as to the types and volume of dangerous goods they can
carry because of ship design or insurance restrictions, particularly so in the case of
explosives and radioactive materials which also have special stowage requirements.
Most ports restrict handling and transit of explosives and radioactive materials where
safety, security, social and political factors are weighed beyond the practicalities ofmarine transport. Volumes shipped of these commodities are relatively low, andcarried out by specialists. Therefore, only the basic IMDG Code requirements of both
explosives and radioactive materials will be dealt with in this guide.
Many ports restrict other types of dangerous goods (e.g. flammable liquids) for safety
reasons. To determine whether the line can accept the dangerous goods booking,and whether any special conditions or volume restrictions will apply, the shipper willneed to supply the information below. Based on the type of dangerous cargo, therules of the ports of transit and discharge, and the class of ship available, thebooking will be either rejected or accepted and passed on to the next stage.

4

IMDG Code, 2018 Edition Amendment 39-18, Chapter 1.4

Guidance on packing dangerous goods for carriage by sea

13Part A:
Processing
a dangerous
goods
consignment

14Part A – Processing a dangerous goods consignment

Step 1:
Classification ofdangerous goods

A1 Classification
It is fundamental for safety in the transport chain that detailed information on thehazards presented by any dangerous goods are known and readily available for allparties involved in the carriage. Therefore, the first key task of a shipper ofdangerous goods is to identify the hazard that his dangerous goods present bycarrying out the correct UN classification.

A1.1 Identifying the hazard by classification
The UN Manual of Tests and Criteria contains criteria, test methods and procedures
to be used for classification of dangerous goods for transport in all modes, and ofchemicals presenting physical hazards according to the Globally Harmonized Systemof Classification and Labelling of Chemicals (GHS).
These test methods include laboratory procedures for establishing explosivity, toxicity
of liquids, gases and solids, flash points of flammable liquids, temperature thresholds
for flammable solids and self-reactive substances, stability of peroxides, degree ofcorrosivity of acids and alkalis, propensity of substances to polymerize, environmental
damage potential and many other hazardous characteristics.
At the end of the process, dangerous goods are classified into one of nine hazard
classes, allocated a formal Proper Shipping Name and UN identification number, andwhere applicable, graded by packing group into high, medium or low hazard. Where
substances have more than one hazard, all the hazards should be identified in theProper Shipping Name but the most significant hazard, in accordance with the Table
for Precedence of Hazards5, takes prominence.
Classification and hazard identification of the most commonly shipped basechemicals are well established. Shippers of these will have manufacturer’s
authenticated laboratory test reports available and will not need to repeat those tests.
However, shippers of products consisting of innovative combinations of two or morechemicals whose hazardous characteristics are not established will need to arrange
for tests to be done that identify the hazard class(es) and UN Number according to
the UN Manual of Tests and Criteria before the substance can be offered for saleand transport. They cannot be accurately documented for the IMDG Code or othertransport modes until those tests are done, except as small samples dispatched fortest purposes.
Shippers that design and develop chemical products would normally have personnel
with the required skills to test and classify their own products to UN criteria, butshippers who only buy and sell dangerous substances need to obtain the hazardous
classification from the original manufacturer in the form of a Safety Data Sheet. This
will contain the information required for the dangerous goods transport document.

5

IMDG Code, 2018 Edition Amendment 39-18, Section 2.0.3.6

Part A – Processing a dangerous goods consignment

15

A1.2 Summary of the UN classification information in this guide
Section B, the reference section to this guide (the tinted pages) explains theprinciples of the UN classification system as used in the IMDG Code (and other UN
transport protocols). The laboratory methods used to identify the hazard classificationof a substance are outside the scope of this guide, and the hazard classification
process for a substance is done by specialists.
All dangerous goods are classified6 by analysis into one of nine hazard classes:
Class 1 – Explosives
Class 2 – Gases
Class 3 – Flammable liquids
Class 4 – Flammable solids; substances liable to spontaneous combustion;
substances which, in contact with water, emit flammable gases
Class 5 – Oxidizing substances and organic peroxides
Class 6 – Toxic and infectious substancesClass 7 – Radioactive material
Class 8 – Corrosive substancesClass 9 – Miscellaneous dangerous substances and articles (Class 9) andenvironmentally hazardous substances
One very significant classification criteria is the Packing Group. This indicates theoverall degree of danger presented by the substance, and influences the size andtype of packaging options available:
Packing Group I – high degree of danger
Packing Group II – medium degree of danger
Packing Group III – low degree of danger

A1.3 Level of chemical knowledge required to produce an IMDG compliant
consignment and use of safety data sheets
It is necessary to have a professional knowledge of chemistry to carry out many of
the UN tests to initially classify a dangerous substance, but once that classification
has been obtained the classification details are entered to safety data sheet, which
are made freely available by manufacturers.
However, a key point of the IMDG Code is that specialised knowledge of chemistry
is not required to produce an IMDG compliant consignment. Given access to theclassification details in the safety data sheet, any person trained to understand thelayout and meaning of the IMDG Code can prepare a legally compliant dangerous
goods transport document, can check that the packaging is suitable, and can markand label the packages correctly, ready for packing into a cargo transport unit.
All stakeholders need to exercise care to ensure that the safety data sheet isaccurate and current. There are many instances of forged or otherwise inappropriate
data sheets being presented.

6

16

IMDG Code, 2018 Edition Amendment 39-18, Part 2

Part A – Processing a dangerous goods consignment

Step 2:
Selection of
packagingA2 Importance of appropriate packagings
Having classified the dangerous substances and identified their chemical hazards, it
is important for the shipper to ensure that the product is contained within safe andstable packaging.
IMDG Part 4.1 contains the general provisions that define packagings, includingintermediate bulk containers (IBCs) and large packagings, suitable for containing
dangerous goods.
The key requirements for safe packagings• Strong enough to withstand the shocks and loadings of transport and all typesof handling• Designed to prevent loss of content owing to variations in pressure, temperatureor humidity• Not be weakened by contact with the product• Not react with the product to cause a dangerous reaction or affect the quality ofthe product• In use, the package filler must follow the package manufacturer’s closure
procedures so as to ensure effective closure and prevent loss of contents.
For carriage by sea, the IMDG Code requires that packagings (including large
packagings, IBCs, tanks and MEGCs) used for dangerous substances and articles
must conform to a type successfully tested in accordance with IMDG Part 6,“Construction and testing of packagings”. This provides details on the design andconstruction of types of packaging, and the individual test standards to which theymust conform under the UN packaging testing scheme.
Dangerous substances presented in packaging that is not UN-tested are notacceptable for shipment by sea, unless specifically permitted by the Code. For
example, UN-tested packages are not required for goods shipped as Limited
Quantities or Excepted Quantities, but the packaging must still meet the generalsafety provisions of Part 4.
Packagings that have met these standards are conventionally referred to as “UN
tested” or “UN approved” packagings.
These standards apply equally to new, reused and reconditioned packagings used for
dangerous goods.

A2.1 Packaging choice and selection
Selection of suitable packagings and correct filling of them is the shipper’s legal duty.
Packaging selection for individual products within a particular class will varydepending on the chemical nature of the product, and the shipper is required to takethat into account when selecting packaging. At all times, unless specifically
exempted, the packaging must comply with the general and type-specific UN
packaging instructions described in IMDG Part 4.
The shipper’s declaration on the transport document includes a statement certifyingthat the dangerous goods have been correctly packaged according to the IMDG
Code provisions. For example, if a shipper has a liquid product that is corrosive tosteel, the packagings he chooses may be steel drums approved for liquids under the
UN system for the carriage of liquids, but the shipper must ensure the steel is lined
or coated and certified to be resistant to the corrosive nature of his individual product.
Instructions for the correct use of standard packagings such as boxes, drums,
jerricans and bags, as well as IBCs, large packagings, pressure receptacles for gases

Part A – Processing a dangerous goods consignment

17

(cylinders and multi-element gas containers), portable tanks and bulk containers andthey how shall be used are described Packing Instructions set out in IMDG Chapter
4.1, 4.2 and 4.3 respectively, which describe the uses of packagings.

A2.2 Packing Instructions
The majority of entries in the dangerous goods list are assigned packing instructions.
These are numbered and shown in separate columns for standard packages and gas
cylinders, IBCs, and portable tanks (tank containers) respectively.
• DG List Column 8 indicates Packing Instructions for standard packages such asboxes, drums, jerricans, bags and large packages, providing the range of packaging
types that are available to a shipper for the product.
• DG List Column 10 has codes for Packing Instructions for the types ofIntermediate Bulk Containers (IBCs) that may be used.
• DG List Column 13 has codes for Tank Instructions for the types of portable tanks
or bulk containers that may be used.

A2.3 The Packing Instructions tables
IMDG Part 4.1 contains tables listing each Packing Instruction and setting out thedetails of each one. Where individual substances require specialised or a restricted
range of packaging, Packing Provisions are allocated. Packing Provisions are allocatedto individual UN Numbers, and are attached to the Packing Instruction tables.
For quick reference, the Packing Instructions are arranged as follows:• Packing Instruction numbers P001 – P911 apply to standard packagings, boxes,
drums, jerricans, bags, gas cylinders and packaging for articles such as batteries.
• Packing Instructions IBC01 – IBC08, IBC99, IBC100, IBC520 and IBC620 apply
to IBCs.
• Packing Instructions LP01 – LP03, LP99, LP101, LP102, LP200, LP621, LP902 –LP905 apply to Large Packagings.
• IMDG Part 4.2 contains Tank Instructions and Tank Provisions that define howportable tanks and Multi Element Gas Containers (MEGCs) are used.
• IMDG Part 4.3 has instructions for the use of bulk containers, where nointermediate packaging is used, and the product is packed directly into a cargotransport unit.

A2.4 Packing Provisions
Sometimes the nature of an individual substance has special characteristics requiringthat packaging is restricted in size, or is qualified or required to be adapted over andabove the general standard in order to maintain safety. This is shown in a Packing
Provision, set out in a column in the Dangerous Goods List adjacent to the Packing
Instruction. Packing Provisions are set out as extensions of the normal Packing
Provision tables.
• DG List Column 9 has codes for Packing Provisions applicable to standard
packagings (including large packagings) – boxes, drums, jerricans and bags etc.
• DG List Column 11 has codes for Packing Provisions applicable to IBCs.
• DG List Column 14 has codes for Tank Provisions applicable to tanks, multi-element
gas containers and bulk containers.

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Part A – Processing a dangerous goods consignment

A2.5 Packaging for articles classified as dangerous goods
Articles classified as dangerous goods may not be required to be packaged in UN
tested packaging, but the individual entry in the Dangerous Goods List must be checked.
For example, Packing Instruction P003 applies to UN 2800, BATTERIES, WET,NON-SPILLABLE and only requires the batteries to be placed in “suitable outer
packagings” that do not need to be UN-tested. However, the Special Packing
Provision PP16 applies and requires the batteries to be “protected from short circuit”
within the packagings.
In contrast, Packing Instructions P903, P908, P909, P910, P911, LP03, LP904,
LP905 and LP906 apply to UN 3090, LITHIUM METAL BATTERIES and require
the batteries to be packaged in UN-tested packages meeting the test criteria for
Packing Group I (P911 and LP06) and Packing Group II performance level, unless
exempted by Special Provisions elsewhere in the Code.

A2.6 Types of packagings7
Packagings take many forms and may be constructed from a variety of materials or
combination of materials. The provisions for these are available in 6.1.4 forconventional packagings, 6.5.1.4 for IBCs and 6.6.2 for large packagings and aresummarized below.
Composite packagings
Are made of two or more elements that are designed to be used together and notseparated, and may be permanently bonded together e.g. steel drums may have apermanently bonded plastic inner receptacle for extra strength and resistance to theeffect of corrosive products, or multi-layer bags or flexible IBCs may have a sift-proof
plastic inner liner(s) inside a tear-resistant woven outer layer.
Combination packagings
Are those that have independent removable inner packagings containing the productplaced inside an outer packaging that may be fibreboard, wood or plastic, often withshock absorbing and absorbent material between the two elements. Combination
packagings are not designed to be opened during transport. Combination
packagings are tested with the inner packagings filled with product or comparable
substitute inside the outer packaging in the form in which the package will be used.

Construction of a typical combination package for dangerous goods: Separate inner
packagings packed inside a fibreboard outer packaging
Boxes
Fibreboard boxes with inner packagings made of plastic for liquids or solids are oneof the most common packagings for dangerous goods.
Boxes may also be made of steel, aluminium or other metal, wood, plywood,reconstituted wood, and solid or expanded plastics, and generally have inner
packagings that are in contact with the dangerous goods.
7

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Part A – Processing a dangerous goods consignment

19

The maximum net mass for different types of boxes varies according to box design
and Packing Group. The maximum net mass for a box containing dangerous goodsof Packing Group II or III is 400 kg.
Drums
Drums are defined as cylindrical packagings, generally but not necessarily with flatends. They are produced in a wide variety of sizes and may be manufactured fromsteel, aluminium or other metal, plastic, plywood or fibre. They may be single
packagings, combination packagings with removable inners, or composite
packagings with non-removable inner liners.
The maximum net mass for a drum containing any dangerous goods of Packing
Group II or III is 400 kg. The maximum net mass for different types of drum varies
according to design and Packing Group, and are shown in the individual packing
instructions.
Jerricans
Jerricans are defined as rectangular or polygonal packagings and can be up to
120 kg capacity. They are commonly made in smaller sizes, 5 kg up to 30 kg net
mass, with carrying handles for convenient manual handling and retail sale.
Handles are frequently moulded into the top of the package, sometimes preventing
them from nesting vertically, and care must be taken with some designs whenstacking them because they are prone to collapse if over-stowed, and separator
boards between tiers to spread the weight are recommended.
Bags
Bags are suitable for some solid dangerous goods of Packing Groups II and III, andthey may be made of plastic film, multi-wall paper or woven textile, and can besupplied with a variety of inner linings. They may be up to 50 kg capacity, but 25 kg
is more common. Care is needed during manufacture and closure after filling toachieve sift-proof secure stitched seams or welded seams.
Intermediate Bulk Containers (IBCs)8
IBCs are designed for mechanical handling. They can be rigid or flexible and can be
up to 3 cubic metres capacity, although the most common are about 1 metre x 1
metre x 1 metre and about 1 tonne gross weight for easy mechanical handling andpacking into cargo transport units.
Rigid IBCs are commonly of composite design with a plastic inner receptacle in a
metal outer cage. All-metal IBCs can be very robust and be designed for filling ordischarging liquids or solids under gravity or pressure. Flexible IBCs are usually madeof woven plastic fabric, may be lined with impermeable inner layers and have handles
for lifting. Commonly called “big bags” – these are generally certified for one trip only
and are non-returnable units.
Reusable metal, rigid and composite IBCs need to be periodically inspected toensure conformity with design type, internal and external condition and functionalityof service equipment. Operators must examine IBCs before they are put into service,
then after 2.5 years and after 5 years. Inspection reports must be documented andkept by the owner/operator.
Large packagings
These are also designed for mechanical handling and are defined as an outer
packaging intended to contain articles or inner packagings. They exceed 400 kg net
mass or 450 litre capacity but have a volume of not more than three cubic metres.
Large packagings can also be rigid or flexible, with rigid packagings commonly being
manufactured from steel, aluminium or other metal and flexible large packagingsfrom plastics or paper.

8

20

IMDG Code, 2018 Edition Amendment 39-18, Chapters 4.1 and 6.5

Part A – Processing a dangerous goods consignmentRefillable receptacles for gases (gas cylinders)9
Individual refillable gas cylinders are marked and labelled with the UN Number andclass label in the normal way, and may be stowed in shipping containers. Gas
cylinders are subject to variable construction and use requirements, and are subject
to inspection and testing every five or ten years, contingent upon the type of gas –see IMDG Chapter 6.2 for further information.
Pressurised gas cylinders have a unique marking system owing to their specialised
construction requirements (they are often suitable for one type of gas only), long
working life, and extreme stresses which they must withstand. Shippers should
ensure that gas cylinders are subject to the appropriate inspection regime based on
the UN system, or an alternative national test regime, acceptable under UN terms.

Typical rigid composite IBC

Internal valves should be effectively closed and designed so they cannot releaseproduct as a result of vibration, pressure or temperature change. Removable valves
should be detached from the cylinders for transport. Where external cylinder valves
are part of the cylinder design, valves should be protected from impact by guards or
shrouds. If this cannot be done the cylinders should be packed in frames that provide
impact protection for the valves.

A2.7 UN testing, approval and marking of packagings
With very few exceptions (packagings used for ‘Limited Quantities’ or ‘Excepted
Quantities’ consignments being the most notable) dangerous goods transport
packagings must be constructed, tested and approved to United Nations (UN)performance standards.
Under the UN packaging specification scheme, samples of a packaging design typeare subjected to a series of standard tests – such as being dropped, stacked andsubjected to pressure – which simulate predictable transport situations.
Flexible IBCs

The objective is to prove the competence of the packaging design and materials of
construction for carrying dangerous goods.
Separate chapters in Part 6 of the IMDG Code describe the testing regime. By way
of example, Section 6.1.5 identifies the UN tests which must be carried out on thefollowing packaging types: drums, jerricans, boxes, bags and composite packagings.
Tests must be successfully completed before the packaging can be used for
dangerous goods. Once completed a test report and certificate of approval is issued
for the packaging design type.
Certification can only be granted by a competent authority or an organisation
designated for this purpose by a competent authority. The certificate specifies analphanumeric UN packaging mark similar to the example illustrated left.
The UN packaging mark is subsequently applied by the manufacturer to every
packaging made to the tested and approved specification. It identifies certain
constraints on the use of the packaging which the consignor must take into accountwhen deciding how to pack the substance being shipped.
But what does this alphanumeric code mean?

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IMDG Code, 2018 Edition Amendment 39-18, Chapters 4.1 and 6.2

Part A – Processing a dangerous goods consignment

21

Markings for packagings10
Examples of the alphanumeric UN packaging marks used to identify a number ofcommon packaging types are illustrated and explained below.
Plastics drum – 1H2
The ‘1’ identifies the
packaging as a drum
and the ‘H’ identifies it
as a plastics drum. The‘2’ identifies that it has aremovable head drum.

Steel drum – 1A1
The first ‘1’ identifies
the packaging as a
drum and the ‘A’identifies it as being
made from steel. The
second ‘1’ identifies
that this is a nonremovable head drum.

Fibreboard box – 4GThe ‘4’ identifies it as a
box and the ‘G’ identifies
it as being made fromfibreboard.
Further information on the codes used for different packagings can be seen in
Section 6.1.2.
Example packaging mark:1B2/X50/S/16 USA/LR235
This indicates that the packaging is a UN approved Aluminium drum with removeable
head (1B2), has been tested for packing groups I, II and III, relative density, rounded
off to the first decimal, for which the design type has been tested for packagings,
without inner packagings, intended to contain liquids (50), that the packaging is
intended for the transport of solids or inner packagings (S), the year of manufacture
and authorizing state (16 USA) and finally the name of manufacturer or otherpackaging ID (LR235).
IBC and large packagings marking
A similar marking system is used for IBCs and large packagings that have been
manufactured to a UN tested and approved design specification. The packaging
code options used for IBCs are:• rigid, identified by the numbers ‘11’ and ‘21’ for solids, and ‘31’ for liquids; or• flexible, identified by the number ‘13’.
This number is combined with a code identifying the material(s) of construction.
For example, the code for a rigid IBC made from steel and designed to carry a liquid
is 31A (‘31’ for ‘rigid for liquids’ and ‘A’ for ‘steel’).
Example IBC packaging mark:
11A/Y/02 14/CAN/ABC 4-001/5500/1500
This indicates that it is a UN approved rigid steel IBC (11A) designed for packing
group II and III substances (Y), that it was manufactured in February 2014 (02 14)
and the allocation of the mark was authorised by Canada (CAN), the name or symbolof the manufacture and any other identifying mark (ABC 4-001), the stacking test
load in kilograms (5500) and finally the maximum permissible gross mass inkilograms (1500).
Full details of the applicable markings can be found in 6.5.2.

10

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Part A – Processing a dangerous goods consignment

For large packagings there are only two packaging codes used:• 50 – Rigid• 51 – Flexible
Example large packaging mark:50A/X/05 15/N/PQRS/ 2500/1000
This mark indicates a UN approved large steel rigid packaging (50A) which has beentested for packing groups I, II and III, the month and year of manufacture, May 2015(05 15), that it was authorised in Norway (N), it was manufactured by ‘PQRS’, thestacking load test in kilograms (2500) and finally the maximum permissible grossmass in kilograms (1000).
Full details of the applicable markings can be found in Section 6.6.3.

Part A – Processing a dangerous goods consignment

23

Step 3:Marking andlabelling of
packages

A3 Marking and labelling of packages
Safe transport and handling procedures can only be maintained during the transportof dangerous goods by sea if everyone involved has ready access to information
about the risks presented by the goods concerned – container packers/handlers, theship’s crew, the emergency services etc.
Appropriate and readily recognisable warnings on packages can help achieve
this objective.
The IMDG Code requires a range of warnings – in the form of marks and labels –to be applied to packages being shipped by sea.
It is the consignor’s (shipper’s) duty to ensure that packages containing dangerous
goods display all the marks and labels required for the sea journey.
The term ‘marks’ refers to the application of:• UN Number (Section 5.2.1.1)• The Proper Shipping Name (Section 5.2.1.1)• Marine pollutant mark (as applicable) (Section 5.2.1.6)• Orientation marks (as applicable) (Section 5.2.1.7)• Limited quantity mark (as applicable) (Section 3.4.5)• Excepted quantity mark (as applicable) (Section 3.5.4)• Any class or substance specific marks (as applicable)– see Chapter 5.2 for specific details
The term ‘labelling’ refers to the application of:• the hazard class diamond label (Section 5.2.2)• sub-hazard diamond labels (as applicable) (Section 5.2.2)• any class specific label (as applicable) – see Chapter 5.2 for specific details
Let’s look at an example:

Here we can see the following marks and labels:
UN Number : UN 2826
PSN : ETHYL CHLOROTHIOFORMATE

Orientation markMarine pollutant markNote: in the image above you can also see the UN Packaging mark in the bottom left
hand corner (4G/X100/S/04USA/ALC), as described in section A2.7 above.

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Part A – Processing a dangerous goods consignment

Class 8 label and Class 3 sub-hazard labels:

When applying marks and labels the following provisions must be adhered to:
The required marks and labels only need to be displayed once on a package, except
as follows:• IBCs exceeding 450L capacity and large packagings must be marked and labelledon two opposite sides• Orientation arrows (where required – see Section 5.2.1.7) must always be displayedon two opposite sides
On a combination packaging, the relevant transport marks and labels are only requiredon the outer packaging e.g. fibreboard box; they are not needed on inner packagings.
For unpackaged articles, the marks and labels must be displayed on the article itself
or on its cradle or handling, storage or launching device.
Wherever possible, marks and labels must be located on the same surface of the
package and not be obscured by any part of the package or attachment to it. Any
subsidiary hazard label(s) must be displayed next to the primary hazard label.
Labels must satisfy the provisions in Section 5.2.2.2 and conform, in terms ofcolour, symbols, numbers and general format, to the specimen labels shown in
Section 5.2.2.2.2. They must be in the form of a square set at an angle of 45°(diamond-shaped) with minimum dimensions of 100 mm by 100 mm, except in thecase of packages of such dimensions that they can only bear smaller labels – see
Section 5.2.2.2.1.1 for an illustration of this.
The label may include text such as the UN Number, or words describing the hazard
class (e.g. “corrosive”) provided the text does not obscure or detract from the otherrequired label elements.
Limited Quantity and Excepted Quantity marks
Packages shipped in accordance with the rules for “Limited Quantities” or “Excepted
Quantities” are not subject to the standard marking and labelling requirements
highlighted above. They do not need to be marked with the PSN and UN Number ofthe contents or a marine pollutant mark and no danger or subsidiary hazard labels
are needed. Instead they have their own specific identifying marks as follows:* Class number to beshown here** Name of the consignor
or of the consignee to beshown here if notelsewhere on the package

Limited Quantity markExcepted Quantity markNote: as well as ensuring that packagings are marked and labelled to identify thehazards contained within, the CTU containing the packagings must also bear similar
identifying marks and large labels, known as placards – see Section A6.13.
Part A – Processing a dangerous goods consignment

25

Step 4:
Preparing thetransport
document forbooking with theshipping line

A4 Information the shipper is required to present when booking a dangerous
goods consignment with a shipping line
This section discusses the information that the shipper is required to provide whenoffering cargo to a shipping line. It also indicates the way that information must bepresented on the final transport document that is presented to the cargo transport
unit packer (who will complete and sign the packing certificate section) and theshipping line.
The shipping line booking staff who receive this information will process it andaccept or reject the cargo on the strength of the information provided. If theinformation conflicts with the IMDG Code requirements the booking will be rejected.
The section looks at the dangerous goods details in the shipper’s declaration that the
shipper should supply when making the original cargo booking, providing examples
where appropriate.

A4.1 Identification and display of dangerous goods details
The dangerous goods details are specified in various sections of the IMDG Code, but
the details required for the cargo booking and transport document are found in
IMDG Part 5 and the Dangerous Goods List.
The details required will vary according to the type of dangerous goods.

A4.2 Universal details required in a dangerous goods booking
This section contains the cargo details that are common for every dangerous
goods shipment:
UN Number11
The four-digit number in Column 1 of the Dangerous Goods List with the letters“UN” placed in front:
As it appears on shipper’s declaration: “UN 2022”.
Proper Shipping Name12
The name of a substance or article shown in Column 2 of the IMDG Dangerous
Goods List.
As it appears on shipper’s declaration: “UN 2022, CRESYLIC ACID”.
OR
Not Otherwise Specified (N.O.S.) Proper Shipping Name13
N.O.S. generic names are used to describe a shipper’s own mixture or solution ofdangerous goods that are not listed in the Dangerous Goods List.
To complete an N.O.S. Proper Shipping Name, the technical name(s) of the hazardous
components in the mixture must be specified and added in brackets after the genericname. Not more than the two constituents which most predominantly contribute to
the hazard or hazards of the mixture or of the articles need to be shown.
The transport document displays N.O.S. entries as the generic description shown incolumn 2 (selected from IMDG Code Appendix A) followed in brackets by thevariable hazardous components.
As it appears on the shipper’s declaration: “UN 1993, FLAMMABLE LIQUID, N.O.S.
(contains 60% propylamine)”.

IMDG Code, 2018 Edition Amendment 39-18, Section 2.0.2
IMDG Code, 2018 Edition Amendment 39-18, Sections 2.0.2 and 3.1.2
13 IMDG Code, 2018 Edition Amendment 39-18, Section 3.1.2.8
11
12

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Part A – Processing a dangerous goods consignment

Class14
The Class is the hazard classification of a substance as determined by the UN
Classification tests and is shown in Column 3 of the Dangerous Goods List. Use thenumerical entry in Column 3 immediately after the Proper Shipping Name:
As it appears on shipper’s declaration: “UN 2022, CRESYLIC ACID, Class 6.1”.
See section B3 below on Classification.
Subsidiary hazard15
If a substance has more than one hazard characteristic this must be identified in theDangerous Goods List. In such cases the main class is shown in Column 3 and in
addition any subsidiary hazard class(es) shown in Column 4. Note that a maximum of
two subsidiary hazards are only ever included.
If there is a subsidiary hazard class applicable this must be placed within brackets
after the main class.
As it appears on shipper’s declaration:“UN 2901, BROMINE CHLORIDE, Class 2.3, (5.1/8)”.
Packing group16
The Packing Group (PG) I, II or III indicates the degree of danger with PG I as thegreatest danger and PG III as low danger. Not all UN Numbers have packing groups,
but most of the entries in Classes 3, 4 (other than self-reactive substances), 5.1, 6.1,
8 and most in 9 have a packing group. These are indicated by I, II or III in Column 5of the Dangerous Goods List.
As it appears on shipper’s declaration:“UN 2022, CRESYLIC ACID, Class 6.1, 8, PG II”.
See section B6 below on Packing Groups.
Number and type of packages17
These are a simple description of the packages and must always be included except
for empty, unclean packagings. e.g. 80 x Drums or 440 fibreboard boxes
The IMDG Code does not require the transport document to include the following in
the description of the type of packaging:• the material of which the packaging is made• the packaging codes• the number, type and capacity of each inner packaging
Note: Shipping lines may request some or all of these items as a cross check, andfrequently require the packaging code (e.g. 4G for fibreboard boxes).
Net and gross weight of each type of dangerous goods in the consignment
The net weight is the weight of a dangerous substance without the packaging. If
more than one substance is in the consignment, the net weight of each UN Number
must be shown separately. The gross weight is combined weight of the dangerous
goods and the packaging.

IMDG Code, 2018 Edition Amendment 39-18, Section 2.0.1.1
IMDG Code, 2018 Edition Amendment 39-18, Section 2.0.0
16 IMDG Code, 2018 Edition Amendment 39-18, Section 2.0.1.3
17 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.5.1
14

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Part A – Processing a dangerous goods consignment27

Typical declarations
Example 1
No. and type of packages:

80 x drums (+ net and gross mass)

UN Number:UN 2322

Details from the Dangerous Goods List:
Proper Shipping Name:

Trichlorobutene

Class:

6.1

Sub-hazard:

N/A

Packing group:

PG II

Marine pollutant:

Yes

IMDG Declaration of 80 drums as it would appear on the shipper’s declaration:
80 x drums (+ net and gross mass)
UN 2322, TRICHLOROBUTENE, 6.1, PG II, MARINE POLLUTANTExample 2
No. and type of packages:

500 x jerricans (+ net and gross mass)

Details from the Dangerous Goods List:
UN Number:UN 1098

Proper Shipping Name:

Allyl AlcoholClass:

6.1 Toxic

Sub-hazard:

3 Flammable liquid

Packing group:

PG 1

Flashpoint:(+21°C c.c.).

Marine pollutant:

Yes

IMDG Declaration of 500 jerricans as it would appear on the shipper’s declaration:
500 x jerricans (+ net and gross mass)
UN 1098, ALLYL ALCOHOL, 6.1, (3), PG I (+21°C c.c.) MARINE POLLUTANTExample 3
No. and type of packages:

100 fibreboard boxes (+ net and gross mass)

Details from the Dangerous Goods List:
UN Number:

UN 1993

Proper Shipping Name:

Flammable liquid N.O.S. (Ethanol and Dodecylphenol)

Class:

3 Flammable liquid

Packing Group:II

Flashpoint:(+18°C c.c.)Marine pollutant:

Yes

IMDG Declaration for 100 fibreboard boxes as it would appear on the shipper’s
declaration:
100 x fibreboard boxes (+ net and gross mass)
UN 1993, FLAMMABLE LIQUID N.O.S. (Ethanol and Dodecylphenol), 3, PG II(+18°C c.c.) Marine Pollutant.

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Part A – Processing a dangerous goods consignment

A4.3 Variable cargo details
This section lists a variable range of common and less common cargo details that the
shipper may be required to provide.
In addition to the details listed in the previous section, the shipping line may require
supplementary mandatory information from the IMDG Code that will vary dependingon the nature and classification of the dangerous goods.
Most of this information can be obtained in the Dangerous Goods List of the IMDG
Code, but some has to be obtained from within the text of the Code or from theshipper’s classification in the case of N.O.S. substances. Shippers and freight
forwarders that do not have a good working knowledge of the IMDG Code, should
always be encouraged to seek advice from experts in the dangerous goods
department of the shipping line regarding documentation requirements, but shippinglines will not make decisions on classification – that must come from the shipper.
While shipping lines will try to be helpful when taking bookings, it must be
understood that it is the shipper’s legal duty to present accurate and full descriptionsof dangerous cargoes offered, and the assistance that shipping lines can provide islegally limited.
Consequentially, incorrectly documented or badly packed cargo will be rejected atbooking stage or shut out even if the booking has been accepted in principle, anddelays and unplanned cost overheads will be incurred for remedial work.
The following are variable cargo details that the IMDG Code may require to be
included in the shipper’s declaration, depending on the type of cargo offered.
Flashpoint18 for Class 3 substances and substances with a subsidiary
Class 3 hazard
Class 3 substances are liquids that that give off a flammable vapour at temperaturesat or below 60ºC. This is normally referred to as the ‘flashpoint’ and must be lower orhigher than the reference temperature indicated in the Dangerous Goods List.
The flashpoint must be included in the shipper’s declaration for a flammable liquid andbe added after the Packing Group in brackets according to shipper’s determination.
This also applies to substances with a subsidiary hazard of Class 3.
As it appears on shipper’s declaration:“UN 1090, ACETONE, 3, PG II, (-20ZC c.c.)”Marine pollutant19
Marine pollutants are substances or articles that are hazardous for the marine
environment. Any class of dangerous goods substance (apart from class 7) can also
be a marine pollutant, but not all of them are. Also, substances that are not otherwiseclassified as dangerous goods may fit the criteria for classification as marine
pollutants and are classified as “Environmentally Hazardous Substances,
Solid/Liquid, N.O.S., Class 9”.
When goods are marine pollutants the words “MARINE POLLUTANT” are added at
the end of the description of the dangerous goods.
As it appears on shipper’s declaration:“UN 2826, ETHYL CHLOROTHIOFORMATE, 8, (3), MARINE POLLUTANT”
Solid or liquid
The UN classification system differentiates between solid and liquid states of thesame product, as the hazards are different. Where the words “SOLID” or “LIQUID”
appear in the Proper Shipping Name in Column 2 of the Dangerous Goods List it
must be included in the declaration.
18
19

IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.4.3.6
IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.4.3.5

Part A – Processing a dangerous goods consignment29

As it appears on shipper’s declaration:“UN 3429, CHLOROTOLUIDINES, LIQUID, 6.1, PG III,UN 2239, CHLOROTOLUIDINES, SOLID, 6.1, PG III”
Polymerizing substances20 of Classes 2, 3, 4.1, 6.1 and 8
These are substances that, at 50ºC or less, without chemical or temperaturestabilization, are liable to undergo a strongly exothermic reaction resulting in theformation of larger molecules or polymers, evolving heat and gas.
The person offering the substance for transport must ensure that it will notpolymerize at temperatures liable to be encountered during transport, and must takemeasures to stabilize the product, either by chemical or thermal stabilization21.
When stabilization is by thermal control, the shipper’s declaration for polymerizing
substances must include the Control Temperature and Emergency Temperature22.
Stabilized substances23
When substances would be forbidden for transport because they are unstable andliable to react dangerously or polymerize at temperatures encountered duringtransport, they may be chemically or thermally stabilized, or both.
When substances are thermally stabilized for transport, the word “STABILIZED”
becomes part of the Proper Shipping name.
If the substance is thermally stabilized the shipper’s declaration must include theControl Temperature and Emergency Temperature.
Control temperature and emergency temperature24
Required to be shown on documentation for dangerous substances that have a
Self Accelerating Decomposition Temperature (SADT) that may be encountered intransport and that must be carried below a specific temperature under controlledtemperature conditions.
As it appears on shipper’s declaration: “CONTROL TEMPERATURE +20° C” and“EMERGENCY TEMPERATURE +30°C”.
Empty uncleaned packages25
Including drums, gas cylinders, large packagings, intermediate bulk containers,(IBCs), bulk containers, tanks (all kinds) and tank containers, containing dangerous
goods residue.
Nominally empty uncleaned packages that contain residue of dangerous goods arestill dangerous to handle, can give off dangerous vapours, and may explode in fires.
Such items must be declared, documented, marked and labelled with Proper
Shipping Name, UN Number and class, sub-hazard, flashpoint etc, as for any normal
dangerous goods with an additional clause on the declaration to indicate thepackage is nominally empty.
As it appears on shipper’s declaration: “EMPTY UNCLEANED” or “RESIDUE LASTCONTAINED” should appear before or after the Proper Shipping Name.
Wastes26
Dangerous goods transported as wastes for recycling or disposal must be declared to theshipping line and on the shipper’s declaration. This is a requirement of the IMDG Code,but it is likely to also be a requirement of local legislation, such as the EC Transfrontier
Shipment of Waste Regulations, and may be subject to local port regulations.

See Section B9 below on Special controls for polymerizing and unstable substances stabilized
for transport
21 IMDG Code, 2018 Edition Amendment 39-18, Section 7.3.7
22 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.5.5
23 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.5.4
24 See Section B9 below for further details on Control and Emergency temperatures
25 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.4.3.2
26 IMDG Code, 2018 Edition Amendment 39-18, Sections 2.0.5 and 5.4.1.4.3.3
20

30

Part A – Processing a dangerous goods consignmentAs it appears on shipper’s declaration: The word “WASTE” should appear before theProper Shipping Name.
Note: Many shipping lines are unwilling to carry wastes because they can bevicariously liable for charges if wastes are mis-declared.
Salvage packagings including large salvage packagings and salvage
pressure receptacles 27
Cargo shipped in salvage packaging including large salvage packagings and salvage
pressure receptacles, for whatever reason, must be notified to the shipping line. The
salvage packaging used must conform to United Nations test standards for PG II.
As it appears on shipper’s declaration: The words “SALVAGE PACKAGE” or“SALVAGE PRESSURE RECEPTACLE” should be added to the document
together with the number of salvage packages and an estimate of the quantity (kg or
litres) of dangerous goods in the salvage package(s).
Radioactive materials28
Many shipping lines do not carry radioactive materials because of the difficulty inplacing insurance and because many ports do not permit the transit ofradioactive materials.
Owing to complexity of radioactive materials there is a great deal of information andcertification related to the product and its packaging, as well as safety instructions
and emergency procedures that could be justifiably requested by the shipping line.
As each shipping line will come to its own considered opinion about the carriage ofradioactive materials and the controls it wishes to apply, this section will not go into
the details that could be requested. The statutory documentation details are set out
in the IMDG Code.
Explosives29
Like radioactive materials there are insurance and port transit difficulties shipping
explosives. To consider accepting explosives, the shipping line will need to know the
HAZARD DIVISION and COMPATIBILITY GROUP of explosives as these will
determine the shipboard segregation, port restrictions, and insurance limits of thepotential cargo. Many ports accept no explosives except Class 1.4S, the least restrictive.
The quantity of explosives is measured in net explosive quantity (NEQ) – also
referred to as the Net Explosives Content (NEC) which is the amount of explosives
compound in the article consignment. The gross weight of ancillary equipment
incorporated in or around the explosives is unimportant – only the NEQ matters forthe calculation of port limits and shipboard segregation.
As it appears on shipper’s declaration: A typical description of an explosives
consignment would be as follows:
20 x boxes, UN 0012, CARTRIDGES, SMALL ARMS, Class 1.4,
Compatibility Group S, Net explosive quantity (NEQ) 15 kilograms
Net weight 550 kilograms
Gross weight 600 kilograms
Carriage at elevated temperature30
Liquids carried in tanks at 100°C or more and solids carried at 240°C or more must
be declared, even if the substance is not classed as dangerous goods at normal
temperatures.
As it appears on shipper’s declaration: The words “MOLTEN” or “ELEVATEDTEMPERATURE” may appear as part of the Proper Shipping Name, but if this is not
the case, the word “HOT” should precede the Proper Shipping Name on the document.

IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.5.3
IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.5.7
29 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.5.9
30 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.4.3.4
27
28

Part A – Processing a dangerous goods consignment

31

Fumigated cargo transport units31
Many cargo transport units carrying non-hazardous cargoes particularly unprocessedfood products such as beans and rice, and some carrying dangerous goods cargoes
are fumigated in transit for pest control reasons.
The method is by the introduction of highly toxic penetrative gas, usually a derivative ofphosphine. All methods create a hazard when fumigated units are stowed in confined
spaces below deck on ships, and a severe hazard for any person who may be required
to enter the cargo transport unit before it has been ventilated to clear the gas.
A container shipped under fumigation becomes a dangerous goods movement,
regardless of the cargo, and must be declared, documented and manifested as
dangerous goods.
As it appears on shipper’s declaration:“UN 3359, FUMIGATED CARGO TRANSPORT UNIT, CLASS 9”This description should be followed in the document or accompanied by a fumigation
certificate with the following information:• The date and time of fumigation• The type of fumigant• The amount of fumigant used
The documents shall include instructions for disposal of any residual fumigant or
fumigation device.
Emergency telephone numbers
There is no requirement in the IMDG Code for the shipper to provide his telephone
number to assist in an emergency. However, it is good practice for shippers toprovide them, even though it may not be a 24/7 number.
Not all shippers can provide 24 hour numbers, but some countries including USA
have legislation requiring a 24 hour emergency number so commercial organisations
exist to provide them.
As it appears on shipper’s declaration: The telephone number should be entered on
shipper’s declaration in such a way that it cannot be confused with any part of the
cargo description.

A4.4 The dangerous goods transport document
While the previous sections dealt with the details that shippers may be required toprovide when making a dangerous goods booking, this section looks at how thosedetails should be entered on the dangerous goods transport document, the formal
document that must accompany the consignment.
The transport document can be in any format but must contain the declaration
details of the dangerous goods, the wording of the shipper’s declaration and thewording of the packing certificate from the UN model in IMDG Chapter 5.4. The
packing certificate may be on a separate document to the shipper’s declaration, but
is most commonly on a version of the UN combined form shown below. This is form
is multimodal and can be used for all surface modes.
Note that the use of electronic data processing (EDP) and electronic datainterchange (EDI) transmission techniques is permitted as an alternative tosubmission of paper documentation.
Example of the multimodal dangerous goods form – see IMDG Code 5.4.5

31

32

IMDG Code, 2018 Edition Amendment 39-18, Section 5.5.2

Part A – Processing a dangerous goods consignmentAs well as the dangerous information, the name and address of the consignor andthe consignee of the dangerous goods must be included on the transport document
along with the date when the document or an electronic copy of it was prepared or
given to the initial carrier.
Certification of the dangerous goods transport document
Once all details have been completed on the dangerous goods transport document it
must include a declaration or certification, signed and dated by the consignor, statingthat the consignment is acceptable for transport and that the goods are properly
packaged, marked and labelled and in proper condition for transport by sea.
Further information on the consignor's/shipper's declaration, including an example ofa completed dangerous goods transport document, may be found at Section A7.2
and A7.3 of this guide.
If EDP or EDI is used to transmit the document, the signature(s) may be electronic
signature(s) or may be replaced by the name(s) in capitals of the person authorised
to sign.

Part A – Processing a dangerous goods consignment

33

Container/vehicle packing certificate
When dangerous goods shipped by sea are packed into a container, vehicle or trailer,
those responsible for the packing operation must provide a ‘container/vehicle
packing certificate’ specifying the container/vehicle identification number(s) andcertifying that the operation has been carried out in accordance with the conditions
listed in IMDG 5.4.2.1.
As mentioned above, the information required on the transport document and thecontainer/vehicle packing certificate may be incorporated into a single document,
otherwise they must be attached to each other.
See Step 7 for further information on the packing certificate.

A4.5 Additional certification32
In addition to the shipper’s declaration on the transport document (dangerous goods
document/dangerous goods form) some consignments will require additional
certification to be given to the line. Some examples are below:• Weathering certificate• Exemption certificate• Letter of indemnity• Competent Authority Approval

32

34

IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.4 and Chapter 7.9

Part A – Processing a dangerous goods consignment

Step 5:IMDG
segregation

A5 Segregation of incompatible dangerous goods

IMDG Part 7 predominantly looks at stowage and segregation of dangerous goods
both within a CTU and between CTUs onboard a ship.
Here though we focus on segregation within in a CTU as this is one of the major
considerations when packing containers.

A5.1 Introduction
Segregation in the context of the IMDG Code is the process of separating two or
more dangerous substances or articles which are considered mutually incompatible
when their packing or stowage together may result in undue hazards in case ofleakage or spillage, or any other accident.
Segregation can be considered in terms of:• between packages on deck, within the hold of a ship or loaded inside a CTU;
• between packages and CTUs; or• between CTUs.
As far as cargo packers are concerned, this means not packing incompatible
dangerous goods in the same cargo transport unit; for ship stowage planners itmeans stowing cargo transport units containing incompatible dangerous goods in
different parts of the ship to prevent a dangerous reaction between the contents ofthe different CTUs.
There are instructions in IMDG Chapter 7.2 for calculating the rules for determining
which dangerous goods are prohibited in the same shipping container and which
may be packed together.
In the following sections we focus on segregation within a CTU and the process thepacker must follow when packing different dangerous goods into the same CTU.

A5.2 Segregation checks when preparing a mixed load dangerous
shipment for transport
There are two key points at which a segregation check must be carried out. The firstshould be carried out by the shipper before offering a multiple hazard cargo, andthen when a packer is preparing to pack multiple hazard cargo into a single cargotransport unit.
A shipper offering different types of dangerous goods in the same consignment
needs to determine if the goods can be packed in the same cargo transport.
However, if the shipper sends his dangerous goods to a consolidator he has nocontrol over what is packed into the cargo transport unit. It is always the party who isin charge of packing the unit who must carry out the definitive segregation check.
Packers consolidating dangerous goods of different types into a cargo transport unit
for several different shippers need to carry out a segregation check between each of
the proposed dangerous goods items before packing commences as it is their
responsibility to sign the container packing certificate that attests, amongst otherthings, that the IMDG Code segregation requirements have been followed.

A5.3 Methods for checking the segregation
The only method of ensuring compliance is to follow the IMDG segregation rules
although there are different options for doing this:Part A – Processing a dangerous goods consignment

35

IMDG Code books
Train staff to consult the segregation rules in IMDG Chapter 7.2 and follow the rules
manually. This requires a basic understanding of classification as well as knowledgeof the segregation process. It can become complex when there is a high number ofdangerous goods items being shipped together in the same cargo transport unit.
Online validation systems
The often complex nature of applying the IMDG Code segregation rules can beassisted via computer based or online validation tools. UN Numbers are fed into theprogram and an IMDG Code compliance/non-compliance report can be
automatically generated.
Hazcheck Systems produced by Exis Technologies provide a number of solutions toassist with IMDG Code validation including complex segregation calculations. Further
details can be found at www.hazcheck.com. The screenshot below is taken from
Hazcheck Online and highlights the validation results for an incompatible dangerous
goods load:

Computerised systems like this are useful in calculating segregation, but users are
required to be familiar with the software as well as understand the IMDG Codesegregation process.
Software embedded in the shipping line booking system
Shipping lines frequently have IMDG Code software embedded into their booking
systems to assist in identifying segregation errors at the booking stage. This allows
errors to be quickly picked up before the shipment enters the transport stage.

A5.4 The IMDG Code segregation check process
The following outlines the main considerations when checking segregation for a
missed load of dangerous goods items.

36

Part A – Processing a dangerous goods consignment

Identify and gather all the dangerous goods details
To carry out a segregation check you will need to gather the UN Numbers, theclasses, sub-hazards, and packing groups of the dangerous goods to be packed, andfor N.O.S. whether or not they have a segregation group applied.
Check the segregation requirements between classes and sub-hazards
First check the compatibility between the classes of dangerous goods. Some classes
are incompatible with others, and must never be packed in the same shipping container.
If a substance has a sub-hazard, that must also be checked for segregation restrictions
against other classes and other sub-hazards in the same way as the main hazard
class. In order to do this table 7.2.4 of the IMDG Code, shown below, must be used.
Class

1.1 1.3 1.4 2.1 2.2 2.3
1.2 1.6
1.5

3

4.1 4.2 4.3 5.1 5.2 6.1 6.2

7

8

9

Explosives

1.1 1.2 1.5

*

*

*

4

2

2

4

4

4

4

4

4

2

4

2

4

X

Explosives

1.3 1.6

*

*

*

4

2

2

4

3

3

4

4

4

2

4

2

2

X

Explosives

1.4

*

*

*

2

1

1

2

2

2

2

2

2

X

4

2

2

X

Flammable gases

2.1

4

4

2

X

X

X

2

1

2

2

2

2

X

4

2

1

X

Non-toxic, non-flammable gases

2.2

2

2

1

X

X

X

1

X

1

X

X

1

X

2

1

X

X

Toxic gases

2.3

2

2

1

X

X

X

2

X

2

X

X

2

X

2

1

X

X

Flammable liquids

3

4

4

2

2

1

2

X

X

2

2

2

2

X

3

2

X

X

Flammable solids (including
self-reactive substances andsolid desensitized explosives

4.1

4

3

2

1

X

X

X

X

1

X

1

2

X

3

2

1

X

Substance liable tospontaneous combustion

4.2

4

3

2

2

1

2

2

1

X

1

2

2

1

3

2

1

X

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

4

4

2

2

X

X

2

X

1

X

2

2

X

2

2

1

X

Oxidizing substances (agents)

5.1

4

4

2

2

X

X

2

1

2

2

X

2

1

3

1

2

X

Organic peroxides

5.2

4

4

2

2

1

2

2

2

2

2

2

X

1

3

2

2

X

Toxic substances

6.1

2

2

X

X

X

X

X

X

1

X

1

1

X

1

X

X

X

Infectious substances

6.2

4

4

4

4

2

2

3

3

3

2

3

3

1

X

3

3

X

Radioactive material

7

2

2

2

2

1

1

2

2

2

2

1

2

X

3

X

2

X

Corrosive substances

8

4

2

2

1

X

X

X

1

1

1

2

2

X

3

2

X

X

Miscellaneous dangerous
substances and articles

9

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

The numbers and symbols in the table have the following meanings:
1 – “away from”
2 – “separated from”
3 – “separated by a complete compartment or hold from”
4 – “separated longitudinally by an intervening complete compartment or hold from”
X – the Dangerous Goods List has to be consulted to verify whether there are
specific segregation provisions* – see 7. 2.7.1 of this chapter for the segregation provisions between Class 1
substances or articles
Let’s look at an example of how this is applied and see if a Class 3 substance can be
shipped together with a Class 4.1 substance. Using table 7.2.4 we see the following:

Part A – Processing a dangerous goods consignment

37

Class

1.1
1.2
1.5

1.3
1.6

1.4

2.1

2.2

2.3

3

4.1

4.2

4.3

5.1 (continued
through theclasses)

Explosives 1.1

1.2

1.5

*

*

*

4

2

2

4

4

4

4

4

Explosives

1.3

1.6

*

*

*

4

2

2

4

3

3

4

4

1.4

*

*

*

2

1

1

2

2

2

2

2

2.1

4

4

2

x

x

x

2

1

2

2

2

2.2

2

2

1

x

x

x

1

x

1

x

x

2.3

2

2

1

x

x

x

2

x

2

x

x

3

4

4

2

2

1

2

x

x

2

1

2

4.1

4

3

2

1

x

x

x

x

1

x

1

4.2

4

3

2

2

1

2

2

1

x

1

2

4.3

4

4

2

2

x

x

1

x

1

x

2

5.1

4

4

2

2

x

x

2

1

2

2

x

5.2

4

4

2

2

1

2

2

2

2

2

2

Explosives(continued through the classes)

Since the two classes line up with an “x” in the crossover box this means that they
are compatible at general class and sub-hazard level, and may be compatible to bepacked in the same cargo transport unit.
If a 1, 2, 3, or 4 were displayed in the crossover box, this would mean that substanceswere not compatible and the segregation process stops there.
However, as the properties of individual substances and articles within each class mayvary greatly, the Dangerous Goods List, column 16b, must also be consulted forparticular provisions for segregation. Individual substances may be incompatible with asubstance of another class, or incompatible with substances in the same class as itself.
IMPORTANT: The individual segregation requirements in column 16b of thedangerous goods list take precedence over the general class provisions.

Check for specific segregation requirements in column 16b of the dangerous
goods list
As well as checking the generic class segregation requirements in 7.2.4 you mustalso check if there are any specific segregation requirements in column 16b. These
segregation requirements will be referenced via either:
Segregation group code(s) as per 7.2.5; and/or
Segregation code(s) as per 7.2.8.
If there are no class segregation clashes found in 7.2.4 it is important to check that
there are also no specific segregation clashes arising from these two additional
requirements. An example of how these appear in the dangerous goods list is
shown below:

38

Part A – Processing a dangerous goods consignment

Column 1
UN Number

Column 2
Proper Shipping Name

Column 3
Class

Column 16b
Segregation

2714

ZINC RESINATE

4.1

SGG7

2716

1,4-BUTYNEDIOL

6.1

SG35
SG36
SG55

2719

BARIUM BROMATE

5.1 (6.1)

SGG3
SG38
SG49

The meaning of these codes can be found in 7.2.5 (segregation group codes) and7.2.8 (segregation codes). From our example above:
UN 2714 – SGG7 – Heavy metal compoundUN 2716 – SG35, SG36 and SG55 –SG35 Stow “separated from” SGG1 – acids
SG36 Stow “separated from” SGG18 – alkalis
SG55 Stow “separated from” mercury salts
UN 2719 – SGG3, SG38 and SG49 –SGG3 – Bromate
SG38 Stow “separated from” SGG2 – ammonium compounds
SG49 Stow “separated from” SGG6 – cyanides
But what does this means in terms of segregation?
For UN 2714 this means that presence of SGG7 identifies this as belonging tosegregation group 7, heavy metal compounds. If this is stowed in a CTU with any othersubstance or article that requires segregating from heavy metal compounds then there
would be clash and these items must be segregated i.e. not stowed in the same CTU.
For UN 2716, there are a number of additional segregation requirements to consider.
If this substance is loaded in the same CTU as any other DG identified as being a‘acid’, ‘alkali’ or ‘mercury salt’ then this substance must be separated from that DG.
For UN 2719, this substance is a member of segregation group 3, bromates so if it
stowed in a CTU with any substance or article that must be segregated frombromates there would be a clash and the two items must not be stowed in the same
CTU. In addition, this commodity must also be separated from ‘ammonium
compounds’ and ‘cyanides’, so any DG loaded in the same CTU belonging to either ofthese two segregation groups must also not be stowed in the same CTU.
There are 18 segregation groups33 in total, all of which are listed below (with therelevant code that appears in column 16b in brackets):
1. Acids (SGG1 or SGG1a)
2. Ammonium compounds (SGG2)
3. Bromates (SGG3)
4. Chlorates (SGG4)
5. Chlorites (SGG5)
6. Cyanides (SGG6)
7.

Heavy metals and their salts (SGG7)

8. Hypochlorites (SGG8)
9. Lead and its compounds (SGG9)33

IMDG Code, 2018 Edition Amendment 39-18, Section 3.1.4.4

Part A – Processing a dangerous goods consignment39

10. Liquid halogenated hydrocarbons (SGG10)
11. Mercury and mercury compounds (SGG11)
12. Nitrites and their mixtures (SGG12)
13. Perchlorates (SGG13)
14. Permanganates (SGG14)
15. Powdered metals (SGG15)
16. Peroxides (SGG16)
17. Azides (SGG17)
18. Alkalis (SGG18)
There are 78 segregation codes34, an example of some of these is supplied below:
Segregation
code

Description

SG1

For packages carrying a subsidiary hazard label of class 1,
segregation as for class 1, division 1.3. However, in relation to goodsof class 1, segregation as for the primary hazard.

SG9

Stow “away from” class 4.3.

SG14

Stow “separated from” class 1 except for division 1.4S.

SG24

Stow “away from” SGG17 – azides.

SG26

In addition: from goods of classes 2.1 and 3 when stowed on deckof a containership a minimum distance of two container spaces
athwartship shall be maintained, when stowed on ro-ro ships a
distance of 6 m athwartship shall be maintained.

SG34

When containing ammonium compoundsstow “away from”
SGG4 – chlorates or SGG13 – perchlorates and explosives
containing chlorates or perchlorates.

SG48

Stow “separated from” combustible material (particularly liquids).
Combustible material does not include packing materials or dunnage.

SG59

Stow “separated from” SGG14 – permanganates.

SG68

If flashpoint 60ºC c.c. or below, segregation as for class 3 but“away from” class4.1.

SG78

Stow “separated longitudinally by an intervening complete
compartment or hold from” division 1.1, 1.2, and 1.5.

A5.5 Segregation group allocation for N.O.S. substances
Segregation is more problematic for N.O.S. substances used for generic entries,
mixtures, solutions and preparations. The technical names that comprise this N.O.S.
shipment might properly belong to segregation groups. If an N.O.S. substance hassignificant components that are in a particular segregation group, it would be likelythat the N.O.S, substance should be included in that segregation group for the
purposes of segregation, and if so, the shipper should allocate a segregation groupand mention it on his shipper’s declaration on the transport document.
ExampleUN 1760, CORROSIVE LIQUID, N.O.S. (Phosphoric acid, acetic acid),8, PG III, IMDG Code segregation group 1 – Acids

34

40

IMDG Code, 2018 Edition Amendment 39-18, Section 7.2.8

Part A – Processing a dangerous goods consignment

A5.6 Special segregation provisions and exemptions35
There are a number of special segregation provisions and exemptions from thesegregation requirements. These include:• Exemptions from taking into account conflicting subsidiary hazards if thesubstances are proven not to react dangerously with each other36• Exemptions for chemically similar substances37• Exemptions for class 8 acids and alkalis meeting certain conditions38• Exemptions for dangerous goods in ‘limited quantities’ or ‘excepted quantities’
provided they do not react dangerously with each other39

IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.11.1
IMDG Code, 2018 Edition Amendment 39-18, Section 7.2.6.1
37 IMDG Code, 2018 Edition Amendment 39-18, Section 7.2.6.3
38 IMDG Code, 2018 Edition Amendment 39-18, Section 7.2.6.5
39 IMDG Code, 2018 Edition Amendment 39-18, Sections 3.4.4 and 3.5.8
35

36Part A – Processing a dangerous goods consignment

41

Step 6:
Packing the cargotransport unit
40

A6 Packing the cargo transport unit
The packer is legally responsible for ensuring the dangerous goods are correctly
presented and the cargo transport unit safely packed. There are a number of
pre-packing checks the packer should build into his procedures to ensure thateverything is in order before packing commences.
These checks will identify problems in advance, and add to the safety of theconsignment, and assist the cargo handlers who will physically lift and stow thecargo. There are suggested checklists included in the Appendix to this Guide.

A6.1 Pre-packing assessment
Before packing commences, the packages and documentation should be checked by
a competent person and the following checks made:• The transport documents containing the shipper’s declaration(s) contain the full details• The packages have been checked for marks and labels, especially packages made up
into palletised unit loads• The package marks and labels tally with the details on the transport document• Confirm that segregation checks for mixed hazard goods have been successfully
carried out• Packages are checked for damage and any damaged packages are set aside• The packages are assessed for size, weight and strength• Any requirement for special handling equipment (e.g. drum clamps) is noted• Any special factors of the packages or stow are noted• Lashings, strops, air bags, pallets, timber and sheet material to support and brace thestow are available to the packers

A6.2 Creating a stow plan for the packers41
With the information about the consignment complete, a competent person should
create a stow plan and load list that can be given to the packers and handlingequipment operators.
This should guide the packers so that packing takes account of the following
key factors:• The size and type of packages so that weight is distributed evenly throughout the
shipping container• That packages are stacked in a way that does not overstress any individual package• That adequate securing and bracing of packages is done and gaps can be filled during
packing using materials as necessary to ensure the packages do not move in transit• The stow plan should indicate which packages are heavy and which are light, withthe lighter packages stowed on top of the heavier.

Further guidance can be found in the CTU Code:www.unece.org/trans/wp24/guidelinespackingctus/intro.html
41 IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code),
Chapter 3.2, 8, 9.1, 9.2 and 9.3
4042Part A – Processing a dangerous goods consignment

The stow plan should allocate cargo weight distribution
Measure the packages tomake sure they will fit into
your container
Check the weights ofpackages – then makesure the weight is spread
evenly across container
floor

Maximum 60% of
weight of cargo in
50% of length ofcargo transport unit

Weight spread evenly– container hangs level– no lateral stress on
cargo during lifting

Weight at one end –container dangerously
unbalanced

Part A – Processing a dangerous goods consignment

43

Lateral stress placed on cargo during lifting as container tips causes packages toshift resulting in a risk of crushing. Apart from the risk of packages being breached
and allowing dangerous goods to escape, the lifting equipment may be damaged, oroverbalance, adding physical injury and plant damage to the hazards of not balancing
the stow.

A6.3 Checking the condition of the cargo transport unit42
The cargo transport unit into which the cargo is packed becomes a “package” for thedangerous goods during the sea journey, so it must be checked to ensure that it issuitable for its job. The following section applies specifically to containers, but some
aspects will also apply to vehicles loaded to ro-ro ships.
Before packing any cargo transport unit, the condition of the unit should be visuallychecked by a responsible person to determine the following• Is it clean, dry and safe for packers to work in?
Ensure any marks and/or placards relating to previous shipments are removed.
• Is it suitable for dangerous goods?
• Is the container structurally sound?
• Is it within the legal safety inspection date?
• Is the plated capacity sufficient to carry the weight you intend to pack?
Check the maximum cargo weight marked on the right hand door.
Reject any cargo transport unit that is damaged or unsuitable.
Residue
Residue or contamination on the floor may be a hazardous substance that will injure
your employees or react with or spoil your cargo. Reject a contaminated container orclean it, having regard to potential injury to cleaners from an unknown substance.
Pest contamination
The CTU Code states “All persons involved in the movement of CTUs also have aduty to ensure, in accordance with their roles and responsibilities in the supply chain,that the CTU is not infested with plants, plant products, insects or other animals”43.
Structural damage
Check visually for any indication of excessive corrosion, cracks or impact damage tomain floor bearers or corner posts that may make the shipping container unsafe to lift.
Floor condition
Check that floor panels have not been damaged by overloaded fork lift trucks.
Holes and leaks
Check for holes in the roof and sides – many packages will be susceptible todamage from rain or seawater, and some dangerous goods react violently on contact
with water. Subject to safe working procedures, one method to detect holes is to
stand inside the container and close the doors.
Nails in the floor
Check the floor for nails protruding from the floor, and remove them. Timber blocks
and battens are often nailed to floors, and protruding nails are often left behind.
These are a frequent cause of damage to pallets and packages, particularly drums
packed direct to the container floor.

IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code),
Chapters 4 & 8 and Annex 4
43 See “Prevention of Pest Contamination of Containers: Joint Industry Guidelines for Cleaning of Containers”
www.worldshipping.org/industry-issues/safety/Pest_Contamination_Cleaning_Guidelines_Feb_2017.pdf
4244Part A – Processing a dangerous goods consignment

Old placards
Remove any redundant dangerous goods marks and placards from previous use – check
both sides, and both ends – if they cannot be removed, ensure they are painted out.
Container data plate
Check the inspection information on data plate on the door.
Left: ACEP data plate –continuous inspection
Right: data plate withnext due inspection
date stamp

If the plate displays the letters “ACEP” it means the container operator subscribes to
the Approved Continuous Examination Program and the container will meet theContainer Safety Convention requirements for five yearly and 30 month
examinations, and will normally also be inspected more frequently when thecontainer passes through the operator’s depot. If there is no ACEP mark, the data
plate is stamped with the next due date for inspection. If the date has expired, reject
the container. However, do not rely only upon data plate date stamps – use visualinspection and common sense.

A6.4 Packing the cargo transport unit44
The way the packages of dangerous goods are packed into a shipping container isthe most important factor in making the transport safe. Poor packing leading to intransit package damage, leaks and spills is the most common cause of damage togoods of all kind in cargo transport units. When dangerous goods are involved thepotential consequences for ships are amplified. The following guidance is based on
observation of numerous incidents. Follow the guidance and it will help you to avoid
the most common problems.
Never pack damaged packages into a shipping container
It is an over-riding principle that damaged or leaking packages are not packed into acargo transport unit. This applies to hazardous and non-hazardous materials. Despite
this, it is not uncommon to find that leaking packages have been packed.
Packages are accidently damaged from time to time during the handling as a resultof human error, or use of unsuitable handling equipment. Individual cargo handlers
may be reluctant to draw attention to the fact that they have caused damage for fearof repercussions, and companies may find it more convenient to conceal damaged
packages in a freight container than to set them aside and accept the cost ofclean-up, disposal, short-shipment or delays waiting for replacement packages. This
is not acceptable.
Spillages of dangerous goods may react with the floor of the container, timberpackaging/pallets or other cargo in a dangerous and unpredictable way. Spillages of
non-hazardous goods may react with other cargo, spoil or taint other cargo, or
damage other packages.

44

See also the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code)Part A – Processing a dangerous goods consignment

45

Pack dangerous goods closest to the door
If you are packing a cargo transport unit with a mixture of dangerous goods
packages and non-hazardous packages, always put the dangerous goods packages
closest to the door, with the labels also facing the door. In case of spillage or problem
with the dangerous goods, it is preferable that they are packed next to the doors
where the hazard class can be immediately identified when the emergency
responders are able to access the contents of the container.

✗✓
If the dangerous goods are stowed at the front of the shipping container, and there isa dangerous release from broken packages, the whole container will have to be
unpacked by workers in protective equipment before the dangerous goods arereached. This makes emergency response much more difficult, lengthy, expensive
and potentially dangerous.
Packages are only required to have labels on one side (two sides for IBCs) so as far
as possible, packages should be stacked so that the labels are facing the door,
where they can be seen by persons unpacking the shipping container or dealing
with a problem.

Packages stacked with dangerous goods labels facing the door

46

Part A – Processing a dangerous goods consignment

Pack solids over liquids
When drums of liquid have to be packed with packaged solid goods, never pack sothat solids are over-packed by liquids. In general liquids are often heavier than solids,
so it makes sense to pack with weight down, provided the drums are strong and canbear the weight. However, the main reason is for safety. If the drums leak, there will
be a release of liquid that will first be drawn downwards by the force of gravity, andwill then spread horizontally along the floor.
If the packages of solid goods are stowed on top of the drums, contact between thesolid goods and the spilt liquid will be reduced. This reduces the risk of a dangerous
reaction, and it is possible that no damage to the solid goods occurs at all.

If solids are stowed on top of liquids, even if a drum becomes damaged and fails,
there is a good chance that packages stowed above will remain unaffected.
Over-stowing cargo in shipping containers – Light over heavy
Over-stowing of one sort of cargo by another is proper and normal practice, when
done with regard to the strength and weight of packages involved. However, there
are many recorded incidents of packages of cargo in shipping containers being
crushed because they were over-stowed by goods heavier than they could bear.

To pack a cargo transport unit safely takes skill and planning based on awareness ofthe strength and contents of the packages.
It may seem obvious that it is not a good idea to pack heavy machinery parts on top
of fibreboard boxes containing fragile goods such as aerosols or glass bottles. To anexperienced packer, it is a simple decision to pack the heavy cases first, and put thefibreboard boxes on top. However, an unskilled packer may not appreciate the weight
difference and simply see an opportunity to build a flat platform of fibreboard boxes
that are perfect on which to place the heavy machinery. The fibreboard boxes may
survive the packing process but collapse once the cargo transport unit starts moving.
Inexperienced packers may mean no harm, but can do great damage to cargo
without intention, simply because they do not understand the forces that will work on
the shipping container at sea.
Part A – Processing a dangerous goods consignment

47

A6.5 Stacking capacity of packages – 20' versus 40' cargo transport unit
Packages are tested under the UN package certification system for stacking
strength by stacking them and leaving them for a period of time in a motionlesssituation, although vibration test protocols are becoming available.
Stacking tests do not fully
replicate the rigorous
conditions inside a cargotransport unit in transit,
where the packages are
subjected to all kinds ofmotion and vibration. In
reality, despite passing astatic stacking test, thelower tiers of cargo may
collapse under their own
weight, as demonstrated
in this photograph

Using sheet material between tiers is always recommended as a way of evenly
distributing the weight. A more effective way is to use a 40' container in preference
to a 20'.
Goods may physically fit within the cubic capacity of a 20' container, but that does
not mean it will travel safely. If the cargo from a 20' container is placed in a 40'
container the stack weight on the lower tier of packages will be halved. Although it
will cost more to ship a 40' container, it may make the difference between a
consignment arriving safely and intact, or damaged and unsaleable.
Stacking strength of packages is difficult to judge, and expensive errors are
frequently made. If the shipper has chosen packages of doubtful robustness, theforwarder should make the shipper aware of the safer option of paying a little more
for a 40' container.

L

M

Using a 40' container
Using a 40’ container instead of a 20’
instead of a 20' increases
increasescosts,
shipping
costs,
but greatly
shipping
but
greatly
reduces thestacking pressure
reduces
thedownward
downward
on lower tiersof packages
by reducing thestackingpressure
on lowertiers
packages bystackofheight.
reducing the stack heightL

M

Because a 40' unit has been used, timber bracing will be needed tosecure the packages from lateral movement in the upper tier because
the upper tier does not reach from end to end of the shipping container

48

Part A – Processing a dangerous goods consignment

A6.6 Gap-stacking for air circulation
Some substances, particularly of Classes 4.1, 4.2 and 5.2, are sensitive to heat, or are
liable to self-heat. Consignments of packages may need to be packed for transport
such that air can circulate between individual packages. This helps to dissipate heatfrom local areas and prevent “hot spots” from developing deep inside the container.
Reefer containers may be specified by the shipper to provide thermal control.
Shippers must provide clear guidance on packing if this system is required.
Packages may be stacked directly into the container, or may be palletised. Gaps left
between the packages should not be so large as to create “point loading” effect on
the corners of the packages.
It may be desirable to use a 40' container in preference to a 20' to keep the stacks
as low as practicable. This will enable the stack heights to be halved and the air
space inside the shipping container to be maximised.
While clearly air circulation is an important consideration, it is critical that appropriate
account is taken of the need to block, brace and secure cargo to protect it against
the dynamic forces that will occur during transport.

A6.7 Packing drummed cargo into cargo transport units
Steel and plastic drums of around 200 litre capacity are a common package choicefor dangerous goods, but drums of up to 400 litres are acceptable for someproducts. A 20' container will comfortably take 80 x 200 litre steel or plastic drums
and this is a common consignment. Drums are produced in a range of smaller sizes.
Strength and resistance of drums
Drums can be very robust, particularly plastic drums and steel drums with plastic
liners, but both are vulnerable in certain areas. If drums that contain liquid arepunctured, there is the obvious potential for a significant release of dangerous goods
from a small hole.

High quality modern drums are resistant
to damage, but are not indestructible

Plastic and steel drums will withstand a fair amount of rough handling before thesidewalls rupture, and will deform extensively on impact before rupturing. Plastic drums
will retain their original shape after a severe impact, but they are prone to blowing out
their closures if subjected to sudden impact such as dropping. Also at very hightemperatures and in strong direct sunlight the walls soften, giving them lessresistance to cutting and a greater liability to lose rigidity if over-stowed heavily. Bothmaterials are vulnerable to cutting if the sidewalls are struck with a sharp object.
If heavily over-stowed, plastic drums are liable to deform gradually, making the whole
load unstable. Steel drums largely avoid this.
Handling drums on pallets
It is common to pack drums to a pallet as several can be handled in one lift, and no
special drum-handling equipment is needed. However, fork lift drivers need to beaware that steel drums puncture easily – they need to take care when working thatthe fork lift arms do not protrude beyond the pallet being lifted, and stab the nearside
drum on the pallet previously positioned. This is a common type of incident during
packing, because it occurs outside the operator’s range of vision.

Part A – Processing a dangerous goods consignment

49

Punctured drums MUST be removed from the cargo transport unit
Drums leaking from damage received during packing are sometimes not removed
from the container, causing problems later in the journey. If dangerous goods are
involved, emergency procedures should be instigated by the fork lift operator.
Recommended good practice for handling drums:• Drums are easy to handle if the right handling equipment is provided.
Drums stabbed by fork lift – a common
cause of drum damage during handling• Loose drums are best handled using appropriate drum clamps attached to fork lifts.
• Drums banded to pallets can be lifted four or more at a time, and can be packed
using a conventional fork lift.
• Palletised drums should be banded or film-wrapped tightly together, and banded tothe pallet.
• Excessive manual rolling of full steel drums should be avoided, particularly over roughconcrete, muddy ground, or ground containing small stones, as the drum seams or
sidewalls can be damaged and stones can get embedded on the bottom of drums,
and can cause punctures to the drums later in transport or during handling.

Drums on pallets should be wrappedwith film or banded to keep thembound together as a unit

Drums being packed with drum clamps

50Part A – Processing a dangerous goods consignment

Banding on pallets
Steel drums are also prone to sideways chafing if the rolling hoops align exactly
during extended transit, particularly by rail, which can generate intense vibration.

Rolling hoop chafing
Drums can be wornaway in transit where
the rolling hoops line
up and are in contact
for extended journeys

Recommended good practice for avoiding sideways chafing
In order to avoid edge to edge contact of the rolling hoops, particularly for long sea
journeys, it is advisable to put plastic or heavy cardboard sections between drums
bound together on pallets to prevent metal-to-metal abrasion.
Drums on the roll45
It is forbidden to stow drums containing dangerous goods “on the roll”. Drums haveclosures at the top that are not designed to be below the liquid level.

✗Drums containing dangerous goods shall always be stowed in an upright position
unless otherwise authorised by the competent authority.
Using sheet timber spreader sheets between tiers of drums
Steel drums are designed to be stacked in tiers, and are often loose-packed into
cargo transport units using drum clamp attachments.
However, steel on steel contact between the upper and lower drums during a sea
voyage provides no resistance to movement, and the drums are liable to slide, causing
the metal of the upper drum to be worn away on the lower rim seal, and drums to abradeagainst the container walls. This can lead to leakage from drums in the upper tier.
Placing sheet timber material between the layers of drums can easily prevent thissliding motion and reduces the build-up of pressure points motion where drums abradeagainst each other. Low-grade plywood is suitable, but chipboard is not recommended
as it has less integral strength and degrades quickly in damp conditions.
Placing timber sheet between tiers of plastic drums also makes the stow more rigid
and stable.

45

IMDG Code, 2018 Edition Amendment 39-18, Section 7.3.3.4

Part A – Processing a dangerous goods consignment51

A6.8 Packing dangerous goods on pallets
Stacking and wrapping packages to pallets to make unit loads is universal practice.
However, some problems can arise from careless use of pallets, and pallets can be
the indirect cause of serious releases of dangerous goods.
Point-loading – pressure damage to cargo overstowed by palletised goods
Palletised cargo stowed in upper and lower tiers inside cargo transport units candamage the cargo below, if the packages below are susceptible to pressure damage.
This occurs if the weight of the palletised cargo is transferred to the goods below
through the pallet’s corner blocks, and is not spread evenly. The result is point-loading.
Point loading
Here, a pallet has
damaged the drums
below. The indent of thepallet above can be seenon the top of the drum inthe corner. This could
have been prevented byusing a spreader sheet ofplywood between thetiers of pallets

If the packaging of the goods on the lower tier is susceptible to point-loading
damage, for example bags, plastic drums, paint pails, plastic and light steel jerricans(particularly the commonplace 5 litre light steel jerricans frequently used to retaildangerous goods), the packaging can collapse. This allows the product to escapeand the pallet to further collapse.
If the surface of the cargo onto which the upper tier of pallets is packed is uneven,for instance bagged cargo, rounded plastic drums, or if the sizes of the packages on
the lower tier is uneven, the pallet above may deform to the point of partial
disintegration, causing further potential damage to cargo from protruding nails or
split wood. The upper tier will become unstable if pallets break up, causing the cargo
to shift inside the container, causing further cargo damage and further load instability.
Recommended good practice to avoid point-loading
The best protection is the provision of a layer of timber sheet material placed overcargo on lower tiers to spread the weight of over-stowed pallets evenly and prevent
point loading. Low-grade plywood sheeting commonly used in the constructionindustry (shuttering board) to retain liquid concrete is suitable as it is robust,
economical and widely available.
Common problems caused by pallet failure
Some pallets are robust and have strong lower bearers and flat load bearing upper
panels made of solid boards. Heavyweight pallets are made for repeated use, areresistant to deformation, and can bear substantial loading without deformation or riskof disintegration. However, many pallets are designed for single use, and are
constructed simply, economically and use low quality timber. Many are of extremely lightand flimsy construction. This is acceptable provided the limits of the pallet are taken into
account. Heavy cargo placed on to light grade pallets will deform or break the bearers.
The less robustly the pallet is constructed the more likely the pallet bearers will
deform both under the weight of the cargo, and to the shape of the surface beneath.
Even if the cargo is not damaged in transit, deformed pallets can make unpacking
the goods by fork lift very difficult, particularly when stowed with flexible IBCs. Whenpallets break up, it is often difficult to remove cargo from cargo transport units
without causing further damage to the packages of cargo.

52

Part A – Processing a dangerous goods consignment

Lightweight pallets havebeen used for heavy
cargo that has caused
the pallets to break up
and point packing has
caused the plastic drums
beneath to deform andcollapse

It is common for a fork lift operator to accidentally stab a package with the forks
underneath the pallet while attempting to pack or unpack collapsed pallets. Flexible
IBCs (usually 1-tonne woven polyester bags) damaged in this manner may releaseconsiderable amount of product and are difficult to handle manually. If fine powders
such as carbon black are released, the recovery operation is dirty and contamination
is difficult to contain.
If palletised boxes or 25 kg bags are involved, the pallet loads can be broken down
manually and unit loads dismantled piece by piece. This adds greatly to the time andcost of handling, and defeats the objective of unitising the cargo in the first place. It
also adds to the risk of individual packages being damaged during manual handling,
and the time and cost of unpacking a container of dangerous goods in this way isconsiderable if workers need to wear breathing apparatus and protective clothing.
Recommended good practice to avoid collapse of pallets
It is best to select pallets strong enough to accept the mass to be borne by them. It
may sound obvious but it is surprising how many times pallets are simply not strong
enough to perform their function – to support the mass of the cargo during
mechanical handling. It is accepted that in many situations there will not be a great
choice of pallets, and perhaps only lightweight economy pallets are available.
However, such pallets can easily be strengthened by cutting timber sheet material(such as plywood) to the same size as the pallet, and placing it on top of the pallet
before packing it, and between tiers if the pallets are being stacked one on the other.
This will distribute the weight evenly and help to keep flimsy pallets intact by
preventing the bearers from deforming.
Pallet inspection and selection
Many pallets are cheaply made from poor quality timber, and even well-made pallets will
break up eventually if continuously re-used. It is common for nails to work out of the top
boards and protrude upwards, presenting a risk of tearing bags or puncturing drums
placed on the pallets. Such nails are not easy to see, so if old pallets are being re-used,
the pallets should be checked carefully for split corner blocks and protruding nails.

Typical nail-puncture damage
Red dye can be seen leaking from ahole made by a nail that was protrudingfrom a broken palletDrums in particular present a problem. If placed on top of a protruding nail it iscommon for the bottom of the drum to be pierced, then temporarily sealed by thenail, so that the packers cannot observe the damage. The hole remains sealed until
the container is moved. The nail hole is then gradually enlarged by the nail acting asa file, wearing away the metal or plastic of the drum until the hole is enlarged enoughto release the product.
Use of second-hand or economy pallets can appear to be a money saver, but theultimate cost in cargo damage, extra handling, spillage response costs andincidents caused by release of dangerous goods means that cheap pallets can be afalse economy.

Part A – Processing a dangerous goods consignment

53

Recommended good practice in choice and selection of pallets fordangerous goods
Before using any pallets, but particularly new economy pallets and second use
pallets, they should be inspected for protruding nails and rejected or repaired. The
use of timber sheeting cut to the size of the pallets will prevent nails from damaging
the cargo, while adding to the strength of the pallet. However, low quality pallets are
not recommended for use with dangerous goods.

A6.9 Solid frame Intermediate Bulk Containers (IBCs)
Solid frame IBCs are very common re-usable packages, a kind of small tank for liquids
or powders designed for convenient mechanical handling. The most common size isaround 1,000 litres in capacity and weighing around 1 tonne filled, but they may be
up to 3,000 litres. A common design type is a semi-rigid plastic inner receptacle
protected by a metal frame with a filler cap on the top and valve near the bottom,
filled and discharged by gravity. While the frame is generally sturdy, the inner isvulnerable and not designed to withstand external pressure, point-loading or impact.
Left: Typical composite
IBC (Intermediate Bulk
Container) – innerplastic receptacle
inside a rigid metal
cage – not designed to
be separated in use
Right: An IBC with the
top of the innerreceptacle broken bycareless overstowing

Stacking composite IBCs
Most composite IBCs are designed to be stacked, one on top of the other. If they areof the same design, this works well and they nest together securely. However, there
is no standard design or size. Many instances have been investigated where IBCs ofdifferent shapes and profiles carrying liquids have been stacked two-high incontainers, causing a variety of failures of the inner receptacles of the lower tier.
IBCs have data plates that record inspection dates and display symbols indicating
the maximum stacking load,46 as shown in the figures below:
Left: Symbol for IBCs
capable of being stacked,
with the maximum stackweight indicatedRight: Symbol for IBCs
NOT capable of being
stacked

46

54

IMDG Code, 2018 Edition Amendment 39-18, Section 6.5.2.2.2

Part A – Processing a dangerous goods consignment

Common causes of IBC failures in transport
The following problems can occur if stacked IBCs do not fit together or “nest”
securely one on top of the other, or are carelessly over-stowed with other cargo:
Point loading punctures
If the upper IBC is slightly smaller than the lower, or is misaligned, one or more of thefeet of the upper IBC can rest on the inner receptacle of the lower, eventuallycausing a puncture under pressure, forcing the contents of the lower IBC to be
expelled. This leads to tilting of the upper IBC, causing further instability in the load.
Excessive downward pressure on an inner receptacle causes the closure to failIf the upper IBC is smaller all round than the lower, it can sit inside the frame of thelower IBC, resting on the top of the inner receptacle. This will put excessive
downward pressure upon the inner receptacle causing it to deform inwards, which
can force the contents past the closure, or cause the closure to rupture, or cause theinner receptacle to fail catastrophically.
Damage during packing
If IBCs do not fit squarely together when stacked in the cargo transport unit because
they are not the same size or shape, it is often difficult to use the fork lift truck
without causing damage to one or other of the units during packing and unpacking.
Damage may be done to valves or the vulnerable inner receptacle, out of the line ofvision of the fork lift driver, perhaps without his knowledge.
Damage from overstowing
When one tier of IBCs is stacked inside a container it is tempting to use the flat topsof the IBCs as a load platform for other goods. IBCs are not designed to accept
random overstowing. Unless the overstowed packages are very light in weight, it iseasy to apply excessive downward pressure on the IBC, crushing the innerreceptacle, again forcing product past the closure, causing rupture of the closure orcatastrophic failure of the inner tank.
The inner plastic
receptacle of this IBC
has partly collapsed
under the weight of apallet that has broken
through the top sectionof the IBC’s protective
metal frame

Good practice in the packing of IBCs
For the best results, IBCs of different design should not be mixed. If this cannot be
avoided, the best solution is to board out on top of the lower tier of IBCs withwooden sheet material, cut to make a false floor. With this in place, the lower tier isprotected and a tier of different shaped IBCs can safely be packed on top. Withtimber sheet material on top strengthened by timber planks or bearers, point loading
is avoided, and a single tier of IBCs can safely withstand the weight of items placed
on top of them as indicated by the stack weight symbol on the data plate.

Part A – Processing a dangerous goods consignment55

A6.10 Securing the cargo inside the cargo transport unit47
Unsecured packages are a major cause of damage to cargo. When non-hazardous
cargo is damaged, the effect is expensive, time consuming, causes irritation tocustomers, and can cause cancellation of trade contracts. When the damage involves
dangerous goods, it is all these things, plus it can create the conditions for a fire or
explosion, catastrophic to a ship at sea, risking death and injury, and widespreadcargo destruction, and disruption of the supply chain.
This cargo wasinsufficiently secured.
Gaps were left into
which cargo fell and as aresult cargo was lost
through breakage andcontamination

Gap filling using pallets
The aim of securing cargo is to ensure it does not move within the shipping
container. Movement results in damage to packages and consequent loss of cargocontainment. In an ideal situation, cargo would fit neatly into containers with no gaps
between packages of cargo, and no gaps between packages of cargo and the wallsof the container. If there are gaps, the gaps must be filled.
Using pallets and timber
to fill a gap and make agate between the cargo
and the doors

Various methods can be used. A crude but effective method is to use pallets to fillgaps. They are freely available in most packing facilities, are light and easy to fit into
place, and a convenient shape. Any smaller gaps between pallets can be filled out
with planks of wood.
Pallets can be used in combination with heavy timber struts to produce effective
walls to brace cargo. This is not an approved method, but it is a very common
procedure, and if done carefully is effective.

Using inflatable air bags to fill a gap
between rows of pallets

Gap filling using air bags
A more sophisticated method of gap filling is to use inflatable airbags. These are
more expensive and need air pumps to inflate the bags, but they are very
effective. Care must be taken not to over-inflate bags in cold temperatures if the
cargo is going to the tropics – as the air inside the bags will expand and could
burst the bags.

47

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Chapter 9.4 and Annex 7

Part A – Processing a dangerous goods consignment

Blocking and bracing
Often there is a large gap between the cargo and the container doors, and it is morepractical to build a “gate” behind the cargo, and support that with timber bearers than
it is to physically fill the gap.

Timber “gate” to restrain cargo and bracing struts running back from gate to rearcorner posts to support the gate restrains both upper and lower tiers of cargo.

Upright battens
wedged against
the container
corner posts – (thestrongest part ofthe container) takethe strain

Timber cross-struts tohold back the cargo

The weight of the cargo
is transferred to thecorner posts by sturdy
bearers nailed together

Blocking and bracing to achieve equal weight distribution
If individual packages of cargo are heavy, it is sometimes necessary to place cargo in
the centre of the container to achieve reasonable weight distribution. This may
require blocking and bracing at both ends of the top tier of cargo.

Blocking to prevent fore and aft movement of packages in the upper tier that does
not reach from end to end of the shipping container

Part A – Processing a dangerous goods consignment

57

Batten nailed
to the floor

A sturdy timber batten 100mm x 150mm nailed to the floor of the shipping container
is an effective way of resisting fore and aft movement for low profile packages ifthey are securely banded to pallets

A6.11 Lashing cargo inside cargo transport units
Most cargo transport units are manufactured with lashing points or tie down points
along the bottom and top rails. Such anchor points that are provided along thebottom rail are usually rated at 10 kN48 in any direction. The Lashing points along the
top side rails are usually rated at 5 kN. There is often also a tie bar running along theside walls at a height of about 1 metre above floor level. These are not designed totake substantial weights. There is no reason not to use lashing points where thecargo allows access, but blocking and bracing and gap filling is often a more
effective method of securing cargo.
Container lashing points

It is recognised that using strops and ropes to lash down cargo inside cargo transportunits using the lashing points provided is difficult – much more difficult than lashing flat
racks for instance, where good all-round access is available. Access inside the shipping
container after and during packing cargo is usually awkward and restrictive, and it isoften not easy to position the lashings where they would be most effective. It istherefore easier and more effective to fill the gaps between pieces of cargo inside box
containers to prevent them from moving than to lash them using the lashing points.

A6.12 The packer’s documentation – the packing certificate49
When dangerous goods have been packed into a cargo transport unit for sea, apacking certificate must be prepared and signed by the packer.
This is a binding declaration signed by the packer to state that he has checked thatthe goods have been packed, segregated, marked, labelled and secured in the cargotransport unit in compliance with the provisions IMDG Code, and that cargo transport
unit itself is fit to carry the goods.

A6.13 Placarding and marking cargo transport units50
When dangerous goods have been packed into a shipping container, placards andmarks must be fixed to the outside of the shipping container to indicate the hazard
class or classes, including sub-hazards of the dangerous goods inside.
Placards must be fixed to both sides, front and back of the shipping container.
Note: The packer is responsible for attaching placards to the outside of the container.

A kilonewton, being the measurement of the force required to accelerate a mass of one kilogram at
a rate of one meter per second squared.
49 IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.2
50 IMDG Code, 2018 Edition Amendment 39-18, Chapter 5.3
48

58

Part A – Processing a dangerous goods consignment

Single hazardous
substance ofClass 3(less than
4000 kg)51
Diamond placard(250mm x 250mm)
both sides and bothends of cargotransport unit

Single hazardous
substance ofClass 3 (more than
4000 kg)52
Diamond placard(250mm x 250mm)
and UN Number onorange panel bothsides and bothends of cargotransport unit

250 mm

300 mmAdding UN Numbers
120 mm

UN 1296

UN 1296

Two acceptable waysof adding UN numbers
to placards on cargotransport units

250 mm51
52

IMDG Code, 2018 Edition Amendment 39-18, Section 5.3.1.1
IMDG Code, 2018 Edition Amendment 39-18, Section 5.3.2.1

Part A – Processing a dangerous goods consignment

59

When it is required to display the UN Number, it can be displayed on separate
orange panels (right) or on white panels on the placards (left).
Two substances ofdangerous goods
Placard for bothclasses on bothsides, front andrear of cargotransport unit

Placards required for two dangerous substances, both with a single hazard class
One dangerous
substance with
sub-hazards
If dangerous goods
cargo has a subhazards, placards
for the main hazard
class and sub-hazard
must be displayed
If there is a single
substance more than
4000 kg the UN
Number is added
Placard for bothclasses and UN
Number on bothsides, front andrear of cargotransport unit

Placards and UN Number required for single substance with a sub-hazard,
more than 4000 kg
250 mmMarine pollutant mark53
Marine pollutant marks must be displayed on both sides front and back of a shipping
container that contains any dangerous goods classed as marine pollutant.
250 mm

250 mm

250 mm

The marine pollutant mark is added to cargo transport units carrying substances thatare environmentally hazardous but not otherwise dangerous, and also to substancesthat are classified as being both dangerous goods and also environmentallyhazardous as a sub-hazard
Limited Quantities mark54
Limited quantity marks must be displayed on both sides and front and back of ashipping container that contains dangerous goods in limited quantities only.
A CTU containing BOTH dangerous goods packed in “limited quantities” and otherdangerous goods must be placarded and marked according to the provisions
applicable to the other dangerous goods. No “limited quantities” mark is required on
the CTU in this instance.
53
54

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IMDG Code, 2018 Edition Amendment 39-18, Section 5.3.2.3
IMDG Code, 2018 Edition Amendment 39-18, Section 5.3.2.4

Part A – Processing a dangerous goods consignment

Step 7:
The packing
certificate
55

A7 The purpose of the packing certificate
After dangerous goods have been packed into any cargo transport unit (containers
or vehicles) for a maritime journey a certificate must be signed by the packer tocertify that the dangerous goods have been properly marked and labelled,segregated, secured, that no leaking packages were packed, and the container has
been correctly placarded and that the packages and the cargo transport unit comply
with every requirement of the IMDG code. This is called the “packing certificate”.

A7.1 Who signs the packing certificate?
The person directly controlling the cargo transport unit packing operation is
responsible for signing the packing certificate.
Shippers can only sign packing certificates if they also control the cargo transport
unit packing operation. Shippers that pack their own dangerous goods into cargotransport units become the packers and are legally obliged to complete and sign thepacking certificate section of the dangerous goods transport document as well as
the shipper’s declaration.
Shippers should not issue shipper’s declarations to any third party with the packing
certificate signed before the cargo transport unit has been packed. Shippers whoarrange for third parties to pack their dangerous goods into cargo transport units on
their behalf should never complete or sign the packing certificate at any stage.

A7.2 Packing certificate on a combined document
Most organisations use a dangerous goods transport document based on the UN
multimodal document that includes both the shipper’s declaration and the packing
certificate on a single document – a “combined document”. See related informationin Section A4.4 and a completed example of the UN multimodal document
illustrated below.
Shippers using a third party to pack their dangerous goods will complete and sign
the shipper’s declaration section on the combined document, and send that with thedangerous goods to the packer.
The packer must ensure that he completes and signs the packing certificate sectionof the dangerous goods transport document after the dangerous goods have been
packed and the cargo transport unit has been sealed for transport.
The shipping line will require a signed copy of the packing certificate before loading
the cargo transport unit to a ship.

A7.3 Legal status of the packing certificate
Like the shipper’s declaration, the packing certificate is also a legal declaration. No
technical details about the dangerous goods are added by the packer, he only adds
his signature, name, status, company and date of signing to the document, but by
doing so he creates a legally binding statement that he accepts responsibility for thesafe condition, marking, labelling, placarding, packing and securing of the dangerous
goods in the cargo transport unit, and the structural integrity of the unit itself.

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Part A – Processing a dangerous goods consignment

61

A7.4 Legally binding statement by the cargo consolidator / cargo transport
unit packer56
The specific safety factors concerning the packing of dangerous goods into a cargotransport unit for which the packer accepts responsibility are set out in clauses on
the reverse page of the UN model dangerous goods form that is reproduced in the
IMDG Code:

56

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IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.5.1

Part A – Processing a dangerous goods consignment

The signature given overleaf in box 20
must be that of the person controllingthe container/vehicle operation.

When materials are transported in bulk
packagings, the cargo has been evenly
distributed in the container/vehicle.

It is certified that:

The packages and the container/vehicle
have been properly marked, labelled andplacarded. Any irrelevant mark, labelsand placards have been removed.

The container/vehicle was clean, dry
and apparently fit to receive the goods.
If the consignments include goods ofclass 1, other than division 1.4, thecontainer/vehicle is structurally
serviceable.
No incompatible goods have been
packed into the container/vehicle
unless specially authorized by thecompetent authority.
All packages have been externallyinspected for damage and only soundpackages packed.
Drums have been stowed in an uprightposition unless otherwise authorized by
the competent authority.
All packages have been properly packed
and secured in the container/vehicle.

When substances presenting a risk ofasphyxiation are used for cooling or
conditioning purposes (such as dry ice(UN 1845) or nitrogen, refrigerated
liquid (UN 1977) or argon, refrigerated
liquid (UN 1951)), the container/
vehicle is externally marked inaccordance with 5.5.3.6.
When this Dangerous Goods Form isused as a container/vehicle packing
certificate only, not a combined
document, a dangerous goods
Declaration signed by the shipper or
supplier must have been issued/received to cover each dangerous
goods consignment packed in thecontainer/vehicle.
Note: The container/vehicle packing
certificate is not required for tanks.

A7.5 Summary of the provisions of the packing certificate
In summary, the packing certificate certifies that the dangerous goods packages
were properly marked and labelled, packed in good condition, properly segregatedfollowing IMDG Code rules, the cargo transport unit was itself in good condition, andthe goods were packed and secured in a fit state to withstand a journey by sea, andthe cargo transport unit was marked and placarded according to IMDG requirements.

Part A – Processing a dangerous goods consignment

63

The final
objective:
Safely loading
containers to
the shipLoading the ship – the role of the cargo planner
After the packer shuts the doors on a cargo transport unit and applies the security
seal, under normal circumstances no-one will see inside a container until it reaches
its destination. The cargo transport unit will be delivered to the marine terminal where
it will wait its turn to be hoisted aboard a ship with hundreds of others, and the sea
journey will begin.
The position where dangerous goods are stowed on the ship is carefully selected by
specialists called cargo planners, and the safety of the ship depends on theirdecisions. The position is chosen by the cargo planner based on the dangerous
goods information given to him by the shipping line booking staff originating from theshipper or forwarder, and the container packer.
This is safety critical information for the ship. The data passes through many hands
to the cargo planner so it is vital that the data is correct and comprehensive and does
not get omitted, altered or shortened. This could lead the planner to create a stowage
that makes the ship unsafe.
Precise and comprehensive information is vital to the plan
It is of absolute and utmost importance that packers declare EXACTLY what items ofdangerous goods are in the consignments they have booked. There must be no
hidden dangerous goods. There must be absolutely NO QUESTION that all
dangerous goods have been declared to the shipping line and the identity and details
are included on the transport document.
If there are one, two, three or more types of dangerous goods in a freight container
the packer must tell the shipping line about each and every one.
Only with this assurance can the cargo planners stow the cargo on the ship in a safe way.
In view of the frequency and severity of incidents, the IMO has set out guidance57 in
relation to inspection programmes for cargo transport units, encouraging governments
to undertake CTU inspections and report their findings.
A number of container shipping lines have additionally implemented inspection
programmes in order both to enhance safety aboard their ships and improve goodpractice amongst shippers.
Further the Cargo Incident Notification System (CINS) was launched in September
2011 to increase safety in the supply chain, reduce the number of cargo incidents onboard ships and on land, and highlight the risks caused by certain cargoes and/or
packing failures. CINS enables analysis of operational information on cargo andcontainer incidents which lead to injury or loss of life, loss or serious damage ofassets and environmental concerns.

Undeclared dangerous
goods are totally
unacceptable forcarriage by sea

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Part A – Processing a dangerous goods consignment

Calculating stowage and segregation
Planning where to put containers on a container ship is a complex and precise
operation. The planners will choose a location for every individual dangerous goods
container based on what they know about the design of the ship and what they havebeen told about the dangerous goods by the shipper and packer. Containers may beburied deep in the hold of a ship, positioned on deck where the crew can carry out
daily monitoring, stowed as far as possible from the crew’s quarters, stowed where
they will not be exposed to heat, or stowed away from other dangerous goods.
Stowage on the ship
Stowage means “where on the ship” a container is put. This is an important decisionthat can only be taken when the design of the ship and the dangerous goods cargodetails are known. Bearing in mind that turnaround in a single port call may run into
thousands of containers on and off a 20,000 TEU ultra large container ship, this ischallenging operation.
Despite the numbers, the cargo planners choose an exact location on the ship forevery dangerous goods shipping container, based on the data provided by theshipper. Cargoes that have to be monitored must be located on deck, heat sensitive
cargoes must be located where they will not be affected by sources of heat, andincompatible cargoes must be physically kept apart.
Segregation of dangerous goods on the ship
Segregation as applied to ship stowage means not loading containers carrying
incompatible dangerous goods next to or close to each other. They will be located at
a distance apart on the ship58. The rules are strictly adhered to in order to minimise areaction in dangerous goods in one container spreading to dangerous goods inadjacent containers. Some substances are considered such a high risk combination
they must be separated on the ship by at least two fireproof walls.
Despite the fact that dangerous goods appear visually to be intrinsically safe in theircontainers, evidence from ship fires is very much the opposite. When involved in fires
on ships, heat inside containerised cargo builds up to the ignition point of the cargosurprisingly quickly, and being encased in the container, the fire fighting water or CO2
is prevented from reaching the seat of fire. Once a fire takes hold on a ship it is very
difficult to contain, and below deck they are practically impossible to access.
Knowing exactly what dangerous goods are in a container, and where they are on theship is paramount in the minds of ship planners and ship’s crews, and all depends on
the accuracy of the information supplied by the shipper and the packer.
Protecting temperature-sensitive substances from sources of heat
Some substances are sensitive to heat and will begin an uncontrollable polymerizingor self-heating reaction if exposed to raised temperatures. Stabilization and thermal
control are used to counter-act this, but locating them on the ship where they will not
be exposed to local sources of heat is critical. Heat can come from three sources:
Heat from the ship’s machinery
The largest container ships are 400 metres long and carry over 20,000 TEU (20'equivalent containers). Ship’s engines and other machinery needed to power suchships are equally massive, and generate huge amounts of heat in steam pipes,
exhaust pipes and fuel heaters that can be adjacent to cargo carrying spaces.
Heat from the sunContents of containers carried on deck that are fully exposed to the sun can alsoreach very high temperatures and in tropical regions temperatures of up to 60°C
have been recorded by monitoring devices inside cargo transport units.
Heat from other cargoSome cargoes are carried in tanks at an elevated temperature to keep them fromsolidifying from the liquid to the solid state. Cargo stowed adjacent to them will bedirectly affected.

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Part A – Processing a dangerous goods consignment

65

Areas that ship planners must avoid when stowing heat sensitive cargoes
Danger area
Containers subject to direct
heat from the sunDanger area
Containers subject toheating from ship’s
machinery

Danger area
Containers subject toheating from hot fueltanks

ExampleUN 2880, CALCIUM HYPOCHLORITE, 5.1
Stowage instructions include: “SW1 Protect from sources of heat” and “SW11
Shaded from direct sunlight”
These instructions tell the ship planner that he must not allow the container to beplaced in the ship close to hot machinery, fuel heaters or steam or exhaust pipes,
or in an exposed location on deck where it can be heated directly by sunlight.

Ship planners depend on the shipper’s information to load a safe ship
Ship planners use sophisticated planning software to assist them handle the huge
numbers of containers involved in ship port operations when creating a stowage planin compliance with the IMDG Code rules. However, that software, the sophisticatedresources of the shipping line and the skill and experience of the ship planners isuseless and ineffective if the basic information provided by the shipper is wrong, orthere is information missing, whether accidentally or deliberately.
WARNING!
Ship planners depend entirely on the accuracy of information supplied by theshipper and container packer.
If you do not report every UN Number, the proper ship segregation and stowage
checks cannot be made.
Missing or inaccurate dangerous goods information will result in
unsafe stowage.
If you fail to declare, you place the ship in danger and are in breach of statelegislation.
In the event that mis-declaration leads to an incident, you render yourself liablefor civil court action for damage recovery and injury compensation.
A more detailed and extensive description of the issues concerning stowage of
dangerous goods on board ships can be found in the CINS publication, “Safety
Considerations for Ship Operators Related to Risk-Based Stowage of Dangerous
Goods on Containerships”.59

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Part A – Processing a dangerous goods consignment

Conclusion

We hope that you find this guide book helpful.
If you are a shipper, apart from classifying yourcargo accurately, is important for you to ensurethat the packaging you have selected is suitably
robust for the rigours of a maritime journey.
As well as being subjected the vibration andstop/start forces of road or rail journey to andfrom a port, your cargo transport unit may beloaded onto and discharged from several ships
before reaching its destination, and be
subjected to the lateral and vertical centrifugal
forces of ships at sea.
Beyond that we hope we have shown how important it is that the information anddocumentation provided by shippers or forwarding agents to the shipping line is honest,
comprehensive and accurately identifies the Proper Shipping Names of all thedangerous goods in the consignment along with packaging and quantities, and thatthe signature on the shipper’s declaration is more than just a meaningless convention.
Shipping line booking staff have a responsibility to understand the nature of thedangerous goods and their potential hazards, and to insist that full details are provided,
particularly for N.O.S. substances where the substances have an unlimited range ofvariable characteristics that do not appear in the IMDG Code as a simple look up.
Cargo transport unit packers have an over-arching responsibility and legal duty toensure that dangerous goods packed for shipment by sea are secured against
movement, not leaking, and packed in such a way that they are able to withstand thepredictable forces that will exerted on them. Packers are required to issue a signed
packing certificate to confirm compliance with all aspects of the IMDG Code.
The supply chain demands more and more speed, electronic semi-automatic systems
for booking and organising unit load movements are evolving and migrating into
every aspect of logistics. Containerised movements are being concentrated into asmaller number of ever-larger ships and maritime terminals. Higher traffic volume isthe aim of all organisations, and there is less time to scrutinise individual
consignment details, and consequently the system demands a higher standard ofprofessionalism from those processing the data.
UK P&I Club and TT Club offer this guide to encourage and support all thoseseeking a higher level of understanding and professionalism in the safe transport ofdangerous goods by sea.

Part A – Processing a dangerous goods consignment

67

Part B:
Reference andClassification

Part B – Reference and Classification

69

Introduction

The purpose of this reference section is toexplain the main operational terms andprovisions referenced to in the IMDG Code andPart A of this guide, and to provide some
information on key issues.
B1 What are dangerous goods and how are they identified?
Dangerous goods are substances and articles that have the potential to kill or injure
people, cause damage to ships and other transport equipment, damage theenvironment and disrupt the supply chain.
Some workers who handle dangerous goods do not recognise them for what they
are because they have not been trained to do so. They do not know what dangerous
goods are, and therefore cannot understand the hazards to themselves and others.
This section includes a brief guide to the UN system for identification of types ofdangerous goods.
Dangerous goods are classified and listed in the United Nations classification
system. Classification test methods and classification criteria are described fully in
the UN Manual of Tests and Criteria, and referred to in Part 2 of the International
Maritime Dangerous Goods (IMDG) Code. Dangerous goods that are classified as
dangerous for carriage by sea can be found listed and described in Part 3.2 of the
IMDG Code in the “Dangerous Goods List”. This lists all dangerous goods
numerically by UN Number.
Substances and articles classified as dangerous goods or marine pollutants underthe IMDG Code may not necessarily be classified as dangerous goods for carriage
by local domestic, road or rail transport regulations. For example UN 1372, FIBRESANIMAL or FIBRES VEGETABLE, burnt, wet or damp are not subject to the roadtransport regulations of ADR, but are subject to sea transport regulations of the
IMDG Code.
Note: If the dangerous goods are to be transported by sea, it is the IMDG Codeclassification and rules that take precedence, but local regulations for transport by roador rail may also need to be considered to allow the unit to be delivered to the ship.

B2 Structure of the International Maritime Dangerous Goods (IMDG) CodeThe international rules for shipping dangerous goods by sea in cargo transport units(containers and ro-ro vehicles) are contained in the IMDG Code, which is producedby the International Maritime Organisation (IMO) which is an agency of the United
Nations. The Code is updated by the IMO with a new edition every two years60.
The IMDG Code is implemented through the international Convention for the Safetyof Life at Sea (SOLAS). Nation states that sign up to the SOLAS Convention agree
to enact domestic legislation to enforce the IMDG Code on their registered ships
internationally and other ships in their territorial waters.
Any organisation involved in any way with the transport of dangerous goods by sea
cannot function without reference to the IMDG Code.

60

70

The IMDG Code is developed from the UN Model Regulations, which are drawn up by the United
Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods
on a biennial basis. The Model Regulations aim to allow uniform development of regulations governing
all modes of transport. See www.unece.org/trans/danger/publi/unrec/rev13/13nature_e.html

Part B – Reference and Classification

B2.1 Format of the IMDG CodePart 1

General Provisions, Definitions and Training (including forbidden goods,
legal status and security)

Part 2

Classification

Part 3Dangerous Goods List, Special Provisions and Exceptions(including segregation groups, Limited and Excepted Quantities)

Part 4

Packing and Tank Provisions (Use of Packaging)

Part 5

Consignment Procedures (including marking and labelling, placarding
and marking CTUs, documentation and special provisions)

Part 6

Construction and Testing of Packagings, IBCs, Large Packagings,
Portable Tanks, MEGCs and Road Tank Vehicles

Part 7

Provisions Concerning Transport Operations (including stowage
and segregation)

B2.2 The Dangerous Goods List (numerical index)61
The IMDG Code is the mandatory guidance document for manufacturers, shippers,
cargo transport unit packers, forwarding agents, ports and of course mariners for
carriage of dangerous goods on contain ships and ro-ro ships. All dangerous goods
are listed in the Dangerous Goods List, which is in the form of a matrix and is the key
point of reference to locate the rules for identification, packing, marking labelling anddocumenting any dangerous goods for sea.
Dangerous goods are listed numerically by their UN Number in the Dangerous Goods
List which displays references at the head of each of 18 columns to where in the
Code the relevant information for aspect of the Code can be found.
This is a simplified representation of the information that can be found in the 18 columns
in the Dangerous Goods List. It shows the information that can be retrieved from theDangerous Goods List for UN 2210, MANEB or MANEB PREPARATION with notless than 60% maneb.

61

1

2

3

4

5

6

UN
Number

Proper Shipping
Name

Class ordivision

Subsidiaryhazard(s)Packing
group

Specialprovisions

2210

MANEB or MANEBPREPARATION with notless than 60% maneb

4.2

4.3
P

III

273

7a

7b

8

9

10

11

LimitedQuantities

Excepted
Quantities

Packing
Instructions

Packing
Provisions

IBC
Instructions

IBC
Provisions

0

E1

P002

PP100

IBC06

-

IMDG Code, 2018 Edition Amendment 39-18, Chapter 3.2

Part B – Reference and Classification

71

12

13

14

Portable tanks and bulk containers-

Tank
Instructions

Col 12 noT1longer used

15

16a

16b

EmS

Stowage& handling

Segregation

F-G, S-L

Category A
H1

SG26
SG29

Tank
Provisions
TP33

17

18

Properties and observations

UN NumberYellow powder, liable to heat and to ignite spontaneously in air.
May evolve toxic, irritating or flammable fumes when wet, when
involved in a fire or in contact with acids. Used as fungicide.

2210

If you are in the business of preparing dangerous goods documentation or packing
dangerous goods for transport by sea, it is impossible to work safely and legally
without reference to the instructions and information in the IMDG Code, using theDangerous Goods List as the focal point of reference.

B2.3 The Alphabetical Index
At the end of Volume 2 of the Code there is an Index of Proper Shipping Names ofdangerous goods listed alphabetically, showing the class and UN Number of each toenable reference to the full details in the Dangerous Goods List.
Included in this Index are synonyms, alternative names to those PSNs that occur inthe dangerous goods list. If the word ‘see’ appears after the name of the substance,material or article, the name concerned is not the official description to be used when
it is transported. The Proper Shipping Name and associated transport provisions canbe found using the UN Number listed against it.
As an example, for chloroethane, the index includes the word ‘see’ and directs us to
UN 1037 which has the correct Proper Shipping Name of ‘ETHYL CHLORIDE’. ThisPSN is the one that must be included on the transport documentation.

B3 Classification of dangerous goods for transport
Before any substance is placed on the market, it should be subjected to a series of
UN-specified tests to determine whether it has any dangerous properties such as
flammability, toxicity, or whether it reacts with common substances making them
dangerous for use or during transport. If a substance or article is found to have properties
that make it potentially hazardous during transport it is classified under the UN system
as “dangerous goods” and is included in the IMDG Code Dangerous Goods List.
Before offering dangerous goods for transport, the shipper must make a shipper’s
dangerous goods declaration. Therefore, it is the shipper’s duty to obtain formal
hazard classification from the manufacturer of the dangerous goods offered, or test it
himself. Some classification test methods are described in IMDG Part 2, but ingeneral the tests are specialised and outside the scope of this guide.
The following section on classification is to clarify which details derived from the UN
classification system the shipper is required to provide to the shipping line whenbooking a consignment for carriage by sea in order to comply with the IMDG Code.

72

Part B – Reference and Classification

B3.1 What is classification of dangerous goods?
Before dangerous goods can be accepted for shipment by sea, the shipper mustensure he has obtained a classification resulting from standard UN hazard
identification tests.
These tests enable hazard classification (Proper Shipping Name, UN Number,hazard class, packing group and other dangerous goods details demanded on
documentation by the IMDG Code) to be identified and submitted to the shippingline. The shipper must present a signed dangerous goods declaration document
containing these same dangerous goods details to the person designated to packthe cargo transport unit. The shipper’s declaration is a binding agreement with theshipping line that the goods have been accurately described.
The IMDG Code requires that dangerous goods are classified into one of nine main
hazard classes, according to the nature of the hazard. These classes are described
below one by one.
Some of the nine classes are
sub-divided. Each class andclass sub-division is represented
by a different diamond shaped
identification symbol.

The first process of classification identifies substances or articles as having
characteristics that place it in one or more of the nine dangerous goods classes
described below62.
Having identified the class, the classification process continues to determine the UN
Number, Proper Shipping Name, packing group and other details to exactly identify
the hazardous properties of each substance.

B3.2 Classification by hazard class (IMDG Part 2 – Classes 1 to 9)
There are standard UN classification test methods prescribed to identify each class.
The less technically complex tests are included in IMDG Part 2. These tests will
determine what class, or class sub-division a particular dangerous substance will beassigned. If there is more than one dangerous characteristic, a subsidiary hazard will
be added to the main class.

62

See IMDG Code, 2018 Edition Amendment 39-18, Chapters 2.1 to 2.9 for full details

Part B – Reference and Classification73

Class 1: Explosives63 (sub-divided according to the type of hazard)
Class 1.1 – Mass explosion hazard
Class 1.2 – Projection hazard but no mass explosion hazard
Class 1.3 – Fire hazard and either a minor blast hazard or a minor
projection hazard or both, but no mass explosion hazard
Class 1.4 – No significant hazard
Class 1.5 – Very insensitive substances with mass explosion hazard
Class 1.6 – Extremely insensitive articles with no mass explosion hazard
Class 2: Gases64 (sub-divided according to the type of hazard)
Class 2.1 – Flammable gases
Class 2.2 – Non-flammable, non-toxic gases
Class 2.3 – Toxic gases
Class 3: Flammable liquids65
Class 4: Flammable solids66 (sub-divided according to the type of hazard)
Class 4.1 – Flammable solids, self-reactive substances, solid desensitized
explosives and polymerizing substancesClass 4.2 – Substances liable to spontaneously combustion
Class 4.3 – Substances which, in contact with water, emit flammable gases
Class 5: Oxidising substances and organic peroxides67(sub-divided according to the type of hazard)
Class 5.1 – Oxidising substancesClass 5.2 – Organic peroxides
Class 6: Toxic and infectious substances(sub-divided according to the type of hazard)
Class 6.1 – Toxic substancesClass 6.2 – Infectious substancesClass 7: Radioactive material
Class 8: Corrosive substancesClass 9: Miscellaneous dangerous substances and articles (class 9) andenvironmentally hazardous substances and marine pollutants

Class 1 – Explosives: hazard divisions 1.1 – 1.668
The range of substances and articles classified as explosives is wide and covers a
range of risks and hazards. Therefore, explosives are sub-divided into “hazard
divisions” to indicate the nature and degree of hazard as follows:

Class 1.1 – Substances and articles which have a mass explosion hazard
If one part of a consignment of 1.1 explosives detonates, it is likely that the entire
consignment will detonate simultaneously in a single mass explosion. The size of the
explosive blast would be related to the quantity of explosives in the consignment.
Example: UN 0034, BOMBS, with bursting charge
On Division 1 labels:* = Place for compatibility group – to be left blank if explosive is the subsidiary hazard

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IMDG Code, 2018 Edition Amendment 39-18, Chapter 2.2
65 IMDG Code, 2018 Edition Amendment 39-18, Chapter 2.3
66 IMDG Code, 2018 Edition Amendment 39-18, Chapter 2.4
67 IMDG Code, 2018 Edition Amendment 39-18, Chapter 2.5
68 IMDG Code, 2018 Edition Amendment 39-18, Section 2.1.1.4
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Class 1.2 – Substances and articles which have a projection hazard but nota mass explosion hazard
If a consignment of 1.2 explosives is detonated, no mass explosion will result. However,there will be a projectile hazard and a series of smaller explosions is possible, throwing
out projectiles that may themselves explode away from the original explosion.
Example: UN 0295, ROCKETS with bursting charge

Class 1.3 – Substances and articles which have a fire hazard and either aminor blast hazard or a minor projection hazard or both, but not a mass
explosion hazard
If a consignment of type 1.3 explosives is detonated, there will be a major fire hazard
and minor blast or minor projectile hazard, but not a mass explosion hazard.
Example: UN 0186, ROCKET MOTORSClass 1.4 – Substances and articles which present no significant hazard
If a consignment of type 1.4 explosives is detonated, there will be no major blast,
projectile or fire hazard. Additionally, hazards from articles in Compatibility Group “S”
will be largely confined to the packaging and will not hinder fire-fighting.
Example: UN 0012, CARTRIDGES, SMALL ARMSClass 1.5 – Very insensitive substances which have a mass explosion hazard
Explosive substances which possess a major blast hazard but are so insensitive they
are unlikely to detonate accidentally in the event of a fire.
Example: UN 0332, EXPLOSIVES, BLASTING, TYPE EClass 1.6 – Extremely insensitive articles which do not have a mass
explosion hazard
Explosive articles with negligible probability of accidental detonation during transport.
Example: UN 0486, ARTICLES, EXPLOSIVE, EXTREMELY INSENSITIVE

Explosives have a class, hazard division and uniquely a “compatibility group” and“NEC” (net explosive content). See NEC and COMPATIBILITY GROUP below:
Details forwarded by the shipper on a Class 1 shipping document• UN Number• Proper Shipping Name
• Class 1• Division 1.1, 1.2, 1.3, 1.4, 1.5 or 1.6• Compatibility group A, B, C, D, E, F, G, H, J, K, L, N or S
• Sub-hazard (if applicable)• NEC (Net Explosive Content – i.e. amount of explosive compound in an article –also called the Net Explosive Quantity (NEQ)• Marine pollutant (if applicable)• Number and type of packages• Net mass
• Gross massPart B – Reference and Classification

75Compatibility group (explosives only)69
Uniquely, explosives are always allocated a compatibility group. This is a further subclassification of Class 1 (explosives) to indicate the segregation requirements of agiven explosive from other types of explosives in all modes of transport.
The compatibility group is indicated by a letter A, B, C, D, E, F, G, H, J, K, L, N or S.
Mixed packing of explosives (packing explosives of different compatibility groups inthe same freight container other than with compatibility group “S”) is generally
prohibited because mixing types of explosives can increase the risk andconsequences of an accidental detonation. There are exceptions – mixed cargoprohibitions and permitted mixed consignments are displayed in a table in IMDG 7.2.7.
The class, hazard division and compatibility group and N.E.C. of explosives must
always be included in the shipper’s declaration to determine requirements forstowage and segregation and compliance with port explosive licence and ship
insurance conditions.
Net explosive content (NEC)This is the amount of explosive material in an explosive article or consignment, as
opposed to the net weight of the article (e.g. the weight of explosive compound in abomb, without the weight of the metal casing, fusing and other mechanisms). Also
called the “net explosive quantity” (NEQ), “net explosive mass” or in the case of
fireworks, the “powder weight”.
Applies to Class 1 (Explosives) only, and must be included in documentation.
These details must be verified by a signed declaration from the shipper.

Class 2 – Gases (sub-divided into 2.1, 2.2 and 2.3)
Class 2 substances are gases at normal temperature and pressure. During transport
they are compressed, liquefied, refrigerated, dissolved in a liquid solvent or adsorbed
onto a solid porous material. Escaped gas may be heavier than air, may travel somedistance from the source, and create explosion, asphyxiation or toxicity hazard inships and buildings, being liable to collect in the lowest connected level. Class 2
includes manufactured articles such as aerosols, lighters, lighter refills, fire
extinguishers and fuel cell cartridges charged with compressed or liquefied gas.
The class is sub-divided according to the different properties of the gas:

Class 2.1 – Flammable gases70
Flammable gas mixed with air can be ignited by a spark or source of heat to cause
an explosion in open or enclosed space or inside a containment vessel.
Example: UN 1978, PROPANE
Note: This label may also be used with the symbol, line and “2” in white on a red background.

Class 2.2 – Non-flammable, non-toxic gases71
Risk of asphyxiation of persons in enclosed spaces, or oxidizing gases which may,generally by providing oxygen, cause or contribute to the combustion of other material.
Example: UN 1013, CARBON DIOXIDE
Note: This label may also be used with the symbol, line and “2” in black on a green background.

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Class 2.3 - Toxic gas72
Inhalation of toxic gas can lead to death or injury to persons. Toxic gas may travel
some distance from the original leak, through ships, buildings and open space, andmay have delayed health effects.
Example: UN 2199, PHOSPHINE

Details forwarded by the shipper on a Class 2 shipping document• UN Number• Proper Shipping Name
• Class 2• Division 2.1, 2.2 or 2.3• Sub-hazard (if applicable)• Marine pollutant (if applicable)• Number and type of packages• Net mass of liquid gas product or liquid volume of compressed gas container• Gross mass
These details must be verified by a signed declaration from the shipper.

Class 3 – Flammable liquids73
The UN classification system classes liquids as flammable if they have a “flashpoint”
of 60°C or below. Flashpoint is the lowest temperature at which a liquid produces
vapour that will ignite on exposure to an open flame or spark and the flashpoint must
be quoted in the transport document.
Note 1: Flammable liquids will not self-ignite at their flashpoints – they self-ignite at their “ignition
temperature”, which is higher.
Note 2: This label may also be used with the symbol, line and “3” in white on a red background.

Example: UN 1203, GASOLINEClass 3 includes flammable viscous substances such as adhesives, and substancestransported at elevated temperatures in a liquid state that produce flammable vapour
at the transport temperature if the transport temperature is mechanically maintained
above 60°C.
Details forwarded by the shipper on a Class 3 shipping document• UN Number• Proper Shipping Name
• Class 3• Sub-hazard (if applicable)• Packing group (I, II or III)• Flashpoint• Marine pollutant (if applicable)• Number and type of packages• Net mass or volume of Class 3• Gross mass
These details must be verified by a signed declaration from the shipper.

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77Class 4 – Flammable solids: (sub-divided into 4.1, 4.2 and 4.3)
Class 4 deals with substances, other than those classified as explosives, which,under conditions of transport, are readily combustible or may cause or contribute toa fire. There are three sub-divisions:Class 4.1 – Flammable solids74
This class includes:
Self-reactive substances;
Solid desensitized explosives;
Polymerizing substances and mixtures;
A wide range of substances that are easily ignited by heat or friction.
Examples: UN 1331, MATCHES, UN 3532, POLYMERIZING SUBSTANCE,LIQUID, STABILIZED, N.O.S.

Class 4.2 – Spontaneously combustible substances75
Includes pyrophoric solids and liquids that are liable to spontaneous heating or
spontaneous combustion on contact with air, and self-heating substances that slowly
generate heat on contact with air.
Example: UN 1381, PHOSPHORUS, WHITE DRY

Class 4.3 – Substances which, in contact with water, emit flammable gases76
Solids and liquids which on contact with water react to produce dangerous quantitiesof flammable gas, and may produce sufficient heat to cause ignition.
Note: This label may also be used with the symbol, line and “4” in white on a blue background.

Example: UN 1428, SODIUM

Details forwarded by the shipper on a Class 4 shipping document• UN Number• Proper Shipping Name
• Class/Division 4.1, 4.2 or 4.3• Sub-hazard (if applicable)• Packing group (I, II or III)
• Marine pollutant (if applicable)• Control temperature (if carried under temperature control)• Emergency temperature (if carried under temperature control)• Number and type of packages• Net mass or volume of Class 4.1, 4.2 or 4.3• Gross mass
These details must be verified by a signed declaration from the shipper.

Class 5 – Oxidising substances (sub-divided into 5.1 and 5.2)

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Class 5.1 – Oxidising agents77
Substances that although not necessarily flammable in themselves, yield oxygen
when involved in a fire, increasing the hazard and intensity of fire. May become highly
flammable or spontaneously ignite if mixed with common organic materials such asflour, sawdust, oils or sugar.
Example: UN 2067, AMMONIUM NITRATE BASED FERTILIZERClass 5.2 – Organic peroxides78
These are substances liable to spontaneous, sometimes explosive, exothermic
decomposition at normal or elevated temperatures or by contact with othersubstances. Temperature-controlled carriage is required for some peroxides.
Extremely dangerous to the eyes – minimum contact with cornea of eye causes
severe damage.
Note: The red/yellow version of this label may also be used with the symbol in white on the redbackground.

Example: UN 3109, ORGANIC PEROXIDE TYPE F, LIQUID,
tert-BUTYL PEROXYACETATE <32%

Details forwarded by the shipper on a Class 5.1 or 5.2 shipping document• UN Number• Proper Shipping Name
• Class/Division 5.1 or 5.2• Sub-hazard (if applicable)• Packing group (I, II or III)*• Marine pollutant (if applicable)• Control temperature (if carried under temperature control• Emergency temperature (if carried under temperature control)• Number and type of packages• Net mass
• Gross mass
*Organic peroxides have no packing group but are classified by hazard type A to G

These details must be verified by a signed declaration from the shipper.

Class 6 – Toxic and infectious substances (sub-divided into 6.1 and 6.2)

Class 6.1 – Toxic substances79
These are substances that cause injury or death if they enter the human body. Entry
can be by inhalation of dusts and vapours, accidental ingestion, or direct contact withthe skin.
Toxic substances may be in the form of liquids, solids, powders or granules andprecautions must be paid to avoid skin contact if packages are damaged.
Example: UN 1558, ARSENICIMDG Code, 2018 Edition Amendment 39-18, Section 2.5.2
IMDG Code, 2018 Edition Amendment 39-18, Section 2.5.3
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Details forwarded by the shipper on a Class 6.1 shipping document• UN Number• Proper Shipping Name
• Class 6.1• Sub-hazard (if applicable)• Packing group (I, II or III)
• Marine pollutant (if applicable)• Number and type of packages• Net mass or volume of Class 6.1• Gross mass
These details must be verified by a signed declaration from the shipper.

Class 6.2 – Infectious substances (biological hazard)80
Substances of Class 6.2 contain live micro-organisms which could cause disease tohumans or animals. They include bacteria, viruses, parasites, fungi, and otherpathogens. Consignments may consist of infected products, decomposing organic
material, diagnostic specimens, laboratory cultures, medical waste or non-sterile
animal products.
Example: UN 2814, INFECTIOUS SUBSTANCE, AFFECTING HUMANS

Details forwarded by the shipper on a Class 6.2 shipping document• UN Number 2814, UN Number 2900, UN Number 3373 or UN 3291
• Proper Shipping Name
• Class 6.2• Number and type of packages• Net mass or volume of Class 6.2• Gross mass
• The full address or the consignee• Name and telephone number of a responsible person• These details must be verified by a signed declaration from the shipper.
These details must be verified by a signed declaration from the shipper.

Class 7 – Radioactive material81

Low level
radiation

Intermediatelevel radiation

High level
radiation

Fissile radioactive
material

Substances that produce radioactivity above specified levels must be declared asradioactive material for shipment by sea. This includes packages and other objects
that have become contaminated by radioactive material. Class 7 labels indicate thelevel of radioactivity, and whether the consignment contains fissile material.

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Regardless of the nature of the radioactive material inside the package, the amountof detectable radiation outside the package is strictly controlled. This is achieved byshielding built into the inner packaging. Construction and design of transport
packaging for radioactive materials are subject to strict international scrutiny andagreement. Provided the consignment was packed under controlled conditions byqualified persons, it will be safe to handle in transport, but of course packages ofradioactive materials must never be opened or repaired without qualified supervision.
Preparation of Class 7 shipments is complex and is subject to specialised
procedures beyond the scope of this guide82.
Example: UN 2977, URANIUM HEXAFLUORIDEClass 8 – Corrosive substances83
Corrosive substances of Class 8 are those that destroy living tissue on contact.
Certain corrosive materials corrode various metals, and some can corrode glass andearthenware. Some substances only become corrosive on contact with water or
airborne moisture and form corrosive gases. Some corrosive substances react withorganic materials to generate heat.
Class 8 substances include acids and alkalis that may react dangerously if mixed,
requiring close attention to the IMDG Code segregation rules.
This class includes articles such as batteries that contain corrosive substances.
Example: UN 1789, HYDROCHLORIC ACID

Details forwarded by the shipper on a Class 8 shipping document• UN Number• Proper Shipping Name
• Class 8• Sub-hazard (if applicable)• Packing group (I, II or III)
• Marine pollutant (if applicable)• Number and type of packages• Net mass or volume of Class 8• Gross mass
These details must be verified by a signed declaration from the shipper.

Class 9 – Miscellaneous dangerous substances and articles (class 9) andenvironmentally hazardous substances84
Substances and articles of Class 9 generally do not fit into any other class, but may
present significant risk under certain circumstances.
Class 9 covers a wide range of hazards, including goods that are only hazardous
under certain conditions. It includes:• substances and articles not covered by other classes which experience has shown,or may show, to be of such a dangerous character that the provisions of part A ofchapter VII of SOLAS 1974, as amended, must apply.

For the additional documentation requirements see IMDG Code, 2018 Edition Amendment 39-18,
Section 5.4.1.5.7
83 IMDG Code, 2018 Edition Amendment 39-18, Chapter 2.8
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Part B – Reference and Classification81

• substances not subject to the provisions of part A in chapter VII of SOLAS 1974,
but subject to the provisions of Annex III of MARPOL 73/78, as amended(marine pollutants).
Class 9 sub-divisions
The substances and articles of class 9 are subdivided as follows:• Substances which, on inhalation as fine dust, may endanger health e.g.
ASBESTOS, AMPHIBOLE• Substances evolving flammable vapour e.g. POLYMERIC BEADS, EXPANDABLE,
evolving flammable vapour• Lithium batteries e.g. LITHIUM ION BATTERIES (including lithium ion
polymer batteries)• Ammonium nitrate based fertilizers e.g. AMMONIUM NITRATE BASED FERTILIZER• Capacitors i.e. CAPACITOR, ELECTRIC DOUBLE LAYER• Life-saving appliances e.g. LIFE-SAVING APPLIANCES, SELF-INFLATING• Substances and articles which, in the event of fire, may form dioxins e.g.
HALOGENATED MONOMETHYLDIPHENYLMETHANES, LIQUID• Substances transported or offered for transport at elevated temperatures e.g.
ELEVATED TEMPERATURE SOLID, N.O.S., at or above 240°C• Environmentally hazardous substances e.g. ENVIRONMENTALLY HAZARDOUS
SUBSTANCE, LIQUID, N.O.S.
• Genetically modified microorganisms (GMMOs) and genetically modified
organisms (GMOs) e.g. GENETICALLY MODIFIED ORGANISMS• Other substances or articles presenting a danger during transport but notmeeting the definitions of another class e.g. ENGINE, INTERNAL COMBUSTION
or MACHINERY, INTERNAL COMBUSTION
Environmentally hazardous substances (aquatic environment)85
Environmentally hazardous substances are liquid or solid substances which arepollutants to the aquatic environment and solutions and mixtures of such substances(such as preparations and wastes).
The classification criteria for environmentally hazardous substances (including
solutions and mixtures) are detailed in depth in IMDG 2.9.3.2 to 2.9.3.4.
Note: For the purposes of the IMDG Code, the environmentally hazardous substances(aquatic environment) criteria contained in Chapter 2.9 apply to the classification ofmarine pollutants in Chapter 2.10 which we look at in the next section.
Lithium batteries86
Lithium batteries are a family of batteries with different chemistries, comprising many
types of cathodes and electrolytes. There are two types covered in the IMDG Code:
Lithium metal batteries – these are generally primary (non-rechargeable) batteries
that have lithium metal or lithium compounds as an anode. They are generally used to
power devices such as watches, calculators etc
Lithium ion batteries – these are a secondary (rechargeable) battery where thelithium is only present in an ionic form in the electrolyte. They are generally used to
power devices such as mobile telephones, laptops etc

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Details forwarded by the shipper on a Class 9 shipping document• UN Number• Proper Shipping Name
• Class 9• Packing group I, II or III (if applicable)• Marine pollutant (if applicable)• Number and type of packages• Net mass or volume of Class 9• Gross mass
These details must be verified by a signed declaration from the shipper.

B3.3 Marine pollutants87
Marine pollutants are defined in the IMDG Code as substances which are subject tothe provisions of Annex III of Marpol 73/78, as amended.
Many dangerous substances assigned to classes 1 to 6.2, 8 and 9 are also deemed
to be marine pollutants i.e. substances which are harmful to the marine environment
because of their tendency to bioaccumulate harmful toxins in living seafood; or theirhigh toxicity to aquatic life.
Packages andshipping containers
carrying marine
pollutants must
display the marine
pollutant markKnown marine pollutants are identified as such by the inclusion of a ‘P’ symbol incolumn 4 of the DGL and in the ‘MP’ column in the Index of the IMDG Code.
It is important to note however, that even if a substance is not marked with a ‘P’ in
the DGL (or ‘MP’ in the Index) it does not mean it isn’t a pollutant; if it meets thecriteria in IMDG 2.10.3 and 2.9.3 it must still be declared as a marine pollutant andshipped accordingly.
A marine pollutant which possesses properties of classes 1 to 8 must be classified(and identified) accordingly; if it doesn’t meet the criteria for assignment to classes 1
to 8, it must be offered for transport under class 9 using one of the following entries:
ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. UN 3077, or
ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. UN 3082
When transporting marine pollutants the shipper must include “Marine Pollutant” on
the transport document and the goods must be declared, documented, marked,
labelled and placarded as a marine pollutant.
Note: there is an exemption from all provisions of the IMDG Code for substancesclassified as marine pollutants if the following conditions apply:• Single packages or inner packages of combination packages do not exceed 5 litresfor liquids or 5 kg for solids (equivalent to Limited Quantity provisions)• Packaging must meet the general packaging provisions of IMDG Part 4• The marine pollutant does not meet the classification criteria for any other hazard class
It is important to note that when marine pollutants also meet the criteria for inclusion
in another hazard class, all the provisions of the Code relevant to any additional
hazard(s) continue to apply.

B4 Subsidiary hazards (sub-hazards)
Most substances have a single dangerous property, and when classified this becomes
the hazard “CLASS”. Some substances have more than one dangerous property e.g.
a toxic liquid may also be flammable. The degrees of hazard for each property of a
substance are determined by classification. These are then compared against eachother in a UN Table of Hazard Precedence (IMDG 2.0.3). The table will indicate which
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of the hazards is the more aggressive, and this becomes the CLASS. The hazard(s)judged to be the lesser hazard(s) becomes the “SUBSIDIARY HAZARD(S)”.
Any class of dangerous goods except Class 9 may potentially have a subsidiary hazard.
When describing dangerous goods in any document, any applicable sub-hazards
must be included in brackets after the main class e.g. UN 3405, BARIUM
CHLORATE SOLUTION, 5.1, (6.1)

B5 Entries in the Dangerous Goods List: UN numbering system and Proper
Shipping Names88
Substances classified into one of the classes of hazardous goods under the UN
system are allocated a universally agreed name by a United Nations agency called
the Committee of Experts on the Transport of Dangerous goods. This is the“PROPER SHIPPING NAME” and it is listed in Column 2 of the IMDG Dangerous
Goods List, and in the IMDG alphabetical Index.
Every substance or article or generic N.O.S. hazard category that has a Proper
Shipping Name is also allocated a unique four-digit number, hence the numbers are
known as “UN Numbers”.
The UN Number is entered in Column 1 of the Dangerous Goods List (IMDG 3.2)
and is the required starting point for obtaining data from the Dangerous Goods List.
The Proper Shipping Name is entered in Column 2.
This number is intermodal and assists greatly in avoiding errors by providing a simple
check when transposing names of chemicals with long complex chemical names in adifferent language, during documentation and emergency response.

B5.1 The four types of Proper Shipping Name entries in the Dangerous
Goods List89
Type 1: Single-substance entries for well-defined individual substancesor articles
For pure substances entered in the Dangerous Goods List, the UN Number andProper Shipping Name can stand alone:
Example: “UN 2022, CRESYLIC ACID”
Type 2: Group entries for well-defined groups of substances or articles
Some types of substance or article differ in composition but have identical hazard
characteristics, so as far as transport is concerned may be treated as alike:
Examples: “UN 1133, ADHESIVES” and “UN 1266, PERFUMERY PRODUCT”
Type 3: Group entries for substances with a similar chemical or technical nature
Some types of substance have different names but similar chemical composition, so
as far as transport is concerned may be treated as alike:
Examples: “UN 1477, NITRATES, ORGANIC, N.O.S.” and“UN 1987, ALCOHOLS, N.O.S.”
Type 4: General N.O.S. entries used to classify products made from mixturesof substances meeting the criteria of one or more hazard classes
Combining or diluting chemicals has the effect of altering the hazard characteristicsof the component substances from those of the pure state to something else, and
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there are limitless ways in which chemical substances can be combined to makeuseful products.
It is not practicable to make an entry in the Dangerous Goods List for every possiblecombination of components, so N.O.S. generic names are used to overcome this.
N.O.S. Proper Shipping Names describe the hazard classification, not the substance.
There is an extensive list of N.O.S. generic names in IMDG Appendix A. When theclassification process is completed, the most appropriate N.O.S. Proper Shipping
Name in Appendix A is chosen from the list90.
N.O.S. Proper Shipping Names are shown in Column 2 of the Dangerous Goods List
but only the generic part of the name describing the hazard, e.g. “FLAMMABLE
LIQUID, N.O.S.” and this is usually not the full Proper Shipping Name. With
exceptions, in most cases N.O.S. entries are allocated Special Provision SP 274
which requires the Proper Shipping Name to be supplemented with the technicalname of the dangerous components of the mixture. The shipper must add at least
one chemical ingredient to an N.O.S. Proper Shipping Name to complete it.
The technical names are added in brackets after the generic description to provide
emergency information. If there is more than one hazardous component, only thenames of the two most hazardous components need be identified in this way.
Example: a 75% solution of propanol (flammable liquid) in water would not havethe same characteristics as pure propanol so it would be classified as:“UN 1993, FLAMMABLE LIQUID N.O.S. (Contains propanol), 3”
Example: A liquid mixture containing 15% hydrochloric acid (corrosive) and 60%
arsenic (toxic) would not be classified as either arsenic or hydrochlororic acid, so
would be classified under the N.O.S. criteria as:“UN 3289 TOXIC LIQUID, CORROSIVE, INORGANIC N.O.S. (Contains arsenic
and hydrochloric acid), 6.1 (8).”Additional information the shipper may need to supply for N.O.S. substances
For defined substances such as ADHESIVES, the variable dangerous goods details
are tabulated in the Dangerous Goods List. For N.O.S. substances, because of theirvariable component range, the shipper may have to obtain any of the following
factors from his classification and include them in his declaration:• Packing Group (IMDG 2.0.1.3)• Flashpoint (flammable liquids only)• Marine pollutant (IMDG 2.10 and 2.0.1.2)• Segregation group* (IMDG 3.1.4, and 7.2.5)• Control and Emergency temperatures (5.4.1.5.4)* If it is appropriate that an N.O.S substance should be included in one of the 18 segregation groups(see IMDG 3.1.4) the shipper shall include that segregation group in his cargo booking and shipper’s
declaration (see also Part A Segregation).

B6 Packing groups
Most dangerous goods are allocated a packing group (PG) according to their degreeof danger:
Packing Group I – High danger
Packing Group II – Medium danger
Packing Group III – Low danger
Dangerous substances of hazard classes 3, some of class 4.1, 4.2, 4.3, 5.1, 6.1, 8 andsome of class 9 must be designated a packing group. The criteria for determining thepacking group is found in the classification section of each class in IMDG Part 2.

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Packing groups are not assigned to articles or to explosives of Class 1 or gases ofClass 2. Organic peroxides of Class 5.2 and self-reactive substances of Class 4.1
do not have packing groups but are allocated a Type ( A to G) according to degreeof danger91.
Rules for determining packing groups and types are found in IMDG Chapter 2 in thesection containing classification rules for each of the classes.
Where packing groups are allocated to a UN Number, that packing group is indicatedin column 5 of the Dangerous Goods List.
The packing group of N.O.S. mixtures and solutions will depend on the degree of
danger as determined by the classification tests carried out by the shipper/productsupplier. Some N.O.S entries are listed under more than one packing group because
the composition of mixtures is variable, and may have a greater or lesser
concentration of the dangerous substance in the mixture. The multiple entries makesense because the packing group affects the type of packaging, and may change thepackaging requirements.
Where a packing group exists, it must be included on the cargo booking and in
the shipper’s declaration/ transport document, but does not need to be displayedon packages.

B7 Articles containing dangerous goods N.O.S.
Articles containing dangerous goods may be classified under the PSN for thedangerous goods they contain or in accordance with IMDG 2.0.6.
An “article” could be machinery, apparatus or other devices containing one or moredangerous goods (or residues thereof) that are an integral element of the article,
necessary for its functioning. They must be assigned to the appropriate classdetermined by the hazard(s) present using, where applicable, the Precedence ofHazards table in 2.0.3.6 for each of the dangerous goods contained in the article.
Any subsidiary hazards must be representative of the primary hazard posed by theother dangerous goods contained within the article.
The provision for articles containing dangerous goods do not apply to:• articles for which a more specific proper shipping name already exists in theDangerous Goods List of Chapter 3.2; and• dangerous goods of class 1, class 6.2, class 7 or radioactive material containedin articles.
For articles which do not have an existing proper shipping name and which contain
only dangerous goods within the permitted limited quantity amounts specified incolumn 7a of the DGL, UN 3363 and SP301 of Chapter 3.3 apply.

B8 Determination of flashpoints for flammable liquids
The flashpoint is the lowest temperature at which a flammable liquid produces
vapour which can be ignited by a naked flame or spark. Liquids classed as Class 3
flammable liquids in the UN classification system have a flashpoint of 60°C or below.
It is the shipper’s responsibility to determine the flashpoint in the classification
process, and to include it in the shipper’s declaration.
Liquids with a flashpoint above 60°C are not regarded as flammable liquids by the
IMDG Code.

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Descriptions of substances with a sub-hazard of Class 3 are required to include theflashpoint in the document.
Flashpoints for technically pure Class 3 substances are displayed in Column 17 of
the Dangerous Goods List. Flashpoints for N.O.S. substances depend upon thecomponent parts of the substance, and the shipper must determine the flashpoint byproduct testing and declare the finding in his shipper’s declaration.

B9 Special controls for polymerizing and unstable substances stabilized
for transport
Substances that are chemically unstable such as self-reactive substances, organic
peroxides and substances liable to polymerize shall not be accepted for transportunless stabilization precautions have been taken to prevent the possibility of adangerous exothermic decomposition or polymerization.
Stabilization may require temperature control or addition of stabilizing chemicals, or a
combination of both. Control and emergency temperatures must be specified on the
shipper’s booking information and in the transport document for temperature
controlled transport. Additionally, the word “STABILIZED” must be included on thetransport document.
Note: for substances which have the word ‘Stabilized’ added as part of the proper
shipping name in accordance with 3.1.2.6, stowage category D and SW1 (protectedfrom sources of heat) will apply.
If stabilization is by temperature control the words “TEMPERATURE CONTROL”
must also be added to the proper shipping name as per 3.1.2.6.2.
Carriage of temperature controlled dangerous goods is likely to be subject tomonitoring at sea, so deck stowage is usually required that allows temperaturechecks and direct access for emergency response.
Polymerizing substances may be found in Class 2 (Gases), Class 3 (Flammable liquids),
Class 6.1 (Toxic) and Class 8 (Corrosive). Polymerizing substances that do not meetthe criteria for other hazard classes are allocated Class 4.1. These are subject tospecial carriage conditions92.
Control temperature
Control temperature is the maximum safe temperature at which self-reactive or
polymerizing dangerous goods that are sensitive to temperature should normally be
carried. It is set at a margin below the Self-Accelerating Decomposition Temperature(SADT), and if this temperature is exceeded, intervention and possible cargo jettison
will be considered.
Emergency temperature
The temperature at which substances required to be carried at a controlledtemperature become unstable, will spoil or begin to react dangerously and should
trigger alarm systems.

B10 Dangerous goods forbidden for transport
Substances or articles that are liable to explode, dangerously react, produce a flame
or dangerous evolution of heat or dangerous emission of toxic, corrosive or
flammable gases or vapours under normal conditions of transport are prohibited.
The following Special Provisions identify substances that are forbidden for carriage
by sea under the IMDG Code: Special Provisions 349, 350, 351, 352, 353 and 90093.

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87

Note: there are instances in other special provisions whereby certain substances may beprohibited for transport depending on certain criteria. If there are any special provisions
applicable to a substance or article being shipped these must always be checked.

B11 Additional certification that may be required from the shipper

B11.1 Weathering certificate94
Some substances are safe to ship only after a period of weathering following
production, to allow chemical reaction or internal self-heating to stabilize.
Certification should be provided by the shipper to confirm that a sufficient period of
weathering has been allowed before shipment.
Requirement for a weathering certificate appears in the IMDG Code Dangerous
Goods List under column 17 Properties and Observations – examples UN 1376,
IRON OXIDE, SPENT. The weathering period is eight weeks unless packed in metal
drums, and UN 1361, CARBON, which requires cooling before shipping. The
shipping company may have requirements for weathering certificates for additional
substances such as fishmeal and carbon products.

B11.2 Exemption certificate95
Some substances included in the IMDG Code Dangerous Goods List are nothazardous under certain circumstances, and do not need to be treated as dangerous
goods. Example: CARBON, ACTIVATED UN 1362 is listed as “spontaneously
combustible”. However, production methods for activated carbon vary, and someproduction processes produce activated carbon that is not self-heating and therefore
the product is not subject to the IMDG Code.
If the shipper claims that his product is not hazardous and should therefore be
exempt from IMDG rules for any reason, a certificate from the competent authority of
the country where the product is made explaining why his product should be
exempted is likely to be requested by the shipping company. A copy of this certificate
should be attached to the transport documents to travel with the load to avoid
potential difficulties with inspection authorities and at transhipment ports.

B11.3 Letter of indemnity
Letters of indemnity form no part of the IMDG Code, but shipping line policy may
request the shipper to supply one as a condition of acceptance for controlledtemperature dangerous goods. These generally state that while the line will carry out
due diligence to care for the machinery in the cargo transport unit controlling thetemperature, the line bears no responsibility for consequences of failure or
malfunction of that machinery, or that the shipper bears full liability for any
consequences arising from the nature of the substance carried.

B11.4 Competent authority approval96
There are occasional circumstances when shippers request a shipment to be madeunder conditions that are prohibited by the IMDG Code, but are nevertheless consideredsafe, because special compensatory measures have been taken. In such cases theshipper is entitled to request the competent authority of the country of shipment tojudge the measures, and, if found satisfactory, to issue a certificate of approval for the
shipment to go ahead. The competent authority will consider the request and only if
convinced that there is no increased risk to safety, will issue a certificate of approval.
This must be sent to the shipping line and a copy must travel with the goods.

IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.4.1.1
IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.4.1.2
96 IMDG Code, 2018 Edition Amendment 39-18, Chapter 7.9
94
95

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Part B – Reference and Classification

B11.5 Tank inspection certificates
There are no provisions in the IMDG Code to provide packing certificates whendangerous goods are loaded into tank containers. The equivalent for tanks is a “fillingcertificate” issued when the tank is filled to state that the tank is compatible with the
product and has been filled and closed correctly. There is no requirement in the
IMDG Code for the shipper to provide a filling certificate.
However, many shipping lines request a copy of the tank inspection certificate. Thisis a certificate issued after a mandatory tank inspection carried out when tanks are
first commissioned and at 2.5 yearly intervals thereafter to state that the tank is ingood condition and meets the design specifications.

B12 Provisions for empty uncleaned tank containers
Note: Filling and carriage of filled tank containers are outside the scope of this guide,
but the following key points are worth noting:• Empty uncleaned tanks and MEGCs that have carried dangerous goods are stillclassed as dangerous goods until the tank has been cleaned and purged97.
• Depending upon the tank design, empty uncleaned tanks may contain hundreds oflitres of residue.
• A dangerous chemical/air vapour mixture may remain in the tank that may present
a high risk of explosion of the tank in a fire, until the tank has been cleaned.
• Empty uncleaned tank containers must be declared and documented with the classand UN Number and described as “EMPTY UNCLEANED” or “RESIDUE LASTCONTAINED” on the cargo booking and shipper’s declaration98• Empty uncleaned tanks must display the UN Number, marks and placards of thedangerous goods as if the tank were full.

B13 Provisions for shipping dangerous goods in Limited Quantities99

B13.1 General advantages of shipping in Limited Quantities
Many shippers choose to consign their goods under the Limited Quantities
provisions when permitted by the IMDG Code because such goods are subject toless stringent packaging, marking and labelling requirements and fewer of therestrictions for transport by road and sea. This makes Limited Quantities attractive tomanufacturers and shippers of dangerous goods products that are mass-produced
for the consumer market and packaged for retail display and sale.

B13.2 IMDG advantages of shipping in Limited Quantities
For sea transport, the main advantage is that the segregation restrictions between
classes are relaxed for dangerous goods in Limited Quantities. In practice, this meansthat packages of different classes of dangerous goods shipped in Limited Quantities,
normally required be segregated and shipped in separate cargo transport units, may be
shipped in the same shipping container, provided they are in separate packages. This
greatly simplifies the distribution supply chain for organisations servicing retail outlets.
One segregation factor is not relaxed – different classes of dangerous goods thatare regarded as incompatible must not be packed into the same outer package, evenin Limited Quantities.

IMDG Code, 2016 Edition Amendment 39-18, Section 4.2.1.5, 4.2.2.6, 4.2.3.5 and 4.2.4.7
IMDG Code, 2018 Edition Amendment 39-18, Section 5.4.1.4.3.2
99 IMDG Code, 2018 Edition Amendment 39-18, Chapter 3.4
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89

B13.3 Rationality of allowing relaxed rules for Limited Quantities
The safety rationale for allowing relaxations for the transport of dangerous goods in
Limited Quantities is based on risk assessment. By replacing large packagings(e.g. a 200 litre drum) with a number of very small ones (e.g. 200 x 1 litre
receptacles), and then placing the receptacles into outer packaging, the potential
hazard and, therefore, the risk is measurably reduced. The potential spillage scale isreduced from 200 litres to 1 litre if one package becomes punctured.

Repackage1 x 200 litres

200 x 1 litre

9 x 1 litre

Limited Quantity
package

B13.4 Rule variations for dangerous goods in Limited Quantities
The IMDG Code requirements for packaging, marking, labelling and documentationof dangerous goods in Limited Quantities are different from those of “normal”
dangerous goods consignments. This section explains what those differences are100.

B13.5 Packaging for Limited Quantities101
Packaging requirements for goods shipped by sea as Limited Quantities are lessstringent than for other dangerous goods:• Packaging does not have to be UN-tested, but it must not leak, and must be built tofulfil the general packaging design criteria of IMDG Part 4• Substances in receptacles must be in a two-part combination package comprising
inner packagings placed inside outer packagings. Intermediate packaging is
optional and the gross mass of the package must not exceed 30 kg (see below for
exception to this)• Robust articles in Limited Quantities such as aerosols are not required to bepacked in inner receptacles and may be placed directly into outer packagings or inshrink-wrapped trays that meet the general packaging requirements of IMDG Part 4.
Intermediate packaging is not required provided the article is not likely to breakduring transport. Shrink-wrapped trays must not exceed 20 kg• The maximum mass for solids and capacity for liquids of the inner package isvariable and determined by the UN Number and the packing group. The allowablemaximum mass/capacity for inner packaging for each UN entry is displayed incolumn 7(a) of the Dangerous Goods List. If the mass/capacity of the inner
packaging exceeds this figure, the goods cannot be classified as Limited Quantities• There is no upper limit to the total number or weight of packages in Limited
Quantities that may be packed to a cargo transport unit – a single shipping
container may be packed to its maximum safe working load with packages ofdangerous goods in Limited Quantities
100
101

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IMDG Code, 2018 Edition Amendment 39-18, Section 3.4.2

Part B – Reference and Classification

• Limited Quantities packages may be made up into units, for instance, shrinkwrapped onto pallets

B13.6 Package marking requirements for Limited Quantities
The marking requirements for packages of Limited Quantities are less stringent thanfor “normal” dangerous goods102.
Each package must be marked with the Limited Quantities mark (see illustration)
regardless of class.
• There is no requirement to mark packages with the Proper Shipping Name, UN
Number, or apply the hazard class label or marine pollutant mark
• Inner packagings do not need to be marked or labelled because the outer
packaging should not be opened in transit• Packages containing liquids must display orientation arrows on opposing sides

UN 1165
DIOXANE

The Limited Quantities
mark does not containthe UN Number

No marks or labels
are required on
inner packagings

B13.7 Documentation requirements for Limited Quantities
Dangerous goods consigned in Limited Quantities must be documented with asigned shipper’s declaration stating the number and type of packages, UN Number,
Proper Shipping Name, Class, Packing Group etc in the normal way, but in addition,
the declaration must be supplemented with words “LTD QTY” or “DANGEROUS
GOODS IN LIMITED QUANTITY” after the dangerous goods description.
Dangerous goods in Limited Quantities packed in cargo transport units need apacking certificate in the normal way.

B13.8 Marking requirements for cargo transport units carrying dangerous
goods in Limited Quantities
Shipping containers of dangerous goods in Limited Quantities only should notdisplay any hazard class(es) placards or UN Numbers, but they should instead display
the Limited Quantities mark 250 mm x 250 mm on both sides, front and back.

B13.9 Summary of criteria for shipping Limited Quantities103
There are conditions for allowing dangerous goods to be classified as Limited
Quantities. The general rules are as follows:• Dangerous goods must be in PG II or PG III only

102
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Part B – Reference and Classification

91• Dangerous goods in PG I are prohibited as Limited Quantities (with minor exceptions)• Must be in a combination package – inner packaging placed inside an outer
packaging (with exception for articles in shrink-wrapped trays)• There is a maximum permissible mass/capacity to be determined for the inner
packaging, variable depending upon the UN Number, shown in column 7a of theDangerous Goods List
• There is a maximum allowable mass for the complete packaging (see below)• There is no upper restriction on the overall number of packages of dangerous
goods meeting the requirements of the Limited Quantities rules that may be
shipped in a cargo transport unit
• Marking and labelling requirements are different (see below)• Different classes of dangerous goods in Limited Quantities may be only shipped in
the same package provided the segregation rules of IMDG 7.2 indicate they arecompatible, and the goods will not react dangerously with each other• Dangerous goods of classes that are not compatible according to IMDG 7.2 may be
shipped in the same shipping container provided they are in Limited Quantities andin different outer packages
Note: To check if dangerous goods can be shipped as Limited Quantities you need toknow details of the inner and outer packaging sizes.

B14 Excepted Quantities104
Dangerous goods may be shipped in Excepted Quantities which allows exemptions
from many of the IMDG Code rules for very small packages (less than 30 grams or
30 mLs per inner packaging).
Dangerous goods of medium and low hazard in Packing Groups II and III may be
shipped as Excepted Quantities but not high hazard goods of Packing Group I. This
is intended to simplify transport of goods traditionally shipped in very small packages
such as retail perfumes, cosmetics, personal care items and medicines without
application of many of the normal IMDG Code requirements.
Only the following provisions of the IMDG Code apply regarding goods in
Excepted Quantities:• Training• Classification including Packing Group criteria• Packagings must meet the general packaging standard of IMDG Part 4, but
packagings do not need to be UN tested• The normal documentation requirements of IMDG 5.4
The segregation provisions of the IMDG Code do not apply to goods in Excepted
Quantities.
An alphanumeric code in Column 7b of the Dangerous Goods List indicates whether
a substance may be shipped as Excepted Quantities. “E0” shown in Column 7b
indicates that goods are not permitted to be shipped as Excepted Quantities.
However, there are stipulations for packaging. There must be inners of restricted size
packed into outers with intermediate cushioning material capable of absorbing any
liquid spillage from the inner packaging, and the complete package as prepared fortransport must pass the drop and stack tests described in IMDG 3.5.3.
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Consignments of dangerous goods in Excepted Quantities must be documented in
the normal way with the words “Dangerous goods in Excepted Quantities” added.
Goods indicated as E1, E2, E3, E4 or E5 in Column 7b of the Dangerous Goods List
may be shipped as Excepted Quantities provided the packaging thresholds in thefollowing table are not exceeded:
Code

Max net quantity(grams or mLs or watercapacity of gas container)
per inner packaging

Max net quantity(grams or mLs or watercapacity of gas container)
per outer packaging

E0

Not permitted

Not permitted

E1

30

1000

E2

30

500

E3

30

300

E4

1

500

E5

1

300

There are further exemptions from IMDG Code rules for some categories ofdangerous goods in Excepted Quantities if the packages contain 1 gram or 1 mL orless of product105.
The number of packages in a single cargo transport unit containing dangerous goods
in Excepted Quantities shall not exceed 1000 packages.

B14.1 Marking requirements for Excepted Quantities
Packages must display the Excepted Quantities mark as shown, with the Class
number. If the name of the consignor or consignee is not shown on the package, oneof the other must be shown on the mark. No marking is required for the cargotransport unit.

* Class number** Name of the consignor or consignee

B15 Fumigated cargo transport units UN 3359106
See also the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units(CTU Code), Annex 9 and IMO publication “Revised Recommendations on the Safe
Use of Pesticides in Ships” as applicable to the fumigation of cargo transport units.

B15.1 Purpose of fumigation
Many cargo transport units carrying non-hazardous cargoes and some carrying
dangerous goods cargoes are fumigated while in transit by road and sea. Fumigation
was traditionally done to eliminate insect and bacteriological infestation in foodstuffs,
textiles and packaged goods, but has been extended to sterilisation of timber pallets,
packaging and dunnage to comply with national phytosanitary control regulations
105
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IMDG Code, 2018 Edition Amendment 39-18, Section 3.5.1.4
IMDG Code, 2018 Edition Amendment 39-18, Chapter 5.5

Part B – Reference and Classification93

enacted to prevent the accidental introduction of alien species that attack forests,
crops or native indigenous species.

B15.2 Hazards of fumigation
A fumigated unit is a closed cargo transport unit packed with cargo that is under
fumigation. Fumigation is done by introducing solid or liquid materials that produce
gases that are highly toxic (commonly Phosphine) or asphyxiant, then sealing thecontainer. The result is a cargo transport unit that is highly dangerous to enter, andpotentially dangerous to load below deck in certain types of ship because of the risk of
toxic gas escaping from the containers and injuring crew in occupied parts of the ship.
Ships need to be aware of which containers are under fumigation so that appropriate
stowage arrangements can be made and precautions taken.
Failure to declare fumigated units to the line is a breach of the IMDG Code and if
discovered on the quay can lead to short shipment of containers, delays in port, andprosecution of shippers by enforcement agencies. Shippers who consign fumigatedunits should carefully observe this section of the guide to ensure that proper
procedures are followed.
It is imperative that shippers notify the shipping line of any cargo transport unit tobe shipped under fumigation when making the booking.

B15.3 Definition of “fumigated cargo transport unit”(UN 3359 Special Provision 302 and IMDG 5.5)
A fumigated unit (containing toxic or asphyxiant gas for fumigation) is classified as
dangerous goods under the IMDG Code as follows:
UN 3359, FUMIGATED CARGO TRANSPORT UNIT, CLASS 9
A fumigated unit is subject to the IMDG Code until it has been ventilated by opening
the doors or by mechanical extraction until no harmful concentration of gas remains.

B15.4 IMDG operational requirements for fumigated cargo transport units107
Because of the highly dangerous nature of the fumigant gases used, the IMDG
Code specifies conditions for transporting fumigated units. These are contained in
IMDG 5.5 and in Special Provision 302 and the IMO “Recommendations for the Safe
Use of Pesticides in Ships”.

B15.5 Applying the fumigant to the cargo transport unit
Fumigation should be done according to the provisions of IMO publication“Recommendations for the Safe Use of Pesticides in Ships” as amended. Only cargotransport units that can be effectively sealed to prevent escape of gas can be used
for fumigation in transit. (Note: closed type cargo transport units can be sealed byapplying adhesive tape over air vents and around door seals). Fumigant shall not beapplied to a cargo transport unit once it has been loaded aboard a ship.

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B15.6 Marking of fumigated cargo transport units108
Fumigated units shall display the following warning mark on the outside of the doors
until such time as the cargo transport unit has been ventilated and no dangerous levelsof gas remain inside. Then the fumigation warning mark (illustrated) shall be removed.
The mark shall indicate:• Type of fumigant used
• Date of application• Time of application• Date of ventilation (if ventilation has been done)

300 mmNote: Fumigated units are not required to display Class 9 placards to indicate thefumigation hazard. Placard requirements for other dangerous goods that are carriedas cargo in a fumigated unit will be required in the normal way, in addition to thefumigation mark on the doors shown below:

400 mm
B15.7 Documentation for fumigated cargo transport units109
The shipper should present the shipping line with a document that indicates thefollowing information*:• UN 3359• FUMIGATED CARGO TRANSPORT UNIT
• Class 9• Type of fumigant used
• Amount of fumigant used
• Date and time of fumigation• Instructions for disposal of any residual fumigant or fumigation device***Note 1: A dangerous goods declaration must be made and presented in the normal way for any
dangerous goods in the cargo. This may be totally separate from documents providing information
on fumigation.
There is no requirement to present fumigation information on a UN-type dangerous goods
declaration, although these are often used and are good for the purpose, as they are readily
identifiable as dangerous goods information. A certificate of fumigation from the fumigation company
that applied the fumigant is also acceptable.
**Note 2: Disposal of residue: Some fumigant materials are solid plates or tablets that break down toa powdery residue as they release toxic gas over a period of time. When the shipping container is
unpacked, these residues should be removed from the container and disposed of with care, as they
may be capable of releasing gas on movement or exposure to air.

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IMDG Code, 2018 Edition Amendment 39-18, Section 5.5.2.4

Part B – Reference and Classification

95

B15.8 Loading fumigated cargo transport units to ships110
Because of the seriousness of the hazards arising from fumigated units, the IMDG
Code has instructions for the ship, that are summarised below:• The master shall be informed prior to loading any fumigated unit
• Fumigated cargo transport units shall be carried on ships in accordance with the
IMDG Code provisions for UN 3359 and MSC.1/Circ.1361 Revised
recommendations of the safe use of pesticides in ships• Fumigated units shall not be allowed onboard until sufficient period of time has
elapsed to allow a uniform concentration of gas throughout the cargo in it. This
period will vary according to the type of fumigant and nature of the cargo• When fumigated units are stowed under deck, equipment for detecting fumigant
gas(es) shall be carried on the ship with instructions for their use

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Part B – Reference and Classification

Case study

Liability judgment in ‘MSC Flaminia’111
The judgment in ‘MSC Flaminia’ found that extensive information available concerning
the stability of the commodity was ignored and not disclosed to the carrier. The judge
found that, “Disaster was a foreseeable result”.
Facts
Many will be aware of the essential facts behind this incident aboard ‘MSC Flaminia’.
In mid- July 2012, the ship was crossing the Atlantic from the United States boundfor Antwerp, Belgium, having left New Orleans, Louisiana some fourteen days earlier,laden with containerised cargo.
Alarms began sounding early on the morning of 14 July, alerting the crew to a smoky
cloud rising from one of the cargo holds. Firefighting procedures were initiated, but
an explosion cost the lives of three crewmembers and the fire continued to burn for anumber of weeks whilst the ship remained at sea.
In an earlier part of the complex and protracted proceedings, the Court had determinedthat the explosion was the result of runaway auto-polymerization of cargo consistingof divinylbenzene (DVB), stowed in the hold. Having reached a conclusion on thecausation, the more recent phase of the trial was to establish responsibilities between
the parties remaining in the proceedings, being essentially the owner, manager andoperator interests in the ship itself, the shipper of the DVB, and both the freight
forwarder and NVOC involved.
A case note of this nature can hardly do justice to the range of arguments andcounter-arguments raised between the parties; the judgment makes very interestingreading, providing detailed analysis of the facts, logistics industry processes, and theinterface of mandatory regulations and contractual terms. Most important, however, isthe clear application of the law.
Analysis
Relying heavily on the decision in ‘DG Harmony’, the judge stated the breach of the
duty of care “may arise both from a failure to conform with regulatory requirements,
or with standard industry or reasonable practice”, neatly balancing the interface ofobligations under regulation and general negligence. As a consequence, it was foundreasonable for the carrier to assume that the cargo was “manufactured and had
been delivered in a manner that would allow it to arrive safely at an overseas
destination under normal voyage conditions”; there was no expectation, absent
additional warning, that the carrier be aware of “dangers greater than those detailed
in the International Maritime Dangerous Goods (IMDG) Code”. By extension, ashipper has a duty to “warn the carrier of dangers posed by the cargo”. Importantly,
the judge concluded that there is “nothing in the IMDG Code [stating] that a shipper
and NVOCC may not provide additional information”.

111

In re M/V MSC Flaminia No. 12-cv-8892 (KBF) www.leagle.com/decision/infdco20180911a96
Originally published as TT Talk “Legal eagle: the consequences of foreseeability” on 15 January 2019

Case study97While the commodity was, at the time of the shipment, correctly classified as Class 9,
UN 3082112 , this was a generic listing that, absent more specific information, denotedthat the goods did not present dangers covered by any of the other classes. However,the circumstances were found to be other than “normal, reasonably anticipatedconditions” in that, contrary to the shipper’s own internal protocols, the shipment was
authorised to be loaded in a hotter location, with no additional measures, such as
specific temperature monitoring or carriage in refrigerated containers.
These factors were compounded by the NVOC with deficient system infrastructure,on which there was misguided reliance, and poor training together with amisunderstanding that industry practice sees the Dangerous Goods Declaration(DGD) as the “primary source of safe handling information for dangerous goods”,
rather than the Safety Data Sheet that may typically accompany the bill of
lading/carriage document. Critically, the DGD needs to contain sufficient information
to warn the carrier and permit appropriate actions, including stowage decisions.
Decision
The court found that the shipper failed to take account of the nature of the cargo
and specific circumstances of this shipment. The NVOC failed to act on the extensive
information available from the shipper and specifically did not disclose key
information about the cargo to the carrier. Following this reasoning, both the shipper
and NVOC were strictly liable under US Carriage of Goods by Sea Act (COGSA),
because while the carrier was aware of the generic dangers posed by the cargo, it
did not have “sufficient and relevant information” (and hence no responsibility) for the
specific additional hazards presented.
The judge went further to analyse the bill of lading terms, finding specific obligations
in relation to dangerous goods and a full indemnity (including “all reasonable legal
expenses and costs”) in favour of the carrier.
Comment
This case may be rare in that the shipper and NVOC were substantial US resident
entities. Not only did the evidence build sufficiently to pin liability to them, but there
were none of the common pitfalls concerning enforcement of the judgment (oncequantum has been determined).
The clear messages for shippers concern compliance with their own procedures,and ensuring that actions are considered and justifiable. The court was equallyclear that NVOCs are exposed where their negligence causes or contributes to aloss that is foreseeable.

Utilising the bill of lading provisions was particularly favourable to the carrier since it
presents the potential (in the US) to recover beyond the scope of COGSA alone.

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Classification for DVB was subsequently changed in Amendment 38-16 to Class 4.1 (Flammablesolids, self-reactive substances, solid desensitized explosives and polymerizing substances), UN 3532

Case studyReferences

IMDG Code Amendment 39-18
The references in this guide apply to IMDG Code Amendment 39-18 that will comeinto force on 1 January 2020 for two years to 31 December 2021, but may be
applied voluntarily from 1 January 2019.
The previous Amendment, 38-16, may no longer be used after 31 December 2019.
This and all previous versions should be destroyed and any reliant corporate
procedures updated as appropriate.
The IMDG Code is updated by the International Maritime Organization with a new
Amendment every two years, based on the UN Recommendations on the Transportof Dangerous Goods Model Regulations, a guidance document developed by theUnited Nations to harmonise dangerous goods transport regulations.

Transition year wheneither amendment is valid

2017

Year when a single
amendment is valid

2018

2019

2020

2021

2022

2023

38–16

39–18

40–20

The International Maritime Dangerous Goods Code (IMDG Code) is published by theInternational Maritime Organization, 4 Albert Embankment, London SE1 7SR

IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units(CTU Code), 2014
CTU Code Sales number IC284E, ISBN 978-92-801-1629-8
The CTU Code is available in print and electronic versions from the IMO, ILO andUNECE websites. The IMO website113 includes subsequent material. The UNECE
website114 maintains searchable pages and links to language versions. The CTU Codeis thus available in Arabic, Chinese, English, French, German, Russian and Spanish.

Fumigation guidance“Recommendations on the Safe Use of Pesticides in Ships” available from theInternational Maritime Organization in the IMDG Code Supplement.
“Fumigation of ships and their Cargoes” guidance on fumigation published by the UK
P&I Club is available free of charge from the UK Club website115.

www.imo.org/en/OurWork/Safety/Cargoes/CargoSecuring/Pages/CTU-Code.aspx
www.unece.org/trans/wp24/guidelinespackingctus/intro.html
114 www.ukpandi.com/ukpandi/resource.nsf/Files/CtoC8/$FILE/CtoC8.pdf
112
113

Checklists

99

Checklists

This section contains three checklists intended
for easy photocopying. They are based on
IMDG Code processes and are included toassist shippers and container packers to carryout key functions in the correct way:
Shipper’s dangerous goods declaration checklist
This provides a guide to key pieces of dangerous goods information the shipper
must include on his dangerous goods declaration.

Consolidator’s dangerous goods training and procedure checklist
This is a simple management checklist consisting of a number of questions acontainer consolidator/packer may ask about his own organisation in regard to theway dangerous goods are handled. The questions are a way of identifying whichpeople carry out particular operations on a given site, how they do it, whether they do
it correctly in terms of the IMDG Code, and whether they have been given adequate
materials, information, supervision and training to carry out their tasks properly. The
aim is to help to identify any knowledge or procedural gaps in the system, so thatmanagement can take corrective measures.

Dangerous goods container packer’s checklist
This provides a guide to information the packer should have, the checks he shouldmake on dangerous goods packages and the shipping container before he starts
packing a container, and the physical and documentary processes he should follow
to comply with the IMDG Code during and after packing.

Checklists

101Shipper’s dangerous goods declaration checklist
Note: this checklist is not exhaustive and is only applicable where relevant. Other information may be required depending on
the commodity being carried.
Consignment reference no:
Have you completed the following information? Tickas appropriate

Entered shipper’s name and addressEntered consignee’s name and address

Port of loadingEntered journey details:

Port of destination
Final destination
Name of ship

Entered number and type of packages for each UN NumberEntered dangerous goods details for each UN Number:

UN Number
Proper Shipping NameClassEntered additional information, where applicable,
for each UN Number according to the IMDG Code:Sub-Hazard
Packing Group
Flashpoint
Marine pollutant
Control temperature
Emergency temperature
NECEntered quantity details for each UN Number:

Net dangerous goods cargo weight
Gross dangerous goods cargo weight
Gross weight including tare weight of containerEntered the name of your company

Completed the shipper’s declaration:

Entered your name and job title
Entered the date and place where you created the document
Entered the signature of the responsible person
102

Checklists

Consolidator’s dangerous goods training andprocedure checklist
This is a checklist to confirm that you have sound operating procedures. Tick

Do you know who receives dangerous goods into your site?

as appropriate

Is anyone responsible for checking shipping containers
before packing?

Are they trained to check documentation andpackage marking?

Have they been trained in what to check for?

Does anyone keep a record of dangerous goods on
your site?

Have fork lift operators been trained in IMDG Codesegregation?

Is the record kept up-to-date?

Have fork lift operators received training in packing
dangerous goods and non-hazardous cargo into containers?

Is the location recorded?
Do your personnel palletise/re-package/shrink-wrap
dangerous goods packages, or put put them into
overpacks?

Is anyone responsible for ensuring that packages havebeen secured inside the shipping container?
Have they been trained to secure cargo?

Have they been trained to mark and label the packages
to IMDG rules?

Are timber, plywood sheet and securing materials
available?

Are packing plans prepared for cargo transport units?

Are tools available for cutting timber and plywood sheets?

Do you know who controls packing of dangerous goods
into shipping containers?

Are people trained to use them?
Are container manifests prepared?

Do they have access to the IMDG Code rules?
Are manifests checked to include all the dangerous goods?
Have they been trained to understand IMDG Codesegregation?

Do you know who is responsible for applying hazard
warning placards and marks?
Have they been trained?
Is the stock of placards and marks adequate?
Are seals applied and seal numbers recorded?
Are packing certificates completed and signed?
Have the persons authorised to sign the packing
certificates been trained and do they understand the legal
significance of packing certificates?

Checklists

103Dangerous goods container packer’s checklist
Container no:
Have you completed the following information? Tickas appropriate

You have received the shipper’s dangerous goods
declaration

Check you have removed old redundant placards andmarks from the container

The details on the dangerous goods declaration agreewith the labels on the packages

Check that the date on the container safety approval plateis valid, or that the plate is marked with “ACEP”

The shipper has signed the shipper’s declaration

Create a packing plan for packers to follow

Packages or drums are not leaking
Packages show the correct marks and labels:

If packing different types (different UN Numbers)of dangerous goods, check IMDG segregation rules
before packing

Proper Shipping NameDistribute the cargo weight evenly along the container

Class label

Place dangerous goods packages nearest to the doors

UN Number
Sub-hazard label (if applicable)

Fill all gaps between packages or effectively secure andbrace packages to ensure that packages inside thecontainer cannot move

Marine pollutant mark (if applicable)

Secure the doors

UN Packaging code (unless Limited Quantities)

Fix security seal to the doors and carefully record the seal
number on the dangerous goods document

Limited Quantities diamond mark (if applicable)
You understand the nature of the hazard from the labels

Enter the container number on the dangerous goods
document

You have inspected the condition of the container
before packing:Fix the correct placards and marks to the outside of thecontainer on both sides, front and backCheck for residue

Sign the packing certificate

Check for nails in floor

Ensure that the dangerous goods document and packing
certificate are passed to the ship with the container

Check for holes
Check for excessive damage

104

Checklists

About us

UK P&I ClubUK P&I Club is a leading provider of P&I insurance and other services to theinternational shipping community. Established in 1865, the UK P&I Club insuresover 240 million tonnes of owned and chartered shipping through its international
offices and claims network. ‘A (Stable)’ rated by Standard & Poor’s with freereserves and hybrid capital of $597m, the UK P&I Club is renowned for its specialist
skills and expertise that ensure ‘best in class’ underwriting, claims handling and loss
prevention services.
www.ukpandi.com

TT Club
TT Club is the international transport and logistics industry’s leading provider of
insurance and related risk management services. Established in 1968, the Club’s
membership comprises ship operators, ports and terminals, road, rail and airfreight
operators, logistics companies and container lessors. As a mutual insurer, the Club
exists to provide its policyholders with benefits, which include specialist underwriting
expertise, a worldwide office network providing claims management services, andfirst class risk management and loss prevention advice.
www.ttclub.com

Thomas Miller
UK P&I Club and TT Club are managed by Thomas Miller, an independent andinternational provider of market leading insurance services. Most of the businesses
we currently own or manage are acknowledged leaders in their chosen market.
Our portfolio includes mutual organisations and, increasingly, specialist insurance
services businesses.
www.thomasmiller.com

About us105

A vision for safer practices indangerous goods shipping…
over 30 years later and still developing innovative
solutions for the Safety of Life at Sea.

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safety.. wwwwww.hazcheck.com
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