Amendment 35-10 of International Maritime Dangerous Goods Code Now Mandatory

Background on the IMDG Code

The International Maritime Dangerous Goods (IMDG) Code is the worldwide regulation for transporting dangerous goods by sea. The IMDG Code is written in conjunction with the International Convention for the Safety of Life at Sea (SOLAS) and the International Convention for the Prevention of Pollution from Ships (MARPOL). The IMDG Code was developed as a uniform international code for the transport of dangerous goods by sea covering the classification, packaging, marking, labeling, placarding, stowage and segregation of cargo.

The most recent changes to the code were implemented in Amendment 35-10 and enacted in the 2010 edition of the IMDG code, which was published in late 2010. While the 2010 edition was in effect on a voluntary basis during 2011, it became mandatory on Jan. 1, 2012.

Changes Implemented in Amendment 35-10

The 2010 is the first edition of the IMDG Code to include change marking (i.e., squares, triangles, and circles with an “x”) in the margins to identify which requirements have been added, amended or removed since the last edition. These editorial markings are similar to existing marks in the ICAO Technical Instructions or the A.I.R. Shipper.  Other key changes to the IMDG Code in the 2010 edition include:

  • Limited Quantity Marking:  One of the most far-reaching changes involves the new limited quantity markings.  Limited quantity packages will no longer require the material’s UN identification number. Packages containing limited quantities of dangerous goods need not be labeled nor marked with the marine pollutant mark, proper shipping name, or UN number. Additionally, cargo transport units containing dangerous goods in only limited quantities shall not be placarded; however, CTU’s shall be marked on the exterior with the limited quantity marking which shall have the minimum dimensions of 250mm x 250mm.  The special exception that was provided for “consumer commodities” has been removed.  This will have significant implications for companies that ship consumer commodities by sea since they will now be required to use shipping papers and appropriate markings.
  • Fumigated Containers:  Provisions for fumigated containers have been consolidated in Section 5.5.2 of the IMDG Code. They include mandatory training for fumigators, marking and placarding requirements, and the need for a fumigation certificate for UN 3359 in transit.  The fumigation container marks have also changed.
  • “ENGINE, INTERNAL COMBUSTION or VEHICLE, FLAMMABLE GAS POWERED or VEHICLE, FLAMMABLE LIQUID POWERED or ENGINE, FUEL CELL, FLAMMABLE GAS POWERED or ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED or VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED or VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED” (UN3166) are now fully regulated unless specifically excluded under the new Special Provision (SP) 961.
    • SP 961 provides exceptions for roll–on/roll–off ships, empty or near–empty fuel tanks, and wet or dry electrical battery–powered vehicles.
    • SP 962 provides the carriage requirements for UN 3166. These include limiting liquid fuel tanks to 1/4 full or 250 L max; documentation; visual inspections of fuel tanks and batteries; and an exception for marks, labels, and placards.
  • Marking Size:  Minimum marking sizes now apply for packages and container transport units including portable tanks.
  • Document retention: Shipping papers (dangerous goods transport documents) now must be retained for a minimum of three months. When they are stored electronically, the shipper and carrier must be able to reproduce them in printed form.
  • General awareness and function-specific training for shore-side staff must be timely:
    • 1.3.1.1: Employees shall be trained in accordance with the provisions of 1.3.1 before assuming responsibilities and shall only perform functions, for which required training has not yet been provided, under the direct supervision of a trained person.”
  • A new section (7.5.4, “Tracking and monitoring equipment”) has been added.  It states that if tracking and monitoring equipment is to be used, it must be of a type certified to be safe for the dangerous goods that will be carried within the cargo transport unit. The IMDG Code references the International Electrotechnical Commission publication IEC 60079.
  • The Code allows the use of electronic shipping papers as an equivalent to hardcopy documentation, with certain provisions. To better address the combination of electronic and hardcopy documentation, the phrase “transport information” is used in favor of “shipping papers” or “transport document,” the rationale being “transport information” addresses the information itself, and not the form in which it is presented. Section 5.4.1 is renamed “Dangerous Goods Transport Information” and a new section (5.4.6, “Retention of Dangerous Goods Transport Information”) has been added.
  • There are 20 new entries in the Dangerous Goods List:
    • UN 0509 – POWDER, SMOKELESS
    • UN 1471 – LITHIUM HYPOCHLORITE, DRY or LITHIUM HYPOCHLORITE MIXTURE
    • UN 3166 –  ENGINE, INTERNAL COMBUSTION or VEHICLE, FLAMMABLE GAS POWERED or VEHICLE, FLAMMABLE LIQUID POWERED or ENGINE, FUEL CELL, FLAMMABLE GAS POWERED or ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED or VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED or VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED
    • UN 3482 – ALKALI METAL DISPERSION, FLAMMABLE or ALKALINE EARTH METAL DISPERSION, FLAMMABLE
    • UN 3483 – MOTOR FUEL ANTI-KNOCK MIXTURE, FLAMMABLE
    • UN 3484 – HYDRAZINE AQUEOUS SOLUTION, FLAMMABLE with more than 37% hydrazine, by mass
    • UN 3485 – CALCIUM HYPOCHLORITE, DRY, CORROSIVE or CALCIUM HYPOCHLORITE MIXTURE, DRY, CORROSIVE with more than 39% available chlorine (8.8% available oxygen)
    • UN 3486 – CALCIUM HYPOCHLORITE MIXTURE, DRY, CORROSIVE with more than 10% but not more than 39% available chlorine
    • UN 3487 (PG II & III) – CALCIUM HYPOCHLORITE, HYDRATED, CORROSIVE or CALCIUM HYPOCHLORITE, HYDRATED MIXTURE CORROSIVE with not less than 5.5% but not more than 16% water
    • UN 3488 – TOXIC BY INHALATION LIQUID, FLAMMABLE, CORROSIVE, N.O.S. with an inhalation toxicity lower than or equal to 200 ml/m³ and saturated vapour concentration greater than or equal to 500 LC50
    • UN 3489 – TOXIC BY INHALATION LIQUID, FLAMMABLE, CORROSIVE, N.O.S. with an inhalation toxicity lower than or equal to 1000 ml/m³ and saturated vapour concentration greater than or equal to 10 LC50
    • UN 3490 – TOXIC BY INHALATION LIQUID, WATER-REACTIVE, FLAMMABLE, N.O.S. with an inhalation toxicity lower than or equal to 200 ml/m³ and saturated vapour concentration greater than or equal to 500 LC50
    • UN 3491 – TOXIC BY INHALATION LIQUID, WATER-REACTIVE, FLAMMABLE, N.O.S. with an inhalation toxicity lower than or equal to 1000 ml/m³ and saturated vapour concentration greater than or equal to 10 LC50
    • UN 3492 – TOXIC BY INHALATION LIQUID, CORROSIVE, FLAMMABLE, N.O.S. with an inhalation toxicity lower than or equal to 200 ml/m³ and saturated vapour concentration greater than or equal to 500 LC50
    • UN 3493 – TOXIC BY INHALATION LIQUID, CORROSIVE, FLAMMABLE, N.O.S. with an inhalation toxicity lower than or equal to 1000 ml/m³ and saturated vapour concentration greater than or equal to 10 LC50
    • UN 3494 (PG I, II & III) – PETROLEUM SOUR CRUDE OIL, FLAMMABLE, TOXIC
    • UN 3495 – IODINE
    • UN 3496 – BATTERIES, NICKEL-METAL HYDRIDE
  • Exclusions of gases of classes 2.2 for certain items, such as balls intended for use in sports, tires (inflated) and light bulbs containing pressurized gas have been added.

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  1. Gregory Sutherland said:

    Where in the IMDG code is this change located??

    ■Marking Size: Minimum marking sizes now apply for packages and container transport units including portable tanks.

  2. Bob Richard said:

    I should clarify that the minimum marking size for packagings will not apply until Amdt. 36-12 comes into force. There will be a 1 year transition period so these will apply from January 1, 2014.

    5.3.20.2 currently requires the proper shipping name to be not less than 65 mm high on CTUs (e.g. portable tanks).

    Amendment 36-12 paragraph 5.2.1.1 will include a new second sentence as follows:
    “The UN number and the letters “UN” shall be at least 12 mm high, except
    for packagings of 30 litres or 30 kg capacity or less, when they shall be at
    least 6 mm in height and for packagings of 5 litres or 5 kg or less when they shall be of an appropriate size.”.

  3. Bob Richard said:

    I should clarify that the minimum marking size for packagings will not apply until Amdt. 36-12 comes into force. There will be a 1 year transition period so these will apply from January 1, 2014.

    5.3.20.2 currently requires the proper shipping name to be not less than 65 mm high on CTUs (e.g. portable tanks).

    Amendment 36-12 paragraph 5.2.1.1 will include a new second sentence as follows:
    “The UN number and the letters “UN” shall be at least 12 mm high, except
    for packagings of 30 litres or 30 kg capacity or less, when they shall be at
    least 6 mm in height and for packagings of 5 litres or 5 kg or less when they shall be of an appropriate size.”.

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