shipping hazardous materials by vessel

Compliance Reference

Shipping Hazardous Materials by Vessel

Lion Technology Inc.570 Lafayette RoadSparta, NJ 07871(973) 383-0800http://www.lion.com


© Lion Technology Inc.

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LION CORPORATE POLICIES

Confidentiality

Any non-public information supplied by the client is kept as top confidential until and unless a formal release is obtained.

The nature and scope of our services for any client are considered to be confidential.

Information to be supplied to outside agencies (e.g. reports, requests for exemptions, permits, or registrations) will be, when requested, prepared by LION TECHNOLOGY INC. and then vetted, approved, and submitted by the client and not LION TECHNOLOGY INC. The client assumes full responsibility for the accuracy, completeness, and scope of information supplied in all cases, whether researched, prepared, and/or drafted by LION TECHNOLOGY INC. or not.

In instances where LION TECHNOLOGY INC. may represent a client, either openly or on a nondis-closed (blind) basis, only information approved by the client will be presented, and the client assumes responsibility therefore in all instances and aspects.

In the event of termination of our services per any agreements in effect, such materials or infor-mation as particularly relate to the client will be promptly returned and/or destroyed.

Ethics

Our responsibility is to our clients. Our goal is to assist them in complying with and, where pos-sible, benefiting from the hazardous materials/wastes regulations affecting their business area. We do endeavor to guide implementation of the most practical and inexpensive programs possible to achieve safety and compliance.

Concurrently, we have assumed the profes-sional and social responsibility to meet the objec-tives of protecting human and environmental health, safety, and integrity. Therefore, we do not assist in finding “loopholes” or developing avoid-ance procedures not in the spirit of said laws and responsibilities.

We deal only with subcontractors, suppliers, and professionals as have been found to maintain similar high standards of integrity, capabilities, and ethics. This protects both our clients and our own interests, and we are adamant in this regard.

Copyrights

The GMP (Good Management Practices) System and all related materials, modules, liter-ature, and other elements thereof are the copy-righted property of LION TECHNOLOGY INC. No copies, photographs or recordings, or duplications in any form may be made without specific written authorization from LION TECHNOLOGY INC.

Disclaimer

This workshop has been designed to provide guidelines for compliance with the applicable Acts, Rules, and Regulations thereunder as in effect at the date of publication hereof. Notwithstanding that the workshops are intended to serve such pur-poses, LION TECHNOLOGY INC. and/or any and all agents or affiliates, cannot and shall not be or become liable or responsible in any way, with or without the use of these workshops, in connection with or for any loss, injury, damage, penalty, or vio-lation to, by or in respect of any person or property, however caused. Neither LION TECHNOLOGY INC. nor any of their agents or affiliates, act or pur-port to act as legal counsel, guarantor, warrantor, or insurer with respect to the workshops and/or the contents thereof.

Errors and OmissionsAs stated in the promotional materials, we

here again state our policy on errors and omissions. All conclusions, information, worksheets, or other actions resulting from these meetings should be reviewed with your legal counsel before proceed-ing. Neither LION TECHNOLOGY INC., its Divi-sions, representatives, or personnel assume any responsibility for errors and/or omissions regard-less of cause and by whom.

Your attendance, participation, and/or any actions are to be with this explicit understanding.

Preface


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OUR GOAL FOR THIS WORKSHOP

Your Training—US DOT Mandates

This Shipping Hazardous Materials by Vessel Workshop provides US DOT-required regulatory training for managers of hazardous materials. Our primary goal for the workshop is to give you a comprehensive understand-ing of how international air transportation rules work and to enable you to find your way through the regulations to determine the applicability of various requirements to your particular materials and circumstances.

This workshop is intended to provide gen-eral awareness training and function-specific training for the hazmat compliance profes-sional. To satisfy DOT training requirements, you must also receive and document chemical safety training sufficient to your duties and in compliance with DOT rules discussed herein. For a few unique jobs in hazardous materi-als transportation, some additional specialty training may be required (e.g., if your com-pany maintains its own tank trucks, you may require training and periodic review of the tank construction details).

What You Already Know

In this workshop, we assume students come with a working knowledge of the U.S. Department of Transportation rules, found at 49 CFR. Students without this knowledge should attend Lion’s Hazardous Materials Transportation Workshop.

Training Others in Your Organization

US DOT rules require training for all per-sons involved in any way with hazardous materials transportation. Please keep in mind, however, that the training you are now receiv-ing is not the training needed by your opera-tions personnel. You are the key to successful hazmat compliance and safety because you will be working with the regulations, deter-mining requirements, and then instructing others in your company in the procedures to correctly and safely ship or transport hazard-ous materials.

Throughout this workshop and these manuals, you will find suggestions, checklists, formats, and tips to help you establish an effec-tive hazmat compliance system. These include training tools and materials. Please remem-ber, however, that training itself is a skill to be learned and developed. If your company has a training department of any kind, we strongly advise that you work with them in developing and presenting any in-house operations train-ing. If you do not have such resources, you should carefully select the best trainer or train-ers in your group (training teams work very well) to perform this function.

Training vs. Consulting

We welcome and appreciate your partic-ipation with questions, and we make every effort to use real-life examples to illustrate regulatory principles. However, please keep in mind that we have limited time and cannot always answer specific questions that are not of



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general interest. Lion offers consulting services in the form of telephone Hotline accounts, spe-cial projects, and on-site consulting to assist you with needs beyond the scope of this train-ing. If you are interested in receiving infor-mation on any of these services, please call us at 973-383-0800. We will be happy to help in whatever way that we can.


Preface

Introduction

Step 1 .............................................................................................Classification

Step 2 ............................................................................................ Identification

Step 3 ..................................................................................................... Packing

Step 4 ................................................................................Marking and Labeling

Step 5 ......................................................................................... Documentation

Step 6 ..........................................Placarding and Marking Cargo Transport Units

Step 7 ................................................................................ Transport Operations

Step 8 ............................................................................... Incidents and Security

Step 9 ................................................................. Administrative Responsibilities

Step 10 ....................................................................... Keeping Up With Changes

Index

© Lion Technology Inc.IMDG CR

Preface


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DETAILED TABLE OF CONTENTSCompliance Reference

Introduction

DOT, IMO, and the IMDG Code..........................................................................................1

DOT Requirements for Using the IMDG Code .................................................................2

Structure of the IMDG Code ................................................................................................5

Additional IMO Standards and Publications ...................................................................7

Compliance and Enforcement ............................................................................................9

Ten Steps to Vessel Transportation of Dangerous Goods .............................................10

49 CFR Part 171 ...................................................................................................................12

Step 1—Classification

Step 1—Classification ........................................................................................................21

Hazard Class Definitions/Tests .......................................................................................23

The IMDG Code’s Hazard Classes and Divisions ..........................................................25

Determining Subclassifications ........................................................................................33

The Dangerous Goods Classification Process ................................................................34

Classifying Dangerous Goods Not Named on the Dangerous Goods List ...............36

Practical Issues in Dangerous Goods Classification ......................................................37

Multiple-hazard Materials ................................................................................................38

Classifying Marine Pollutants ..........................................................................................41

“Overclassifying” a Material as a Dangerous Good .....................................................42

Classifying Samples for Transport ...................................................................................43

Forbidden Dangerous Goods ...........................................................................................44

The Dangerous Goods Classification Process: Example: Propellant and Rocket Fuel ........................................................................46

Step 2—Identification

Step 2—Identification ........................................................................................................53

The 3.2 Dangerous Goods List .........................................................................................54

Selecting a Proper Shipping Name ..................................................................................56

Naming Mixtures and Solutions ......................................................................................61

Naming Marine Pollutants ...............................................................................................63

Modifying Proper Shipping Names ................................................................................64

Segregation Groups............................................................................................................67


Detailed Table of Contents, continued


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Step 3—PackingStep 3—Packing ..................................................................................................................69

Packaging Definitions ........................................................................................................71

IMDG vs. DOT Packaging Requirements .......................................................................76

Using the 3.2 Dangerous Goods List ...............................................................................77

Basic Packaging Concerns .................................................................................................78

General Provisions for Packagings, IBCs, and Large Packagings ...............................79

Authorized IMDG Packaging ...........................................................................................83

Packing Instructions for Packagings, IBCs, and Large Packagings ............................85

UN Specification Marks for Packagings .........................................................................89

Packaging Identification Codes for Non-bulk UN Specification Packagings ...........92

Marking of Non-bulk Packages .......................................................................................95

UN Specification Marks for Large Packagings ..............................................................96

Marking of Intermediate Bulk Containers .....................................................................97

UN Specification Marks for IBCs .....................................................................................98

Additional IBC Markings ................................................................................................101

Special Provisions.............................................................................................................103

Limited Quantity Packaging ..........................................................................................104

Excepted Quantity Packaging ........................................................................................106

Portable Tanks, Multi-Element Gas Containers (MEGCs), and Bulk Containers ...109

Special Packaging Issues .................................................................................................114

Step 4—Marking and LabelingStep 4—Marking and Labeling ......................................................................................117

General Marking and Labeling Requirements .............................................................118

Marking and Labeling Requirements for Fully Regulated Packages .......................121

Additional Marking and Labeling Requirements for Fully Regulated Non-bulk Packages........................................................................122

Special Marking and Labeling Situations .....................................................................126

Marking Requirements for Overpacks, Unit Loads, and Salvage Packaging .........135

Preface



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Step 5—DocumentationStep 5—Documentation ..................................................................................................137

Standard Transport Document Descriptions ...............................................................139

Indicating Quantities on Transport Documents ..........................................................141

Modifying the Dangerous Goods Description .............................................................142

Shipper’s Certification .....................................................................................................148

DOT Emergency Response Information .......................................................................149

Additional Documentation Requirements ...................................................................152

Retention of Shipping Papers .........................................................................................154

Step 6—Placarding and Marking Cargo Transport Units

Step 6—Placarding and Marking Cargo Transport Units ..........................................155

Placarding Cargo Transport Units .................................................................................156

Marking Cargo Transport Units .....................................................................................159

Step 7—Transport Operations

Step 7—Transport Operations ........................................................................................165

Packing Cargo Transport Units ......................................................................................166

Dangerous Goods Segregation .......................................................................................170

Dangerous Goods Stowage .............................................................................................173

Step 8—Incidents and Security

Step 8—Incidents and Security ......................................................................................175

Incident Reports ...............................................................................................................177

Emergency Response Requirements .............................................................................180

Dangerous Goods Cargo Security .................................................................................181

Hazmat Cargo Security Plans .........................................................................................182

Dangerous Goods Cargo Security Plans .......................................................................184

Step 9—Administrative Responsibilities

Step 9—Administrative Responsibilities ......................................................................187

IMDG Approvals and Exemptions ................................................................................188

IMO Organization ............................................................................................................190




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Step 10—Keeping Up With Changes

Step 10—Keeping Up With Changes .............................................................................193

IMDG Regulatory Updates .............................................................................................195

Training: 49 CFR vs. the IMDG Code .............................................................................197

Training Your Hazmat Employees .................................................................................199

Compliance Training Programs .....................................................................................200

Index



Introduction



CONTENTS

DOT, IMO, and the IMDG Code ...........................................................................................1

DOT Requirements for Using the IMDG Code ...................................................................2

Structure of the IMDG Code ..................................................................................................5

Additional IMO Standards and Publications .....................................................................7

Compliance and Enforcement ..............................................................................................9

Ten Steps to Vessel Transportation of Dangerous Goods ...............................................10

49 CFR Part 171.....................................................................................................................12

Introduction


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DOT, IMO, AND THE IMDG CODE

US DOT vs. IMO

The US DOT

The US DOT (United States Department of Transportation) is the regulatory agency in charge of all transportation within the United States. The Agency is tasked with creating the regulations to implement the laws created by Congress.

The US DOT publishes the Hazardous Materials Regulations, which are sometimes referred to as the “HMR.” The hazardous materials regulations are Federal rules that, by law, must be followed when shipping hazard-ous materials, or hazmat.

The IMO

The IMO (International Maritime Organi-zation) is a specialized agency of the United Nations that focuses on the improvement of safety at sea and the prevention of pollution from ships. The IMO also deals with interna-tional aspects of liability and compensation and the facilitation of maritime traffic.

In order to achieve these objectives, IMO member countries (174 Member States and 3 Associate Members) develop and promote the adoption of conventions, protocols, codes, and recommendations concerned with the above.

The IMO publishes the International Mar-itime Dangerous Goods Code, or IMDG Code. The IMDG Code is a uniform international code for the safe vessel transport of dangerous goods by sea that addresses the issues of pack-

ing, container traffic, and stowage, with partic-ular reference to the segregation of incompat-ible substances. The IMDG Code is intended to protect crew members and also to prevent marine pollution.

Shipping Hazmat/Dangerous Goods by Vessel [49 CFR 171.22]

The US DOT has requirements for ship-ping hazardous materials by highway, rail, vessel, and air. However, as long as certain additional conditions are met, the DOT autho-rizes shippers to follow the IMDG Code in lieu of the DOT regulations:

• When shipping by vessel in the US, and

• Before and after the voyage (i.e., getting to and from the port).

Hazardous Materials vs. Dangerous Goods

The US DOT regulates shipments of “haz-ardous materials.” The IMDG Code, on the other hand, regulates shipments of “danger-ous goods.” As we will see in the next section, the definitions of these two things are fairly similar, but there are a few key differences.

For most of this manual, unless we are specifically covering DOT requirements, we will refer to the materials that are being regu-lated while shipped as “dangerous goods.”



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DOT REQUIREMENTS FOR USING THE IMDG CODE

Four Conditions for Using the IMDG Code

In order to use the IMDG Code when ship-ping a hazardous material, four conditions must be met:

1. At least part of the trip must be by vessel.

2. The material cannot be forbidden from transport by the DOT.

DOT forbidden materials are described as forbidden at:

– 49 CFR 173.21.

– Column 3 of the 49 CFR 172.101 Table.

– Column 9A of the 49 CFR 172.101 Table if transported by passenger aircraft.

– Column 9B of the 49 CFR 172.101 Table if transported by cargo aircraft.

3. If the material is regulated by the DOT, but NOT by IMDG rules, it cannot be shipped under IMDG rules as non-hazardous.

4. Certain DOT regulations (i.e., the DOT “extras”) must still be met.

DOT “Extras” Required for All Shipments [49 CFR 171.22(g) and 171.25(b)]

The following DOT requirements must be met for all shipments, even when follow-ing IMDG requirements for shipping danger-ous goods:

1. Emergency response information require-ments in 49 CFR 172, Subpart G.

2. Training requirements in 49 CFR 172, Subpart H.

This subpart requires that all hazmat employees receive general awareness, security awareness, and function-specific training. If employees will be operating under the IMDG rules, then function-specific training must include training in the use of these international standards.

3. Security requirements in 49 CFR 172, Subpart I.

This subpart prescribes requirements for development and implementation of plans to address security risks related to the transport of hazardous materials in commerce.

4. General packaging requirements in 49 CFR 173.24 and 173.24a (preparing packages so that they can withstand the rigors of normal transportation, using authorized packagings, properly closing packages, etc.).

Introduction


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DOT Requirements for Using the IMDG Code, continued

5. Requirements for reuse, reconditioning, and remanufacturing of packagings in 49 CFR 173.28.

6. Incident reporting requirements in 49 CFR 171.15 and 171.16 for incidents within the US or aboard a vessel any-where in commerce if registered in the United States.

7. Registration requirements in 49 CFR 107, Subpart G.

8. Applicable requirements in 49 CFR 171 and 176 regarding carriage by vessel.

DOT “Extras” Required for Specific Shipments [49 CFR 171.23(a) and (b) and 171.25(b) and (c)]

In addition to the DOT rules that apply to all shipments shipped under the IMDG Code, the DOT also has specific, additional require-ments for the following materials:

1. Hazardous substances (“RQ” communi-cations required)

2. Hazardous wastes (the word “waste” must be included as part of the Proper Shipping Name and manifesting require-ments must be met)

3. Marine pollutants (bulk packages must be marked with the marine pollutant mark and shipping papers must include the words “marine pollutant”)

4. Cylinders

5. Aerosols

6. Safety devices for vehicles, vessels, or aircraft (e.g., airbags)

7. Chemical oxygen generators

8. Explosives

9. Organic peroxides

10. Poison inhalation hazards

11. Radioactives

12. Self-reactives

13. Lithium-metal batteries

14. Dangerous goods shipped in portable tanks

15. Dangerous goods shipped in intermediate bulk containers (IBCs)

Bulk Packagings Other Than IBCs and Portable Tanks

Bulk packagings other than IBCs and por-table tanks must conform to the requirements at 49 CFR 171–180.

Transport by Highway or Rail Before or After Vessel Transportation [49 CFR 171.25(b)(1) and (2) and 172, Subpart F]

In general, the shipper is allowed to follow IMDG rules for the entire trip, including trans-port of the package to and from the port by ground. However, even though the package itself may be prepared according to IMDG



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DOT Requirements for Using the IMDG Code, continued

rules, the carrier rules at 49 CFR 174 and 177 still apply to the handling of the package while the package is being transported by rail or on the highway. These would include rules for things such as:

• Acceptance and transportation of hazmat by private, common, or contract carriers by motor vehicle or by rail carriers.

• Loading and unloading of vehicles.

• Driver training.

• Requirements for complying with Federal Motor Carrier Safety Administration regulations (FMCSA) and Federal Railroad Administration (FRA) rules.

• Segregation and separation of hazmat packages. (Note: The DOT authorizes shippers to follow the segregation re-quirements of Part 7 of the IMDG Code in lieu of DOT segregation requirements.)

• Placarding of vehicles and rail cars.

• Use of shipping papers.

• Making records, equipment, packagings, etc. available to the DOT for inspection.

• Responding to accidents.

Special Situations [49 CFR 172, Subparts D, E, and F]

Depending on the material, certain situa-tions involve more unique marking, labeling and placarding requirements when it comes to transport to/from a ship yard. For example:

• Combustible liquid placards are required for the ground portion of a trip but are prohibited for the vessel portion.

• A cargo transport unit containing a material that is a marine pollutant by vessel mode only (i.e., not per ground rules) may display the “MP” mark during the ground portion of the trip, but is not required to do so.

Use of the IMDG Code in Port Areas [49 CFR 171.25(d)]

Hazardous materials being imported into or exported from the United States (or pass-ing through the United States in the course of being shipped between other countries out-side the United States) may be offered and accepted for transportation by motor vehicle within a single port area (including contigu-ous harbors) when packaged, marked, classed, labeled, stowed, and segregated in accordance with the IMDG Code.

Within a port area, only three DOT require-ments must be met:

1. DOT shipping papers must accompany the shipment.

2. The motor vehicle must be placarded according to applicable DOT rules.

3. Any applicable vessel carrier rules at 49 CFR 176 must be followed.

NOTE: If the shipment will only be transferred between vessels and will never be trans-ported by public highway, then an emergency response number is not required on the ship-ping papers.

Introduction


Notes:

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STRUCTURE OF THE IMDG CODE

Overall Structure and Pagination

The IMDG Code is updated every other year and completely republished as a two-volume book set. The Code is divided into seven parts, followed by two appendices and an index. Volume 2 contains Part 3, the appendices, and the Index, while Volume 1 contains everything else.

Unlike the DOT regulations, which start numbering each section at 1, the pages of each volume of the IMDG Code are numbered con-tinuously and sequentially from the first sec-tion to the last. Volume 2 restarts numbering at page 1.

Format of the Code

The IMDG Code is divided into parts, chap-ters, sections, and subsections. Parts, chapters, sections, and subsections are formatted by numbers separated by “points.” For example, the standards for container packing certificates are in IMDG 5.4.2, meaning:

– Section 2

– Of Chapter 5.4

– Of Part 5

– Of the IMDG Code.

In some cases, section numbering can go very deep into subsections. For example, Sec-tion 4.2.1.9.1.1 is a detailed rule on the maxi-mum degree of filling for portable tanks.

Like DOT rules, IMDG rules contain many important tables. Tables are cited by the sec-tion or subsection in which they are located.

Symbols in the IMDG Code

The following symbols placed against an item in the IMDG Code indicate changes from the previous edition.

n – New item

∆ – Changed item

⊗ – Deleted item

Sections of the IMDG Code

Part 1 – General Provisions, Definitions, and Training

• Applicability of regulations

• Forbidden dangerous goods

• Definition of dangerous goods

• Training requirements

• Security provisions

• General provisions for radioactives



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Structure of the IMDG Code, continued

Part 2 – Classification

• Definitions of hazard classes

• Rules for shipping samples for testing

• Definition of marine pollutants

Part 3 – Dangerous Goods List, Special Provisions, and Exceptions

• Rules for selecting Proper Shipping Names

• The Dangerous Goods List

• Special provisions

• Rules for limited quantities

• Rules for excepted quantities

Part 4 – Packing and Tank Provisions

• Packing rules for non-bulk and bulk packagings, including IBCs and large packagings

• Packing rules for portable tanks

• Packing rules for bulk containers

Part 5 – Consignment Procedures

• General provisions

• Marking and labeling requirements

• Placarding and marking requirements for CTUs and bulk containers

• Documentation

• Special provisions for fumigants and coolants

Part 6 – Construction and Testing of Packagings

• Requirements for construction and testing of packagings

• Requirements for approvals of pack-agings

Part 7 – Provisions Concerning Transport Operations

• Requirements for stowage

• Requirements for segregation

• Requirements for packing and transport-ing cargo transport units (CTUs)

• Requirements for precautions to take in the event of fires

• Requirements for exemptions, approvals and certificates

Appendices and Index of the IMDG Code

Located in Volume 2, the IMDG Code also includes two appendices and an Index:

• Appendix A – List of generic and N.O.S. Proper Shipping Names

• Appendix B – Glossary of Explosive Terms

• Index – Alphabetical list of names on the 3.2 Dangerous Goods List

Introduction


Notes:

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ADDITIONAL IMO STANDARDS AND PUBLICATIONS

IMDG Code Supplement

The IMDG Code Supplement incorporates a number of separate publications in one docu-ment, including:

• Emergency response (The EmS Guide) and first aid (MFAG) guides for dangerous cargo incidents.

• Incident reporting rules and guidelines under MARPOL.

• Guidelines for packing cargo transport units (CTUs).

• Related IMO resolutions and guidelines.

SOLAS Convention (International Convention for the Safety of Life at Sea)

This is the central international agree-ment on the subject of maritime safety. The SOLAS Convention covers a wide range of measures designed to improve the safety of shipping. The Convention is one of the oldest of its kind—the first version was adopted in 1914 following the sinking of the Titanic with the loss of more than 1,500 lives. Since then, there have been four more versions of SOLAS. The present version was adopted in 1974 and entered into force in 1980.

SOLAS forms the basis and authority for the IMDG Code and many other interna-

tional maritime rules. It is published by the IMO in a consolidated edition, including text of the SOLAS Convention, its Protocols, and all amendments in effect on the date of pub-lication.

MARPOL (The International Convention for the Prevention of Pollution from Ships)

This is the central international agreement on the subject of marine pollution. It is also the source of the IMDG Code and 49 CFR rules for marine pollutants as dangerous goods. MARPOL is published by the IMO together with unified interpretations of the articles and all protocols and Annexes of the Convention.

ISPS (International Ship and Port Facility Security) Code

Developed under the International Con-vention for the Safety of Life at Sea (SOLAS), these rules establish an international frame-work for cooperation between contracting governments, government agencies, local administrations, and the shipping and port industries to detect security threats and take preventive measures against security incidents affecting ships or port facilities used in inter-national trade.

The ISPS Code is divided into two parts. Part A presents mandatory requirements, and



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Additional IMO Standards and Publications, continued

Part B contains recommendatory guidance regarding the provisions of Chapter XI-2 of the Convention and Part A of the Code.

CSS Code (Code of Safe Practice for Cargo Stowage and Securing)

The CSS Code is a narrative discussion of safe stowage and securing of cargo aboard ships. Primarily for vessel operators, it includes mention of special arrangements shippers may need to make with them (e.g., for securing motor vehicles aboard RO-RO vessels).

Provisions Concerning the Reporting of Incidents Involving Harmful Substances Under MARPOL

This is a compilation of rules and guidance based on MARPOL Article 8. This publication includes:

• Article 8 of MARPOL.

• Resolution MEPC.21(22).

• Amendments to Protocol I of MARPOL.

• Resolution A.851(20)—General Principles for Ship Reporting Systems and Ship Re-porting Requirements, including Guide-lines for Reporting Incidents Involving Dangerous Goods, Harmful Substances, and/or Marine Pollutants.

• A list of agencies or officials of admin-istrations responsible for receiving and processing such reports.

BC CODE (Code of Safe Practice for Solid Bulk Cargo)

Developed under the authority of Annex D to the SOLAS Convention, the BC Code first entered into force on July 1, 1986. It provides international standards for the shipment of all solid bulk cargo except grain. Among others, it includes rules for:

• Cargo assessment and acceptance.

• Classification of properties, characteris-tics, and hazards.

• Loading, trimming, and monitoring.

• Safety and emergency response.

• Confined space entry.

NOTE: Solid bulk cargo refers to cargo that is received and loaded directly into the cargo spaces of a ship, without any intermediate containment or packaging. [IMDG 1.2.1]

Introduction


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COMPLIANCE AND ENFORCEMENT

IMO and DOT

The International Maritime Organization (IMO) does not enforce any rules. Enforce-ment is the sole responsibility of each country in which hazmat shipping or transportation takes place. The US DOT is the enforcement agency in the United States. A shipment can be “illegal” if it violates either DOT or IMO rules.

Domestic vs. International Shipping

Domestic shippers and vessel carriers are only required to comply with the IMDG Code when, and to the degree that, the DOT says so.

International shippers may need to satisfy the rules of other countries. Because of this, full compliance with all IMDG Code requirements may be mandatory when shipping interna-tionally by vessel.

DOT Fines and Penalties

DOT penalty determinations are based on the statutory criteria provided at 49 U.S.C. 5123(c) and on the DOT’s informal civil pen-alty guidelines provided at Appendix A to 49 CFR 107, Subpart D.

Civil Penalties

Civil penalties are assessed for “knowing” violations of the regulations.

• Maximum penalty is $81,993 per day, per incident.

• Maximum penalty is $191,316 for viola-tions resulting in:

– Death,

– Serious illness,

– Severe injury, or

– Substantial destruction of property.

• Minimum fine for violations related to training is $493 per day, per incident.

Criminal Penalties

Criminal penalties are assessed for “know-ing and willful” violations of the regulations, or if a person acts recklessly or with “deliber-ate indifference or conscious disregard to the consequences” of his or her actions, even if he or she did not consciously choose to break the law. The Justice Department will prosecute criminal cases.

• Maximum individual penalties are:

– $250,000 per incident.

– Five years in jail.

• Maximum organizational penalty is $500,000 per day, per incident.



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TEN STEPS TO VESSEL TRANSPORTATION OF DANGEROUS GOODS

Step IMDG Code Common Additional 49 CFR Rules

#1. Classification • Is it a dangerous good? [IMDG 2.0.1]

• Classification based on name [IMDG 2.0.2]

• What is/are the hazard(s)? Degree of hazard? [IMDG 2.1–2.9]

• Priority of multiple hazards [IMDG 2.0.3]

• Marine pollutants [IMDG 2.10]

• Samples [IMDG 2.0.4]

• Hazardous substances [49 CFR 171.8 and 172.101, Appendix A]

• Hazardous wastes [49 CFR 171.8]

• Combustible liquids [49 CFR 173.120]

• DOT forbidden materials [49 CFR 173.21, et al.]

• Approvals for explosives, airbags, organic peroxides, self-reactive materials, etc.

#2. Identification • Selecting the most specific Proper Shipping Name available [IMDG 2.0.2 / IMDG Part 3 (Vol. 2) Ap-pendix A, Generic Names (Vol. 2) Alphabetical Index (End of Vol. 2)]

• Hazardous wastes must add the word “Waste” [49 CFR 171.23(b)(6)]

• Aerosols must meet the DOT’s definition [49 CFR 171.8]

#3. Packing • “Packagings” [IMDG 4.1.1, 4.1.3, 4.1.4]

• Limited quantity [IMDG 3.4]

• Excepted quantities [IMDG 3.5]

• IBCs [IMDG 4.1.1, 4.1.2, 4.1.3, 4.1.4]

• Additional rules per hazard class (Class 1, 2, 4.1, 5.2, 6.2, 7) [IMDG 4.1.5–4.1.9]

• Construction and testing of packag-ings [IMDG Part 6]

• Packaging approvals, etc., as com-petent authority

• Most bulk packages (except IBCs)

• Definition of “aerosols” [49 CFR 171.23 (b)(1)]

• DOT general packaging and re-use/reconditioning rules [49 CFR 173.24, 173.24a, and 173.28]

#4. Marking and Labeling

• Marking packages, including IBCs [IMDG 5.2.1]

• Labeling packages, including IBCs [IMDG 5.2.2]

• Marking Cargo Transport Units [IMDG 5.3.2]

• Poison inhalation hazards [49 CFR 172.313]

• Primary lithium batteries [49 CFR 171.25(b)(3)]

• Hazardous substances must add RQ communications [49 CFR 172.324]

Introduction

Ten Steps to Vessel Transportation of Dangerous Goods, continued


Page 11

Step IMDG Code Common Additional 49 CFR Rules

#5. Documentation • Dangerous goods documentation [IMDG 5.4.1]

• Container/vehicle packing certifi-cate [IMDG 5.4.2]

• Emergency response information [IMDG 5.4.3.4]

• Other documentation [IMDG 5.4.4]

• The IMDG Multimodal Dangerous Goods Form [IMDG 5.4.5]

• Emergency response documents and emergency telephone number [49 CFR, Subpart G]

• Hazardous wastes must be ac-companied by a manifest [49 CFR 171.23(b)(6)(iii) and 172.205]

• Materials meeting the definition of poison must be identified as such [49 CFR 172.203(m)]

• Hazardous substances must add RQ communications [49 CFR 172.203(c)]

#6. Placarding and Marking CTUs

• Cargo Transport Units [IMDG 5.3.1]

• See also: Marking of CTUs [IMDG 5.3.2]

• Placarding motor vehicles [49 CFR 172, Subpart F]

#7. Transport Operations

• Stowage [IMDG 7.1]

• Segregation [IMDG 7.2]

• Packing CTUs [IMDG 7.3 and IMDG Supplement]

• Fire precautions [IMDG 7.8]

• Some hazardous materials carriers’ rules [49 CFR 177]

• Modal authorities (e.g., Federal Motor Carrier Safety Administra-tion, US Coast Guard)

• Certain portable tanks may not be unloaded while still on the trans-port vehicle [49 CFR 171.25(c)(4)]

#8. Incidents and Security

• Incident response and reporting [IMDG Supplement]

• Security [IMDG 1.4 and ISPS Code]

• Incident reporting [49 CFR 171.15–171.16; 40 CFR 302 (RQs)]

• Highway incident response—e.g., 49 CFR 177, Subpart D

• Security [49 CFR 172, Subpart I]

#9. Administrative Responsibilities

• Exemptions [IMDG 7.9.1]

• Approvals and certificates [IMDG 7.9.2]

• Competent authority contacts [IMDG 7.9.3]

• Registering your company

• Applications for and party to ex-emptions [49 CFR 106–107]

#10. Keeping Up With Changes

• Membership Services

• IMDG revisions (biennial amend-ments)

• Training—content and records [IMDG 1.3]

• Following the Federal Register

• Training—content, frequency, and records [49 CFR 172, Subpart H]



Page 12

49 CFR §171.1

49 CFR PART 171General Information, Regulations and

Definitions

Table of Contents

Subpart A—Applicability, General Require-ments, and North American Shipments

§171.1 Applicability of Hazardous Materials Reg-ulations (HMR) to persons and functions.

§171.2 General requirements.

§171.3 Hazardous waste.

§171.4 Marine pollutants.

§171.6 Control numbers under the Paperwork Reduction Act.

§171.7 Reference materials.

§171.8 Definitions and abbreviations.

§171.9 Rules of construction.

§171.10 Units of measure.

§171.11 [Reserved]

§171.12 North American Shipments.

§171.12a [Reserved]

§171.14 [Reserved]

Subpart B—Incident Reporting, Notification, BOE Approvals and Authorization

§171.15 Immediate notice of certain hazardous materials incidents.

§171.16 Detailed hazardous materials incident reports.

§171.17 [Reserved]

§171.18 [Reserved]

§171.19 Approvals or authorizations issued by the Bureau of Explosives.

§171.20 Submission of Examination Reports.

§171.21 Assistance in investigations and special studies.

Subpart C—Authorization and Requirements for the Use of International Transport Standards and Regulations

§171.22 Authorization and conditions for the use of international standards and regulations.

§171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regula-tions.

§171.24 Additional requirements for the use of the ICAO Technical Instructions.

§171.25 Additional requirements for the use of the IMDG Code.

§171.26 Additional requirements for the use of the IAEA Regulations.

Authority: 49 U.S.C. 5101–5128, 44701; Pub. L. 101–410 section 4; Pub. L. 104–134, section 31001; Pub. L. 114–74 section 4 (28 U.S.C. 2461 note); 49 CFR 1.81 and 1.97.

Source: 49 CFR Oct. 1, 1990, unless otherwise noted.

[Source Note: At 47 FR 54821, Dec. 6, 1982, added new §171.11, and at 50 FR 41520, Oct. 11, 1985, added §171.12a. At 50 FR 41519, at 50 FR 45730, at 50 FR 48420, at 51 FR 5969, February 18, 1986, at 51 FR 23078, June 25, 1986, at 51 FR 42176, Nov. 21, 1986, and at 51 FR 44791, Dec. 12, 1986, and at 52 FR 24474, July 1, 1987, and at 52 FR 29527, Aug. 10, 1987, and at 52 FR 36672, Sept. 30, 1987, revised authority citation; and at 54 FR 25813, June 19, 1989, added §171.21; and at 55 FR 875, January 10, 1990, revised authority citation; and at 52 FR 52466, December 21, 1990, revised titles of 171.10, 171.11, 171.12, and 171.14; and at 56 FR 8624, February 28, 1991, revised authority citation, and at 56 FR 66157, December 20, 1991, removed and reserved §171.4 and §171.5, and revised titles of 171.6 and 171.10. At 57 FR 52934, Nov. 5, 1992, added 171.4; and at 57 FR 59309, December 15, 1992, revised authority citation; and at 58 FR 6870, February 2, 1993, revised authority citation and added §171.5; and at 58 FR 33305, June 16, 1993, removed and reserved §171.5 and revised authority citation; and at 59 FR 28490, June 2, 1994, revised authority cita-tion; and at 59 FR 48763, September 22, 1994, revised authority citation. At 61 FR 18931, April 29, 1996, removed 171.13. At 62 FR 2977, January 21, 1997, revised authority citation; and at 62 FR 7647, February 19, 1997, added new 171.5 and revised authority citation. At 62 FR 39404, July 22, 1997, revised 171.14 heading. At 62 FR 44048, August 18, 1997, revised authority citation. At 63 FR 37459, July 10, 1998, removed and reserved §171.18. At 64 FR 28046, May 24, 1999, removed §171.5. At 68 FR 61937, October 30, 2003, effective October 1, 2004, revised §171.1 heading. At 69 FR 30588, May 28, 2004, delayed effective date from October 1, 2004 to January 1, 2005. At 69 FR 70902, December 8, 2004, further delayed effective date from January 1, 2005 (refer to May 28, 2004, 69 FR 30588) to June 1, 2005. At 70 FR 20031, April 15, 2005, effective June 1, 2005, corrected authority citation. At 72 FR 25170, May 3, 2007, effective October 1, 2007, revised entire Part 171 to designate §171.1–§171.14 as Subpart A; designated §§171.15–171.21 as Subpart B; and added new Subpart C (§§171.22–171.26); removed and reserved §§171.11 and 171.12a; and revised heading to §171.12. At 72 FR 55684, October 1, 2007, revised heading to §171.22. At 76 FR 43525, July 20, 2011, effective August 19, 2011, removed and reserved §171.14. At 78 FR 22800, April 17, 2013, revised authority cita-tion. At 80 FR 54440, September 10, 2015, effective November 9, 2015, revised authority citation. At 81 FR 42268, June 29, 2016, effective August 1, 2016, revised authority citation.]

Introduction

© Lion Technology Inc..

Page 13

49 CFR §171.22

Subpart C—Authorization and Requirements for the Use of

International Transport Standards and Regulations

§171.22 Authorization and conditions for the use of international standards and reg-ulations.

(a) Authorized international standards and regu-lations. This subpart authorizes, with certain condi-tions and limitations, the offering for transportation and the transportation in commerce of hazardous materials in accordance with the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), the International Maritime Dangerous Goods Code (IMDG Code), Transport Canada’s Transportation of Dangerous Goods Regulations (Transport Canada TDG Reg-ulations), and the International Atomic Energy Agency Regulations for the Safe Transport of Radioactive Material (IAEA Regulations) (IBR, see §171.7).

(b) Limitations on the use of international stan-dards and regulations. A hazardous material that is offered for transportation or transported in accor-dance with the international standards and regula-tions authorized in paragraph (a) of this section—

(1) Is subject to the requirements of the applicable international standard or regulation and must be offered for transportation or transported in conformance with the applicable standard or regu-lation; and

(2) Must conform to all applicable require-ments of this subpart.

(c) Materials excepted from regulation under international standards and regulations. A material designated as a hazardous material under this subchapter, but excepted from or not subject to the international transport standards and regula-tions authorized in paragraph (a) of this section (e.g., paragraph 1.16 of the Transport Canada TDG Regulations excepts from regulation quantities of hazardous materials less than or equal to 500 kg gross transported by rail) must be transported in accordance with all applicable requirements of this subchapter.

(d) Materials not regulated under this subchapter. Materials not designated as hazardous materials under this subchapter but regulated by an interna-tional transport standard or regulation authorized in paragraph (a) of this section may be offered for transportation and transported in the United States in full compliance (i.e., packaged, marked, labeled, classed, described, stowed, segregated, secured) with the applicable international transport stan-dard or regulation.

(e) Forbidden materials. No person may offer for transportation or transport a hazardous mate-rial that is a forbidden material or package as des-ignated in—

(1) Section 173.21 of this subchapter;

(2) Column (3) of the §172.101 Table of this subchapter;

(3) Column (9A) of the §172.101 Table of this subchapter when offered for transportation or transported on passenger aircraft or passenger railcar; or

(4) Column (9B) of the §172.101 Table of this subchapter when offered for transportation or transported by cargo aircraft.

(f) Complete information and certification.

(1) Except for shipments into the United States from Canada conforming to §171.12, each person importing a hazardous material into the United States must provide the shipper, and the for-warding agent at the place of entry into the United States, timely and complete written information as to the requirements of this subchapter applicable to the particular shipment.

(2) The shipper, directly or through the forwarding agent at the place of entry, must pro-vide the initial U.S. carrier with the shipper’s cer-tification required by §172.204 of this subchapter, unless the shipment is otherwise excepted from the certification requirement. Except for shipments for which the certification requirement does not apply, a carrier may not accept a hazardous material for transportation unless provided a shipper’s certi-fication.

(3) All shipping paper information and package markings required in accordance with this subchapter must be in English. The use of shipping



Page 14

49 CFR §171.23

papers and a package marked with both English and a language other than English, in order to dually comply with this subchapter and the regu-lations of a foreign entity, is permitted under this subchapter.

(4) Each person who provides for transpor-tation or receives for transportation (see §§174.24, 175.30, 176.24 and 177.817 of this subchapter) a shipping paper must retain a copy of the shipping paper or an electronic image thereof that is accessi-ble at or through its principal place of business in accordance with §172.201(e) of this subchapter.

(g) Additional requirements for the use of inter-national standards and regulations. All shipments offered for transportation or transported in the United States in accordance with this subpart must conform to the following requirements of this sub-chapter, as applicable:

(1) The emergency response informa-tion requirements in subpart G of part 172 of this subchapter;

(2) The training requirements in subpart H of part 172 of this subchapter, including func-tion-specific training in the use of the international transport standards and regulations authorized in paragraph (a) of this section, as applicable;

(3) The security requirements in subpart I of part 172 of this subchapter;

(4) The incident reporting requirements in §§171.15 and 171.16 of this part for incidents occur-ring within the jurisdiction of the United States including on board vessels in the navigable waters of the United States and aboard aircraft of United States registry anywhere in air commerce;

(5) For export shipments, the general packaging requirements in §§173.24 and 173.24a of this subchapter;

(6) For export shipments, the requirements for the reuse, reconditioning, and remanufacture of packagings in §173.28 of this subchapter; and

(7) The registration requirements in sub-part G of part 107 of this chapter.

[Source Note: At 72 FR 55091, September 28, 2007, corrected May 3, 2007, 72 FR 25173 entry for (g)(5) and (g)(6). At 72 FR 55684, October 1, 2007, revised section heading. At 74 FR 53186, October 16, 2009, revised (a). At 76 FR 56311, September 13,

2011, revised (f)(2). At 80 FR 72920, November 23, 2015, effective December 23, 2015, revised (f)(4). At 81 FR 35513, June 2, 2016, effective July 5, 2016, revised (f)(1).]

§171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Trans-port Canada TDG Regulations, or the IAEA Regulations.

All shipments offered for transportation or transported in the United States under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations (IBR, see §171.7) must conform to the requirements of this section, as applicable.

(a) Conditions and requirements for cylinders—

(1) Except as provided in this paragraph (a), a filled cylinder (pressure receptacle) manu-factured to other than a DOT specification or a UN standard in accordance with part 178 of this sub-chapter, a DOT exemption or special permit cylin-der, a TC, CTC, CRC, or BTC cylinder authorized under §171.12, or a cylinder used as a fire extin-guisher in conformance with §173.309(a) of this subchapter, may not be transported to, from, or within the United States.

(2) Cylinders (including UN pressure receptacles) transported to, from, or within the United States must conform to the applicable requirements of this subchapter. Unless otherwise excepted in this subchapter, a cylinder must not be transported unless—

(i) The cylinder is manufactured, inspected and tested in accordance with a DOT specification or a UN standard prescribed in part 178 of this sub-chapter, or a TC, CTC, CRC, or BTC specification set out in the Transport Canada TDG Regulations (IBR, see §171.7), except that cylinders not conforming to these requirements must meet the requirements in paragraph (a)(3), (4), or (5) of this section;

(ii) The cylinder is equipped with a pres-sure relief device in accordance with §173.301(f) of this subchapter and conforms to the applicable requirements in part 173 of this subchapter for the hazardous material involved;

Introduction


Page 15

49 CFR §171.23

(iii) The openings on an aluminum cylin-der in oxygen service conform to the requirements of this paragraph, except when the cylinder is used for aircraft parts or used aboard an aircraft in accor-dance with the applicable airworthiness require-ments and operating regulations. An aluminum DOT specification cylinder must have an opening configured with straight (parallel) threads. A UN pressure receptacle may have straight (parallel) or tapered threads provided the UN pressure recepta-cle is marked with the thread type, e.g. “17E, 25E, 18P, or 25P” and fitted with the properly marked valve; and

(iv) A UN pressure receptacle is marked with “USA” as a country of approval in confor-mance with §§178.69 and 178.70 of this subchapter, or “CAN” for Canada.

(3) Importation of cylinders for discharge within a single port area. A cylinder manufactured to other than a DOT specification or UN standard in accordance with part 178 of this subchapter, or a TC, CTC, BTC, or CRC specification cylinder set out in the Transport Canada TDG Regulations (IBR, see §171.7), and certified as being in conformance with the transportation regulations of another country may be authorized, upon written request to and approval by the Associate Administrator, for trans-portation within a single port area, provided—

(i) The cylinder is transported in a closed freight container;

(ii) The cylinder is certified by the importer to provide a level of safety at least equivalent to that required by the regulations in this subchapter for a comparable DOT, TC, CTC, BTC, or CRC spec-ification or UN cylinder; and

(iii) The cylinder is not refilled for export unless in compliance with paragraph (a)(4) of this section.

(4) Filling of cylinders for export or for use on board a vessel. A cylinder not manufactured, inspected, tested and marked in accordance with part 178 of this subchapter, or a cylinder manufac-tured to other than a UN standard, DOT specifica-tion, exemption or special permit, or other than a TC, CTC, BTC, or CRC specification, may be filled with a gas in the United States and offered for

transportation and transported for export or alter-natively, for use on board a vessel, if the following conditions are met:

(i) The cylinder has been requalified and marked with the month and year of requalification in accordance with subpart C of part 180 of this subchapter, or has been requalified as authorized by the Associate Administrator;

(ii) In addition to other requirements of this subchapter, the maximum filling density, ser-vice pressure, and pressure relief device for each cylinder conform to the requirements of this part for the gas involved; and

(iii) The bill of lading or other shipping paper identifies the cylinder and includes the fol-lowing certification: “This cylinder has (These cylinders have) been qualified, as required, and filled in accordance with the DOT requirements for export.”

(5) Cylinders not equipped with pressure relief devices. A DOT specification or a UN cylin-der manufactured, inspected, tested and marked in accordance with part 178 of this subchapter and otherwise conforms to the requirements of part 173 of this subchapter for the gas involved, except that the cylinder is not equipped with a pressure relief device may be filled with a gas and offered for transportation and transported for export if the following conditions are met:

(i) Each DOT specification cylinder or UN pressure receptacle must be plainly and durably marked “For Export Only”;

(ii) The shipping paper must carry the following certification: “This cylinder has (These cylinders have) been retested and refilled in accor-dance with the DOT requirements for export.”; and

(iii) The emergency response information provided with the shipment and available from the emergency response telephone contact person must indicate that the pressure receptacles are not fitted with pressure relief devices and provide appropri-ate guidance for exposure to fire.

(b) Conditions and requirements specific to certain materials—



Page 16

49 CFR §171.23

(1) Aerosols. Except for a limited quantity of a compressed gas in a container of not more than 4 fluid ounces capacity meeting the requirements in §173.306(a)(1) of this subchapter, the proper ship-ping name “Aerosol,” UN1950, may be used only for a nonrefillable receptacle containing a gas com-pressed, liquefied, or dissolved under pressure the sole purpose of which is to expel a nonpoisonous (other than Division 6.1, Packing Group III mate-rial) liquid, paste, or powder and fitted with a self-closing release device (see §171.8). In addition, an aerosol must be in a metal packaging when the packaging exceeds 7.22 cubic inches.

(2) Safety devices for vehicles, vessels or air-craft, e.g. air bag inflators, air bag modules, seat-belt pretensioners, and pyromechanical devices. For each safety device, the shipping paper description must conform to the requirements in §173.166(c) of this subchapter.

(i) The EX number or product code must be included in association with the basic shipping description. When a product code is used, it must be traceable to the specific EX number assigned to the inflator, module or seatbelt pretensioner by the Associate Administrator. The EX number or prod-uct code is not required to be marked on the out-side package.

(ii) The proper shipping name “Articles, pyrotechnic for technical purposes, UN0431” must be used for all air bag inflators, air bag modules, and seat-belt pretensioners meeting the criteria for a Division 1.4G material.

(3) Chemical oxygen generators. Chemical oxygen generators must be approved, classed, described, packaged, and transported in accor-dance with the requirements of this subchapter.

(4) Class 1 (explosive) materials. Prior to being transported, Class 1 (explosive) materials must be approved by the Associate Administrator in accordance with §173.56 of this subchapter. Each package containing a Class 1 (explosive) material must conform to the marking requirements in §172.320 of this subchapter.

(5) Hazardous substances. A material meet-ing the definition of a hazardous substance as defined in §171.8, must conform to the shipping

paper requirements in §172.203(c) of this subchap-ter and the marking requirements in §172.324 of this subchapter:

(i) The proper shipping name must iden-tify the hazardous substance by name, or the name of the substance must be entered in parentheses in association with the basic description and marked on the package in association with the proper ship-ping name. If the hazardous substance meets the definition for a hazardous waste, the waste code (for example, D001), may be used to identify the hazardous substance;

(ii) The shipping paper and the package markings must identify at least two hazardous sub-stances with the lowest reportable quantities (RQs) when the material contains two or more hazardous substances; and

(iii) The letters “RQ” must be entered on the shipping paper either before or after the basic description, and marked on the package in associ-ation with the proper shipping name for each haz-ardous substance listed.

(6) Hazardous wastes. A material meeting the definition of a hazardous waste (see §171.8) must conform to the following:

(i) The shipping paper and the package markings must include the word “Waste” immedi-ately preceding the proper shipping name;

(ii) The shipping paper must be retained by the shipper and by each carrier for three years after the material is accepted by the initial carrier (see §172.205(e)(5)); and

(iii) A hazardous waste manifest must be completed in accordance with §172.205 of this subchapter.

(7) Marine pollutants. Except for marine pollutants (see §171.8) transported in accordance with the IMDG Code, marine pollutants trans-ported in bulk packages must meet the shipping paper requirements in §172.203(l) of this subchapter and the package marking requirements in §172.322 of this subchapter.

Introduction


Page 17

49 CFR §171.23

(8) Organic peroxides. Organic peroxides not identified by technical name in the Organic Peroxide Table in §173.225(c) of this subchapter must be approved by the Associate Administrator in accordance with §173.128(d) of this subchapter.

(9) [Removed and reserved].

(10) Poisonous by inhalation materials. A material poisonous by inhalation (see §171.8) must conform to the following requirements:

(i) The words “Poison-Inhalation Hazard” or “Toxic-Inhalation Hazard” and the words “Zone A,” “Zone B,” “Zone C,” or “Zone D” for gases, or “Zone A” or “Zone B” for liquids, as appropriate, must be entered on the shipping paper immedi-ately following the basic shipping description. The word “Poison” or “Toxic” or the phrase “Poison-In-halation Hazard” or “Toxic-Inhalation Hazard” need not be repeated if it otherwise appears in the shipping description;

(ii) The material must be packaged in accor-dance with the requirements of this subchapter;

(iii) The package must be marked in accor-dance with §172.313 of this subchapter; and

(iv) Except as provided in subparagraph (B) of this paragraph (b)(10)(iv) and for a package containing anhydrous ammonia prepared in accor-dance with the Transport Canada TDG Regulations, the package must be labeled or placarded with POISON INHALATION HAZARD or POISON GAS, as appropriate, in accordance with Subparts E and F of part 172 of this subchapter.

(A) For a package transported in accor-dance with the IMDG Code in a closed transport vehicle or freight container, a label or placard con-forming to the IMDG Code specifications for a “Class 2.3” or “Class 6.1” label or placard may be substituted for the POISON GAS or POISON INHA-LATION HAZARD label or placard, as appropri-ate. The transport vehicle or freight container must be marked with the identification numbers for the hazardous material, regardless of the total quantity contained in the transport vehicle or freight con-tainer, in the manner specified in §172.313(c) of this subchapter and placarded as required by subpart F of part 172 of this subchapter.

(B) For a package transported in accor-dance with the Transport Canada TDG Regulations in a closed transport vehicle or freight container, a label or placard conforming to the TDG Regula-tions specifications for a “Class 2.3” or “Class 6.1” label or placard may be substituted for the POISON GAS or POISON INHALATION HAZARD label or placard, as appropriate. The transport vehicle or freight container must be marked with the identifi-cation numbers for the hazardous material, regard-less of the total quantity contained in the transport vehicle or freight container, in the manner specified in §172.313(c) of this subchapter and placarded as required by subpart F of part 172 of this subchap-ter. While in transportation in the United States, the transport vehicle or freight container may also be placarded in accordance with the appropriate Transport Canada TDG Regulations in addition to being placarded with the POISON GAS or POISON INHALATION HAZARD placards.

(11) Class 7 (radioactive) materials.

(i) Highway route controlled quantities (see §173.403 of this subchapter) must be shipped in accordance with §§172.203(d)(4) and (d)(10); 172.507, and 173.22(c) of this subchapter;

(ii) For fissile materials and Type B, Type B(U), and Type B(M) packagings, the competent authority certification and any necessary revalida-tion must be obtained from the appropriate compe-tent authorities as specified in §§173.471, 173.472, and 173.473 of this subchapter, and all requirements of the certificates and revalidations must be met;

(iii) Type A package contents are limited in accordance with §173.431 of this subchapter;

(iv) The country of origin for the shipment must have adopted the edition of SSR–6 of the IAEA Regulations referenced in §171.7.

(v) The shipment must conform to the requirements of §173.448, when applicable;

(vi) The definition for “radioactive mate-rial” in §173.403 of this subchapter must be applied to radioactive materials transported under the pro-visions of this subpart;



Page 18

49 CFR §171.25

(vii) Except for limited quantities, the shipment must conform to the requirements of §172.204(c)(4) of this subchapter; and

(viii) Excepted packages of radioactive material, instruments or articles, or articles contain-ing natural uranium or thorium must conform to the requirements of §§173.421, 173.424, or 173.426 of this subchapter, as appropriate.

(ix) Packages containing fissile materials must conform to the requirements of §173.453 to be otherwise excepted from the requirements of Sub-part I of Part 173 for fissile materials.

(12) Self-reactive materials. Self-reactive materials not identified by technical name in the Self-reactive Materials Table in §173.224(b) of this subchapter must be approved by the Associate Administrator in accordance with §173.124 (a)(2)(iii) of this subchapter.

[Source Note: At 72 FR 55684, October 1, 2007, revised (b)(5) introductory text. At 73 FR 57004, October 1, 2008, revised (a)(3)(iii). At 76 FR 3345, January 19, 2011, removed and reserved (b)(9). At 76 FR 56311, September 13, 2011, revised (a)(4)(ii). At 78 FR 60751, October 2, 2013, effective October 1, 2013, restored (a)(4)(iii). At 78 FR 65468, October 31, 2013, revised (b)(8). At 80 FR 1116, January 8, 2015, effective January 1, 2015, revised (b)(2) and (b)(11)(iv), and added (b)(11)(ix). At 80 FR 72920, November 23, 2015, effective December 23, 2015, revised (a)(4)(ii) and (a)(5) introductory text. At 81 FR 35513, June 2, 2016, effective July 5, 2016, revised (b)(10)(iv)(A)–(b)(10)(iv)(B). At 82 FR 15837, March 30, 2017, revised (a).]

* * * * *

§171.25 Additional requirements for the use of the IMDG Code.

(a) A hazardous material may be offered for transportation or transported to, from or within the United States by vessel, and by motor carrier and rail in accordance with the IMDG Code (IBR, see §171.7), as authorized in §171.22, provided all or part of the movement is by vessel. Such shipments must conform to the requirements in §171.22, as applicable, and this section.

(b) Any person who offers for transportation or transports a hazardous material in accordance with the IMDG Code must conform to the follow-ing additional conditions and requirements:

(1) Unless specified otherwise in this sub-chapter, a shipment must conform to the require-ments in part 176 of this subchapter. For transpor-tation by rail or highway prior to or subsequent to transportation by vessel, a shipment must conform to the applicable requirements of parts 174 and 177 respectively, of this subchapter, and the motor vehicle or rail car must be placarded in accordance with subpart F of part 172 of this subchapter. When a hazardous material regulated by this subchapter for transportation by highway is transported by motor vehicle on a public highway or by rail under the provisions of subpart C of part 171, the segre-gation requirements of Part 7, Chapter 7.2 of the IMDG Code are authorized.

(2) For transportation by vessel, the stow-age and segregation requirements in Part 7 of the IMDG Code may be substituted for the stowage and segregation requirements in part 176 of this subchapter.

(3) The outside of each package con-taining lithium metal cells or batteries (UN3090) transported in accordance with special provision 188 of the IMDG Code must be marked “PRI-MARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” or “LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIR-CRAFT”, or labeled with a CARGO AIRCRAFT ONLY label specified in §172.448 of this subchapter. The provisions of this paragraph do not apply to packages that contain 5 kg (11 pounds) net weight or less of lithium metal cells or batteries that are packed with, or contained in, equipment.

(4) Material consigned under UN3166 and UN3171 (e.g., Engines, internal combustion, etc., Vehicles, etc. and Battery-powered equipment) may be prepared in accordance with the IMDG Code or this subchapter.

(c) Conditions and requirements for bulk packag-ings. Except for IBCs and UN portable tanks used for the transportation of liquids or solids, bulk packagings must conform to the requirements of this subchapter. Additionally, the following requirements apply:

(1) UN portable tanks must conform to the requirements in Special Provisions TP37, TP38,

Introduction


Page 19

49 CFR §171.25

TP44 and TP45 when applicable, and any applica-ble bulk special provisions assigned to the hazard-ous material in the Hazardous Materials Table in §172.101 of this subchapter;

(2) IMO Type 5 portable tanks must con-form to DOT Specification 51 or UN portable tank requirements, unless specifically authorized in this subchapter or approved by the Associate Admin-istrator;

(3) Except as specified in this subpart, for a material poisonous (toxic) by inhalation, the T Codes specified in Column 13 of the Dangerous Goods List in the IMDG Code may be applied to the transportation of those materials in IM, IMO and DOT Specification 51 portable tanks, when these portable tanks are authorized in accordance with the requirements of this subchapter; and

(4) No person may offer an IM or UN por-table tank containing liquid hazardous materials of Class 3, PG I or II, or PG III with a flash point less than 100°F (38°C); Division 5.1, PG I or II; or Divi-sion 6.1, PG I or II, for unloading while it remains on a transport vehicle with the motive power unit attached, unless it conforms to the requirements in §177.834(o) of this subchapter.

(d) Use of IMDG Code in port areas.

(1) Except for Division 1.1, 1.2, and Class 7 materials, a hazardous material being imported into or exported from the United States or passing through the United States in the course of being shipped between locations outside the United States may be offered and accepted for transportation and transported by motor vehicle within a single port area, including contiguous harbors, when pack-aged, marked, classed, labeled, stowed and segre-gated in accordance with the IMDG Code, offered and accepted in accordance with the requirements of subparts C and F of part 172 of this subchapter pertaining to shipping papers and placarding, and otherwise conforms to the applicable requirements of part 176 of this subchapter.

(2) The requirement in §172.201(d) of this subchapter for an emergency telephone number does not apply to shipments made in accordance with the IMDG Code if the hazardous material is not offloaded from the vessel, or is offloaded between ocean vessels at a U.S. port facility with-out being transported by public highway.

[Source Note: [At 72 FR 44847, August 9, 2007, effective January 1, 2008, added (b)(3). At 73 FR 57004, October 1, 2008, revised (b)(1) and (b)(2). At 74 FR 2233, January 14, 2009, effective February 13, 2009, added (c)(5) and (d)(3). At 76 FR 3345, January 19, 2011, revised (b)(1), added (b)(4), and removed (c)(5) and (d)(3). At 79 FR 46034, August 6, 2014, revised (b)(3). At 80 FR 1116, January 8, 2015, effective January 1, 2015, revised (b)(3).]

* * * * *



CONTENTS

Step 1—Classification ..........................................................................................................21

Hazard Class Definitions/Tests .........................................................................................23

The IMDG Code’s Hazard Classes and Divisions ............................................................25

Determining Subclassifications ..........................................................................................33

The Dangerous Goods Classification Process ..................................................................34

Classifying Dangerous Goods Not Named on the Dangerous Goods List .................36

Practical Issues in Dangerous Goods Classification .......................................................37

Multiple-hazard Materials ..................................................................................................38

Classifying Marine Pollutants ............................................................................................41

“Overclassifying” a Material as a Dangerous Good .......................................................42

Classifying Samples for Transport .....................................................................................43

Forbidden Dangerous Goods .............................................................................................44

The Dangerous Goods Classification Process: Example: Propellant and Rocket Fuel ..........................................................................46



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STEP 1—CLASSIFICATIONIs It a Dangerous Good?

Key Regulatory References

Regulation What’s There?

IMDG Part 2 Classifying dangerous goods

IMDG 2.0.1 Classes, divisions, packing groups

IMDG 2.0.3Classification of substances, mixtures, and solutions with multiple hazards

IMDG 1.1.3, 3.3.1, and 7.1.3 Forbidden dangerous goods

49 CFR 171.22–23 and 171.25

Use of the IMDG Code

49 CFR 173, Subparts C, D,

and I

Classifying hazardous materials

49 CFR 173.21, 173.24, and

173.54

Forbidden hazardous materials

What’s It All About?

The first step in the dangerous goods ship-ping process is to classify the material being shipped to determine whether or not it is a dangerous good.

It is the responsibility of the shipper, or consignor, of a material to assure that the material is properly classified. All decisions

and requirements regarding naming, pack-aging, marking, labeling, etc., are based to a large extent on the actual hazards of the mate-rial. Because of this, any mistakes made at this stage will likely carry through and impact most, if not all, of the later steps in the ship-ping process.

When classifying a dangerous good, the shipper must determine:

• The type of hazard posed by a material (e.g., is it flammable, toxic, dangerous when wet, etc.).

– The type of hazard is indicated by its hazard class or division.

• The degree or severity of the hazard posed by a material.

– The degree of hazard is indicated by the “packing group” for most materials, compatibility group for explosives, and generic types for flammable solids and organic peroxides.

In addition, shippers must also deter-mine if their materials are marine pollutants or wastes.

What You Already Need to Know

To classify dangerous goods under the IMDG Code, you need to know the physi-cal and chemical properties of your material. Examples of the type of information you may need to know include:



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Step 1—Classification, continued

• Physical state; (i.e., is it a liquid, solid, or gas).

• Flash point.

• Initial boiling point.

• Acute toxicological effects (i.e., how much does it take to kill people if exposed).

• Effect on skin tissue or metals.

• Chemical/constituent make-up.

• Reactivity data (i.e., does it react if ex-posed to air or water).

• Radioactivity, if any.

Where Does This Information Come From?

A Safety Data Sheet (SDS) may provide some of this information; however, it is import-ant that you do not rely solely on an SDS to make IMDG hazard classifications!

Other sources of information include:

• Chemical texts/reference books,

• Analytical data, and

• Manufacturer’s technical data.



Page 23

HAZARD CLASS DEFINITIONS/TESTS

Following are summaries of the US DOT and IMDG hazard classes and divisions, listed in class order. For the full hazard class definition, refer to the US DOT regulations at 49 CFR Part 173 and IMDG Chapters 2.1 through 2.10.

Class and Division

Name and description of class or division Reference for Definitions

None Forbidden materialsElectrical devices likely to create sparks or heat, heavily magnetic materials for air shipment, incompatible materials in the same package, materials that may undergo self-accelerated decomposition, ketone peroxides, etc.

49 CFR 173.21

None Forbidden dangerous goodsUnless otherwise provided in the Code, any substance or article that, as presented for transport, is liable to explode, dangerously react, or produce a flame or dangerous evo-lution of heat or dangerous emission of toxic, corrosive, or flammable gases or vapours under normal conditions of transport.

IMDG 1.1.3

None Forbidden explosivesIndividual listed chemicals, listed chemical groups, leaking explosives packages, loaded firearms, etc.

IMDG 2.1 49 CFR 173.54

1.1 Substances and articles that have a mass explosion hazardEntire mass explodes simultaneously (e.g., plastic explosives).

IMDG 2.1.1.4

1.2 Substances and articles that have a projection hazard but no mass explosion hazardThe explosion causes the throwing of a projectile or projectiles (e.g., shrapnel).

IMDG 2.1.1.4

1.3 Substances and articles that have predominately a fire hazardThe explosion initiates combustion.

IMDG 2.1.1.4

1.4 Substances and articles that present no significant hazardThe explosion is not likely to throw any fragments of appreciable size and the explosion is largely confined to the package.

IMDG 2.1.1.4

1.5 Very insensitive substances that have a mass explosion hazard (blasting agents)These will explode, but normally require a strong initiator to cause the explosion (more likely to explode when in large quantities typically transported in a ship).

IMDG 2.1.1.4

1.6 Extremely insensitive articles that do not have a mass explosion hazardThere is no mass explosive potential; hazard limited to the explosion of a single article.

IMDG 2.1.1.4

2.1 Flammable gasesGases that burn readily in air.

IMDG 2.2.2.1

2.2 Non-flammable, non-toxic gasesA gas which is either an asphyxiant, an oxidizer, or simply a gas that is neither flamma-ble nor toxic.

IMDG 2.2.2.2

2.3 Toxic gasesGases known to be so toxic or corrosive that they pose a hazard to human health or that are presumed to be toxic or corrosive because they have an LC50 ≤ 5,000 mL/m3 (ppm) (i.e., 0.005% concentration in air will kill half of the animals in a laboratory test). NOTE: Gases meeting this classification due to corrosivity are classified as toxic with a subsidi-ary hazard of corrosivity.

IMDG 2.2.2.3


Hazard Class Definitions/Tests, continued


Page 24

Class and Division

Name and description of class or division Reference for Definitions

3 Flammable liquidLiquids with a flash point ≤ 60°C (≤ 140°F) closed cup (c.c.) and liquid desensitized explosives (explosive substances dissolved or suspended in water or other liquid sub-stances to suppress their explosive properties).IMDG does not regulate “combustible liquids.”

IMDG 2.3.1

4.1 Flammable solids, self-reactive substances, solid desensitized explosives, and polymer-izing substancesSolids that are readily combustible or may cause or contribute to fire through friction; self-reactive substances (solids and liquids) and polymerizing substances that are liable to undergo a strongly exothermic reaction; and solid desensitized explosives that may explode if not diluted sufficiently.

IMDG 2.4.2

4.2 Substances liable to spontaneous combustionSubstances that even in small quantities are able to spontaneously ignite within five minutes on exposure to air or materials that when present in large amounts (kg) after long periods of time (hours or days) can self-heat to the point of self-ignition and com-bustion. Consists of pyrophoric and self-heating substances.

IMDG 2.4.3 and 2.4.5

4.3 Substances that, when in contact with water, emit flammable gasesSubstances that are able to spontaneously ignite or emit flammable gases in dangerous quantities when they contact water.

IMDG 2.4.4 and 2.4.5

5.1 Oxidizing substancesSubstances that are not necessarily combustible, but that cause or contribute to the combustion of other materials, usually by yielding oxygen (e.g., sodium nitrite, oxygen gas, hydrogen peroxide).

IMDG 2.5.1 and 2.5.2

5.2 Organic peroxidesOrganic substances that contain at least two oxygen atoms in the - O - O - structure. Thermally unstable substances that may undergo exothermic, self-accelerating decom-position.

IMDG 2.5.1 and 2.5.3

6.1 Toxic substancesSolids or liquids that are toxic by ingestion, inhalation, or skin contact.

IMDG 2.6.1 and 2.6.2

6.2 Infectious substancesDisease-causing organisms, tissue or body fluid samples for medical diagnosis, biolog-ical products, and medical wastes. Also includes genetically modified organisms and micro-organisms (GMOs and GMMOs).

IMDG 2.6.1 and 2.6.3

7 Radioactive materialsAny material containing radionuclides where both the activity concentration and the total activity in the consignment exceed specified values.

IMDG 2.7.1

8 Corrosive substancesSubstances that cause irreversible damage to skin or dissolve steel or aluminium.

IMDG 2.8.1

9 Miscellaneous dangerous substances and articles (Class 9) and environmentally haz-ardous substancesClass 9 materials present a danger not covered by other hazard classes and include all of the following: materials shipped hot; wastes (hazardous); marine pollutants; other materials specifically listed as Class 9 (e.g., asbestos and lithium batteries); EPA- regulated hazardous substances (per US DOT); and GMOs and GMMOs.

IMDG 2.9.1 and 2.10

49 CFR 173.140 and 173.141



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Page 25

THE IMDG CODE’S HAZARD CLASSES AND DIVISIONS

DOT Hazard Classes vs. Divisions

Under the DOT regulations, a hazard class is a set of hazards that are represented by a whole number (e.g., Class 3 for flammable liq-uids or Class 8 for corrosive materials). When a hazard class is broken up into similar hazards, these are referred to as “divisions,” which are represented by decimal numbers.

For example, Class 2, Compressed gases, is divided into:

• Division 2.1, Flammable gases.

• Division 2.2, Non-flammable, non-poi-sonous gases.

• Division 2.3, Poisonous gases.

IMDG Hazard Classes vs. Divisions

Under the IMDG Code, only the “subcate-gories” of Class 1 Explosives are referred to as “divisions.” In all other cases, the subcatego-ries of a broader hazard class are also referred to as “class.”

For example, Class 2, Gases, is divided into:

• Class 2.1, Flammable gases.

• Class 2.2, Non-flammable, non-toxic gases.

• Class 2.3, Toxic gases.

Division 1.1 Explosives [IMDG 2.1.1.4]

Division 1.1 consists of explosives that have a mass explosion hazard. A mass explo-sion would be one that affects almost the entire load instantaneously.

Division 1.1 explosives include things like TNT, gunpowder, or plastic explosives.


Division 1.2 consists of explosives that have a projection hazard but not a mass explo-sion hazard.



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The IMDG Code’s Hazard Classes and Divisions, continued

Division 1.2 explosives include things such as hand grenades, mines, and cannon shells.


Division 1.3 consists of explosives that have a fire hazard and either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard.

Division 1.3 explosives include things such as rocket motors, special fireworks, and flash powders (such as used at concerts).


Division 1.4 consists of explosives that present a minor explosion hazard. The explo-sive effects are largely confined to the package

and no projection of fragments of appreciable size or range would be expected.

Division 1.4 explosives would include things such as small arms ammunition and common fireworks such as sparklers.


Division 1.5 consists of very insensitive explosives. This division is comprised of sub-stances that have a mass explosion hazard but are so insensitive that there is very little prob-ability of initiation or of transition from burn-ing to detonation under normal conditions of transport.

Division 1.5 explosives include things such as construction and demolition explosives.

NOTE: Because the probability of transition from burning to detonation is greater when large quantities of Division 1.5 explosives are transported in a vessel, Division 1.5 explosives are subject to the same stowage provisions as Division 1.1.



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Page 27



Division 1.6 consists of extremely insensi-tive articles that do not have a mass explosion hazard. This division is comprised of articles which contain only extremely insensitive det-onating substances and which demonstrate a negligible probability of accidental initiation or propagation.

Division 1.6 explosives are usually devices that contain small amounts of 1.5 explosives and are therefore the least dangerous of the Class 1 materials.

NOTE: The hazard of Division 1.6 explosives is limited to the explosion of a single article.

Class 2.1 Flammable Gases [IMDG 2.2.2.1]

A flammable gas is any material that is a gas at 20°C (68°F) or less at standard atmospheric pressure and burns readily in air. Common examples of flammable gases would include acetylene, propane, and many spray paints.

NOTE: If a material is shipped under pressure or chilled to keep it in a liquid state, it is still classified as a gas under the IMDG Code.

Class 2.2 Non-Flammable, Non-Toxic Gases [IMDG 2.2.2.2]

Class 2.2 include gases that:

• Are asphyxiant (i.e., gases that dilute or replace the oxygen normally in the atmosphere); or

• Are oxidizing (i.e., gases that may, generally by providing oxygen, cause or contribute to the combustion of other materials more than air does); or

• Do not meet the definitions of Class 2.1 or 2.3.

Common examples of Class 2.2 gases include helium, nitrous oxide (i.e., “laughing gas”), and liquid nitrogen.



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Class 2.3 Toxic Gases [IMDG 2.2.2.3]

A toxic gas is any material that is a gas at 20°C (68°F) or less at standard atmospheric pressure and that is either known to be so toxic or corrosive to humans that it poses a hazard or presumed to be toxic or corrosive to humans based on animal testing.

There are two significant differences between the DOT and the IMDG Code defini-tions of a Class 2.3 gas. First, the IMDG Code definition specifically includes corrosive gases. Second, there are no hazard zones for Class 2.3 gases under the IMDG Code.

Common examples of Class 2.3 gases include carbon monoxide, chlorine, and sulfur dioxide.

Class 3 Flammable Liquids [IMDG 2.3.1]

Class 3 includes:

• Flammable liquids.

• Liquid desensitized explosives.

Flammable liquids are liquids with flash points of 60°C (140°F) or less (closed cup test.) The flash point is the temperature at which an ignition source near the liquid could “flash” back and ignite the vapours. Examples of flam-mable liquids would include gasoline, ace-tone, ethanol, and many paints and common solvents.

Liquid sensitized explosives are explosive substances that are dissolved or suspended in water or other liquid substances to form a homogeneous liquid to suppress their explo-sive properties. An example of a liquid desen-sitized explosive is a nitroglycerine solution in alcohol.

NOTE: Although they are regulated by the US DOT hazmat regulations, “combustible liquids” (i.e., liquids with flash points greater than 60°C (140°F) and less than 93°C (200°F)) are not regulated under the IMDG rules.



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Page 29


Class 4.1 Flammable Solids, Self-reactive Substances, Solid Desensitized Explosives, and Polymerizing Substances [IMDG 2.4.2]

Class 4.1 includes four types of materials:

1. Flammable solids: Materials that ignite by friction, such as matches, or readily combustible solids that burn fast and hot when ignited, such as small pieces of magnesium metal.

2. Self-reactive substances: Materials that can violently decompose even without oxygen, such as certain types of epoxy compounds.

3. Solid desensitized explosives: Explo-sives wetted with water or alcohols to form a homogeneous solid mixture to suppress their explosive properties.

4. Polymerizing substances: Substances that, without stabilization, are liable to undergo a strongly exothermic reaction resulting in the formation of larger molecules or of polymers.

Class 4.2 Substances Liable to Spontaneous Combustion [IMDG 2.4.3]

Class 4.2 includes two types of materials:

1. Pyrophoric substances: Materials that, even in small quantities, are liable to ignite within five minutes after coming into contact with air. Examples include things such as phosphorus metal and certain barium and calcium alloys.

2. Self-heating substances: A solid or liq-uid that can gradually react with air to self-heat and eventually ignite. Exam-ples include things such as iron metal shavings, nitrocellulose based plastics, and bleached paper towels that are damp with flammable paint or solvent.



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Class 4.3 Substances Which, In Contact with Water, Emit Flammable Gases [IMDG 2.4.4]

Class 4.3 substances which, in contact with water, emit flammable gases (i.e., “dangerous when wet”) include materials that are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities. For example, sodium metal will undergo a reaction and produce hydrogen gas when it comes into contact with water.

NOTE: The DOT includes a toxic gas genera-tion criterion to Class 4.3.

Class 5.1 Oxidizing Substances [IMDG 2.5.1 and 2.5.2]

Oxidizing substances, or oxidizers, are materials that are not necessarily combusti-ble themselves, but may cause or contribute to the combustion of other materials more than air does. Usually they do this by provid-ing oxygen.

Examples of oxidizers include things such as perchloric acid; hydrogen peroxide; nitrates, which are commonly used in fertilizers; and, of course, oxygen.

Class 5.2 Organic Peroxides [IMDG 2.5.1 and 2.5.3]

Organic peroxides are thermally unsta-ble chemicals that may undergo exothermic self-accelerating decomposition, meaning that they can release large and dangerous amounts of heat and energy. Organic peroxides contain both an oxidizer (or oxygen) and an organic fuel in a single chemical.

Examples of organic peroxides include things such as benzoyl peroxide and methyl ethyl ketone peroxide.



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Class 6.1 Toxic Substances [IMDG 2.6.1 and 2.6.2]

Class 6.1 toxic substances include solids and liquids that are either known to be toxic to humans or are presumed to be toxic to humans based on the results of animal testing. Classi-fication as a toxic substance can be based on the oral, dermal, or inhalation toxicity of the material.

Examples of toxic substances include things such as arsenic, chloroform, cyanide solutions, and many pesticides.

Class 6.2 Infectious Substances [IMDG 2.6.1 and 2.6.3]

Class 6.2 infectious substances are materi-als that are known or reasonably expected to contain a pathogen. Examples of pathogens include bacteria, viruses, parasites, and fungi.

Class 6.2 materials include actual micro-organisms, toxins that are produced by micro-organisms, and medical wastes. Class 6.2 not only includes substances that are dangerous to humans, but also substances that are consid-ered dangerous only to animals.

NOTE: The IMDG Code includes Genetically Modified Microorganisms (GMMOs) and Genetically Modified Organisms (GMOs) in its definition of Class 6.2 infectious substances. The US DOT does not.

Class 7 Radioactive Materials [IMDG 2.7.1]

Class 7 radioactive material includes everything from low-level radioactive dyes and reagents that are used in laboratories to highly radioactive nuclear fuels.



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Class 8 Corrosive Substances [IMDG 2.8.1]

A material is considered to be a Class 8 corrosive substance if it:

1. Causes irreversible damage to human skin after an exposure time of four hours or less, within an observation time of 14 days or less.

2. Corrodes steel or aluminium at a rate greater than 6.25 mm (¼ inch) per year.

Examples of corrosives include bat-tery acid, acetic acid, and sodium hydroxide solution.

Class 9 Miscellaneous Dangerous Substances and Articles and Environmentally Hazardous Substances [IMDG 2.9.1]

Class 9 miscellaneous dangerous goods are materials that pose a hazard during trans-portation and therefore need to be regulated when shipped, but they do NOT meet the defi-nition of any other hazard class.

There are several ways a material could be considered a Class 9 material:

1. Certain materials or items are designated by the IMDG Code as Class 9 materials. They are listed and named on the 3.2 Dangerous Goods List as such. Examples include asbestos, lithium batteries, dry ice, and air bags.

2. Materials that meet the definition of an environmentally hazardous substance (aquatic environment), elevated-tem-perature material, Genetically Modified Microorganisms (GMMO), or Genetically Modified Organisms (GMO) are assigned to Class 9 IF they do not meet the defi-nition of one of the other eight hazard classes.

NOTE: The IMDG Code does not include cri-teria for hazardous waste or hazardous sub-stances (as defined by the DOT). However, these materials may be transported as Class 9 materials under the IMDG Code if they meet the DOT’s criteria.



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DETERMINING SUBCLASSIFICATIONSIMDG Part 2

In addition to determining the hazard class, many hazardous materials must be fur-ther classified based on the severity of the hazard that they pose as well as other issues. These subclassifications include:

• Packing groups.

• Hazard zones.

• Generic types.

• Compatibility groups.

Packing Groups

The degree of hazard for dangerous goods in Classes 3, 4, 5.1, 6.1, 8, and 9 is indicated by the packing group. The packing group is rep-resented by a Roman numeral I, II, or III.

• PG I indicates “great” danger.

• PG II indicates “medium” danger.

• PG III indicates “minor” danger.

Determining the Packing Group

Packing groups for dangerous goods are listed in Column 5 of the 3.2 Dangerous Goods List for each Proper Shipping Name. If there is more than one packing group listed for a generic or N.O.S. name , then you must use the criteria

provided in IMDG Chapters 2.3 through 2.8 to determine which one applies to your material. Rules for assigning packing groups follow the definitions of each of the hazard classes that are assigned packing groups.

Other Subclassifications

There are several other subclassifications for hazardous materials that are used either instead of or in addition to the packing group. For example:

• Generic types A through G for self-reactive materials (flammable solids) and organic peroxides. Generic type A is the most dangerous; generic type G is the least dangerous. [IMDG 2.4.2.3.3.2]

• Explosives are assigned to compatibility groups, which are used to specify the controls for the transportation and related storage of explosives and to prevent an increase in hazards that could result if certain types of explosives were stored or transported together. [IMDG 2.1.2]

• There are numerous subclassifications for radioactives. [IMDG 2.7]



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THE DANGEROUS GOODS CLASSIFICATION PROCESSIMDG 2.0.1.4–2.0.1.6

Materials Specifically Identified on the Dangerous Goods List [IMDG 2.0.1.5]

The first step in the classification process is to determine whether or not the material is a single chemical or a specific article that can be described by a technical name, and if so, whether this name is found on the Dangerous Goods List at IMDG 3.2.

If the technical name of the article or substance is included on the List as a “single entry,” meaning that there is only one packing group associated with the shipping name, then the shipper should use that hazard classifica-tion and Proper Shipping Name.

NOTE: Dangerous goods listed by name may contain trace amounts of other materials that do not affect their classification.

Examples of articles and substances that are specifically named on the 3.2 Dangerous Goods List would include:

• Acetic acid, glacial.

• Chloroform.

• Lithium-metal batteries.

NOTE: The IMDG Code differs from 49 CFR in this regard. At 49 CFR 172.101(c)(12), the DOT explicitly states that the listed hazard(s) must match the actual hazard of the material being shipped. However, the IMDG Code says, “trust us” if you find a substance or article explicitly

identified in the 3.2 Dangerous Goods List. The “trust us” rule does NOT apply to mixtures and solutions, which must be classified based on their chemical and physical properties.

Materials NOT Specifically Identified on the Dangerous Goods List [IMDG 2.0.1.4 and 2.0.1.6]

If the substance or article is not a single chemical or specific article described by a tech-nical name specifically listed on the 3.2 Dan-gerous Goods List, then the shipper must clas-sify it by:

• Checking to see if the material is forbid-den from transport under the IMDG Code.

• Comparing its known properties with the definitions for the various classes/divi-sions given in IMDG Chapters 2.1 to 2.10.

• Determining ALL hazard class/division criteria the material meets.

• Determining all necessary subclassifi-cations (packing group, compatibility group, etc.).

• Using the precedence rules at IMDG 2.0.3 to determine the primary hazard and the subsidiary hazard(s) for articles or sub-stances with multiple hazards.



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The Dangerous Goods Classification Process, continued

The Index vs. The List

Because entries on the 3.2 Danger-ous Goods List are arranged in order of UN number rather than alphabetically, shippers will usually need to look up their material in the Index to the IMDG Code in order to find it. If they find their material, they can then use the UN number identified in the Index to find the name for the material in the 3.2 Danger-ous Goods List and determine if the material is included in the List as a single entry.



Page 36

CLASSIFYING DANGEROUS GOODS NOT NAMED ON THE DANGEROUS GOODS LIST

1. Collect Data

The first step is to gather information about the dangerous good by identifying its properties, including:

• What is the physical state of the material? Liquid? Solid? Gas?

• What are its chemical/physical/toxico-logical properties?

• What are the ingredients?

2. Consider Options

Based on your knowledge of the danger-ous good being shipped, it is usually possible to eliminate most of the hazard classes and identify some that the substance/article might possibly have. For example:

• If it’s liquid, it can’t be Class 2, since Class 2 dangerous goods are gases.

• If it’s solid, it can’t be Class 3, since Class 3 dangerous goods are flammable liquids.

Next, consider what its other properties are. Might it be flammable? Might it destroy skin or corrode steel? Might it be fatal in small doses if inhaled, swallowed, or absorbed through skin?

Browse the list of hazard classes at IMDG 2.0.1.1 to identify hazard classes you think the dangerous good might have.

3. Confirm or Deny Hazard Classes and Applicable Subclassifications

Once you know which hazards are possi-ble, the last step in the process is to go to the appropriate regulatory reference for each “sus-pect” hazard class to see how that hazard class is defined, and then determine if your danger-ous good has that hazard. You will also need to identify which subclassifications apply to the dangerous good at this time as well (e.g., Pack-ing Group I, II, III, Generic Type A, B, etc.).

Hazard class definitions are found in Part 2 of the IMDG Code. Each hazard class number is the chapter number, for example,

• The definition of Hazard Class 3 sub-stances is found at IMDG 2.3.

• The definition for Hazard Class 8 is found at IMDG 2.8.

NOTE: It is possible to meet more than one hazard class definition. In order to correctly classify dangerous good for transportation, you must determine all of the hazards actu-ally posed by the substance/article as well as which hazard is the primary hazard and which hazard or hazards are the subsidiary hazards.



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PRACTICAL ISSUES IN DANGEROUS GOODS CLASSIFICATION

Classification Is Based on the Hazards as Offered

In general, the IMDG Code regulates dan-gerous goods on the basis of the hazard actu-ally posed by the substance at the point that it is offered for transportation. It is the shipper’s responsibility to identify these hazards.

Classification Is Not Based Solely on the Individual Constituents

Hazards of individual constituents in a mixture may help determine the hazard posed by the mixture, but it is the mixture that must, ultimately, be classified and named, based on its properties “as shipped.”

Testing Is Not Required

It is not necessary to quantify or measure every property of a dangerous good or iden-tify 100% of the constituent makeup in order to classify it under the IMDG Code. You must determine whether the properties of the sub-stance cause it to meet or not meet hazard class definitions.

Most of the hazard class definitions pro-vide specific thresholds that may be measured. To determine whether a dangerous good meets one of these hazard class definitions, all you need to know is whether it is is above or below the threshold—the actual number may not be significant.

In many cases, these determinations can be made based on “human experience,” with-out actual laboratory analysis. For example:

• If you know that a substance has a flash point below 10°C and a boiling point above 100°C, it is an IMDG Code flamma-ble liquid (Class 3, Packing Group II). You don’t need to determine the actual flash point or boiling point.

• A substance that destroys skin tissue if in contact with the skin for three minutes or less is classified as a Packing Group I cor-rosive substance (Class 8). Do you know how long your caustic cleaning solution actually takes to destroy skin? Maybe not. But do you at least know that it would definitely take longer than three minutes of contact to destroy the skin? If so, you know it’s not Packing Group I.

Transporting Materials Regulated by the DOT But Not Regulated Under the IMDG Code

If an article or substance is not listed by name at IMDG 3.2 and does not meet the defi-nition of any of the hazard classes, it is not sub-ject to the IMDG Code. However, any material the DOT considers hazardous that is excepted from regulation under international standards must still be transported in accordance with all applicable 49 CFR regulations when it is trans-ported in the United States.



Notes:

Page 38

MULTIPLE-HAZARD MATERIALSIMDG 2.0.3

Articles/Substances With Multiple Hazards

It is common for a single dangerous good to meet the definition of more than one IMDG hazard class or division. The shipper must identify ALL the hazards posed by a material in order to determine the proper hazard clas-sification

For example, a flammable liquid may also be toxic and corrosive. One of those hazards would be the primary hazard, or hazard class, of the material, while the other hazards would be considered “subsidiary hazards.” This will impact later steps in the shipping process. For example:

• All hazards, primary and subsidiary, must be considered in selecting the Proper Shipping Name (Step 2), but it is also important to know which hazard is the primary hazard in order to pick the correct Proper Shipping Name.

• Most subsidiary hazards must be not-ed in the basic description of a material on shipping papers [IMDG 5.4.1.4.1.4]; however, subsidiary hazards are indicat-ed differently than primary hazards in the basic description.

Articles and Substances Specifically Listed on the 3.2 Dangerous Goods List

If an article or substance is explicitly iden-tified on the 3.2 Dangerous Goods List, the list-ing will identify the primary hazard class or division and any subsidiary hazards.

• The primary hazard is indicated in Col-umn 3 of the 3.2 Dangerous Goods List.

• The subsidiary hazard(s), if any, will be indicated in Column 4 of the 3.2 Danger-ous Goods List.

Articles/Substances NOT Specifically Listed on the 3.2 Dangerous Goods List

For substances, mixtures, or solutions that have multiple hazards and that are not spe-cifically listed by name on the 3.2 Dangerous Goods List, the primary hazard and subsidiary hazard(s) are determined using the Precedence of Hazard Table at IMDG 2.0.3.6 UNLESS the material poses a hazard that is “excepted” from the Table.



Notes:

Page 39

Multiple-hazard Materials, continued

Hazard Classes “Excepted” from the Precedence of Hazard Table [IMDG 2.0.3.4]

The precedence of the following hazard classes and divisions is not dealt with in the Precedence of Hazard Table because these pri-mary hazards always take precedence.

1. Explosives—Class 1

2. Gases—Class 2

3. Liquid desensitized explosives—Class 3

4. Self-reactive substances and solid desen-sitized explosives—Class 4.1

5. Pyrophoric substances—Class 4.2

6. Organic peroxides—Class 5.2

7. Toxic substances with Packing Group I vapour inhalation toxicity—Class 6.1

8. Infectious substances—Class 6.2

9. Radioactives—Class 7

Other than radioactive materials in excepted packages (where the other hazardous properties take precedence), radioactive mate-rials having other hazardous properties must always be classified as Class 7, with the most severe of the additional hazards being identi-fied. Radioactive materials in excepted pack-ages having other properties must be classified per the requirements of Special Provision 290 in IMDG 3.3.

Using the Precedence of Hazard Table

To use the Precedence of Hazard Table at IMDG 2.0.3.6:

1. Find the lower-numbered hazard on the left side of the table.

2. Find the higher-numbered hazard on the top of table.

3. Look to see where the relevant row and column intersect in the table.

The class shown at the intersection of the relevant line and column is the primary hazard.

NOTE: The most stringent packing group of the hazards posed by the substance takes precedence over the other packing groups, regardless of the Precedence of Hazard Table.


Multiple-hazard Materials, continued


Page 40

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Page 41

CLASSIFYING MARINE POLLUTANTSIMDG 2.9, 2.10, and 3.2

Classifying Substances as Marine Pollutants [IMDG 2.9, 2.10, and 3.2]

A substance is classified as a marine pol-lutant either by:

• The presence of the symbol “P” in:

– Column 4 of the 3.2 Dangerous Goods List, or

– The “MP” column of the IMDG Code Volume 2 Index; or

• Meeting the criteria for acute or chronic environmentally hazardous substances specified at IMDG 2.9.3.3.1.

Classifying Solutions and Mixtures as Marine Pollutants [IMDG 2.9.3.4 and 2.10.2.5]

When a substance’s effect on the aquatic environment is unknown, or when you are offering a mixture or solution that contains a designated marine pollutant, you must evalu-

ate the material according to IMDG 2.9.3. If the material meets the environmentally hazardous substance criteria, then you must transport it as a marine pollutant.

Hazard Classes for Marine Pollutants [IMDG 2.9.3.3.1 and 2.10.2.3]

Marine pollutants that meet the criteria of Classes 1 through 8 should be assigned to the appropriate hazard class(es). Marine pollut-ants that do not meet the criteria of Classes 1 through 8 should be assigned to Class 9, Pack-ing Group III.

Exception for Small Packages Containing Marine Pollutants [IMDG 2.10.2.7]

Marine pollutants that are packaged in single or combination packagings containing a maximum net quantity (per single or inner packaging) of 5 L or 5 kg are not subject to any other provisions of the IMDG Code applicable to marine pollutants, provided the packag-ing meets the requirements of IMDG 4.1.1.1, 4.1.1.2, and 4.1.1.4 to 4.1.1.8. Marine pollut-ants that also meet the criteria for inclusion in another hazard class are subject to all provi-sions of the IMDG Code relevant to those other hazards.



Notes:

Page 42

“OVERCLASSIFYING” A MATERIAL AS A DANGEROUS GOOD

Because classification can at times be a dif-ficult process, one reaction to the challenge of classification is to want to call a material haz-ardous “just to be safe.”

It is NOT safe to “over-classify” a mate-rial (i.e., to assign hazards that are not, in fact, exhibited by the material). Overclassification can have several undesirable effects.

NOTE: Because the DOT’s and IMDG’s hazard class definitions are not identical, in some cases, a substance or article may be deter-mined to pose an “IMDG hazard,” but not a “DOT hazard.” In these situations, the DOT allows the material to be transported during the ground phase of shipment as a hazardous material/dangerous good. This would not be considered an instance of “overclassification.”

Improper Emergency Response

Responders to a transportation incident may take excessive or improper precautions if materials have been overclassified and identi-fied as posing hazards that they do not actually pose. For example, if responders see hazard communication labels and marks, they will be more cautious and careful in approaching an incident scene. As a result, they may unnec-essarily:

• Keep medical teams away from in-jured people while they wait for extra equipment.

• Shut down roads.

• Call in hazmat teams or fire departments.

• Evacuate the surrounding area.

Reduced Effectiveness of Marks and Labels for Handlers

Employees and others may learn to dis-regard marks and labels if they see them on things that are not hazardous. Then, when they are properly used, employees won’t know if the material really is hazardous or if someone put the label on it just to be “safe.”

Illegal to Overclassify

According to the DOT’s hazardous mate-rials regulations, it is in fact illegal to use DOT hazard marks, labels, placards, or identifica-tion numbers or in any other way represent that a hazardous materials is contained in a package when the material shipped is not, in fact, hazardous. [See, among others, 49 CFR 171.2(f), 172.202(e), 172.303, and 172.401.]



Notes:

Page 43

CLASSIFYING SAMPLES FOR TRANSPORTIMDG 2.0.4

One exception to the restrictions on “over-classifying” dangerous goods is for sub-stances for which you don’t know the actual hazards. If you need to send a sample out for testing in order to find the hazards, you may “over-classify.”

This exclusion only applies to samples being sent for analysis for the purpose of classi-fication. It does NOT apply to product, quality control, or R & D samples sent for testing and analysis.

Tentative Hazard Determination

If a sample of a material is being shipped for testing to determine its hazards, it is legal to assign the sample a “tentative” hazard class and Proper Shipping Name, based on the ship-per’s knowledge of the material and:

• The classification criteria of the IMDG Code.

• The precedence of hazards rules in IMDG 2.0.3.

Assignment of Packing Group

The shipper must assign the material the most stringent packing group for the Proper Shipping Name chosen for the material.

NOTE: This rule is different from the DOT’s rules for assigning packing groups to samples, which state that the shipper should assign the packing group based on his or her knowledge of the material.

Limitations on Samples for Testing

There are certain limitations and require-ments that must be met when making use of this “best guess” relief.

• The shipper must know that the sub-stance would not be prohibited for trans-port under IMDG 1.1.3.

• The shipper must know that the sub-stance would not meet the definition of an explosive, an infectious substance, or a radioactive material.

Additional restrictions apply when ship-ping self-reactives and organic peroxides for testing.

NOTE: Samples sent for analysis must also meet certain requirements for identifica-tion and packaging. These requirements are addressed elsewhere in this Compliance Reference.



Notes:

Page 44

FORBIDDEN DANGEROUS GOODSIMDG 1.1.3, 3.3.1, and 7.1.3

Key Regulations

Regulation What’s There?

IMDG 1.1.3 Criteria for dangerous goods forbidden under any circumstances

IMDG 3.3.1 IMDG special provisions

IMDG 7.1.3 Forbidden on passenger ships

49 CFR 171.22(e)

Forbidden materials

49 CFR 173.21

Criteria for “forbidden” materials

49 CFR 173.24

General rules for all pack-ages, including prohibition on packaging incompatible materials in the same outer packaging

49 CFR 173.54

Definition of “forbidden explosives”

What Does “Forbidden” Mean?

Forbidden dangerous goods are materials that have been determined to be too danger-ous to be safely transported by vessel and as such may not legally be offered for transportation or transported by vessel. Some of these materials are specifically listed as forbidden under var-ious special provisions. Others are forbidden from transport by vessel by being described in the IMDG General Provisions.

Dangerous Goods Forbidden Under Any Circumstances [IMDG 1.1.3]

Unless otherwise provided in the IMDG Code, any substance or article that, as pre-sented for transport, is liable to explode, dan-gerously react, or produce a flame or danger-ous evolution of heat or dangerous emission of toxic, corrosive, or flammable gases or vapours under normal conditions of transport is forbidden from transport.

Dangerous Goods Forbidden per Special Provisions [IMDG 3.3.1]

The following materials are specifically forbidden from transport under the IMDG Code by Special Provisions 349, 350, 351, 352, 353, and 900:

• AMMONIUM BROMATE

• AMMONIUM BROMATE mixed with ammonium salt

• AMMONIUM BROMATE SOLUTION

• AMMONIUM CHLORATE

• AMMONIUM CHLORATE mixed with ammonium salt

• AMMONIUM CHLORATE SOLUTION

• AMMONIUM CHLORITE



Notes:

Page 45

Forbidden Dangerous Goods, continued

• AMMONIUM CHLORITE mixed with ammonium salt

• AMMONIUM CHLORITE SOLUTION

• AMMONIUM HYPOCHLORITE

• AMMONIUM NITRATE liable to self-heating sufficient to initiate de-composition

• AMMONIUM NITRITES and mixtures of an inorganic nitrite with an am-monium salt

• AMMONIUM PERMANGANATE

• AMMONIUM PERMANGANATE mixed with ammonium salt

• AMMONIUM PERMANGANATE SOLUTION

• CHLORIC ACID, AQUEOUS SOLUTION with more than 10% chloric acid

• ETHYL NITRITE pure

• HYDROCYANIC ACID, AQUEOUS SOLUTION (HYDROGEN CYANIDE, AQUEOUS SOLUTION) with more than 20% hydrogen cyanide

• HYDROGEN CHLORIDE, REFRIGER-ATED LIQUID

• HYDROGEN CYANIDE SOLUTION, IN ALCOHOL with more than 45% hydro-gen cyanide

• HYPOCHLORITE mixed with am-monium salt

• MERCURY OXYCYANIDE pure

• METHYL NITRITE

• PERCHLORIC ACID with more than 72% acid, by mass

• SILVER PICRATE, dry or wetted with less than 30% water by mass

• ZINC AMMONIUM NITRITE

Forbidden on Passenger Ships [IMDG 7.1.3]

Column 16a of the 3.2 Dangerous Goods List provides the stowage requirements for dangerous goods on ships. The following stowage categories are prohibited from being transported on most passenger ships:

• Class 1 (explosives):

– Stowage category 03



• Classes 2–9 (other dangerous goods):

– Stowage category D

– Stowage category E

US DOT Forbidden Materials [49 CFR 171.22(e)]

The US DOT does not permit any materi-als forbidden by 49 CFR 171–180 to be shipped under IMDG rules. The DOT maintains a list of forbidden materials here:

https://www.phmsa.dot.gov/ international-program/ forbidden-materials



Notes:

Page 46

THE DANGEROUS GOODS CLASSIFICATION PROCESS: EXAMPLE: PROPELLANT AND ROCKET FUEL

Step 1: Collect Data

The propellant displays the following physical and chemical properties:

• Liquid

• Flash point: 20°C (closed cup)

• Boiling point: 255°C

• Oral toxicity LD50: 40 mg/kg

• Irreversible damage to skin occurs:

– After an exposure time of 2 minutes or less

– Within an observation period of 50 minutes

NOTE: Assume that the material poses no other relevant properties to the dangerous goods classification process.

Step 2: Consider Options

Class 1

We have no information that indicates the propellant could explode. Therefore, we can eliminate this possibility.

Class 2

The propellant is a liquid, not a gas, so it cannot be a Class 2 Compressed Gas.

Class 3

The flash point data indicates that the pro-pellant is likely going to be a flammable liquid, so we will want to look at the definition for Class 3 Flammable Liquids.

Classes 4.1, 4.2, and 4.3

Class 4.1 is flammable solids, so the liquid propellant can’t be Class 4.1 There is nothing in the data indicating that the propellant could be spontaneously combustible or that it would be dangerous if it came into contact with water, so it won’t be a Class 4.2 or 4.3 material either.

Classes 5.1 and 5.2

Classes 5.1 and 5.2 are the oxidizing sub-stances and the organic peroxides, respectively. Since there is nothing in the data regarding the propellant being an oxidizer or an organic per-oxide, we will assume that it won’t meet either of these definitions.

Classes 6.1 and 6.2

Class 6.1 is toxic substances. The oral LD50 data indicates that the propellant might be toxic, so we will want to look at the definition for Class 6.1 Toxic Substances.

Class 6.2 is for infectious substances, and the propellant is obviously not going to be an infectious substance.



Notes:

Page 47

The Dangerous Goods Classification Process: Example: Propellant and Rocket Fuel, continued

Class 7

Class 7 is for radioactive materials, and there is nothing in the data indicating that the propellant would be radioactive.

Class 8

Class 8 is for corrosive substances. The skin damage data indicates that the propellant may be a Class 8 Corrosive Substance, so we’ll need to look up that definition.

Class 9

The last hazard class is Class 9, the mis-cellaneous hazards. There are actually several special issues that must be considered when determining whether or not a material meets the definition of a Class 9, however, we will only need to consider this class if the mate-rial doesn’t meet any of the Hazard Class 1 through 8 definitions.

Conclusion

So, after we’ve considered all the hazard classes, we’re left with three possibilities: Class 3 Flammable Liquids, Class 6.1 Toxic Sub-stances, and Class 8 Corrosive Substances. The next step is to look up the definition of these hazards in the IMDG Code.

Step 3: Confirm or Deny Hazard Classes and Applicable Subclassifications

The definition of flammable liquids is found at IMDG 2.3. The definition of toxic sub-stances is found at IMDG 2.6. The definition of corrosive substances is found at IMDG 2.8.

Determining If the Material Is a Flammable Liquid

Definition of a Flammable Liquid [IMDG 2.3]

The definition of a flammable liquid at IMDG 2.3.1.2 states that flammable liquids are liquids, or mixtures of liquids, or liquids con-taining solids in solution or suspension, that give off a flammable vapour at temperatures at or below 60°C closed cup test, normally referred to as the flash point.

NOTE: “At or below” is another way of saying “less than or equal to,” so a flammable liquid is a liquid with a flash point less than or equal to 60°C.

The propellant has a closed cup flash point of 20°C, which is below the cutoff of 60°C, so it is a flammable liquid.

Exceptions and Additions to the Definition of Flammable Liquid

There is actually more to the definition of a flammable liquid than simply being a liquid with a flash point less than or equal to 60°C. At IMDG 2.3.1.2 through 2.3.1.4, we’ll find a few exceptions and additions to the definition.



Notes:

Page 48


Most of the listed exceptions and addi-tions are fairly uncommon, but if you are responsible for classifying flammable liquids with unusual properties, then you should take some time to become familiar with the entire definition.

Determining the Packing Group for Hazard Class 3

In addition to knowing the hazard class of the material, we also need to determine the degree of hazard, which for flammable liquids is represented by its packing group. The pack-ing group definitions for flammable liquids are at IMDG 2.3.2.

In general, as long as you’re not dealing with viscous liquids, which are subject to some special rules that can be found in IMDG 2.3.2.2, determining the packing group for a flamma-ble liquid is fairly easy if you use the table at IMDG 2.3.2.6, which is shown below.

Class 3—Packing Group Assignment [IMDG 2.3.2.6]

Packing Group

Flash point (closed cup)

Initial boiling point

I ----- ≤ 35°C

II < 23°C > 35°C

III ≥ 23°C to ≤ 60°C > 35°C

Understanding the Table

The first column identifies the three differ-ent packing groups. The second column pro-vides flash point cutoff values for each packing group, and the third column provides boiling point cutoff values for the different groups.

Packing Group I

The determination of whether or not a flammable liquid is a Packing Group I sub-stance is based SOLELY on its initial boiling point. In order for a flammable liquid to be a Packing Group I substance, it must have a boil-ing point less than or equal to 35°C.

The propellant has a boiling point of 255°C. Since this is above 35°C, the propellant cannot be a Packing Group I flammable liquid.

Packing Group II

Both Packing Groups II and III have boil-ing points over 35°C, so the criteria for distin-guishing between the two of them is based on the flash point of the substance.

For a flammable liquid to be a Packing Group II substance, it would have to have a boiling point over 35°C and a flash point less than 23°C.

The propellant has a flash point of 20°C. Since this is below 23°C, the propellant is a Packing Group II flammable liquid.



Notes:

Page 49


Determining If the Material Is a Toxic Substance

Definition of a Toxic Material [IMDG 2.6]

According to the IMDG Code’s definition at IMDG 2.6.1, toxic substances are substances that are liable to cause death or injury or to harm human health if swallowed, inhaled, or by skin contact. To classify a substance as a toxic substance under the IMDG Code, we need to use the table at IMDG 2.6.2.2.4.1.

Class 6.1—Packing Group Assignment Based on Oral Ingestion, Dermal Contact, and Inhalation of Dusts and Mists (IMDG 2.6.2.2.4.1)

Packing Group Oral toxicity LD50 (mg/kg)

Dermal toxicity LD50 (mg/kg)

Inhalation toxicity by dusts and mists LC50 (mg/L)

I ≤ 5.0 ≤ 50 ≤ 0.2

II > 5.0 and ≤ 50 > 50 and ≤ 200 > 0.2 and ≤ 2.0

III > 50 and ≤ 300 > 200 and ≤ 1,000 > 2.0 and ≤ 4.0

Understanding the Table

The first column identifies the three differ-ent packing groups. The next three columns provide the cutoff ranges for oral, dermal, and inhalation toxicity.

Packing Group I

In order for a substance to be a Packing Group I substance based on oral toxicity, it must have an oral toxicity LD50 less than or equal to 5 mg/kg.

The propellant has an oral toxicity of 40 mg/kg. Therefore, it does not meet the defi-nition of a Class 6.1, Toxic Substance, Packing Group I.

Packing Group II

In order for a substance to be a Packing Group II substance based on oral toxicity, it must have an oral toxicity LD50 greater than 5 mg/kg but less than or equal to 50 mg/kg.

Since the propellant has an oral toxicity of 40 mg/kg, it would meet the definition of a Class 6.1, Packing Group II, Toxic Substance.



Notes:

Page 50


Determining If the Material Is a Corrosive Material

Definition of a Corrosive Material [IMDG 2.8]

The IMDG Code defines corrosive sub-stances as substances that will cause irrevers-ible damage to the skin or, in the event of leak-age, materially damage or even destroy other goods or the means of transport.

As was the case with Class 6.1, in order to know if a substance should be assigned to Class 8, we’ll need to determine if it meets the minimum criteria for assignment to a Pack-ing Group III. Therefore, we’ll need to look at the rules for Packing Group assignments at IMDG 2.8.3.

Packing Groups for Class 8

The data that we have indicates that the substance can have a harmful effect on skin. When assigning a packing group to a Class 8 Corrosive Substance on the basis of skin damage data, there are two issues that must be addressed: exposure time and observa-tion time.

The exposure time refers to how long the substance must be in contact with a person’s skin before irreversible damage to the skin occurs. The observation time refers to the length of time it takes for skin damage to appear after the chemical is washed off the skin.

The thresholds for inclusion in each of the three packing groups are described at IMDG 2.8.3.3. However, it is probably actually easier to just use Table 2.8.3.4 to determine the pack-ing group, since it contains the same numbers in a somewhat easier to read format.

Class 8—Packing Group Assignment [IMDG 2.8.3.4]

Packing Group Exposure Time Observation Time Effect

I ≤ 3 min. ≤ 60 min. Irreversible damage of intact skin

II > 3 min. ≤ 1 hr. ≤ 14 days Irreversible damage of intact skin

III > 1 hr. ≤ 4 hr. ≤ 14 days Irreversible damage of intact skin

III -------- -------- Corrosion rate on either steel or alu-minium surfaces exceeding 6.25 mm a year at a test temperature of 55°C

when tested on both materials




Page 51

Packing Group I

Packing Group I includes substances that cause irreversible damage to skin within an observation period of up to 60 minutes, after an exposure time of 3 minutes or less.

This means that the substance would only need to be on the skin for 3 minutes or less to cause damage, and the damage would appear within an hour after exposure.

Packing Group II

Packing Group II includes substances that cause irreversible damage to skin within an observation period of up to 14 days, after an exposure time of more than 3 minutes, but less than or equal to 60 minutes.

This means the substance would need to be on the skin for more than 3 minutes but no longer than an hour to cause damage, and the damage would appear within 14 days after exposure.

Packing Group III

Packing Group III includes substances that cause irreversible damage to skin within an observation period of up to 14 days, after an exposure time of more than 60 minutes but less than or equal to 4 hours.

Packing Group III also includes substances that corrode steel or aluminium surfaces at a rate greater than 6.25 mm (0.25 in.) a year.

Assignment of a Class 8 Packing Group to the Propellant

According to the data, irreversible damage to skin would occur if the propellant was in contact with skin for 2 minutes or less, and the

damage would appear within 50 minutes of the exposure. This would meet the criteria for a Class 8, Packing Group I, Corrosive Substance.

Determining the Primary Hazard

The propellant poses all of the following hazards:

• Class 3, Packing Group II

• Class 6.1, Packing Group II

• Class 8, Packing Group I

The propellant meets the definition of more than one hazard class, so we need to determine the primary hazard class for the substance. Since the propellant does not pose any of the hazards excepted from the Prece-dence of Hazards Table at IMDG 2.0.3.4 and is not specifically listed on the 3.2 Dangerous Goods List, the primary hazard must be deter-mined according to the Precedence of Hazards Table at IMDG 2.0.3.6.

If we match up Class 3, PG II and Class 6.1, PG II on the table, we will find “3” in the box where the hazards intersect.

If we then match up Class 3, PG II and Class 8, PG I (liquid) on the table, we will find “8” in the box where the hazards intersect

Final Classification

Per the rules at IMDG 2.0.3, the primary hazard of the propellant is Class 8 (corrosive substance). The propellant also poses the sub-sidiary hazards of Class 3 (flammable liquid) and Class 6.1 (toxic substance).

The packing group of the propellant is Packing Group I.



CONTENTS

Step 2—Identification ..........................................................................................................53

The 3.2 Dangerous Goods List ...........................................................................................54

Selecting a Proper Shipping Name ....................................................................................56

Naming Mixtures and Solutions ........................................................................................61

Naming Marine Pollutants .................................................................................................63

Modifying Proper Shipping Names ..................................................................................64

Segregation Groups .............................................................................................................67



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STEP 2—IDENTIFICATIONSelecting the Best Proper Shipping Name


Reference What’s There?

IMDG Part 3 Dangerous Goods List

IMDG Part 3, App. A

List of generic and N.O.S. Proper Shipping Names

IMDG Part 3, App. B

Glossary of terms used in the 3.2 Dangerous Goods List

IMDG 3.1 and 3.2

Rules for selecting and using Proper Shipping Names

IMDG 2.0.2 Naming

IMDG 2.0.4 Transport of samples

IMDG 5.4.1 Hazardous waste


The second step in the dangerous goods shipping process is to choose the Proper Ship-ping Name for the material. In doing this, the shipper must find the shipping name entry on IMDG’s 3.2 Dangerous Goods List that is the best one for the material being shipped. Among other things, the shipping name entry on the Dangerous Goods List that the shipper chooses for the material determines:

• The types of packagings that are autho-rized to use to ship the material.

• The minimum hazard labeling for the package.

• The actions that responders will take in the event of a spill or other emergency.

• The maximum quantities allowed per package.

If the shipper selects an incorrect or inap-propriate Proper Shipping Name, it is possible (or even likely) that the material will not be packaged correctly and/or that the response actions indicated will be inappropriate for the material.


To ensure that you select the correct name, you must know:

• All the hazards the material has, and the severity of each.

• Which hazard is primary, if the material has multiple hazards.

• The physical state of the material (you must already know this for clas-sification—it may also be important for naming).

• What the material is (i.e., Is it a sin-gle chemical? What is the chemical? Is it a product formulation? What is it used for?).



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THE 3.2 DANGEROUS GOODS LISTIMDG 3.2.1

(1) UN NumberThe serial number assigned to the mate-rial under the United Nations classifica-tion system (used to identify emergency response information). Must be prefixed with the letters “UN” on package marks and transport documents.

(2) Proper Shipping Name (PSN) [IMDG 3.1.2]

Must use names in UPPERCASE charac-ters. Lowercase words are supplementary and not part of the PSN but are optional.

(5) Packing Group [IMDG 2.0.1.3]The packing group for a material. If more than one is listed, the shipper must deter-mine the correct packing group.

(6) Special Provisions [IMDG 3.3]Special provision codes that apply to a particular material (e.g., packaging limita-tions, restrictions, added requirements). Special provisions specific to the sea mode start at 900.

UN No.

Proper shipping name (PSN)

Class or division

Subsidiary hazard(s)

Packing group

Special provisions

Limited and excepted quantity provisions

Packing IBC

Limited quantities

Excepted quantities

Instruc-tions

Provi-sions

Instruc-tions

Provi-sions

(1) (2) 3.1.2

(3) 2.0

(4) 2.0

(5) 2.0.1.3

(6) 3.3

(7a) 3.4

(7b) 3.5

(8) 4.1.4

(9) 4.1.4

(10) 4.1.4

(11) 4.1.4

1567 BERYLLIUM POWDER 6.1 4.1 II – 500 g E4 P002 PP100 IBC08 B4 B21

1569 BROMOACETONE 6.1 3 P

II – 0 E0 P602 – – –

1570 BRUCINE 6.1 – I 43 0 E5 P002 – IBC07 B11571 BARIUM AZIDE, WETTED with

not less than 50% water, by mass4.1 6.1 I 28 0 E0 P406 PP31 – –

(3) Hazard Class or Division [IMDG 2.0]The primary class or division number associated with a particular Proper Shipping Name.

(4) Subsidiary Hazards [IMDG 2.0]The class or division number(s) of any identified subsidiary hazards. Also identi-fies a dangerous good as a marine pollut-ant (“P”).

(7) Limited and Excepted Quantities [IMDG 3.4 and 3.5]

Column 7a: Maximum quantity per inner packaging authorized for limited quan-tities, if any. Column 7b: Alphanumeric code indicating the maximum amount permitted as an excepted quantity, if any.

(8–11) Packing Columns [IMDG 4.1.4]Provide instructions for packaging dangerous goods for transport.


The 3.2 Dangerous Goods List, continued


Page 55

(12–14) Packing Columns [IMDG 4.2.5 and 4.3]

Provide instructions for packaging dan-gerous goods for transport.

(15) EmS Number [IMDG 5.4.3.2 and 7.8]Refers to relevant emergency schedules for FIRE and SPILLAGE in “The EmS Guide—Revised Emergency Response Procedures for Ships Carrying Danger-ous Goods.”

(16a–16b) Stowage and Segregation [IMDG 7.1, 7.3–7.7]

Stowage and segregation provisions as prescribed in IMDG Part 7.

(17) Properties and ObservationsContains properties and observations for the dangerous goods listed. Provisions in the column are not mandatory.

Portable tanks and bulk containers EmS Stowage and Handling

Segregation Properties and observations UN No.

Tank instructions Provisions

(12) (13) 4.2.5 4.3

(14) 4.2.5

(15) 5.4.3.2

7.8

(16a) 7.1, 7.3–7.7

(16b) 7.2–7.7

(17) (18)

– T3 TP33 F-G, S-G Category A H1

SG25 SG26

White, metallic powder. Toxic if swallowed, by skin contact or by dust inhalation.

1567

– T20 TP2 TP13

F-E, S-D Category D SW2

– When pure, colourless liquid evolving irritating vapour (“Tear Gas”). Flashpoint: approximately 45°C c.c. Toxic if swal-lowed, by skin contact or by inhalation.

1569

– T6 TP33 F-A, S-A Category A – White crystals or powder. Highly toxic if swallowed, by skin contact or by dust inhalation.

1570

– – – F-B, S-J Category D SG7 SGG17 SG30

Desensitized explosive. White crystals or powder. Explosive and sensitive to friction in the dry state. Toxic if swallowed, by skin contact or by dust inhalation. May form extremely sensitive compounds with heavy metals or their salts.

1571

Descriptions of the Columns

Regulations explaining the various col-umns of the 3.2 Dangerous Goods List are found in IMDG 3.1 and 3.2, immediately in front of the List itself.

(18) UN NumberSame as Column 1.

Explanation of Terms

Explanations of many of the terms relat-ing to the entries found on the 3.2 Dangerous Goods List can be found in IMDG 1.2, Defini-tions, Units of Measure, and Abbreviations. In addition, explanations for terms specific to explosives can be found in the glossary in Appendix B following the List.



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SELECTING A PROPER SHIPPING NAMEIMDG 3.2 Dangerous Goods List

There are approximately 3,000 entries on the 3.2 Dangerous Goods List, and the ship-per is responsible for selecting the appropriate entry for the dangerous article or substance being offered.

The Three Rules for Selecting a Proper Shipping Name

There are three basic rules for selecting a Proper Shipping Name:

1. Select the name from the Index to the IMDG Code and/or the 3.2 Dangerous Goods List.

2. Be accurate.

3. Be specific.

The Index vs. the 3.2 Dangerous Goods List

While the Proper Shipping Name techni-cally must come from the selection of entries offered in the 3.2 Dangerous Goods List, in actuality, most shippers will need to look up their material in the Index first because the List is sorted by UN number, not alphabetically.

The Index at the end of Volume 2 contains an alphabetical listing of Proper Shipping Names, synonyms, secondary names, initials, abbreviations of names, etc., that can be used to facilitate the search for the Proper Shipping Name in the 3.2 Dangerous Goods List. Once shippers have found a possible name, they can use the UN number listed for the name to look

up the entry in the 3.2 Dangerous Goods List to confirm that it is an accurate name, and then determine the requirements for shipping the material.

Rule #1: Select the Name from the Index and/or the 3.2 List of Dangerous Goods

Uppercase vs. Lowercase Letters

The first rule in selecting Proper Shipping Names is that the shipper must select the name from the Index or the 3.2 Dangerous Goods List. The shipper must select and use names that are in UPPERCASE letters, meaning that they are not written in lowercase letters.

For example, if you were shipping “meth-ylene chloride” and looked up that name in the Index, you would see that it is in lower-case letters, so you could not use that name to describe the shipment. Instead, the Index tells you to “see 1593.” If you then look up UN 1593 on the List, you’ll see “DICHLOROMETH-ANE,” so that is the name you need to use for the shipment.

In some cases, the lowercase name in the Index will tell the shipper to “see” a different name, rather than a UN number. For exam-ple, if you were to look up “Bombs, target identification,” you would see that the words are in lowercase letters, so you could not use that name to describe the shipment. Instead of providing a UN number, though, the entry



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Selecting a Proper Shipping Name, continued

instead says to “see AMMUNITION, ILLU-MINATING.” If you then look up AMMUNI-TION, ILLUMINATING in the Index, you will find three separate entries, each in uppercase letters, each posing different hazards, and each with a different UN number. You would then need to pick the entry that best described your particular material.

NOTE: In addition to the uppercase letters, a Proper Shipping Name can also include num-bers, Greek letters, “sec,” “tert,” and the letters m, n, o, p, which form an integral part of the name, for example:

2-BROMOPENTANE

n-PROPYL ISOCYANATE

tert-BUTYLCYCLOHEXYL CHLOROFORMATE

Alternative Uppercase Names

In some cases, an alternative Proper Ship-ping Name may appear on the List in paren-theses following the main name. For exam-ple, if you were shipping “diethyl ether” and looked up that name in the Index, you would see that it is in uppercase letters, so you could use that name to describe the shipment. If you then look up UN 1155 (the number indicated in the Index for diethyl ether) on the Danger-ous Goods List, you’ll see “DIETHYL ETHER (ETHYL ETHER).” Therefore, either DIETHYL ETHER or ETHYL ETHER could be used for the shipment.

Additional Lowercase Words

In some cases, a Proper Shipping Name consists of words in uppercase letters that are followed by words in lowercase letters. In

these cases, the words in lowercase letters are optional extra words that can be used if the shipper wants to use them, but they are not a required part of the Proper Shipping Name.

For example, if you were shipping adhe-sives and looked the material up in the Index or the Dangerous Goods List, you would find the entry “ADHESIVES containing flamma-ble liquid.” When describing the material on transport documents and package marks, you could use either “ADHESIVES” or “ADHE-SIVES containing flammable liquid” as the Proper Shipping Name.

Rule #2: Be Accurate

The shipper must pick a name that describes what the material actually is. This means that the name that is selected for the material must match (as applicable):

• The description of the material (e.g., pes-ticide, paint, alcohol, acetone, or corro-sive liquid).

• The hazard class.

• The packing group (if applicable).

• The hazard zone (if applicable).

• Any subsidiary hazard(s).

For example, the shipping name “Paint” appears in five separate entries on the 3.2 Dan-gerous Goods List—three entries for Class 3, Packing Groups I, II, and III (UN 1263) and two entries for Class 8, Packing Groups II and III (UN 3066). If a shipper wanted to ship paint that was not flammable or corrosive but was instead toxic (Class 6.1), then the ship-per would not be allowed to call the mate-



Notes:

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rial “paint” when it was shipped and would need to choose a different shipping name from the 3.2 Dangerous Goods List that accurately described the material.

Rule #3: Be Specific [IMDG 2.0.2.2 and 3.1.2.7]

In many cases, there may be more than one “accurate” name for a particular material. The IMDG Code, however, also requires the shipper to choose the most specific name available on the 3.2 Dangerous Goods List. The following represent the types of entries in the List, in the preferred order of use:

1. Single entries for well-defined substanc-es or articles. For example:

– Acetone

– Batteries, Wet, Filled with Acid

– Ethyl Nitrite Solution

2. Generic entries for well-defined groups of substances or articles (that are not N.O.S. entries). For example:

– Adhesives

– Perfumery Product

– Organic Peroxide Type B, Liquid

3. Specific N.O.S. entries covering a group of substances or articles of a particular chemical or technical nature. For example:

– Alcohols, N.O.S.

– Hydrocarbon Gas Mixture, Compressed, N.O.S.

– Nitrates, Inorganic, N.O.S.

4. General N.O.S. entries covering a group of substances or articles meeting the criteria of one or more hazard classes. For example:

– Flammable Liquid, N.O.S.

– Flammable Liquid, Toxic, N.O.S.

– Compressed Gas, Toxic, Flammable, Corrosive, N.O.S.

NOTE: When not specifically listed, hydrates may be transported under the Proper Shipping Name for the anhydrous substance.

Other Factors to Consider

Identification Number

When you pick the shipping name, you’ll also be getting the UN number from the Index or Column 1 of the 3.2 Dangerous Goods List. The UN number provides a cross-reference to specific instructions on what to do in response to spills or fires involving the material. These instructions are all found in the DOT’s “Emer-gency Response Guidebook,” or “ERG book.”

When you’re choosing a name, take a look at what emergency response actions the UN number sends you to in the Emergency Response Guidebook. Are the response actions it describes appropriate for your specific mate-rial? If not, then you might consider finding a better name for your material, which references the correct emergency response measures.



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Packaging Authorization

References to packing instructions per shipping name are given in Columns 8, 10, and 13 of the 3.2 Dangerous Goods List. In some cases, reading the specific packing instruc-tion will shed additional light on what type of material the entry in the List was meant for. Depending on the packing instruction, it may become apparent that the packaging described is not appropriate for your material. This may be an indication that a particular entry isn’t the best one. Conversely, the description found in the packing instruction may confirm your decision to use that Proper Shipping Name.

Special Provisions

Special provision codes are indicated in Column 6 of the 3.2 Dangerous Goods List. The explanation for each code is found in IMDG 3.3, following the List. Because special provisions may affect how a material is clas-sified, described, or packaged, they should be checked as part of the dangerous goods classi-fication/identification process.

The following are a few examples of spe-cial provisions that could impact the classifica-tion and identification process:

• Proper Shipping Name “Methanol” is assigned Special Provision 279.

– Special Provision 279 states: “The substance is assigned to this classifica-tion or packing group based on human experience rather than the strict appli-cation of classification criteria set out in this Code.”

• Proper Shipping Name “Flammable liquid, n.o.s.” is assigned Special Pro-vision 274.

– Special Provision 274 states: “For the purposes of documentation and pack-age marking, the proper shipping name shall be supplemented with the techni-cal name.”

• Proper Shipping Names “Paint” and “Paint Related Material” are assigned Special Provision 367.

– Special Provision 367 states: “For the purposes of documentation and pack-age marking: The proper shipping name “PAINT RELATED MATERIAL” may be used for consignments of pack-ages containing “paint” and “paint re-lated material” in the same package....”

List of the Main Generic and N.O.S. Proper Shipping Names [Appendix A to IMDG 3.2]

To assist in finding the best name for a material, a list of the main generic entries and all of the N.O.S. Proper Shipping Names can be found in Appendix A to IMDG 3.2, sorted by hazard class or division. Within each hazard class or division, the names are placed into three groups as follows:

1. Specific entries covering a group of sub-stances or articles of a particular chemical or technical nature

2. Pesticide entries for Class 3 and Class 6.1

3. General entries covering a group of substances or articles having one or more general dangerous properties




Page 60

Appendix A – List of Generic and N.O.S. Proper Shipping Names, Excerpt

∆ Class or divisions

Subsidiary hazard

UN number

Proper Shipping Name

CLASS 2

Class 2.1

Specific entries

2.1 1964 HYDROCARBON GAS MIXTURE, COMPRESSED, N.O.S.

2.1 1965 HYDROCARBON GAS MIXTURE, LIQUEFIED, N.O.S.

2.1 3354 INSECTICIDE GAS, FLAMMABLE, N.O.S.

General entries

2.1 1954 COMPRESSED GAS, FLAMMABLE, N.O.S.

2.1 3161 LIQUEFIED GAS, FLAMMABLE, N.O.S.

2.1 3167 GAS SAMPLE, NON-PRESSURIZED, FLAMMABLE, N.O.S., not refrigerated liquid

2.1 3312 GAS, REFRIGERATED LIQUID, FLAMMABLE, N.O.S.

2.1 3501 CHEMICAL UNDER PRESSURE, FLAMMABLE, N.O.S.

2.1 3510 ADSORBED GAS, FLAMMABLE, N.O.S.

■ 2.1 See 2.0.6.6 3537 ARTICLES CONTAINING FLAMMABLE GAS, N.O.S.

2.1 6.1 3504 CHEMICAL UNDER PRESSURE, FLAMMABLE, TOXIC, N.O.S.

2.1 8 3505 CHEMICAL UNDER PRESSURE, FLAMMABLE, CORROSIVE, N.O.S.

Class 2.2

Specific entries

2.2 1078 REFRIGERATED GAS, N.O.S.

2.2 1968 INSECTICIDE GAS, N.O.S.

General entries

2.2 1956 COMPRESSED GAS, N.O.S.

2.2 3163 LIQUEFIED GAS, N.O.S.

2.2 3158 GAS, REFRIGERATED LIQUID, N.O.S.

2.2 3500 CHEMICAL UNDER PRESSURE, N.O.S.

2.2 3511 ADSORBED GAS, N.O.S.

■ 2.2 See 2.0.6.6 3538 ARTICLES CONTAINING NON-FLAMMABLE, NON-TOXIC GAS, N.O.S.

2.2 5.1 3156 COMPRESSED GAS, OXIDIZING, N.O.S.

2.2 5.1 3157 LIQUEFIED GAS, OXIDIZING, N.O.S.

2.2 5.1 3311 GAS, REFRIGERATED LIQUID, OXIDIZING, N.O.S.

2.2 5.1 3513 ADSORBED GAS, OXIDIZING, N.O.S.

2.2 6.1 3502 CHEMCIAL UNDER PRESSURE, TOXIC, N.O.S.

2.2 8 3503 CHEMICAL UNDER PRESSURE, CORROSIVE, N.O.S.1 “n.o.s.” stands for “not otherwise specified.”



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NAMING MIXTURES AND SOLUTIONS

Mixtures vs. Solutions

While not specifically defined in the IMDG Code, the terms “mixture” and “solution” appear throughout the regulations. Below are the meanings of the terms as they are defined by the US Department of Transportation at 49 CFR 171.8:

Mixture: a material composed of more than one chemical compound or element

Solution: any homogeneous liquid mixture of two or more chemical compounds or elements that will not undergo any segre-gation under conditions normal to trans-portation.

Mixtures and Solutions Containing One Dangerous Substance [IMDG 2.0.2.5 and 3.1.3]

If the material to be shipped contains a single dangerous substance that is identified by name on the 3.2 Dangerous Goods List, along with one or more substances not subject to the IMDG Code, then:

• It must be identified by the Proper Ship-ping Name of the listed substance.

• The qualifying word “mixture” or “solu-tion” (as appropriate) must be added to the Proper Shipping Name.

– If it’s a homogeneous liquid mixture, use the word “solution.” For all others, use the word “mixture.”

• The concentration of the mixture or solu-tion may also be indicated after the basic description of the mixture or solution.

In order to describe the material in this manner, the mixture or solution MUST match the hazard class and packing group of the Proper Shipping Name of the single danger-ous substance that is identified by name on the 3.2 Dangerous Goods List.

Example: A mixture contains 75% acetone and a solvent not subject to the IMDG Code.

• The solution is determined to be a Haz-ard Class 3, Packing Group II. This is the same as pure acetone.

• Since neither hazard class nor pack-ing group has changed, it could be named either:

– Acetone solution, or

– Acetone 75% solution.

Exceptions to the Rule for Naming Mixtures [IMDG 2.0.2.5, 3.1.2.8, and 3.1.3.2]

You may not use the Proper Shipping Name for the substance with the word “mix-ture” or “solution” added to the name if any of the following are true:

• The mixture or solution is identified by name on the 3.2 Dangerous Goods List.



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Naming Mixtures and Solutions, continued

• The entry on the 3.2 Dangerous Goods List indicates that it applies only to the pure substance.

• The hazard class or division, subsidiary hazards, physical state, or packing group of the mixture or solution differs from that of the substance identified by name on the 3.2 Dangerous Goods List.

• The properties of the mixture or the solu-tion require different emergency response procedures than those required for the substance identified by name on the 3.2 Dangerous Goods List.

In these situations, the mixture or solution must be described by the most appropriate N.O.S. Proper Shipping Name followed by the technical name of the dangerous substance in parentheses.

Example: A mixture containing acetone and a solvent not subject to the IMDG Code is determined to be a Hazard Class 3 and Pack-ing Group III. Since the packing group has changed from that of pure acetone, the mixture would be named:

– Flammable liquid, N.O.S. (Acetone)

Mixtures and Solutions Containing Predominantly One Dangerous Substance and Traces of Other Dangerous Goods

Unless otherwise specified, a mixture or solution consisting predominantly of a sub-stance listed by name on the 3.2 Dangerous Goods List that also contains traces of other dangerous goods identified on the List should be identified by assigning it the UN number and Proper Shipping Name for the predomi-nant substance.

NOTE: The same restrictions that apply to use of the word “mixture” or “solution” with a single dangerous substance mixed with non-dangerous substances would also apply in this situation.

Mixtures and Solutions Containing Two or More Dangerous Substances [IMDG 2.0.2.9, 2.0.2.10, 3.1.2.8, and 3.1.3]

A mixture or solution containing two or more dangerous goods identified by name on the 3.2 Dangerous Goods List must be described using the Proper Shipping Name from the List that most appropriately describes the material (i.e., it must accurately describe the material, and it must be the most specific name available).

• If the name of the mixture or solution is specifically named in the List, then that name must be assigned to the material (e.g., “Hydrofluoric Acid and Sulphuric Acid Mixture” or “Nitroglycerin solution in alcohol”).

• If the mixture or solution is not specifical-ly listed, then the most accurate and spe-cific generic group name, specific N.O.S. name, or generic N.O.S. name must be assigned to the material (e.g., “Adhe-sives,” “Pesticide, liquid, toxic, N.O.S.” or “Flammable liquid, N.O.S.”).



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NAMING MARINE POLLUTANTSIMDG 2.10 and 3.1.2.9

Marine Pollutants Identified in the Dangerous Goods List

Many marine pollutants are identified as “single entries” or “generic entries” on the IMDG 3.2 Dangerous Goods List. These mate-rials would be assigned the Proper Shipping Name that appears for them in the List, for example:

• Allyl alcohol.

• Lead cyanide.

• Cadmium compound (Cadmium sulphide is assigned to this generic entry in the Index).

Marine Pollutants Identified Only in the Index

Certain marine pollutants, however, are only identified in the Index of the IMDG Code, and are not assigned to a generic or N.O.S. Proper Shipping Name, for example:

• Benomyl.

• Cupric sulphate.

• Linuron.

NOTE: These materials are listed by name in lowercase letters in the Index and identi-fied as marine pollutants by a “P” in the “MP Column.” They do not include instructions to “see” a particular UN number or a different Proper Shipping Name.

Note 1 to the Index

Per “Note 1” to the Index, these marine pollutants may possess properties of Classes 1 through 8. If this is the case, the shipper must classify them accordingly and then choose an appropriate Proper Shipping Name that matches the actual hazard class(es) and pack-ing group of the material.

If one of these materials does NOT possess properties of Classes 1 through 8, however, it must be transported as a Hazard Class 9 under one of the following entries (as appropriate):

• ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., UN 3077

• ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., UN 3082

Marine Pollutants Directed to “see UN 3077” or “see UN 3082”

Any marine pollutant specifically listed as a Hazard Class 9 in the Index that is directed to “see UN 3077” or “see UN 3082” will also be shipped under one of the above entries. Examples of materials associated with these UN numbers are:

• Diphenyl.

• 1-Chlorooctane.

• Calcium naphthenate in solution.



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MODIFYING PROPER SHIPPING NAMESIMDG 2.0.4, 3.1, 3.2, 3.3, and 5.4

The Proper Shipping Name is considered to be the UPPERCASE text shown in Column 2 of the IMDG 3.2 Dangerous Goods List, plus any numbers, Greek letters, “sec,” “tert,” and the letters m, n, o, p that form an integral part of the name. For the purpose of entry on trans-port documents, there are some changes that you may make to this text and some changes that you must make.

Optional Changes [IMDG 3.1.2.1 and 3.1.2.3]

The following modifications are allowed to be made to Proper Shipping Names:

• Portions of the entry in lowercase type may be used in addition to the part in UPPERCASE, but they do not need to be considered part of the Proper Ship-ping Name.

• Proper Shipping Names may be used in the singular or the plural.

• The omission of dots, commas, and simi-lar “minor discrepancies” are allowed, as long as they do not compromise safety.

• When qualifying words are used as part of a Proper Shipping Name, their se-quence is optional.

• When shipping Class 1 (explosive) mate-rials, the Proper Shipping Name may be supplemented by additional text indicat-ing commercial or military names.

Required Changes [IMDG 2.0.4, 3.1.2.5, 3.1.2.6, 3.1.2.8, 3.1.2.9, 3.3, and 5.4.1.4.3]

The following modifications must be made to Proper Shipping Names (where appropriate).

Generic or N.O.S. Entries

Generic and N.O.S. Proper Shipping Names that are assigned Special Provision 274 or 318 in Column 6 of the 3.2 Dangerous Goods List must be supplemented with technical or chemical group names:

• In brackets.

• Immediately following the Proper Ship-ping Name.

Example:

Alcohol, N.O.S. (Methyl-n-amyl carbinol)

The shipper must include the constitu-ent(s) that most predominantly contribute to the hazard(s). If there are multiple constitu-ents, not more than two need be included. If a subsidiary hazard label is required, the tech-nical names must include the constituent that requires the use of the subsidiary label(s).

The technical name must be a recognized chemical or biological name. Trade names may not be used. For pesticides, only the ISO common name(s), name(s) listed in the World Health Organization (WHO) Recommended Clas-



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Modifying Proper Shipping Names, continued

sification of Pesticides by Hazard and Guidelines to Classification, or the name(s) of the active sub-stance(s) may be used as technical names.

NOTE: The requirement to include technical names does not apply to controlled substances in circumstances where their disclosure is pro-hibited by law.

Appropriate modifiers such as “contains” or “containing” or other qualifying words such as “mixture” or “solution” and the percentage of the technical constituent may also be used.

Examples:

PESTICIDE, LIQUID, TOXIC, N.O.S. (drazoxolon)

Flammable Liquid, N.O.S. (contains xylene and benzene)

Flammable Liquid, N.O.S. (20% xylene and 35% benzene)

Flammable Liquid, N.O.S. (toluene solution)

Marine Pollutants

If the Proper Shipping Name used to describe a marine pollutant is a generic or N.O.S. name, it must be supplemented with the recognized chemical name of the marine pollutant. The name of the marine pollutant must appear in brackets immediately after the Proper Shipping Name.

Examples:

Paint (contains triethylbenzene)

ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. (diphenyl)

FLAMMABLE LIQUIDS, N.O.S. (contains dipentene and hexane)

Samples

Unless it is already part of the Proper Ship-ping Name, when shipping under the sample exclusion at IMDG 2.0.4, the word “SAMPLE” must be added to the Proper Shipping Name.

Example:

Flammable liquid, N.O.S., Sample

NOTE: If an N.O.S. name is used for the sample, the shipper is not required to supplement the Proper Shipping Name with technical names.

Wastes

The word “WASTE” must be added to the beginning of the Proper Shipping Name when shipping dangerous goods for disposal or for processing for disposal (unless this is already part of the Proper Shipping Name).

Example:

Waste Toluene



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Modifying Proper Shipping Names, continued

Materials Shipped in a Molten State

The word “MOLTEN” must be added to the Proper Shipping Name when shipping dangerous goods that are “solid” as defined at IMDG 1.2.1, but are being shipped in a molten state (unless this is already part of the Proper Shipping Name).

Example:

Alkylphenol, solid, N.O.S., Molten

Materials Stabilized for Transport

The word “STABILIZED” must be added as part of the Proper Shipping Name of a sub-stance that would be forbidden from trans-port, according to IMDG 1.1.3, due to it being liable to dangerously react under conditions normally encountered in transportation.

NOTE: This is not required when shipping self-reactive substances or organic peroxides or if this is already included as part of the name.

Example:

Toxic liquid, organic, N.O.S., Stabilized

Infectious Substances

Infectious substances in Class 6.2 with a generic shipping name must be supplemented by the biological name of the organism on shipping documents but not on package marks (per Special Provision 318).

Example:

Infectious substance, affecting humans (Monkeypox virus)



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SEGREGATION GROUPSIMDG 3.1.4 and 7.2

Dangerous goods having certain similar chemical properties are grouped together in segregation groups identified at IMDG 3.1.4.4.

Segregation requirements are specified in Column 16b of the 3.2 Dangerous Goods List. These requirements apply to all goods assigned to the respective segregation group.

Eighteen Segregation Groups

There are 18 segregation groups identified by name and group code in the IMDG Code. These groups include:

• Acids (SGG1 or SGG1a).

• Alkalis (SGG18).

• Ammonium compounds (SGG2).

• Cyanides (SGG6).

• Heavy metals and their salts (including their organometallic compounds) (SGG7).

• Powdered metals (SGG15).

Each group lists the Proper Shipping Names of various articles and substances that would be included in that particular segrega-tion group. For example, the “acids” segrega-tion group identifies over 200 Proper Shipping Names belonging to that group, including:

• Acetyl bromide.

• Benzyl chloride.

• Corrosive liquid, acidic, inorganic, n.o.s.

• Hydrochloric acid.

• Sulphuric acid, spent.

Segregation Requirements

The specific segregation requirements are explained at IMDG 7.2. Materials in incompat-ible segregation groups must be shipped:

• “Away from” each other.

• “Separated from” each other.

• “Separated by a complete compartment or hold from” each other.

• “Separated longitudinally by an interven-ing complete compartment or hold from” each other.

Determining Segregation Groups for N.O.S. Entries

Some substances that would fall within a segregation group are not listed by name in the IMDG Code but are instead shipped under N.O.S. entries (e.g., Corrosive liquids, N.O.S.). Although these N.O.S. names are not listed in any segregation group, when shipping any of these substances, the shipper must:



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Segregation Groups, continued

• Determine if inclusion in a segregation group is necessary.

• Note the segregation group on the trans-port document if an assignment to a group has been made.

Mixtures and solutions that are shipped under N.O.S. entries and that contain sub-stances listed in segregation groups are con-sidered to fall within the segregation groups of the listed constituents.

Example:

A shipper is shipping a substance under the Proper Shipping Name “Corrosive liquid, N.O.S.” that contains benzoyl chloride. Since benzoyl chloride is listed in Segregation Group 1, Acids, the ship-per would assign the material to Segrega-tion Group 1 and indicate the following on the transport document:

IMDG Code Segregation Group 1: Acids.



Step 3—Packing

© Lion Technology Inc.20-0407


CONTENTS

Step 3—Packing ....................................................................................................................69

Packaging Definitions ..........................................................................................................71

IMDG vs. DOT Packaging Requirements .........................................................................76

Using the 3.2 Dangerous Goods List .................................................................................77

Basic Packaging Concerns ..................................................................................................78

General Provisions for Packagings, IBCs, and Large Packagings .................................79

Authorized IMDG Packaging ............................................................................................83

Packing Instructions for Packagings, IBCs, and Large Packagings ..............................85

UN Specification Marks for Packagings ...........................................................................89

Packaging Identification Codes for Non-bulk UN Specification Packagings .............92

Marking of Non-bulk Packages .........................................................................................95

UN Specification Marks for Large Packagings ................................................................96

Marking of Intermediate Bulk Containers .......................................................................97

UN Specification Marks for IBCs .......................................................................................98

Additional IBC Markings ..................................................................................................101

Special Provisions ..............................................................................................................103

Limited Quantity Packaging ............................................................................................104

Excepted Quantity Packaging ..........................................................................................106

Portable Tanks, Multi-Element Gas Containers (MEGCs), and Bulk Containers .....109

Special Packaging Issues ...................................................................................................114

Step 3—Packing


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STEP 3—PACKINGWhat Can We Ship It In?



IMDG 1.2 Definitions

IMDG 4.1 Use of packagings, including intermediate bulk containers (IBCs) and large packagings

IMDG 4.2 Use of portable tanks and multiple-element gas containers (MEGCs)

IMDG 4.3 Use of bulk containers

IMDG Part 6

Construction and testing of packagings, intermediate bulk containers (IBCs), large pack-agings, portable tanks, MEGCs, and road tank vehicles

IMDG 3.2 Dangerous Goods List

IMDG 3.3 Special provisions

IMDG 3.4 Limited quantities

IMDG 3.5 Excepted quantities

49 CFR 171.25(c)

Requirement for most bulk packagings to meet DOT requirements at 49 CFR 171–180 when shipped

49 CFR 173.24

DOT general requirements for packagings and packages

49 CFR 173.24a

Additional general require-ments for non-bulk packagings and packages


49 CFR 173.24b

Additional general require-ments for bulk packagings

49 CFR 173.28

Reuse, reconditioning, and remanufacture of packagings


The third step in the dangerous goods shipping process is to package the dangerous good for shipment. As part of this step, the shipper must determine:

• The type of packaging that is allowed to be used.

• The standards or specifications the pack-aging has to meet.

• The rules for filling and closing the pack-aging.

• The rules for placing different kinds of dangerous goods into the same pack-aging.

• Any special rules that apply to the pack-aging.

It is the responsibility of the shipper to ensure that the dangerous goods are properly packaged. The ultimate goal when packaging a dangerous good is to make certain that the dangerous good stays inside the packaging under conditions normally incident to vessel transportation.



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Step 3—Packing, continued


To ensure that the packaging for the arti-cle/substance is correctly selected and used, you must know things such as:

• The dangerous good’s hazard class(es), severity (packing group), and Proper Shipping Name.

• Compatibility issues for the article/substance (e.g., will it corrode steel or aluminium; will it permeate, soften, or weaken certain types of plastic, etc.).

• The physical properties of the article/sub-stance (e.g., density and vapour pressure).

• The type and size of packaging you would like to use.

Step 3—Packing


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PACKAGING DEFINITIONSIMDG 1.2 and 4.1.0

General Definitions

Packaging: One or more receptacles and any other components or materials necessary for the receptacles to perform their con-tainment and other safety functions.

Package: The complete product of the pack-ing operation, consisting of the packaging and its contents prepared for transport.

Types of Packagings

Combination packaging: A combination of packagings for transport purposes, consist-ing of one or more inner packagings secured in an outer packaging in accor-dance with IMDG 4.1.1.5.

NOTE: Single packaging is not defined in the IMDG rules, but would have the same general meaning as the term would have under the DOT regulations (i.e., a non-bulk packaging other than a combination).

Composite packaging: Packaging consist-ing of an outer packaging and an inner receptacle so constructed that the inner receptacle and the outer packaging form an integral packaging. Once assembled, it remains thereafter an integrated single unit; it is filled, stored, transported, and emptied as such.



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Packaging Definitions, continued

Specific Devices

Bags: Flexible packagings made out of paper, plastic film, textiles, woven material, or other suitable materials.

Boxes: Packagings with complete rectangular or polygonal faces, made of metal, wood, plywood, reconstituted wood, fibreboard, plastics, or other suitable material. Small holes for purposes such as ease of han-dling or opening of the box or to meet clas-sification provisions are permitted as long as they do not compromise the integrity of the packaging during transport.

Crates: Outer packagings with incomplete surfaces.

Cylinders: Transportable pressure recepta-cles of a water capacity not exceeding 150 litres.

Drums: Flat-ended or convex-ended cylindri-cal packaging made of metal, fibreboard, plastics, plywood, or other suitable mate-rials. Also includes packagings of other shapes, such as round taper-necked pack-agings or pail-shaped packagings. Wooden barrels and jerricans are not covered by this definition.

Intermediate bulk container (IBC): A rigid or flexible portable packaging, other than a cylinder or portable tank, that is designed for mechanical handling. IBCs typically have a capacity of no more than 3 m3 (3,000 L).

Jerricans: Metal or plastic packagings of rectangular or polygonal cross-section.

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Large packagings: Packagings consisting of an outer packaging that contain articles or inner packagings and:

– Are designed for mechanical handling; and

– Exceed 400 kg net mass or 450 L capac-ity but have a volume of not more than 3 m3 (3,000 L).

NOTE: Although large packaging has a capac-ity that exceeds 400 kg or 450 L, it is not con-sidered bulk packaging because bulk packag-ing is packaging that has no intermediate form of containment.

Tank: A portable tank (including a tank-container), a road tank-vehicle, a rail tank-wagon, or a receptacle to contain solids, liquids, or liquefied gases that has a capacity of not less than 450 litres when used for the transport of gases as defined in IMDG 2.2.1.1.

Additional Containment Systems

Bulk containers: Containment systems (including any liner or coating) intended for the transport of solid substances that are in direct contact with the containment system. Packagings, intermediate bulk containers (IBCs), large packagings, and portable tanks are NOT included.

Bulk containers:

– Are of a permanent character and ac-cordingly strong enough to be suitable for repeated use.

– Are specially designed to facilitate the transport of goods by one or more means of transport without intermedi-ate reloading.

– Are fitted with devices permitting ready handling.

– Have a capacity of not less than 1 cubic metre.

Examples of bulk containers are freight containers, offshore bulk containers, skips, bulk bins, swap bodies, trough-shaped containers, roller containers, and load compartments of vehicles.



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Cargo transport units (CTUs): A road trans-port tank or freight vehicle, railway trans-port tank or freight wagon, multimodal freight container or portable tank, or MEGC (multi-element gas container).

Freight container: An article of transport equipment that is of a permanent character and accordingly strong enough to be suit-able for repeated use. Designed to:

– Facilitate the transport of goods, by one or more modes of transport, without intermediate reloading; and

– Be secured and/or readily handled, having fittings for these purposes, and approved according to the International Convention for Safe Containers.

Large freight container: A freight container that has an internal volume of more than 3 m3.

Offshore bulk container: A bulk container specially designed for repeated use for the transport of dangerous goods to, from, and between offshore facilities.

Overpack: An enclosure used by a single consignor (i.e., shipper) to contain one or more packages and to form one unit for the convenience of handling and stowage during transport. Examples of overpacks are a number of packages either:

– Placed or stacked on to a load board, such as a pallet, and secured by strap-ping, shrink-wrapping, stretch-wrap-ping, or other suitable means; or

– Placed in a protective outer packaging such as a box or crate.

Salvage packaging: Special packagings into which damaged, defective, leaking, or non-conforming dangerous goods pack-ages or dangerous goods that have spilled or leaked, are placed for purposes of transport for recovery or disposal.

Small freight container: A freight container that has an internal volume of not more than 3 m3.

Step 3—Packing


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Unit load: A number of packages that are either:

1. Placed or stacked on and secured by strapping, shrink-wrapping, or other suitable means to a load board, such as a pallet;

2. Placed in a protective outer enclosure, such as a pallet box; or

3. Permanently secured together in a sling.

Other TermsEffectively closed: A liquid-tight closure.

Hermetically sealed: A vapour-tight closure.

Inner packaging: Packaging for which an outer packaging is required for transport.

Inner receptacles: Receptacles that require an outer packaging in order to perform their containment function.

Intermediate packaging: Packagings placed between inner packagings, or articles, and an outer packaging.

Maximum capacity: As used in IMDG 6.1.4, means the maximum inner volume of receptacles or packagings expressed in litres.

Maximum net mass: As used in IMDG 6.1.4, means the maximum net mass of contents in a single packaging or maximum com-bined mass of inner packagings and the contents thereof and is expressed in kilo-grams.

Outer packaging: The outer protection of a composite or combination packaging together with any absorbent materials, cushioning, and any other components necessary to contain and protect inner receptacles or inner packagings.

Receptacles: Containment vessels for receiv-ing and holding substances or articles, including any means of closing.

Securely closed: So closed that dry contents cannot escape during normal handling; the minimum provisions for any closure.

Sift-proof packagings: Packagings imperme-able to dry contents, including fine solid material produced during transport.



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IMDG VS. DOT PACKAGING REQUIREMENTS

Shippers may follow the IMDG Code in lieu of the DOT’s hazardous materials rules at 49 CFR 171–180 for the following types of packagings:

• Non-bulk packages

• IBCs

• Large packagings

• UN portable tanks containing liquids or solids

NOTE: Per 49 CFR 171.25(c), portable tanks are subject to DOT Special Provisions TP37, TP38, TP44, and TP45 and must meet additional DOT requirements even when otherwise shipped under the requirements of the IMDG Code.

Bulk Packages Other Than IBCs and Portable Tanks [49 CFR 171.25(c)]

Bulk packagings other than IBCs and UN portable tanks containing liquids and solids must conform to DOT requirements. In addi-tion, a bulk package being shipped by vessel that is subject to the international standards must also meet all applicable requirements under the IMDG Code.

Additional DOT Packaging Regulations [49 CFR 171.22(g), 171.23(a) and (b), and 171.25(b) and (c)]

Although the DOT does generally allow the use of the IMDG Code when shipping by vessel, there are still many DOT packaging requirements that must be met when shipping within, into, or out of the United States (i.e., the DOT “extras” that always apply as part of the conditions for using the IMDG Code).

These extra requirements include:

• General requirements for packagings and packages.

• Requirements for reuse, reconditioning, and remanufacture of packagings.

• Additional packaging requirements for specific materials, such as:

– Cylinders.

– Aerosols.

– Chemical oxygen generators.

– Poison inhalation hazards.

– Radioactives.

Step 3—Packing


Page 77

USING THE 3.2 DANGEROUS GOODS LISTMaking Packaging Decisions

(5) PACKING GROUP

Based on “degree of hazard.” Determines the stringency of required packaging tests.

(6) SPECIAL PROVISIONS

Additional requirements, clarifications, or reliefs specific to the named dangerous good.

(7a) LIMITED QUANTITIES

Indicates the inner packaging quantity limit for the inner packaging or article.

(7b) EXCEPTED QUANTITIES

An alpha-numeric code indicates maxi-mum inner quantity and total quantity per package.

(8, 10, 12, and 13) PACKING INSTRUCTIONSRefer to the appropriate packing instruction that indicates the type of packaging used for a shipment of dangerous goods. De-tails of the packing instructions appear at IMDG 4.1–4.3.

• Column 8 references instructions for packagings (including large packagings) at IMDG 4.1.4.

• Column 10 references relevant IBC in-structions in IMDG 4.1.4.

• Column 12 used to reference instructions for IMO portable tanks. This column is now reserved.

• Column 13 references instructions for UN tanks and bulk containers at IMDG 4.2.5 and 4.3.

(9, 11, and 14) PACKING PROVISIONSIndicate special packing provisions for that dangerous good.

• Column 9 indicates packing provisions for packagings (including large packag-ings). Packaging Provisions (PP)—see IMDG 4.1.4.1. Large Packaging Provisions (LP)—see IMDG 4.1.4.3.

• Column 11 indicates packing provisions for IBCs (B)—see IMDG 4.1.4.2.

• Column 14 indicates special provisions for portable tanks and road tank vehicles (TP) and bulk containers (BK)—see IMDG 4.2.5, 4.2.6, and 4.3.



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BASIC PACKAGING CONCERNS

When selecting and preparing packages of dangerous goods for shipment by vessel, the shipper must make certain that:

1. The packaging meets all of the applicable general provisions for the packaging.

2. Only authorized packagings are used.

3. All applicable special provisions are met.

General Provisions [IMDG 4.1–4.3]

In almost all cases, the shipper of dan-gerous goods must ensure that the packaging and completed package comply with the gen-eral provisions that apply to all packages of dangerous goods. These rules usually apply regardless of any other requirements of pack-aging regulations.

For the most part, the general provisions are concerned with making certain that dan-gerous goods stay inside their packagings during the cycle of transportation.

Authorized Packaging [Columns 7–14 of the 3.2 Dangerous Goods List]

All packaging used to ship dangerous goods must be authorized for that material.

Each packaging must be constructed, tested, selected, and prepared in accordance with a packing instruction (PI) listed for the material on the 3.2 Dangerous Goods List, as well as all applicable packing provisions iden-tified for a particular material.

NOTE: The packing instructions themselves are in IMDG Part 4.

Special Provisions [Column 6 of the 3.2 Dangerous Goods List]

Special provision codes are listed in Column 6 of the 3.2 Dangerous Goods List. The relevant entry for each code is found in IMDG 3.3, following the List.

Special provisions are used to take into account a dangerous good’s unique hazards or properties. Special provisions often provide helpful information, additional requirements, and variations and sometimes even relief from more stringent rules.

Step 3—Packing


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GENERAL PROVISIONS FOR PACKAGINGS, IBCS, AND LARGE PACKAGINGSIMDG 4.1.1, 4.1.2, and 4.1.3

The general provisions for the packing of dangerous goods in packagings, includ-ing IBCs and large packagings, can be found at IMDG 4.1.1–4.1.3. These provisions are for applicable packing instructions at IMDG 4.1.4 and Class 2, 6.2, and 7 dangerous goods, as indicated.

New, reused, and reconditioned packag-ings; IBCs; and large packagings must meet all applicable provisions.

General Provisions for the Packing of Dangerous Goods in Packagings, Including IBCs and Large Packagings [IMDG 4.1.1]

Packaging Quality [IMDG 4.1.1.1]

Dangerous goods must be packed in good quality packagings that are strong enough to withstand the shocks and loadings normally encountered during transport, including trans-shipment between cargo transport units and between cargo transport units and ware-houses, as well as any removal from a pallet or overpack for subsequent manual or mechani-cal handling.

Closing Packagings [IMDG 4.1.1.1]

Packagings must be constructed and closed so as to prevent any loss of their con-tents that might be caused under normal con-ditions of transport, including vibrations or changes in temperature, humidity, or pressure. Packagings must be closed in accordance with the manufacturer’s written instructions, and no dangerous goods residue may be left on the outside of the package.

Compatibility Requirements [IMDG 4.1.1.2]

All packagings must be compatible with the dangerous goods that they contain. Parts of packagings that will be in direct contact with dangerous goods must not:

• Be affected or significantly weakened by the dangerous goods.

• Cause a dangerous effect (e.g., reacting with the dangerous goods).

• Allow permeation of the dangerous goods that could constitute a danger un-der normal conditions of transport.

Shippers must also ensure that any absor-bent materials and the materials of intermedi-ate packagings are compatible with the dan-gerous goods with which they are packaged.



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General Provisions for Packagings, IBCs, and Large Packagings , continued

Packaging Design and Testing [IMDG 4.1.1.3 and 4.1.1.9]

Unless excepted, each packaging (except inner packagings) must conform to a design type that has been successfully tested in accor-dance with the applicable requirements of IMDG 6.1.5, 6.3.5, 6.5.6, or 6.6.5.

Ullage [IMDG 4.1.1.4]

The filled package must have enough room for liquids to expand (ullage), so that leaking or distortion of the package does not occur during transit. Liquids must not com-pletely fill a packaging at a temperature of 55°C (131°F).

Combination Packagings [IMDG 4.1.1.5]

Inner packagings must be packed in an outer packaging in such a way that under normal conditions of transport, they cannot break, be punctured, or leak their contents into the outer packaging. Inner packagings con-taining liquids must be packed with their clo-sures upward.

Inner packagings that are liable to break or be punctured easily must be secured in their outer packagings with suitable cushioning material. Cushioning and absorbent material must be inert and suited to the nature of the contents. Supplemental intermediate packag-ing is authorized, provided it does not impair performance.

Friction created by the outer packaging must not generate enough heat to chemically alter the stability of the package contents.

Different Dangerous Goods in the Same Outer Packaging [IMDG 4.1.1.6]

Shippers must not pack dangerous goods together in the same outer packagings or large packagings that would react with each other and cause:

• Combustion and/or evolution of consid-erable heat.

• Evolution of flammable, toxic, or asphyx-iant gases.

• The formation of corrosive substances.

• The formation of unstable substances.

Closures [IMDG 4.1.1.7]

The closures of packagings containing wetted or diluted substances must be closed so that the percentage of liquid does not fall below prescribed limits during transport.

Unless specified otherwise in the IMDG Code, packages containing the following sub-stances must be hermetically sealed:

• Substances that evolve flammable gases or vapour.

• Substances that may become explosive if allowed to dry.

• Substances that evolve toxic gases or vapour.

• Substances that evolve corrosive gases or vapour.

• Substances that may react dangerously with the environment.

Step 3—Packing


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Venting [IMDG 4.1.1.8]

If pressure may develop in a package by the emission of gas from the contents, the packaging or IBC may be fitted with a vent, provided that the gas emitted will not cause a dangerous condition on account of its toxicity, its flammability, the quantity released, etc.

Inspection Requirements [IMDG 4.1.1.9]

Before being filled and handed over for transport, every packaging must be inspected to ensure that it is free from corrosion, contam-ination, or other damage. Every IBC must be inspected to ensure that all service equipment is functioning properly. If a packaging is dam-aged and/or shows signs of reduced strength as compared with its approved design type, it cannot be used or must be reconditioned to meet its designed strength and durability.

Internal Pressures [IMDG 4.1.1.10]

Liquids can only be filled into packagings that have an appropriate resistance to the inter-nal pressure that may develop under normal conditions of transport. IBCs shall not be used to carry liquids having a vapour pressure of more than 110 kPa (1.1 bar) at 50°C or 130 kPa (1.3 bar) at 55°C.

“Empty” Packagings [IMDG 4.1.1.11]

An empty packaging that contained dan-gerous goods must be handled in the same manner as a packaging filled with those dan-gerous goods, unless adequate measures have been taken to nullify any hazard.

Leakproof Testing [IMDG 4.1.1.12]

Packagings intended to contain liquids must have successfully undergone a leakproof-ness test and be capable of meeting the appro-priate test level indicated at IMDG 6.1.5.4.4. Packagings must be tested:

• Before they are first used.

• After remanufacturing or reconditioning.

Change in Phase [IMDG 4.1.1.13]

If a solid material may become liquid during transport, the packaging must be able to contain that substance in a liquid phase.

Sift-proof Packagings [IMDG 4.1.1.14]

Packagings used for powdery or granular substances must be sift-proof or must be used with a liner.

Packaging Expiration Dates [IMDG 4.1.1.15]

The period of use permitted for the trans-port of dangerous goods in plastic drums and jerricans, rigid plastic IBCs, and composite IBCs with plastic inner receptacles is five years from the date of manufacture (unless other-wise approved by the competent authority).

Ice as a Coolant [IMDG 4.1.1.16]

When ice is used as a coolant it cannot affect the integrity of the packaging.



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Explosives, Self-reactive Substances, and Organic Peroxides [IMDG 4.1.1.17]

Packagings, IBCs, and large packagings must comply with at least the standards for Packing Group II when used for the transport of the following:

• Class 1.

• Class 4.1, self-reactive substances.

• Class 5.2, organic peroxides.

Additional General Provisions for the Use of IBCs [IMDG 4.1.2]

The following are additional general pro-visions that must be met when transporting a dangerous good in IBCs:

• Measures to prevent electrostatic dis-charge.

• Requirements for inspection and testing.

• Requirements for filling an IBC after the expiration date of required inspection and testing.

• Filling limits for IBCs of Type 31HZ2.

• Requirements for routine maintenance marks.

General Provisions Concerning Packing Instructions [IMDG 4.1.3]

General provisions concerning packing instructions provide information explaining the use of packing instructions and additional requirements that must be met when shipping in packagings, IBCs, and large packagings.

The general provisions concerning pack-ing instructions include:

• Packaging restrictions for substances that are liable to become liquid in transport.

• Requirements for the use of packagings, IBCs, or large packagings for the trans-port of a dangerous good it is not specifi-cally authorized for.

• Requirements for pressure receptacles for liquids and solids.

• Requirements for unpacked articles other than Class 1.

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AUTHORIZED IMDG PACKAGING What Can I Use?

Packaging requirements for specific dan-gerous goods are referenced for each entry on the IMDG 3.2 Dangerous Goods List. You must select a packaging option that is authorized for your specific material, as referenced from this List.

There are three basic steps for determining authorized packaging:

1. Decide which type of packaging you want to use.

2. Look up the quantity limits or packing instructions for the packaging you want to use in the 3.2 Dangerous Goods List.

3. Go to the applicable packaging reference to determine authorized packaging.

Step 1: Decide on the Type of Packaging You Want to Use

The first step to picking an authorized packaging is to decide which type of packag-ing you want to use (boxes, drums, IBCs, por-table tanks, etc.). In general, if you choose to use smaller packagings, the packaging rules become less strict and the shipping rules become less restrictive.

There are five different packaging options for most dangerous goods:

1. Limited quantities

2. Excepted quantities

3. Packagings other than IBCs (boxes, jerri-cans, drums, large packagings, etc.)

4. Intermediate bulk containers

5. Portable tanks, multiple-element gas con-tainers (MEGCs), and bulk containers

Step 2: Look Up the Quantity Limits or Packing Instructions for the Packaging You Want to Use in the 3.2 Dangerous Goods List

Once you have decided on the type of packaging you want to use for the shipment, the next step is to look up the material’s Proper Shipping Name and UN number on the 3.2 Dangerous Goods List and then go to the appropriate packaging column to find either quantity limits or packing instruction codes.

Quantity limits are identified in:

• Column 7a for limited quantity packages.

• Column 7b for excepted quantity packages.



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Authorized IMDG Packaging, continued

Packing instruction (PI) codes for the other types of packaging can be found in separate columns of the List:

• Column 8 for packagings other than IBCs.

• Column 10 for IBCs.

• Column 13 for portable tanks, MEGCs, and bulk containers.

Packing Instruction Codes

Packing instruction codes are alpha-numeric codes.

• Codes for packagings OTHER than large packagings, IBCs, portable tanks, or bulk containers, begin with a “P.”

• Codes for large packagings begin with the letters “LP.”

• Codes for IBCs begin with the letters “IBC.”

• Codes for portable tanks begin with a “T.”

• Codes for bulk containers begin with the letters “BK.”

Packing Instruction Example Shipping Turpentine, UN 1299

A shipper wants to ship UN 1299, TUR-PENTINE:

• If he decides to ship the turpentine in drums, he would look in Column 8 and see that he needs to follow Packing In-struction “P001.”

• If he decides to ship the turpentine in large packagings, he would also look in Column 8 and see that he needs to follow Packing Instruction “LP01.”

• If he decides to ship the turpentine in IBCs, he would look in Column 10 and see that he needs to follow Packing In-struction “IBC03.”

• If he decides to ship the turpentine in por-table tanks, he would look in Column 13 and see that he needs to follow Packing Instruction “T2.”

Step 3: Go to the Applicable Chapter or Packing Instruction to Determine Authorized Packaging

Once you have determined the applicable quantity limits or packing instruction, the final step is to look up the rules for packaging the dangerous good.

The rules for packaging dangerous goods as limited and excepted quantities are found at IMDG 3.4 and 3.5, respectively.

For all other packaging options, you must look up the appropriate packing instruction in IMDG Part 4 to determine:

• Which types of packaging are authorized.

• What requirements must be met to ship the dangerous goods using that kind of packaging.

Step 3—Packing


Notes:

Page 85

PACKING INSTRUCTIONS FOR PACKAGINGS, IBCS, AND LARGE PACKAGINGS

IMDG 4.1.4

Packing instructions for dangerous goods shipped in packagings, IBCs, and large pack-agings are found at IMDG 4.1.4:

• IMDG 4.1.4.1: Instructions for packagings other than IBCs and large packagings (the codes that begin with “P”).

• IMDG 4.1.4.2: Instructions for IBCs (the codes that begin with “IBC”).

• IMDG 4.1.4.3: Instructions for large pack-agings (the codes that begin with “LP”).

Content of Packing Instructions

Each packing instruction for a dangerous good identifies:

• The various types of packagings that can be used to ship the material (fibreboard boxes, steel drums, plastic jerricans, etc.).

• The maximum capacity/net mass for each type of packaging.

• Any “extra” provisions that must be met in order to ship the material.

NOTE: Packing instructions do not typically provide guidance on compatibility.

Determining Type of Packaging and Quantity Limits Example: Diethyl Ether, UN 1155

A shipper wants to ship diethyl ether, UN 1155. Per Column 8 of the Dangerous Goods List, the packing instruction code would be “P001.”

If we look up Packing Instruction P001 at IMDG 4.1.4, we’ll see a table that identi-fies authorized combination packagings and authorized single packagings.

Authorized Combination Packaging for Diethyl Ether

The options for combination packag-ings are identified at the beginning of Pack-ing Instruction P001. The packing instruction identifies:

• Acceptable inner packagings (including size limits).

• Acceptable outer packagings.

• The maximum capacity/net mass for the package (based on the packing group of the material).

NOTE: Each of the options for outer packag-ings is followed by an alpha-numeric code (e.g., fibreboard box, 4G). These codes indicate that the shipper must use “UN specification packagings” as the outer packagings for the shipment.



Notes:

Page 86

Packing Instructions for Packagings, IBCs, and Large Packagings, continued

If the shipper wanted to use glass bottles inside a fibreboard box.

• The glass bottles would be limited to 10 L in size.

• The fibreboard box would need to be a “4G” box.

• The completed package could have a maximum net mass of 75 kg (because di-ethyl ether is a Packing Group I material).

Authorized Single Packaging for Diethyl Ether

The options for single packagings are identified after the options for combination packaging in Packing Instruction P001. In this case, the packing instruction identifies:

• Acceptable single packagings.

• The maximum capacity/net mass for the package (based on the packing group of the material)

NOTE: Except for pressure receptacles, which are subject to other, specific requirements, each of the options for single packagings is followed by a alpha-numeric code (e.g., steel, non-removable head drum 1A1), indicating that the shipper must use “UN specification packagings” for the shipment.

If the shipper wanted to use a steel drum with a non-removable head:

• The drum would need to be a “1A1” steel drum.

• The drum would be limited to 250 L in size (because diethyl ether is a Packing Group I material).

“Extra” Provisions

In addition to the authorizations for pack-agings and capacity limits, packing instruc-tions frequently indicate the requirement to comply with various “extra” provisions:

• General provisions.

• Special (hazard class) packing provisions.

• Additional provisions.

• Special packing provisions.

General Provisions

Applicable general provisions are indi-cated at the very beginning of a packing instruction, but are described elsewhere in the IMDG Code. These provisions apply to EVERY material shipped under a particular packing instruction. The most common general pack-ing provisions are:

• IMDG 4.1.1: General provisions for pack-agings, IBCs, and large packagings.

• IMDG 4.1.2: Additional general provi-sions for IBCs.

• IMDG 4.1.3: General provisions concern-ing how to use packing instructions.

Special (Hazard Class) Packing Provisions

Applicable special (hazard class) packing provisions are indicated at the very beginning of a packing instruction, but are described elsewhere in the IMDG Code These provisions identify additional requirements or criteria that must be met when packaging materials of

Step 3—Packing


Notes:

Page 87


a particular hazard class. Special (hazard class) packing provisions include the following:

• IMDG 4.1.5—Special packing provisions for dangerous goods of Class 1.

• IMDG 4.1.6—Special packing provisions for dangerous goods of Class 2.

• IMDG 4.1.7—Special packing provisions for organic peroxides (Class 5.2) and self-reactive substances of Class 4.1.

• IMDG 4.1.8—Special packing provisions for infectious substances (Class 6.2).

• IMDG 4.1.9—Special packing provisions for Class 7

Additional Provisions

Applicable additional provisions are iden-tified towards the end of a packing instruction. These provisions technically apply to every material shipped under a particular packing instruction, but they might not be applicable to a particular shipment based on how the material was actually packaged. For example, an additional provision might only apply if the material was packaged in something other than drums.

Special Packing Provisions

Applicable special packing provisions are identified at the very end of a packing instruc-tion. These provisions ONLY apply to a mate-rial if they are identified for the material in the Dangerous Goods List by a special packing provision code in Columns 9 or 11 of the Dan-gerous Goods List (“Provisions”):

• Codes beginning with the letters “PP” are for packagings other than IBCs and large packagings.

• Codes beginning with the letters “L” are for large packagings.

• Codes with the letter “B” are for IBCs.

NOTE: Despite the fact that they are both called “special packing provisions” in the IMDG Code, the “special packing provisions” identified by codes in Columns 9 and 11 and described at the end of packing instructions are NOT the same as the “special packing pro-visions” (i.e., special (hazard class) packing provisions) that apply to particular hazard classes and are referenced at the beginning of packing instructions.

Identifying Authorized Packaging and Packing Provisions Example: Flash Powder, UN 0305

A shipper wants to ship Flash Powder, UN 0305, using fibreboard receptacles placed inside fibreboard boxes. Per Column 8 of the Dangerous Goods List, the packing instruction code would be P113. Per Column 9 of the Dan-gerous Goods List, the special packing provi-sion “PP49” would apply.

General Provisions and Special (Hazard Class) Packing Provisions

The packing instruction requires the ship-per to meet the requirements of IMDG 4.1.1, 4.1.3, and 4.1.5. These are the general provi-sions for the packing of packagings like fibre-board boxes (IMDG 4.1.1), the general provi-sions for using packing instructions (IMDG



Notes:

Page 88


4.1.3), and the special (hazard class) packing provisions that apply to shipments of Class 1 explosives (IMDG 4.1.5).

Authorized Packaging

According to Packing Instruction “P113,” the following inner packagings are authorized:

• Bags made of paper, plastics, or rubber-ized textile.

• Receptacles made of fibreboard, metal, plastics, or wood.

In addition, boxes and drums made of fibreboard (as well as several other materi-als such as steel, aluminium, or plywood) are authorized.

Therefore, a “4G” fibreboard box with fibreboard receptacles would be an authorized packaging.

Additional Provisions

Below the various types of acceptable inner and outer packagings, the packing instruction lists one additional provision: the packagings used for the shipment must be sift-proof pack-agings.

Special Packing Provisions

The special packing provisions are listed at the very end of Packing Instruction P113. Per Column 9 of the Dangerous Goods List, Spe-cial Packing Provision “PP49” applies to the shipment. This provision states that “for UN Nos. 0094 and 0305, no more than 50 g of sub-stance shall be packed in an inner packaging.”

This means that even though there were no quantity limitations identified in the autho-rized packaging section of the packing instruc-tion, the amount of flash powder would be limited to a maximum of 50 g in each inner packaging.

NOTE: Two other special packing provi-sions are also listed under Packing Instruc-tion “P113,” but they would not apply to the shipment of flash powder because the codes weren’t identified in Column 9 of the Danger-ous Goods List for the material.

Step 3—Packing


Page 89

UN SPECIFICATION MARKS FOR PACKAGINGSIMDG 6.1.3

Specification Packaging Markings

All UN specification packaging must be manufactured to general standards and then performance-tested for the kinds of articles or substances they are intended to contain. The packaging is then marked to indicate the stan-dard to which it was manufactured and tested.

The requirements for marking UN spec-ification packagings can be found in IMDG Chapter 6.1. The marking is intended to be of assistance to packaging manufacturers, recon-ditioners, packaging users, carriers, and regu-latory authorities.

4G/Y25/S/20/USA/VL8241A1/Y1.4/150/19/USA/VL824/1.0mm/208

Format of Packaging UN Specification Marks

The UN specification mark on packagings must include the following elements in the fol-lowing order:

1. The letters “UN” shown inside of a circle that serves as the certification that the packaging was built and tested to meet specific, international standards for ship-ping specific materials.

2. An alpha-numeric packaging identifica-tion code that indicates:

• The type of packaging (e.g., “1” for drum, “4” for box).

• The material of construction (e.g., “A” for steel, “G” for fibreboard).

• The category of packaging, when ap-propriate (e.g., “1A1” for closed head steel drum vs. “1A2” for open head steel drum).

3. A letter designating the packing group(s) for which the packaging was built and tested:

• “X” for Packing Groups I, II, and III.

• “Y” for Packing Groups II and III.

• “Z” for Packing Group III only.

4. A number that indicates either the mass or the specific gravity the packaging de-sign type has been built and tested for.

• For packagings intended to contain sol-ids or inner packagings, the maximum gross mass (in kg) the packaging has been tested for must be shown.

• For packagings intended to contain liquids without inner packagings, the specific gravity must be shown. If the packaging has not been tested for specific gravities greater than 1.2, the number may be omitted.


UN Specification Marks for Packagings, continued


Page 90

5. The letter “S” or a number indicating the results of a hydrostatic pressure test.

• For packagings intended to contain solid materials or inner packagings, an “S” must be shown.

• For single and composite packagings intended to contain liquids, the hydro-static test pressure the packaging was tested to withstand, in kPa, rounded down to the nearest 10 kPa must be shown.

6. The last two digits of the year during which the packaging was manufactured. “1H” and “3H” (plastic) packagings must also be marked with the month of manufacture in any appropriate manner, including away from the remainder of the markings.

7. The state (country) authorizing the mark indicated by the distinguishing sign used on motor vehicles in international traffic.

8. The name of the manufacturer or other identification of the packaging specified by the appropriate national authority.

Metal drums with a capacity greater than 100 L must also have an indication of the nom-inal thickness of the metal used in the body. This information must be permanently marked on the drum. [IMDG 6.1.3.2]

Standards for the UN Specification Mark

UN specification marks must be durable, legible, and placed in a location and of such a size relative to the packaging as to be readily visible. The mark may be applied in a single line or in multiple lines as long as the correct sequence is used. Slash marks or space should be used to separate the information.

Requirements for Permanent Markings

Every reusable packaging liable to undergo a reconditioning process that could obliterate the UN specification mark must bear the marks in a permanent form that is able to withstand the reconditioning process (e.g., embossed).

NOTE: The “country mark” and “manufac-turer information” are NOT required to be per-manently embossed on the packaging.

Additional UN Specification Marks

Reconditioner’s Marks [IMDG 6.1.3.8]

If a packaging is reconditioned, it must be marked by the reconditioner near the required manufacturer’s marks with the following additional information:

1. The name of the country in which the reconditioning was performed.

2. The name and address or symbol of the reconditioner.

NOTE: Symbols, if used, must be registered with the Associate Administrator.

3. The last two digits of the year during which the packaging was reconditioned.

4. The letter “R.”

5. If the packaging passed a leakproofness test, the letter “L.”

Step 3—Packing

UN Specification Marks for Packagings, continued


Page 91

Other Marks [IMDG 6.1.2.4]

The letters “T,” “V,” or “W” may follow the packaging identification code.

• “T” indicates a salvage packaging.

A “T” drum is a salvage drum that has had a UN solids test performed with water as the test medium instead of a solid material. When performing the “T” test, the drum is not vented after the drop portion of the test, since a salvage drum is intended to be a secondary container not a primary one. [IMDG 6.1.5.1.11]

• “V” indicates variation packaging.

Variation packagings are outer packag-ings that are allowed to be used to ship hazardous materials WITHOUT testing them with the specific inner packagings used for the shipment, provided that cer-tain criteria are met. [IMDG 6.1.5.1.7]

• “W” indicates the packaging is an equiva-lent packaging.

Equivalent packagings are packagings that have different specifications from those identified in IMDG 6.1.4, or that have been tested using methods, or test intervals, other than those specified, but that have been approved by the Associate Administrator for use in shipping hazard-ous materials. [IMDG 6.1.1.2]



Page 92

PACKAGING IDENTIFICATION CODES FOR NON-BULK UN SPECIFICATION PACKAGINGS

The UN specification marking begins with the letters “UN” in a circle, followed by a packaging identification code that identifies the packaging type, material of construction, and category.

Packaging Type Is Indicated by the First Number in the Code (e.g., “1A2”) [IMDG 6.1.2.1.1 and 6.1.2.5]

First Number in the UN Mark Type of Packaging

1 Drum

2 Reserved

3 Jerrican

4 Box

5 Bag

6 Composite Packaging

Material of Construction Is Indicated by a Letter Code (e.g., “1A2”) [IMDG 6.1.2.1.2 and 6.1.2.6]

Letter Material of Construction

A Steel (all types and surface treatments)

B Aluminium

C Natural Wood

D Plywood

F Reconstituted Wood

G Fibreboard

H Plastics Material

L Textile

M Paper, Multi-wall

N Metal (other than steel or aluminium)

P Glass, Porcelain or Stoneware

Step 3—Packing

Packaging Identification Codes for Non-bulk UN Specification Packagings, continued


Page 93

Packaging Category Is Indicated by the Second Number in the Code (e.g., “1A2”) When Applicable [IMDG 6.1.2.7]

Packaging Type Number Category

Plastic, steel, aluminium, and other metal drums and jerricans

1 Non-removable head (i.e., closed head)

2 Removable head (i.e., open head)

Natural wood boxes1 Ordinary

2 With sift-proof walls

Plastic boxes1 Expanded

2 Solid

Woven plastic, textile, and plastic film bags

1 Without inner lining or coating

2 Sift-proof

3 Water-resistant

4 Plastic film bags

Paper bags1 Multi-wall

2 Multi-wall, water-resistant

NOTE: The codes in the above table do NOT apply to composite packagings.

Examples of Identification Codes for Packagings OTHER THAN Composite Packagings

• 4G = box constructed of fibreboard

• 1A1 = steel drum with a non-removable head

• 3H2 = plastic jerrican with a removable head

• 4C2 = natural wood box with sift-proof walls

• 5M2 = multi-wall, water-resistant paper bag


Packaging Identification Codes for Non-bulk UN Specification Packagings, continued


Page 94

Identification Codes for Composite Packagings [IMDG 6.1.2.7]

Because they are composed of two differ-ent materials, two letters are used to identify the materials of construction for composite packagings. The first letter indicates the mate-rials of construction of the inner packaging, while the second applies to the outer packag-ing, for example:

• 6HA = plastic receptacle (H) inside a steel (A) outer packaging.

NOTE: The number “6” indicates that the type of packaging is a composite packaging.

Composite packagings do not have “sub-categories” in the same manner as other non-bulk packagings. Instead, the second number in the code indicates the type of outer pack-aging. It is important to note, however, that the number does NOT correlate to the num-bers that are used to indicate packaging types, as identified at IMDG 6.1.2.5 (e.g., where 1 = drum, 3 = jerrican, etc.). Instead, the meanings of the numbers are explained at IMDG 6.1.2.7 and are listed in the following table excerpt.

Code Subcategory

6HA1 Plastics receptacle in steel drum

6HA2 Plastics receptacle in steel crate or box

6HB1 Plastics receptacle in aluminium drum

6HB2 Plastics receptacle in aluminium crate or box

6HC Plastics receptacle in wooden box

6HD1 Plastics receptacle in plywood drum

6HD2 Plastics receptacle in plywood box

6HG1 Plastics receptacle in fibre drum

6HG2 Plastics receptacle in fibreboard box

6HH1 Plastics receptacle in plastics drum

6HH2 Plastics receptacle in solid plastics box

Step 3—Packing


Page 95

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Notes:

Page 96

UN SPECIFICATION MARKS FOR LARGE PACKAGINGSIMDG 6.6

50A/X/05 19/USA/VL824/2500/1000

51H/Z/09 19/USA/VL824/0/500

Format of Large Packaging UN Specification Marks

The UN specification mark for large pack-agings is similar to the mark for other packag-ings, however, there are key differences. The UN specification mark on large packagings must include the following elements in the fol-lowing order:

1. The letters “UN” shown inside of a circle that serves as the certification that the packaging was built and tested to meet specific, international standards for ship-ping specific materials.

2. An alpha-numeric packaging identifica-tion code that indicates:

• The type of packaging:

– “50” for a large rigid packaging.

– “51” for a flexible large packaging.

• A letter indicating the material of con-struction (e.g., “A” for steel, “G” for fibreboard).

3. A letter designating the packing group(s) for which the packaging was built and tested:

• “X” for Packing Groups I, II, and III.

• “Y” for Packing Groups II and III.

• “Z” for Packing Group III only.

4. The month and year (last two digits) the packaging was manufactured.

5. The state (country) authorizing the mark indicated by the distinguishing sign used on motor vehicles in international traffic.

6. The name of the manufacturer or other identification of the packaging specified by the appropriate national authority.

7. The stacking test load in kilograms (large packagings that are not designed for stacking must be marked with a “0”).

8. The maximum permissible gross mass in kilograms.

Step 3—Packing


Page 97

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Notes:

Page 98

UN SPECIFICATION MARKS FOR IBCSIMDG 6.5

11A/Y/01 20/USA/VL824/2500/1000

13H3/Z/09 19/USA/VL824/0/1500

Format of IBC UN Specification Marks [IMDG 6.5.2.1]

Each IBC manufactured and intended for use to transport dangerous goods must be durably and legibly marked with letters, num-bers, and symbols that are at least 12 mm high, placed in a location where they will be read-ily visible. The various elements must be dis-played in the sequence shown below.

1. The “UN” symbol, signifying that the IBC has been tested to meet specific design elements.

2. A code designating the type of IBC ac-cording to IMDG 6.5.1.4.

3. A letter designating the packing group(s) for which the packaging was tested:

– “X” for Packing Groups I, II, and III.

– “Y” for Packing Groups II and III.

– “Z” for Packing Group III only.

4. The month and the last two digits of the year during which the IBC was manufac-tured.

5. The state (country) authorizing the mark indicated by the distinguishing sign for motor vehicles in international traffic.

6. The name of the manufacturer or other identification of the IBC specified by the appropriate national authority.

7. The stacking test load in kilograms (IBCs that are not designed for stacking must be marked with a “0”).

8. The maximum permissible gross mass in kilograms.

Equivalent Packaging [IMDG 6.5.1.4.4]

The letter “W” may follow the IBC code to indicate that the IBC is an equivalent to the IBC specified.

Step 3—Packing


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UN Specification Marks for IBCs, continued

IBC Packaging Identification Codes [IMDG 6.5.1.4]

Packaging Type Is Indicated by the First Two Numbers in the Code:

Type For solids, discharged: For liquids

By gravity Under pressure of more than 10 kPa (1.45 psig)

Rigid 11 21 31

Flexible 13

Material of Construction Is Indicated by a Letter:

A Steel G FibreboardB Aluminium H PlasticC Natural wood L TextileD Plywood M Multiwall paperF Reconstituted wood N Metal other than steel or aluminium

NOTE: For composite IBCs, two capital letters are used in sequence following the number indicating design type. The first letter indicates the material of construction of the inner receptacle. The second letter indicates the material of construction of the outer IBC.

Examples:

• 11A = Rigid steel IBC for solids dis-charged by gravity.

• 11G = Rigid fibreboard IBC for solids discharged by gravity.

• 13L3 = Flexible textile IBC with a liner for solids discharged by gravity.

• 21B = Rigid aluminium IBC for solids discharged under pressure.

• 21HZ2 = Composite IBCs with a flexible plastic inner receptacle for solids dis-charged under pressure.

• 31B = Rigid aluminium IBC for liquids.


UN Specification Marks for IBCs, continued


Page 100

Packaging Category Is Indicated by a Number After the Letter (When Applicable)

Code Category

11H1 Fitted with structural equipment designed to withstand the whole load when IBCs are stacked, for solids which are loaded or discharged by gravity

11H2 Freestanding, for solids which are loaded or discharged by gravity21H1 Fitted with structural equipment designed to withstand the whole load when

IBCs are stacked, for solids which are loaded or discharged under pressure21H2 Freestanding, for solids which are loaded or discharged under pressure31H1 Fitted with structural equipment designed to withstand the whole load when

IBCs are stacked, for liquids.31H2 Freestanding, for liquids

11HZ1 Composite IBCs with a rigid plastic inner receptacle for solids loaded or dis-charged by gravity

11HZ2 Composite IBCs with a flexible plastic inner receptacle for solids loaded or dis-charged by gravity

21HZ1 Composite IBCs with a rigid plastic inner receptacle for solids loaded or dis-charged under pressure

21HZ2 Composite IBCs with a flexible plastic inner receptacle for solids loaded or dis-charged under pressure

31HZ1 Composite IBCs with a rigid plastic inner receptacle for liquids31HZ2 Composite IBCs with a flexible plastic inner receptacle for liquids13H1 Woven plastic without coating or liner13H2 Woven plastic, coated13H3 Woven plastic with liner13H4 Woven plastic, coated and with liner13H5 Plastic film13L1 Textile without coating or liner13L2 Textile, coated13L3 Textile with liner13L4 Textile, coated and with liner13M1 Paper, multiwall13M2 Paper, multiwall, water resistant

NOTE: The “Z” in the code for composite IBCs must be replaced by a capital letter that indicates the material used for the outer packaging (e.g., 21HA1 = composite IBC with a rigid plastic inner recep-tacle and a steel outer packaging, used for solids discharged under pressure).

Step 3—Packing


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ADDITIONAL IBC MARKINGSIMDG 6.5.2.2

In addition to the UN specification mark-ing, several additional markings may also be required on an IBC based on the specific type of IBC. These markings must appear near the UN specification marking in any place that is readily accessible for inspection. When units of measure are required, the metric unit indi-cated must also appear.

Rigid Plastic and Composite IBCs

Rigid plastic and composite IBCs must be marked with the following information:

• Rated capacity in litres of water at 20°C

• Tare mass in kilograms

• Gauge test pressure in kPa

• The date (month and year) of the last leakproofness test, if applicable

• The date (month and year) of the last inspection

• The maximum loading/discharge pres-sure in kPa or bar, if applicable

NOTE: Markings may be preceded by the nar-rative description of the marking (e.g., “Tare Mass: * * *,” where the “* * *” are replaced with the tare mass in kilograms of the IBC).

Metal IBCs

Metal IBCs must be marked with the fol-lowing information:

• Rated capacity in litres of water at 20°C

• Tare mass in kilograms

• The date (month and year) of the last leakproofness test, if applicable

• The date (month and year) of the last inspection

• The maximum loading/discharge pres-sure in kPa or bar, if applicable

• Body material and minimum thickness in mm

• Serial number assigned by the manu-facturer

NOTE: Markings may be preceded by the nar-rative description of the marking.

Fibreboard and Wooden IBCs

Fibreboard and wooden IBCs must show their tare mass in kilograms.



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Additional IBC Markings, continued

Composite IBCs

Inner Receptacles

The inner receptacles of composite IBCs must be marked with the following informa-tion:

• The code number designating the IBC design type

• A letter designating the packing group(s) for which the packaging was tested

• The name and address or symbol of man-ufacturer

• The date of manufacture (month and year)

• The country authorizing the mark

Detachable Parts

When a composite IBC is designed in such a way that the outer casing is intended to be dismantled for transport when empty, each of the parts intended to be detached when so dis-mantled must be marked with:

• The name and address or symbol of man-ufacturer.

• The date of manufacture (month and year).

Flexible IBCs

Flexible IBCs must be marked with a pictogram displaying recommended lifting methods.

All IBCs

The symbol shown below applicable to an IBC designed for stacking or not designed for stacking, as appropriate, must be marked on all IBCs manufactured, repaired, or remanu-factured after January 1, 2011.

Step 3—Packing


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SPECIAL PROVISIONSColumn 6 of the IMDG 3.2 Dangerous Goods List

Special Provision Codes [IMDG 3.3]

Special provision codes are indicated in Column 6 of the 3.2 Dangerous Goods List. The number indicates the actual provision. Special provisions that are specific to the sea mode of transport start with “900.” The explanation for each code is found in IMDG 3.3, following the List.

Special provisions are used to take into account a dangerous good’s unique hazards or properties. Special provisions often provide helpful information, additional requirements, variations, and sometimes even relief from more stringent rules.

Special provisions may direct the ship-per to:

• Supplement the Proper Shipping Name with technical names.

• Classify the dangerous good differently than would normally be expected.

• Apply additional labels to a package.

• Exclude certain substances from IMDG regulations.

• Prohibit certain substances from being transported by vessel.

Examples of Special Provisions

Safety Devices Pyrotechnical or Electric

Code 289: Safety devices, electrically initiated and safety devices, pyrotechnic installed in vehicles, vessels, or aircraft or in completed components such as steer-ing columns, door panels, seats, etc., are not subject to the provisions of this Code.

Mercury Contained in Manufactured Articles

Code 366: Manufactured instruments and articles containing not more than 1 kg of mercury are not subject to the provisions of this Code.

Calcium Carbide

Code 951: Bulk container shall be her-metically sealed and under a nitro-gen blanket.

Paint Related Material, PG III

Code 955: If a viscous substance and its packaging fulfills the provisions of IMDG 2.3.2.5, the packing provisions of Chap-ter 4.1, the marking and labeling provi-sions of Chapter 5.2, and the package testing provisions of Chapter 6.1 are not applicable.



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LIMITED QUANTITY PACKAGINGIMDG 3.4

Relief from Some Regulations

The limited quantity exception provides relief from many IMDG requirements when shipping small quantities of certain dangerous goods, including most requirements for:

• Marking.

• Labeling.

• Placarding.

• Segregation.

• Packaging testing.

Applicable Regulations [IMDG 3.4.1.2]

Packagings for limited quantities must be prepared according to the requirements at IMDG 3.4. Unless explicitly excluded at IMDG 3.4, the full provisions of the IMDG Code apply to packages of limited quantities. Shippers pre-paring packagings for limited quantities must therefore comply with all requirements for:

• Training [IMDG 1.3].

• Classification [IMDG Part 2].

• Naming/identification [IMDG 3.1 and 3.2].

• Applicable special provisions [IMDG 3.3].

• Documentation [IMDG 5.4]

Packaging Requirements [IMDG 3.4.2]

Dangerous goods that will be transported as limited quantities must be packed in inner packagings placed in suitable outer packag-ings (i.e., in combination packagings).

Packagings for limited quantities must comply with:

• The general provisions at IMDG 4.1.1.1, 4.1.1.2, and 4.1.1.4 to 4.1.1.8.

– These provisions essentially require packages to be strong enough to with-stand the shocks normally encountered during transport and loading, to be properly filled and closed, to be com-patible with the materials they contain, and to be inspected prior to shipment to ensure that they are in good condition.

• The packaging design and construction provisions of IMDG 6.1.4, 6.2.1.2, and 6.2.4.

– Packagings used to ship limited quanti-ties are not required to meet the test-ing requirements of IMDG 6.1.5, 6.3.5, 6.5.4, and 6.6.5 and, therefore, are NOT required to be UN specification packag-ings.

Additional Packaging Issues

Inner packagings are not required to be used when shipping aerosols or “receptacles, small, containing gas.”

Step 3—Packing


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Limited Quantity Packaging, continued

Intermediate packagings may be used, but are not typically required. However, if the inner packagings are liable to break or could easily be punctured, then they must be placed in suitable intermediate packaging meeting all applicable general provisions.

NOTE: Liquid dangerous goods assigned to Class 8, PG II that are shipped in glass, por-celain, or stoneware inner packagings must be enclosed in a compatible and rigid intermedi-ate packaging.

Shrink- or stretch-wrapped trays are acceptable as outer packagings for limited quantities if they meet all applicable general provisions.

Quantity Limitations [IMDG 3.4.1 and 3.4.2]

When shipped as a limited quantity, the inner packaging or article must conform to the quantity limits specified in Column 7a of the 3.2 Dangerous Goods List. If the limit is “0,” then the material may not be shipped as a lim-ited quantity.

In addition, the total gross mass of the entire package cannot exceed 30 kg. If shrink- or stretch-wrapped trays are used as outer packagings, however, then the total gross mass of the package cannot exceed 20 kg.

Stowage and Segregation [IMDG 3.4.3 and 3.4.4]

Limited quantity packages are allocated to Stowage Category A regardless of what is noted in Column 16a of the 3.2 Dangerous Goods List for the particular dangerous good.

Segregation requirements at IMDG 7.2 must be taken into account when shipping different dangerous goods in the same outer packaging. Otherwise, limited quantity pack-ages are not subject to the requirements of IMDG 7.2.



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EXCEPTED QUANTITY PACKAGINGIMDG 3.5

Relief from Some Regulations

The excepted quantity exception provides relief from many IMDG requirements when shipping small quantities of certain dangerous goods, including most requirements for:

• Marking.

• Labeling.

• Placarding.

• Segregation.

• Packaging testing.

Applicable Regulations [IMDG 3.5.1.1]

Dangerous goods that are packaged as “excepted quantities” and meet all of the pro-visions of IMDG 3.5 are excluded from most of the requirements in the IMDG Code.

In addition to the requirements specified at IMDG 3.5, the following requirements apply to excepted quantities:

• Training [IMDG 1.3].

• Classification procedures and packing group criteria [IMDG Part 2].

• Documentation [IMDG 5.4].

Quantity Limits per Package [IMDG 3.5.1.2 and 3.5.1.3]

When preparing dangerous goods to be shipped as excepted quantities, the shipper must limit the amount of dangerous goods in a package to the quantities associated with the EQ code found in Column 7b of the 3.2 Danger-ous Goods List. The limits for these EQ codes are identified in the table at IMDG 3.5.1.2.

Excepted Quantity Codes [IMDG 3.5.1.2]

CodeMaximum Net Quantity per

Inner Packaging

Maximum Net Quantity per

Outer Packaging

E0 Not permitted as Excepted Quantity

E1 30 g / 30 mL 1,000 g / 1,000 mL

E2 30 g / 30 mL 500 g / 500 mL

E3 30 g / 30 mL 300 g / 300 mL

E4 1 g / 1 mL 500 g / 500 mL

E5 1 g / 1 mL 300 g / 300 mL

NOTE: For gases, the volume indicated for inner packagings refers to the water capacity of the inner receptacle, while for outer packag-ings, it refers to the combined water capacity for all inner packagings within a single outer packaging.

Step 3—Packing


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Excepted Quantity Packaging, continued

Example

In Column 7b of the 3.2 Dangerous Goods List, copper chloride is assigned an EQ code of E2. According to the table at IMDG 3.5.1.2, if copper chloride is packaged as an excepted quantity:

• Each inner packaging may contain a maximum net quantity of 30 g of copper chloride.

• The outer packaging may contain a maximum net quantity of 1,000 g (1 kg) of copper chloride.

Multiple Materials in One Outer Package

When dangerous goods with different EQ codes are packed together, the total quantity per outer packaging must be limited to the corresponding limit of the most restrictive EQ code. For example:

• Chloroform is assigned an EQ code of E1, which has a maximum outer packaging quantity limit of 1,000 mL (1 L).

• Diethyl ether is assigned an EQ code of E3, which has a maximum outer packag-ing quantity limit of 300 mL.

• A package containing chloroform and diethyl ether would be limited to a maxi-mum outer packaging quantity of 300 mL.

Packaging Requirements [IMDG 3.5.1.1 and 3.5.2.1]

Dangerous goods shipped as excepted quantities must be packaged in combination packaging that meet the general packing provi-

sions at IMDG 4.1.1.1, 4.1.1.2, 4.1.1.4, 4.1.1.4.1, and 4.1.1.6.

NOTE: These provisions essentially require packages to be strong enough to withstand the shocks normally encountered during transport and loading, to be properly filled and closed, and to be compatible with the materials they contain. Packagings used to ship excepted quantities are NOT required to be UN specifi-cation packagings.

The dangerous goods must not react dan-gerously with cushioning, absorbent material, or packaging material or reduce the integrity or function of the materials.

In addition, the following requirements must also be met:

Inner Packagings

• Inner packagings must be constructed of plastic, glass, porcelain, stoneware, earth-enware, or metal.

• The closures on inner packagings must be held in place with wire, tape, or other positive means, and must be resistant to the dangerous goods.

• Inner packagings must be secured in intermediate packaging with cushioning material so that under conditions normal to transport, they cannot break, be punc-tured, or leak their contents.

Intermediate and Outer Packagings

• Intermediate packaging must be securely packed in strong rigid outer packaging (e.g., wooden, fibreboard, or other equally strong material).



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Excepted Quantity Packaging, continued

• If the excepted quantity package contains liquid dangerous goods, then either the intermediate packaging or outer pack-aging must contain sufficient absorbent to absorb the entire contents of the inner packaging.

NOTE: When the absorbent is placed inside the intermediate packaging, it may also serve as the cushioning material.

The Completed Package

• The package must be capable of passing the drop and stacking tests specified at IMDG 3.5.3.

• Regardless of its orientation, the package must completely contain the contents in case of breakage or leakage.

• The package must be large enough to accommodate all necessary marks.

Excepted Quantity Packages in Overpacks and Cargo Transport Unit (CTU) [IMDG 3.5.2.1.6 and 3.5.5]

Package containing excepted quantities may be placed in overpacks with other dan-gerous goods packages and/or goods that are not subject to the IMDG Code.

The number of excepted quantity pack-ages that can be packed in any cargo transport unit cannot exceed 1,000 packages.

Stowage and Segregation [IMDG 3.5.7 and 3.5.8]

Excepted quantity packages are allocated Stowage Category A regardless of what is noted in Column 16a of the 3.2 Dangerous Goods List for the particular material.

Segregation requirements at IMDG 7.2 to 7.7 are not applicable to excepted quantity packages as long as the dangerous goods in the same outer packaging do not react danger-ously with each other.

De Minimis Quantities [IMDG 3.5.1.4]

Excepted quantities of dangerous goods assigned to codes “E1,” “E2,” “E4,” and “E5” are not subject to any other provisions of the IMDG Code if they meet the following condi-tions:

• The net quantity of material per inner package is ≤ 1 mL for liquids or ≤ 1 g for solids.

• The packaging requirements of IMDG 3.5.2 are met with a few exceptions.

• The packages must be tested according to IMDG 3.5.3.

• The net quantity of dangerous goods per outer packaging is ≤ 100 mL for liquids and gases or ≤ 100 g for solids.

Step 3—Packing


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PORTABLE TANKS, MULTI-ELEMENT GAS CONTAINERS (MEGCs), AND BULK CONTAINERSIMDG 4.2 and 4.3 and 49 CFR 171.25

Bulk Packagings Are Subject to DOT Rules [49 CFR 171.25(d)]

The majority of bulk packagings used to ship dangerous goods from, through, or to the United States must conform to DOT require-ments. The bulk packagings subject to DOT specifications include:

• IM-, IMO-, and DOT-specified portable tanks.

• UN portable tanks containing gases.

• Cargo tank trucks.

• Rail tank cars.

• Multi-Element Gas Containers (MEGCs).

A bulk package being shipped by vessel that is subject to the international standards must also meet all applicable requirements under the IMDG Code.

NOTE: Additional DOT general requirements for bulk packagings for outage, filling, stack-ing, and more can be found at 49 CFR 173.24b.

Additional DOT Rules for UN Portable Tanks Containing Liquids and Solids [49 CFR 171.25(c)(1)]

Although shippers may follow the IMDG rules for UN portable tanks containing liquids

or solids, the DOT requires compliance with Special Provisions “TP37,” “TP38,” “TP44,” and “TP45” when these are assigned to a par-ticular material in Column 7 of the 49 CFR 172.101 Hazardous Materials Table as well as any other applicable bulk special provisions that are assigned in the Hazardous Materials Table to the particular material being shipped. This is true regardless of whether or not the IMDG Code would assign the same special pro-visions.

The specific requirements of Special Provi-sions “TP37,” “TP38,” “TP44,” and “TP45” are found at 49 CFR 172.102:

• TP37: Pertains to the maximum concen-tration of hydrogen peroxide solution in water.

• TP38: Addresses insulation issues.

• TP44: Specifies the use of stainless steel/other metals and related requirements.

• TP45: Specifies the use of stainless steel/other metals and related requirements.



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Portable Tanks, Multi-Element Gas Containers (MEGCs), and Bulk Containers, continued

IMDG Portable Tank Regulations [IMDG 4.2.5]

Materials permitted to be transported in portable tanks are identified by a code in Column 13 of the 3.2 Dangerous Goods List. Any special packing provisions that apply to the shipment are identified by a code in Column 14 of the List.

Packing instructions and special pack-ing provisions for portable tanks are found in IMDG 4.2.5.

Portable Tank General Provisions [IMDG 4.2.1.1–4.2.1.8]

The general provisions for shipping solid substances in portable tanks identify numer-ous requirements, including the following:

• Portable tanks must be adequately pro-tected during transport against damage to the shell and service equipment resulting from lateral and longitudinal impact and overturning.

• “Empty” portable tanks that have not been cleaned and are not gas-free must follow the same requirements as portable tanks filled with the previous substance.

• Substances cannot be transported in ad-joining compartments of shells when they may react dangerously with each other and cause:

– Combustion and/or evolution of con-siderable heat.

– Evolution of flammable, toxic, or as-phyxiant gases.

– The formation of corrosive substances.

– The formation of unstable substances.

– A dangerous rise in pressure.

• The shipper must ensure that the tank is not loaded with substances that are likely to react dangerously with the materials of the shell, gaskets, service equipment, or any protective linings or could form dan-gerous products or significantly weaken these materials.

• Portable tanks may not be offered for transport:

– With a residue of substances that were previously transported remaining on the outside of the shell or service equip-ment.

– When leaking or damaged to such an extent that the integrity of the portable tank or its lifting or securing arrange-ments may be affected.

– Unless the service equipment has been examined and found to be in good working order.

• Portable tanks cannot be filled or dis-charged while on board the vessel.

Portable Tank Additional Provisions [IMDG 4.2.1.10–4.2.1.19, 4.2.2 and 4.2.3]

The IMDG regulations for the use of por-table tanks include additional packing pro-visions applicable to materials of Classes 3, 4.1, 5.2, 7, 8, and solid substances transported above their melting point, as well as general provisions for the use of portable tanks used to transport both non-refrigerated and refrig-erated liquefied Class 2 gases.

Step 3—Packing


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IMDG Multiple-Element Gas Container (MEGC) Regulations [IMDG 4.2.4]

Gases authorized for transport in MEGCs are indicated by an “X” in the “MEGC” column in Tables 1 and 2 of Packing Instruction P200 at IMDG 4.1.4.1.

The general provisions for the use of MEGCs are found at IMDG 4.2.4.

MECG General Provisions [IMDG 4.2.4]

The general provisions for shipping dan-gerous goods in MECGs identify numerous requirements, including the following:

• MECGs must conform to the design, con-struction, inspection, and testing require-ments in IMDG 6.7.5.

• The elements of MECGs must be period-ically inspected according to the require-ments in Packing Instruction P200 and IMDG 6.2.1.6.

• MECGs must be protected during trans-port against damage to the elements and service equipment unless they are con-structed to withstand impact or over-turning.

• The periodic testing and inspection requirements for MECGs are specified at IMDG 6.7.5.12.

– MECGs that are past due for inspection cannot be charged or filled, but may be transported.

• MECGs must be inspected prior to filling to ensure they are authorized for the ma-terial and all applicable provisions have been met.

• Elements of MECGs must be filled ac-cording to the working pressures, filling ratios, and filling provisions specified in Packing Instruction P200 for the particu-lar gas.

• MECGs must not be filled above their maximum permissible gross mass.

• Isolation valves must be closed after fill-ing and remain closed during transport.

• Openings for filling must be closed by caps or plugs, and the shipper must ver-ify the leakproofness of the closures and equipment.

• MECGs must not be offered for filling:

– When damaged to such an extent that the integrity of their pressure recepta-cles or their structural or service equip-ment may be compromised,

– Unless the pressure receptacles and their structural and service equipment have been examined and are in good working order, and

– Unless the required certification, retest, and filling marks are legible.

• Filled MECGs must not be offered for filling:

– When leaking,

– When damaged to such an extent that the integrity of their pressure recepta-cles or their structural or service equip-ment may be compromised,



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– Unless the pressure receptacles and their structural and service equipment have been examined and are in good working order, and

– Unless the required certification, retest, and filling marks are legible.

• “Empty” MECGs that have not been cleaned and purged must comply with the same requirements as MECGs filled with the previous substance.

IMDG Bulk Container Regulations [IMDG 4.3]

The IMDG regulations for shipping solid materials in closed bulk containers are found at IMDG 4.3. Materials that are permitted to be transported in bulk containers are identi-fied by the codes “BK1,” “BK2,” and “BK3” in Column 13 of the 3.2 Dangerous Goods List.

Each “BK” code corresponds to a different type of bulk container. They are:

• BK1: Sheeted bulk containers.

• BK2: Closed bulk containers.

• BK3: Flexible bulk containers.

Bulk Container General Provisions [IMDG 4.3.1]

The regulations for bulk containers do not include specific packing instructions. How-ever, the general provisions for shipping solid substances in bulk containers provide numer-ous requirements for shipping materials in bulk containers, including the following:

• Bulk containers must be siftproof and closed such that the contents cannot escape under normal conditions of transport.

• Bulk solids in bulk containers must be evenly distributed so as to minimize movement that could result in damage to the container or leakage of the dangerous goods.

• Venting devices must be kept clear and operable.

• Bulk solids may not react dangerously with or significantly weaken the bulk container, gaskets, equipment, or protec-tive coatings that are in contact with the contents.

• Before being offered for transport, each bulk container must be inspected and cleaned to ensure that it does not contain any residues on the interior or exterior that could:

– Cause a dangerous reaction with the substance being transported.

– Detrimentally affect the structural in-tegrity of the bulk container.

– Affect the dangerous goods retention capabilities of the bulk container.

• No dangerous residues can be allowed to remain on the outer surfaces of a bulk container during transport.

• “Empty” bulk containers that have con-tained dangerous goods must be treated in the same manner as filled bulk contain-ers unless adequate measures have been taken to nullify any hazard.

Step 3—Packing


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• When bulk containers are used to trans-port bulk goods that are liable to cause a dust explosion or evolve flammable va-pours, measures must be taken to prevent sources of ignition and dangerous elec-trostatic discharge during the transport, loading, and unloading of the dangerous goods.

• Substances that may react dangerously with one another cannot be placed in the same bulk container. Dangerous reactions would be:

– Combustion and/or evolution of con-siderable heat.

– Evolution of flammable, toxic, or as-phyxiant gases.

– The formation of corrosive substances.

– The formation of unstable substances.

• Before a bulk container is filled, it must be visually inspected to ensure that:

– It is structurally serviceable.

– Its interior walls, ceiling, and floors are free from protrusions or damage.

– Any inner liners or substance-retaining equipment are free from rips, tears, or other damage that would compromise its cargo retention abilities.

“Structurally serviceable” means that the bulk container has no major defects in its structural components. Such defects could include any of the following:

– Bends, cracks, or breaks in the structur-al or supporting members that affect the integrity of the container.

– More than two splices in any one top or bottom side rail.

– Door hinges and hardware that are seized, twisted, broken, missing, or otherwise inoperative.

– Gaskets and seals that don’t seal.

• Before a flexible bulk container is filled, it must be visually examined to ensure that it is structurally serviceable; that its textile slings, load-bearing structure straps, body fabric, and lock device parts—including metal and textile parts—are free from pro-trusions or damage; and that inner liners are free from rips, tears, or any other damage.

Bulk Container Additional Provisions [IMDG 4.3.2]

The IMDG regulations for the use of bulk containers include additional packing provi-sions applicable to bulk goods of Classes 4.2, 4.3, 5.1, 6.2, 7, and 8.

Bulk Container Specifications

IMDG design, construction, inspection, and testing requirements for bulk containers are found at IMDG 6.9.

Additional Provisions for BK1 and BK3 Containers [IMDG 4.3.3 and 4.3.4]

Sheeted bulk containers (BK1) must not be used for sea transport, except for UN 3077 not meeting the criteria of IMDG 2.9.3 transported on short international voyages.

Flexible bulk containers (BK3) are only allowed in the holds of general cargo ships. They are not allowed to be transported in cargo transport units.



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SPECIAL PACKAGING ISSUES

Salvage Packagings [IMDG 4.1.1.18 and 4.1.1.19]

Damaged, defective, leaking, or non-conforming packages or dangerous goods that have spilled or leaked may be transported in salvage packagings, provided the following requirements are met:

• Measures are taken to prevent excessive movement of damaged packaging within salvage packaging.

• Sufficient inert absorbent material is add-ed to eliminate any free liquid.

• This type of packaging cannot be used for transport from the facility where the substance is produced.

• Approval is required for use other than emergency purposes during transport.

• Specific marking, labeling, design, and testing requirements apply to salvage packagings.

Testing for Salvage Packaging [IMDG 6.1.5.1.11 and 6.6.5.1.9]

Salvage packagings must be tested sim-ilar to packagings intended for transporting solids or inner packagings. Under IMDG rules, testing must be according to requirements for Packing Group II packagings, except as indi-cated at IMDG 6.1.5.1.11.1 and 6.6.5.1.9.

Salvage Packaging Marks [IMDG 6.1.2.4 and 6.6.2.2]

Salvage packagings must be marked with a UN certification mark similar to that required for other outer packaging. In addition, after the code number designating the type of packaging, the mark must include the letter “T” indicating that it was tested to the special standards for salvage packaging (e.g., “1A2” becomes “1A2 T,” “4G” becomes “4G T”).

Pressure Receptacles, Aerosol Dispensers, and Small Receptacles Containing Gas

The provisions for the construction and testing of pressure receptacles, aerosol dis-pensers, and small receptacles containing gas are found at IMDG 6.2.

Packing instructions “P200” and “P203” refer to the provisions at IMDG 6.2 for the con-struction of cylinders, tubes, pressure drums, bundles of cylinders, and closed cryogenic receptacles.

Step 3—Packing


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Special Packaging Issues, continued

Empty Packagings [IMDG 4.1.1.11]

An empty packaging that previously held a dangerous good must be shipped as if it still contains dangerous goods unless ade-quate measures have been taken to nullify any hazard.

If the hazard has NOT been eradicated, then the package must be identified, marked, labeled, and placarded as required for those dangerous goods.

Portable Tanks [IMDG 4.2.1.5, 4.2.2.6, and 4.2.3.5]

Empty portable tanks that have contained a dangerous good must meet the same require-ments as a filled tank, unless the tank has been cleaned and is gas-free.

MEGCs [IMDG 4.2.4.7]

Empty MEGCs that have contained a dan-gerous good must meet the same requirements as a filled container, unless the tank has been cleaned and purged.

Infectious Substance Packagings

Samples of each packaging intended for use with infectious substances, other than live animals and organisms, must be tested accord-ing to IMDG 6.3.5. These tests include a drop test and a puncture test. A test report must be prepared and made available to the users of the packaging.

Infectious Substance Packaging Marks [IMDG 6.3.4]

Packagings intended to hold infectious substances must be marked as follows:

1. The UN packaging symbol

2. The code designating the type of packaging

3. The text “CLASS 6.2”

4. The last two digits of the year of manu-facture of the packaging

5. The state authorizing the allocation of the mark indicated by the distinguishing sign for motor vehicles in international traffic

6. The name of the manufacturer or other identification of the packaging specified by the appropriate national authority

7. The letter “U” for inner receptacles that are transported without testing according to IMDG 6.3.2.9

Packages Containing Substances Posing Risk of Asphyxiation [IMDG 5.5.3]

Dangerous goods requiring cooling or conditioning assigned to Packing Instruction “P203,” “P620,” “P650,” “P800,” “P901,” and “P904” must meet the appropriate packing instruction requirements.



Notes:

Page 116

Special Packaging Issues, continued

Dangerous goods requiring cooling or con-ditioning assigned to other packing instruc-tions must be:

• Capable of withstanding very low tem-peratures without being weakened by the coolant or conditioner.

• Designed and constructed to permit the release of gas to prevent a buildup of pressure.

• Packed in such a way to prevent move-ment after the coolant or conditioner dissipates.

These packages must be transported in a well-ventilated cargo transport unit.

Radioactives

Special packing provisions for Class 7 packagings, IBCs, and large packagings are found at IMDG 4.1.9. IMDG 4.2.1.16 lists the additional provisions for the transport of Class 7 substances in portable tanks.

IMDG 6.4 contains the provisions for the construction, testing, and approval of packages and material of Class 7 by air. These provisions are reproduced at IMDG 6.4 for information/identification purposes. Packages designed, tested, and approved for air transport may also be transported by sea.



Step 4—Marking and Labeling



CONTENTS

Step 4—Marking and Labeling ........................................................................................117

General Marking and Labeling Requirements ..............................................................118

Marking and Labeling Requirements for Fully Regulated Packages .........................121

Additional Marking and Labeling Requirements for Fully Regulated Non-bulk Packages .........................................................................122

Special Marking and Labeling Situations .......................................................................126

Marking Requirements for Overpacks, Unit Loads, and Salvage Packaging ...........135



Notes:

Page 117

STEP 4—MARKING AND LABELINGHow Do We Let People Know What’s in the Package?



IMDG 3.4 Limited quantities

IMDG 3.5 Excepted quantities

IMDG 5.1.1

Application and general provisions

IMDG 5.1.2

Marking and labeling over-packs and unit loads contain-ing dangerous goods packages

IMDG 5.2.1

Marking dangerous goods packages

IMDG 5.2.2

Labeling dangerous goods packages

49 CFR 171.23 and

171.25

Additional marks and labels required by the DOT


The fourth step in the dangerous goods shipping process is to properly mark and label the package. As part of this step, the shipper must determine:

• The marking requirements that apply to each package.

• The standards that the marks must meet.

• The labels that are required for each package.

• The requirements for displaying the label.


To properly mark and label packages, you must know:

• The material’s primary and subsidiary hazards.

• The material’s Proper Shipping Name.

• Whether the dangerous goods were as-signed generic or N.O.S. Proper Shipping Names.

• The type of packaging being used to ship the material.

• Whether the dangerous goods are being shipped as a “limited quantity” or “ex-cepted quantity.”

• Whether the dangerous goods are marine pollutants.



Notes:

Page 118

GENERAL MARKING AND LABELING REQUIREMENTS

Marks vs. Labels

Although marks and labels are both types of IMDG communications and the terms are sometimes used interchangeably, they are NOT actually the same things. There are very specific rules for marking dangerous goods packages and separate rules for labeling dan-gerous goods packages.

Marks are typically used to:

• Identify what the material in the pack-age actually is.

• Provide emergency response infor-mation.

Labels are typically used to:

• Identify the hazards of the material (e.g., flammable liquid or corrosive material).

• Identify special handling precautions.

General Requirements for Marks [IMDG 5.2.1.2]

Regardless of what you are marking, at a minimum, all marks required by IMDG 5.2 must be :

• Readily visible and legible.

• Displayed on a background of contrast-ing color on the external surface of the package.

• Located away from any other package marks that could substantially reduce their effectiveness.

• Able to survive at least three months immersed in the sea and still be identi-fiable.

In most cases, marks are only required to be placed on one side of the package.

Marking Requirements for IBCs and Large Packagings [IMDG 5.2.1.4]

IBCs and large packagings must be marked in the same manner as any other packages con-taining dangerous goods. IBCs with more than 450 L capacity and large packagings must be marked on two opposing sides of the package.

Marking Requirements for Unpackaged Articles [IMDG 5.2.1.1]

If an article is shipped unpackaged, the marks must be displayed on the article; on its cradle; or on its handling, storage, or launch-ing device.



Notes:

Page 119

General Marking and Labeling Requirements, continued

Multiple Dangerous Goods in a Single Package [IMDG 5.1.4]

If two or more dangerous goods are packed within the same outer packaging, the outer package must be marked as required for each substance.

Specifications for Marks

There is no standardized form for how most marks are placed on a package. Shippers can use a preprinted sticker, print the infor-mation on a tag, or just write the information directly on the package itself with a perma-nent marker.

Minimum Marking Size of UN Numbers [IMDG 5.2.1.1]

When marking the UN number on a pack-age or overpack, the mark must be:

• At least 12 mm (0.5 in.) high for packages greater than 30 L or 30 kg and cylinders greater than 60 L water capacity.

• At least 6 mm (0.25 in.) high for packages greater than 5 L or 5 kg, but less than or equal to 30 L or 30 kg and cylinders less than or equal to 60 L water capacity.

• An appropriate height for packages 5 L or 5 kg or less in size.

NOTE: There are no specific size requirements for marking the Proper Shipping Name on packages or overpacks.

General Requirements for Labels [IMDG 5.2.2.1.6–5.2.2.1.8 and 5.2.2.2]

Regardless of what you’re labeling, at a minimum, all labels required by the IMDG Code must be:

• Unobscured by any part or attachment to the packaging or any other label or mark.

• Displayed on a contrasting background or have either a dotted or solid outer boundary line.

When package dimensions permit, labels must be placed:

• On the same surface of the package near the Proper Shipping Name.

• “On-point” at a 45-degree angle (diamond-shaped).

When different dangerous goods in the same package require multiple labels, they must be affixed next to each other. Primary and subsidiary hazard labels must also be affixed next to each other. Labels do not need to be applied for a subsidiary hazard if a primary hazard label already represents the hazard.

In most cases, labels are only required to be placed on one side of the package.


General Marking and Labeling Requirements, continued


Page 120

Small and/or Irregular-shaped Packages [IMDG 5.2.2.1.6]

If the package has an irregular shape or is of such a small size that a label cannot be affixed to it satisfactorily, the label may be attached to the package using a securely affixed tag or by other suitable methods.

Labeling Requirements for IBCs and Large Packagings [IMDG 5.2.2.1.7]

IBCs and large packagings should be labeled in the same manner as any other pack-ages containing dangerous goods. IBCs with more than 450 L capacity and large packagings must be labeled on two opposing sides of the package.

Specifications for Labels [IMDG 5.2.2.2]

All labels must meet detailed specifica-tions and standards for durability, size, shape, format, symbol, color, and text.

Size, Shape, and Display [IMDG 5.2.2.2.1.1]

Labels must have minimum dimensions of 100 × 100 mm, unless the package dimensions will not permit this size to be displayed. The outer boundary line must be 5 mm from the outer edge of the label.

All hazard labels (except for Divisions 1.4, 1.5, and 1.6) are divided into halves.

• The upper half is reserved for the picto-rial symbol representing the hazard.

• The lower half of the label must contain the class number for 1, 2, 3, 4, 5.1, 5.2, 6, 7, 8, or 9, as appropriate.

• The lower half may also include text indicating the hazard class or the UN number.

NOTE: Text that indicates the hazard class IS REQUIRED on Class 7 labels.

Color Requirements for Symbols, Text, and Numbers on Labels [IMDG 5.2.2.2.1.6]

All symbols, text, and numbers on labels must be in black EXCEPT:

• Class 8 labels shall show the text (if any) and class numbers in white.

• Labels that have entirely green, red, or blue backgrounds may show the sym-bols, text, and numbers in white.

• Class 5.2 labels may show the symbol in white.

• Class 2.1 labels displayed on cylinders and gas cartridges for liquefied petro-leum gases may show the symbols, text, and numbers in the background color of the receptacle if adequate contrast is provided.

Durability of Labels [IMDG 5.2.2.2.1.7]

Labels must be affixed to or stenciled onto a package so that they would be able to sur-vive at least three months immersed in the sea and still remain identifiable.



Notes:

Page 121

MARKING AND LABELING REQUIREMENTS FOR FULLY REGULATED PACKAGES

Standard Marks and Labels

With limited exceptions, fully regulated packages must be marked and labeled with ALL of the following information:

• Proper Shipping Name.

• UN number.

• All applicable hazard class labels.



Notes:

Page 122

ADDITIONAL MARKING AND LABELING REQUIREMENTS FOR FULLY REGULATED NON-BULK PACKAGES

Certain kinds of shipments of fully regu-lated packages will require special marks in addition to the standard marks required on all fully regulated packages.

Orientation Arrows [IMDG 5.2.1.7]

Unless excepted, orientation arrows are required on:

• Combination packagings having inner packagings containing liquid danger-ous goods.

• Single packagings fitted with vents.

• Cryogenic receptacles intended for the transport of refrigerated liquefied gases.

• Machinery or apparatus containing spillable liquid dangerous goods.

Exceptions

Orientation arrows are NOT required on outer packagings containing:

• Pressure receptacles (except cryogenic receptacles.)

• Dangerous goods in inner packagings of not more than 120 mL that are prepared with sufficient absorbent material be-tween the inner and outer packagings to completely absorb the liquid contents.

• Division 6.2 infectious substances in pri-mary receptacles of not more than 50 mL.

• Class 7 radioactive material in Type IP-2, IP-3, A, B(U), B(M), or C packages.

• Articles that are leak-tight in all orienta-tions (alcohol or mercury in thermome-ters, aerosols, etc.).

• Dangerous goods in hermetically sealed inner packagings of not more than 500 mL.



Notes:

Page 123

Additional Marking and Labeling Requirements for Fully Regulated Non-bulk Packages, continued

Requirements for Arrows

The orientation arrows must be:

• Placed on two opposing sides.

• Either red or black.

• Underlined.

• Rectangular in shape and large enough to be clearly visible on the package.

NOTE: The arrows may be outlined with a box, but this is optional. Orientation arrows are not required to be placed on the same surface as other required marks and labels.

Prohibition

Use of the arrows for purposes other than indicating proper package orientation is prohibited.




Page 124

“Generic” Proper Shipping Names [IMDG 3.1.2.8]

When shipping dangerous goods described by “generic” or “not otherwise specified” (N.O.S.)Proper Shipping Names that are listed with Special Provisions 274, the technical name(s) of the haz-ardous constituent(s) must be marked on the package.

• Names must be added in parentheses immediately after the Proper Shipping Name.

• If the material is a mixture, not more than the two components that most predominantly con-tribute to the hazard(s) need be included.

• If a subsidiary hazard label is required, the technical names must include the constituent that requires the use of the subsidiary hazard label.



Notes:

Page 125


Marine Pollutants [IMDG 5.2.1.6]

Packages containing a marine pollutant must be durably marked with the marine pol-lutant mark (also known as the environmen-tally hazardous substance mark).

• The mark must be placed or stenciled adjacent to the Proper Shipping Name and UN number.

• The mark must be placed on two op-posing sides when used on IBCs with more than 450 L capacity and large packagings

• The mark must be black on white or a suitable contrasting background. The dimensions shall be at least 100 × 100 mm, except in cases where the packages are too small for this size of a mark.

Exceptions [IMDG 2.10.2.7]

The marine pollutant mark is NOT required on:

• Limited quantity packages

• Excepted quantity packages

• Single packages containing a net quantity of 5 L or less for liquids or 5 kg or less for solids

• Combination packages containing a net quantity of 5 L or less for liquids or 5 kg or less for solids in each inner packaging

NOTE: The mark may be used on packages that are marine pollutants only under US DOT rules, but not under the IMDG Code.



Notes:

Page 126

SPECIAL MARKING AND LABELING SITUATIONS

Limited Quantities [IMDG 3.4]

Packages shipped as limited quantities are excluded from ALL of the typical marking and label-ing requirements and must ONLY be marked with the limited quantity mark and, if applicable, ori-entation arrows.

The mark should have a minimum size of 100 × 100 mm unless the dimensions of the package will not allow this size, in which case the mark may be reduced to no less than 50 × 50 mm, as long as it remains clearly visible. The width of the lines forming the diamond must be at least 2 mm wide (this may be reduced to 1 mm if the mark is 50 x 50 mm). The top and bottom must be black and the center area should be white or a suitable contrasting background.



Notes:

Page 127

Special Marking and Labeling Situations, continued

The “Air” Limited Quantity Mark [IMDG 3.4.5.2]

If the package has been prepared in accor-dance with the requirements for air shipments (i.e., it meets the quantity limits and additional packaging provisions for air), then the “air eli-gible limited quantity mark” may be used in place of the ground/vessel version.



Notes:

Page 128


Excepted Quantities [IMDG 3.5]

Packages shipped as excepted quantities are excluded from ALL of the typical marking and label-ing requirements and must ONLY be marked with the excepted quantity mark.

• The * must be replaced with the hazard class or division of the materials.

• The ** must be replaced with the name of the shipper or receiver if this information is not found elsewhere on the package.

The hatching and symbol must be the same color, either black or red and the mark must be on a white or contrasting background. The minimum size permitted for the excepted quantity mark is 100 × 100 mm.



Notes:

Page 129


Labeling Fully Regulated Lithium Batteries [IMDG 5.2.2 and 3.3 Special Provision 384]

In addition to all other required marks and labels, packages containing fully regulated lithium batteries must be labeled with the Class 9 Lithium Battery label INSTEAD OF the “standard” Class 9 label.

NOTE: The “standard” Class 9 label was phased out for lithium battery shipments on January 1, 2019.



Notes:

Page 130


Marking Excepted Lithium Batteries [IMDG 3.3 and 5.2.1.10]

Packages containing lithium cells or batteries prepared in accordance with Special Provision 188 are excluded from ALL of the typical marking and labeling requirements and must ONLY be marked with the lithium battery mark. The mark contains both a single asterisk and a double asterisk at the bottom of the mark.

• The single asterisk must be replaced by ALL of the applicable UN number(s) for the type(s) of batteries being shipped. For example, if you were shipping lithium-ion batteries in equipment in the package, you would need to mark “UN 3481” on the package. If more than one type of battery/shipment is contained in the package (e.g., batteries with equipment and in equipment), then all applicable UN numbers must be used.

• The double asterisk must be replaced with a phone number that can be called for additional information about the shipment.

The mark must be a minimum of 120 mm wide by 110 mm high, and the hatching must have a minimum width of 5 mm. The symbol must be black on white or suitable contrasting background, and the hatching must be red. If the size of the packaging requires a smaller mark, the mark may be reduced to 105 mm wide by 74 mm high.



Notes:

Page 131


Class 6.2 Infectious Substances, Biological Substance, Category B [IMDG 4.1.4 Packing Instruction P650]

Packages containing Category B infectious substances must be marked with:

• The Proper Shipping Name “BIOLOGICAL SUBSTANCE, CATEGORY B.”

• The UN number “UN 3373” inside a diamond-shaped mark.

The Proper Shipping Name and “UN 3373” must be in letters and numbers at least 6 mm high. The diamond-shaped mark must have minimum dimensions of 50 mm by 50 mm, and the outer line of the mark must be at least 2 mm wide. The mark must be set at an angle of 45° (on-point), and the Proper Shipping Name must be adjacent to the diamond-shaped mark.



Notes:

Page 132


Marking Packagings Containing a Coolant or Conditioner [IMDG 5.5.3.4]

In addition to any other required marks, packages containing dangerous goods used for cooling or conditioning must be marked with the Proper Shipping Name of these dangerous goods, followed by the words “AS COOLANT” or “AS CONDITIONER” as applicable.

NOTE: The marks must be durable, legible, and placed in a location and of such a size to be readily visible.



Notes:

Page 133


Labeling Corrosives and Poisons [IMDG 5.2.2.1.3.1]

Packages containing Class 8 materials do not need a subsidiary hazard label for Class 6.1 if the toxicity of the material arises solely from the destructive effect on tissue.

Labeling Spontaneously Combustible and Flammable Solids [IMDG 5.2.2.1.3.1]

Packages containing Class 4.2 materials do not need to be labeled with a subsidiary hazard label for Class 4.1.

Labeling Self-reactive Substances [IMDG 5.2.2.1.9]

An EXPLOSIVE subsidiary hazard label must be applied for Type B self-reactive sub-stances, unless the competent authority allows omitting it for a specific packaging.

Labeling Organic Peroxides [IMDG 5.2.2.1.10]

The Class 5.2 label must be affixed to pack-ages containing organic peroxides classified as Types B, C, D, E, or F.

The following special requirements apply to packages containing organic peroxides:

• The Class 5.2 label implies that the product may be flammable, so a FLAM-MABLE LIQUID subsidiary hazard label is not required when the package is labeled with the “5.2” label.

• An EXPLOSIVE subsidiary hazard label is required for Type B organic perox-ides, unless the competent authority allows omitting it for a specific pack-aging.

• A CORROSIVE subsidiary hazard label is required when Packing Group I or II criteria of Class 8 are met.

Labeling Class 2 Materials

Special labeling requirements for pack-ages containing compressed gases are found at IMDG 5.2.2.1.4 and 5.2.2.1.5.

Marking and Labeling Radioactive Materials [IMDG 5.2.1.5 and 5.2.2.1.12]

Marking requirements for packages con-taining radioactives can be found at IMDG 5.2.1.5. These requirements include marking the packages with:

• The shipper’s and/or the receiver’s name and address.

• The permissible gross mass if the gross mass of the package exceeds 50 kg.

• Packaging type indications.

• The trefoil symbol.



Notes:

Page 134


Special labeling requirements for packages containing radioactive materials are found at IMDG 5.2.2.1.12. These requirements include labeling the packages with:

• The contents.

• The activity.

• The transport index.

Empty Packagings [IMDG 5.1.3]

An “empty” packaging that previously contained dangerous goods must be marked and labeled as required for those dangerous goods unless any hazard has been “nullified.”

If all hazards have been nullified, any marks or labels indicating that it had con-tained dangerous goods must be removed or obliterated.

Additional DOT Requirements [49 CFR 171.23 and 171.25]

The DOT has additional marking require-ments that must be met for certain hazardous materials, even when shipping packages under the IMDG Code. Materials subject to additional DOT marking requirements include:

• Hazardous materials shipped in cyl-inders.

• Hazardous substances.

• Hazardous wastes.

• Organic peroxides.

• Poisonous by inhalation hazards.

Additional Marks [IMDG 5.2 Note]

Additional marks or symbols indicating precautions to be taken in handling or storing a package may be displayed on a package, if appropriate. For example, a symbol represent-ing an umbrella could be used to indicate that the package needs to be kept dry.



Page 135

MARKING REQUIREMENTS FOR OVERPACKS, UNIT LOADS, AND SALVAGE PACKAGING

Overpacks and Unit Loads [IMDG 5.1.2]

Unless the marks and labels of all the dangerous goods inside the overpack or unit load are visi-ble, the overpack or unit load must be marked with:

• All applicable marks and labels required on the inside packages (Proper Shipping Name, UN number, orientation arrows, limited quantity mark, etc.).

• The word “OVERPACK” in lettering at least 12 mm high.

NOTE: Do NOT reproduce the packagings’ UN specification codes on the outside of the overpack or unit load device. The word “OVERPACK” signifies that the inside packages are authorized packages and are in full compliance with all applicable regulations.



Notes:

Page 136

Marking Requirements for Overpacks, Unit Loads, and Salvage Packaging, continued

Salvage Packagings [IMDG 5.2.1.3]

All salvage packagings must be additionally marked with the word “SALVAGE” in letters at least 12 mm high.



Step 5—Documentation



CONTENTS

Step 5—Documentation ....................................................................................................137

Standard Transport Document Descriptions .................................................................139

Indicating Quantities on Transport Documents ............................................................141

Modifying the Dangerous Goods Description ...............................................................142

Shipper’s Certification .......................................................................................................148

DOT Emergency Response Information .........................................................................149

Additional Documentation Requirements .....................................................................152

Retention of Shipping Papers ...........................................................................................154



Notes:

Page 137

STEP 5—DOCUMENTATIONInformation the Shipper Must Provide

IMDG 5.4



IMDG 5.4 Rules for transport documents

IMDG 5.4.2–5.4.4

Additional documentation requirements

IMDG 5.5 Special provisions for certain shipments

49 CFR 172, Subpart C

Rules for shipping papers

49 CFR 172, Subpart G

Rules for providing emer-gency response information


The fifth step in the shipping process is to create transport documents to accompany the shipment. Unless a specific exception applies, the shipping papers must include:

• A description of the dangerous goods and any necessary additional descriptions.

• The total quantity of the dangerous goods being shipped.

• The number and kind (e.g., drum, box) of packages being shipped.

• The name and address of the shipper and the receiver.

• The date that the dangerous goods trans-port document, or an electronic copy of it, was prepared or was given to the initial carrier.

• A shipper’s certification.

If the transport document consists of more than one page, then each page must be consec-utively numbered.

Emergency Response Information

Typically, the US DOT requires specific emergency response information to accom-pany all dangerous goods shipments either on or with the transport document.

No Standardized Form Required

The IMDG Code does not require shippers to use a standardized form. A transport docu-ment may be:

• A bill of lading.

• A hazardous waste manifest.

• A shipping order.

• An invoice.

• The IMO’s “Multimodal Dangerous Goods Form.” [IMDG Fig. 5.4.5]

• Any other form or document, provided it contains the information required by IMDG regulations for transport documents.



Notes:

Page 138

Step 5—Documentation, continued


To properly complete transport docu-ments, you must know:

• The dangerous good’s hazard class(es), severity (packing group), Proper Ship-ping Name, and UN number.

• The number and type of packages be-ing shipped.

• The name and address of the shipper AND receiver.

• The total quantity of dangerous goods being shipped.

• Whether the dangerous goods meet the definitions of:

– Wastes,

– Marine pollutants, or

– Elevated-temperature materials.

• Whether the dangerous goods are being shipped under a “limited quantity” or “excepted quantity” exception.

Other Documentation May Be Required

In addition to the transport document and the emergency response information, additional documentation may be required for shipments of dangerous goods. This docu-mentation could include:

• Container/vehicle packing certificates.

• Special lists or manifests.

• Weathering certificates.



Notes:

Page 139

STANDARD TRANSPORT DOCUMENT DESCRIPTIONS

Entries on Transport Documents [IMDG 5.4.1.2]

Except as otherwise provided in the IMDG Code, the person who offers dangerous goods for transport must describe the dangerous goods on a transport document. Regardless of the form used, information on a transport doc-ument must be:

• Easy to identify.

• Legible.

• Durable.

If both dangerous goods and non-dangerous goods are listed in the same document, then the dangerous goods must be listed—or otherwise emphasized—first, before the non-dangerous goods.

NOTE: The US DOT requires that the informa-tion be in English.

The Basic or Dangerous Goods Description [IMDG 5.4.1.4]

The dangerous goods transport document must contain ALL of the following elements, in the order shown, for each dangerous good offered for transport:

1. The UN number, as shown in Column 1 of the 3.2 Dangerous Goods List.

2. The Proper Shipping Name, from Col-umn 2 of the 3.2 Dangerous Goods List (supplemented with technical names where applicable).

3. The primary hazard class, as shown in Column 3 of the 3.2 Dangerous Goods List.

– Any assigned subsidiary hazard class(es) as shown in Column 4 of the 3.2 Dangerous Goods List and any other subsidiary hazards required (subsidiary hazards must be enclosed in parentheses).

4. The packing group, as shown in Column 5 of the 3.2 Dangerous Goods List, in Ro-man numerals.

Examples

UN 1790; Hydrofluoric acid; 8 (6.1); II

UN 1090; Acetone; 3; II

Optional Modifications to the Basic Description

The following modifications may be made to the basic description:

• The letters “PG” may be included preced-ing the packing group.



Notes:

Page 140

Standard Transport Document Descriptions, continued

• The word “Class” or “Division” may be included preceding the primary and/or subsidiary hazards.

• When technical names are used, appro-priate modifiers such as “contains” or “containing” and/or the percentage of the constituent may also be used.

NOTE: Additional modifications are also allowed to be made to the Proper Shipping Name itself (singular vs. plural, addition of uncapitalized text, etc.).

Adding Information to the Dangerous Goods Description [IMDG 5.4.1.5]

Unless specifically permitted or required by the IMDG Code, additional information must be placed AFTER the dangerous goods description.

Examples of Basic Descriptions (Including Optional Modifications)

IMDG Shipping Description

UN 2796, SULPHURIC ACID, CLASS 8, II

UN 2796, Sulphuric Acid with not more than 51% acid, 8, PG II

UN 1745, Bromine pentafluoride, 5.1 (6.1, 8), PG I

UN 3066/Paint related material/8/II

UN1090 - Acetone - 3 - PG II

UN1790; Hydrofluoric acid; 8 (6.1); PG II

UN 1790 Hydrofluoric acid Class 8 (Class 6.1) II

UN 2794, Battery, wet, filled with acid electric storage, 8

UN1203, Gasoline, Class 3, PG II

UN1993; Flammable Liquids, n.o.s. (xylene, heptane); 3; PG II

UN1993; Flammable Liquids, n.o.s. (15% xylene and 15% heptane); 3; PG II

UN1993; Flammable Liquids, n.o.s. (containing xylene and heptane); 3; PG II

NOTE: The various elements of the basic description may be separated by spaces, commas, semico-lons, or any other appropriate form of punctuation.



Notes:

Page 141

INDICATING QUANTITIES ON TRANSPORT DOCUMENTSIMDG 5.4.1.5.1

Indicating Total Quantity

Except for empty uncleaned packagings, the total quantity of dangerous goods covered by the dangerous goods description must be entered on the transport document for each type of dangerous goods AFTER the basic description. When indicating quantities:

• Metric units must be used.

• The total quantity may be indicated as either mass or volume and may be either gross or net.

NOTE: When shipping explosives, the quan-tity must be the net explosive mass.

• Abbreviations may be used to express the unit of measurement for total quantity.

For dangerous goods transported in sal-vage packagings, an estimate of the quantity of dangerous goods may be given.

Indicating Number and Type of Packages

The number and type of packages must be indicated for each shipping description on the transport document (e.g., drum, box) AFTER the basic description. This information may be supplemented with the UN specification pack-aging code (e.g., “4G” for a fibreboard box), but UN specification packaging codes cannot be used by themselves to describe packag-ing types.

Examples

12 steel drums or 12 steel drums (1A1)

15 fibreboard boxes or 15 4G fibreboard boxes



Notes:

Page 142

MODIFYING THE DANGEROUS GOODS DESCRIPTION

Generic and N.O.S. Shipping Descriptions [IMDG 5.4.1.4.3.1]

Proper Shipping Names that are assigned Special Provision 274 or 318 in Column 6 of the 3.2 Dangerous Goods List must be supplemented with technical or chemical group names. If the material is a mixture, then at least the two components that most predominantly contribute to the hazard(s) must be included.

The technical or chemical names must be placed in parentheses immediately following the Proper Shipping Name. If a subsidiary hazard label is required, the technical names must include the constit-uent that requires the use of the subsidiary label(s).


UN 1760 / Corrosive liquids, n.o.s. (Potassium Hydroxide and Sodium Hydroxide) / 8 / II

UN 1760, Corrosive liquids, n.o.s. (Potassium Hydroxide and Sodium Hydroxide Solution), 8, II

UN 2922 / Corrosive liquids, toxic n.o.s. (contains Potassium Hydroxide and Potassium Arsenite) / 8 (6.1)/ II

UN 3143; Dye, solid, toxic, n.o.s. (methyl orange); 6.1; III

UN 2761, ORGANOCHLORINE PESTICIDE, SOLID, TOXIC (Aldrin 19%), Class 6.1, PG III

UN 2814, Infectious substance, affecting humans (Monkeypox virus), Class 6.2



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Modifying the Dangerous Goods Description, continued

Dangerous Goods With Flash Points At or Below 60°C [IMDG 5.4.1.4.3.6]

If the dangerous goods being transported have a flash point ≤ 60°C (in °C closed cup (c.c.)), the minimum flash point must be indicated in parentheses following the basic description. The letters “c.c.” should be included to indicate the “closed cup” testing method.

NOTE: The flash point does not need to be indicated for Class 5.2 organic peroxides that are also flammable.


UN 1230, Methanol, CLASS 3 (CLASS 6.1), II (12°C c.c.)

UN 1263, Paint Related Materials, Class 3, II, (–6°C c.c.)

UN 1993, Flammable liquids, n.o.s. (toluene, acetone), 3, PG II (2°C c.c.)

Limited Quantities [IMDG 5.4.1.5.2]

The words “LIMITED QUANTITY” or “LTD QTY” must be included after the dangerous goods description when shipping materials under the exceptions allowed for dangerous goods packed in limited quantities at IMDG 3.4.


UN 1993, Flammable liquids, n.o.s. (toluene, acetone), 3, PG II (2°C c.c.) LIMITED QUANTITY

UN 3495, Iodine, 8 (6.1), III Limited Quantity

UN 2052, Dipentene, Class 3, PG III (43°C c.c.) Ltd Qty



Notes:

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Marine Pollutants [IMDG 5.4.1.4.3.5]

Marine pollutants must be identified with the words “MARINE POLLUTANT” following the basic description. The term “marine pollutant” may be supplemented with the term “ENVIRON-MENTALLY HAZARDOUS.” In addition, if shipping the marine pollutant under a generic or N.O.S. name, the Proper Shipping Name must be supplemented with the recognized chemical name of the marine pollutant.

NOTE: Marine pollutants in single packages containing less than or equal to 5 L or 5 kg or combina-tion packages with inner packagings that contain less than or equal to 5 L or 5 kg are not required to be identified by the words “MARINE POLLUTANT” on shipping documents. [IMDG 2.10.2.7]


UN 1092, Acrolein, stabilized, Class 6.1 (3), PG I, (–24°C c.c.) Marine Pollutant/Environmentally Hazardous

UN 1866, Resin solution (Dipentene), 3, III (35°C c.c.) MARINE POLLUTANT

UN 2761, ORGANOCHLORINE PESTICIDE, SOLID, TOXIC (Aldrin 19%), Class 6.1, PG III, MARINE POLLUTANT Environmentally Hazardous

Segregation Groups for Substances [IMDG 5.4.1.5.11]

A segregation group must be indicated after the basic description if the following three condi-tions are met:

1. The dangerous good is being shipped under an N.O.S. entry,

2. The material falls into one of the 18 segregation groups found at IMDG 3.1.4, and

3. The Proper Shipping Name is not already listed under that segregation group.


UN 2922; Corrosive liquid, toxic, n.o.s. (Isobutyric anhydride); 8; II; IMDG Code Segregation Group 1 – Acids



Notes:

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Empty Uncleaned Packagings [IMDG 5.4.1.4.3.2]

Empty means of containment (including packagings, IBCs, road tank vehicles, and railway tank wagons) that contain the residue of dangerous goods of any hazard class other than Class 7 must be identified as such on the transport document with the words “EMPTY UNCLEANED” or “RESIDUE LAST CONTAINED” before or after the dangerous goods description.


UN 1090, Acetone, Class 3, PG II (–20°C c.c.) Residue Last Contained

Residue Last Contained UN 1790, Hydrofluoric acid, 8 (6.1), II

Wastes [IMDG 5.4.1.4.3.3]

The word “WASTE” must precede the Proper Shipping Name of waste dangerous goods (other than radioactive wastes) that are transported for disposal or for processing for disposal (unless the word is already part of the shipping name).

NOTE: The US DOT requires that the word “WASTE” be added to all materials that meet the DOT definition of hazardous waste (at 49 CFR 171.8) regardless of whether or not the material is being transported for disposal or for processing for disposal. [49 CFR 172.101(c)(9)]


UN 1090, Waste Acetone, Class 3, PG II (5°C c.c.)

UN 1790, Waste Hydrofluoric acid, 8 (6.1), II

UN 1263, WASTE PAINT RELATED MATERIALS, CLASS 3, II, (–6°C c.c.)



Notes:

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Elevated-temperature Materials [IMDG 5.4.1.4.3.4]

If the Proper Shipping Name of an “ele-vated-temperature material” does not indi-cate the elevated-temperature condition (for example, by using the term “MOLTEN” or “ELEVATED TEMPERATURE” as part of the shipping name), the word “HOT” must imme-diately precede the Proper Shipping Name.

Excepted Quantities [IMDG 5.4.1.5.14]

When shipping excepted quantities, the words “dangerous goods in excepted quan-tities” and the number of packages must be included on the dangerous goods transport document.

NOTE: De minimus quantities of excepted quantity packages assigned to Codes E1, E2, E4, and E5 packaged according to IMDG 3.5.1.4 do not require documentation.

Salvage Packagings [IMDG 5.4.1.5.3]

The words “SALVAGE PACKAGING” or “SALVAGE PRESSURE RECEPTACLE” must be included when shipping dangerous goods in salvage packagings.

Substances Stabilized and Requiring Temperature Control [IMDG 5.4.1.5.4 and 5.4.1.5.5]

If the word “STABILIZED” is part of the Proper Shipping Name and the stabilization is by means of temperature control, or if the control and emergency temperatures must be indicated, then do as follows:

– “Control temperature: ...°C”

– “Emergency temperature: ...°C”

Infectious Substances [IMDG 5.4.1.5.6]

When shipping infectious substances, the full address of the receiver must be shown on the document along with the name and tele-phone number of a responsible person.

Aerosols [IMDG 5.4.1.5.8]

If the capacity of an aerosol is above 1,000 mL, this fact must be declared in the transport document.

Viscous Substances [IMDG 5.4.1.5.10]

Viscous substances transported in accor-dance with the reliefs at IMDG 2.3.2.5 must include the statement “Transport in accor-dance with 2.3.2.5 of the IMDG Code” on the transport document.



Notes:

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Fumigated Units [IMDG 5.5.2.4]

The transport document for a fumigated unit that has not been completely ventilated prior to transport must show the type and amount of fumigant used and the date and time of fumigation. Instructions for disposal of any residual fumigant must also be provided.

Cooled or Conditioned Cargo Transport Units [IMDG 5.5.3.7]

A transport document must accompany CTUs that have been cooled or conditioned and have not been completely ventilated before transport. The document must include:

• The UN number of the coolant or condi-tioner (preceded by the letters “UN”).

• The Proper Shipping Name followed by the words “AS COOLANT” or “AS CON-DITIONER,” as appropriate.

For example:

UN 1845, Carbon Dioxide, Solid, AS COOLANT

Other Requirements for Additional Information

Additional information is also required for shipments of:

• Self-reactive substances, polymeriz-ing substances, and organic peroxides. [IMDG 5.4.1.5.5]

• Radioactive materials. [IMDG 5.4.1.5.7]

• Explosives. [IMDG 5.4.1.5.9]

• Materials subject to 7.2 segregation provi-sions. [IMDG 5.4.1.5.11]

• Solid dangerous goods transported in bulk containers. [IMDG 5.4.1.5.12]

Required DOT Modifications [49 CFR 171.23]

Reportable Quantities

If a single package contains a reportable quantity or more of a hazardous substance listed in Appendix A of the 49 CFR 172.101 Table, then the letters “RQ” should be included before or after the dangerous goods descrip-tion. In addition, if it is not evident by the Proper Shipping Name, the technical constitu-ent name of the hazardous substance must be indicated at the end of the basic description. [See 49 CFR 172.203(c).]

Other DOT Shipping Paper Requirements [49 CFR 171.23(b)(2), (b)(10), and (b)(11)]

The DOT has additional shipping paper requirements for:

• Safety devices for vehicles, vessels, or aircraft (e.g., airbags).

• Poisonous by inhalation materials.

• Radioactive materials.



Notes:

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SHIPPER’S CERTIFICATIONIMDG 5.4.1.6

Every dangerous goods transport docu-ment must include a certification statement and signature.

Certification Statement

By signing a shipper’s certification on a dangerous goods transport document, you are certifying that you “hereby declare”:

• The shipment is accurately described, correctly classified and packaged, and the hazards are identified and communicated correctly according to the regulations.

• The shipment is in all respects in proper condition for transport according to ap-plicable regulations.

The certification does NOT include any clarifying statement like “to the best of my knowledge” or “I believe.” In other words, a “good-faith effort” is NOT enough!

Signatures

The certification statement must be signed and dated by the shipper. In the United States, only those hazmat employees who are fully trained in accordance with 49 CFR 172, Subpart H may sign the certification on a dangerous goods shipping paper. Facsimile (“mechani-cal”) signatures are acceptable where appli-cable laws and regulations recognize the legal validity of facsimile signatures.

NOTE: The United States allows facsimile sig-natures.

If the dangerous goods documentation is presented to the carrier by means of electronic data processing (EDP) or electronic data inter-change (EDI) transmission techniques, the sig-nature(s) may be replaced by the name(s) (in capitals) of the person authorized to sign.

* as appropriate

Shipper’s Certification:

“I hereby declare that the contents of this consignment are fully and accurately described above/below* by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for trans-port according to applicable international and national government regulations.” [IMDG 5.4.1.6.1]



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DOT EMERGENCY RESPONSE INFORMATION49 CFR 172, Subpart G

Emergency response information must be provided by the shipper in written form and maintained by the carrier throughout trans-portation. The information must be provided either on or with the shipping papers. In addi-tion, shipping papers must show an emergency response telephone number, provided by the shipper, for use in the event of an emergency.

NOTE: Almost any time hazardous materials are offered for transportation, transported, received, stored incidental to transportation, or otherwise handled during transportation, this information must be IMMEDIATELY available for use, and must be immediately available to government representatives responding to or investigating an incident.

Exceptions to the Emergency Response Information Requirements [49 CFR 172.600(d)]

Shipments Excluded from ALL of 49 CFR 172, Subpart G

The emergency response information and telephone number requirements of 49 CFR 172, Subpart G do not apply to any shipment that is not required to have shipping papers. Mate-rials excepted from shipping paper require-ments UNDER DOT include:

• Limited quantities, unless material is a hazardous substance or marine pollutant (49 CFR 171.8 and 173.150–155).

• Excepted small quantities (49 CFR 173.4).

• Wet batteries packaged under 49 CFR 173.159(d) or (e).

• Devices containing mercury packaged under 49 CFR 173.164(b) or (c).

• Engines, vehicles, or equipment contain-ing fuels or batteries, packaged under 49 CFR 173.220 and transported by rail or highway only.

• Carbon dioxide, solid (dry ice) packaged under 49 CFR 173.217.

NOTE: Materials excluded from DOT require-ments for shipping papers may still require transport documents when shipped by vessel under IMDG rules (e.g., limited quantity ship-ments require shipping papers under IMDG). Since they are excluded from DOT shipping paper requirements, though, they are still excluded from DOT emergency response information requirements when shipped by vessel, even if other rules require them to be described on a transport document.

Shipments Excluded from Emergency Response Telephone Number Requirement

Shipping papers are not required to include an emergency response telephone number for:

• Materials properly shipped under the shipping names listed at 49 CFR 172.604(d)(2);

• Materials shipped as limited or excepted quantities.



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DOT Emergency Response Information, continued

Emergency Response Information Content [49 CFR 172.602(a)]

Emergency response information is intended to help emergency responders miti-gate emergencies involving hazardous mate-rials that occur during transport. It is distinct from and IN ADDITION TO material descrip-tions on shipping papers.

Emergency response information must include, at a minimum:

• The basic description and technical name of each hazardous material.

• Immediate hazards to health.

• Risks of fire or explosion.

• Immediate precautions to be taken in the event of an accident or incident.

• Immediate methods for handling fires.

• Initial methods for handling spills or leaks in the absence of fire.

• Preliminary first-aid measures.

Providing Emergency Response Information [49 CFR 172.602(b)]

Emergency response information must be printed legibly in English and must be avail-able for use away from the package. There are three options for presenting or providing the required information:

1. On the shipping paper itself.

2. In a document other than the shipping paper, that includes the basic description and technical name of the material (if re-quired by 49 CFR 172.202 and 172.203(k)), and the emergency response information.

– This might be a Safety Data Sheet or other document (e.g., photocopy the appropriate page from the DOT’s Emer-gency Response Guidebook (ERG), add the basic description and technical name, and attach the page to the ship-ping paper).

3. In a separate document that cross-references the basic description of the hazardous material on the shipping paper, such as the DOT’s Emergency Response Guidebook.

The Emergency Response Telephone Number [49 CFR 172.604(a)]

Anyone who offers hazardous materials for transportation is responsible for providing the emergency response telephone number. The phone number is required so that emer-gency responders can get more specific infor-mation about hazardous materials during transportation incidents.



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DOT Emergency Response Information, continued

Requirements for the Phone Number

There are three basic requirements for the emergency response phone number:

1. It must be entered on the shipping paper. The number must appear:

• Immediately following the description of the material. This option allows the shipper to provide separate numbers for each material if they need to.

• In a single “clearly visible location” on the shipping paper if the same tele-phone number applies to all the haz-ardous materials on the shipping paper (for example: “IN CASE OF EMER-GENCY, CONTACT:”).

• In Block #3 on the Uniform Hazardous Waste Manifest.

2. It must be monitored at all times the haz-ardous material is in transportation (24 hours/day, if necessary).

3. It must be the number of a person who is knowledgeable of the hazards and char-acteristics of the hazardous material being shipped and who has comprehensive emergency response and incident mitiga-tion information for the material.

The number may be answered by:

• Someone who immediately “patches” through to the knowledgeable person.

• An organization or person who accepts responsibility for providing the infor-mation required (e.g., a commercial service).

Regardless of who actually answers the phone and provides the information, the ship-per must ensure that the person answering the phone number has received current informa-tion on the material before it is offered for trans-portation. [49 CFR 172.604]

Shipper’s Name Required for Telephone Number [49 CFR 172.604(b)]

If the shipper’s name is not otherwise read-ily available and clearly visible somewhere on the shipping papers, then either:

• The shipper’s name must be entered be-fore, after, above, or below the emergency response phone number, or

• The shipper’s contract number must be entered with a third-party provider’s phone number.

Example:

A freight forwarder receives a shipment and then reships it on a new shipping paper using the emergency response telephone number from the previous documentation. The original shipper’s name or contract number would need to be added to the new shipping paper, near the telephone number.



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ADDITIONAL DOCUMENTATION REQUIREMENTSIMDG 5.4.2–5.4.4

Container/Vehicle Packing Certificate [IMDG 5.4.2]

If dangerous goods are packed or loaded into a container or a vehicle, those responsible for doing the packing must provide a “con-tainer/vehicle packing certificate.”

This certificate specifies the container or vehicle identification number and certifies that the operation was carried out in accor-dance with, among other things, the following conditions:

• The container/vehicle was clean, dry, and apparently fit to receive the goods.

• Packages that needed to be segregated have not been packed together.

• All packages were inspected for damage and only sound packages were loaded.

• Drums have been stowed in an upright position.

• All goods have been properly loaded and, where necessary, adequately braced with securing material to suit the modes of transport for the intended journey.

• Goods loaded in bulk were evenly distrib-uted within the container/vehicle.

• The container/vehicle was properly marked, labeled, and/or placarded.

• If coolant was used, the CTU was proper-ly marked.

• A dangerous goods document was re-ceived for each dangerous goods consign-ment loaded into the container/vehicle.

NOTE: This packing certificate is not required for portable tanks.

Other Required Information [IMDG 5.4.4]

Under certain circumstances, other special certificates or documents are required for ship-ments of dangerous goods, including:

• A weathering certificate (as required for individual entries on the IMDG 3.2 List of Dangerous Goods).

• A certificate exempting a substance from the provisions of the IMDG Code.

• A statement by the appropriate competent authority approving transport of “new” self-reactives and organic peroxides.



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Additional Documentation Requirements, continued

Documentation Required Aboard the Ship [IMDG 5.4.3]

Each ship carrying dangerous goods and marine pollutants must have a special list or manifest that describes the dangerous goods and marine pollutants. The list or manifest must be based on the documentation required under the IMDG Code and must, at the very least, contain for each dangerous good:

• The dangerous goods description and any required additional information.

• The stowage location.

• The total quantity present.

A copy of the list, plan, or manifest must be made available before departure to the person or organization designated by the port State authority.



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Page 154

RETENTION OF SHIPPING PAPERS

IMDG Shipping Paper Retention Requirements

The IMO requires shippers and carriers to retain copies of shipping documents for at least three months from the date the cargo is offered for shipment. [IMDG 5.4.6]

However, if the IMO dangerous goods form is used as the DOT shipping paper, then the shipper and transporter must follow the DOT’s record retention rules.

DOT Shipping Paper Retention Requirements [49 CFR 172.201(e)]

Shippers must keep a paper or electronic copy of all hazardous materials shipping papers for TWO years from the date the ship-ment was accepted for transportation by the initial carrier.

The DOT requires that shippers keep copies of hazardous waste shipping papers for at least THREE years from the date the waste was accepted by the initial carrier.

Carriers must keep a copy of the shipping paper for ONE year from the date it was pro-vided to them.

NOTE: The US EPA also requires generators, transporters, and the receiving treatment, stor-age, or disposal facility (TSDF) to keep copies of the hazardous waste manifest for at least three years. [40 CFR 262.40, 263.22, and 264.71]

Recordkeeping

Records must be made available for inspection by DOT representatives, at the prin-cipal place of business of the shipper.

Companies that provide shipping papers for shippers take on the responsibility of ship-ping paper retention.

Permanent Shipping Papers

The DOT provides some relief for a com-pany using a “permanent” shipping paper with the same shipping name and UN number for the materials they offer.

The company may keep a single copy of the shipping paper (instead of a copy for each shipment), as long as a running record is kept for each shipment made.



CONTENTS

Step 6—Placarding and Marking Cargo Transport Units ............................................155

Placarding Cargo Transport Units ...................................................................................156

Marking Cargo Transport Units .......................................................................................159



Notes:

Page 155

STEP 6—PLACARDING AND MARKING CARGO TRANSPORT UNITSWhat Must Be Displayed on a Cargo Transport Unit (CTU)?



IMDG 3.4 Requirements for limited quan-tities

IMDG 3.5 Requirements for excepted quantities

IMDG 5.3.1

Placarding cargo transport units

IMDG 5.3.2

Marking cargo transport units

IMDG 5.5 Special provisions for cargo transport units

49 CFR 171.22

Authorization and conditions for the use of international stan-dards and regulations

49 CFR 171.23 and

171.25

Additional requirements for the use of the IMDG Code


The sixth step in the dangerous goods shipping process is to placard and mark cargo transport units (CTUs). As part of this step, the shipper must determine:

• Whether placards and/or marks are re-quired for the cargo transport unit.

• Which placards and/or marks are required.

• How the placards and/or marks must be displayed.

Placards are generally affixed to the exte-rior surface of cargo transport units containing dangerous goods to provide a warning that the contents of the unit are dangerous goods and present hazards. In most cases, placards must be displayed on cargo transport units whenever they contain any quantity of dan-gerous goods.

In addition, cargo transport units may need to be marked with the Proper Shipping Name and UN number of their contents.


To properly placard and mark cargo trans-port units, you must know:

• The dangerous good’s hazard class(es), Proper Shipping Name, and UN number.

• Whether the unit contains elevated- temperature materials.

• Whether the unit contains marine pollutants.

• Whether the unit contains packages shipped as limited quantities.

• Whether the unit is a fumigated unit.



Notes:

Page 156

PLACARDING CARGO TRANSPORT UNITS

Definition of a Cargo Transport Unit (CTU)

Cargo transport unit: means a road transport tank or freight vehicle, a railway trans-port tank or freight wagon, a multimodal freight container or portable tank, or an MEGC. [IMDG 1.2.1]

General Placarding Provisions [IMDG 5.3.1.1.1]

Placards must be affixed to the exterior of a cargo transport unit to provide a warn-ing about the contents of the unit UNLESS the marks and/or labels affixed to the packages are clearly visible from the exterior of the cargo transport unit. In most cases, placards must be displayed on cargo transport units whenever they contain any quantity of dangerous goods.

Placards on cargo transport units must be able to withstand at least three months’ immer-sion in the sea and still remain identifiable.

NOTE: Placards must be removed from the cargo transport unit as soon as the danger-ous goods or their residues that triggered the requirements for the placards are removed from the unit.

Requirements for Placarding Primary and Subsidiary Hazards [IMDG 5.3.1.1.2 and 5.3.1.1.3]

With limited exceptions, placards must be displayed on cargo transport units for the pri-mary hazard of all the dangerous goods that they contain. Placards must also be displayed for the subsidiary hazards for each of the sub-stances or articles contained in the cargo trans-port unit when a subsidiary hazard label is required according to IMDG 5.2.2.1.2 (unless the hazard is already indicated by a primary hazard placard).

NOTE: These requirements differ from the regulations of the US DOT, which require subsidiary hazard placards only for specific hazards (e.g., Class 4.3 Dangerous When Wet Materials).

Placarding Exceptions [IMDG 3.5 and 5.3]

Placards are not required on cargo trans-port units carrying:

• Any quantity of explosives, Division 1.4, Compatibility Group S. [IMDG 5.3.1.1.2.1]

• Dangerous goods packaged in excepted quantities. [IMDG 3.5.1.1]



Notes:

Page 157

Placarding Cargo Transport Units, continued

• Dangerous goods packaged in limited quantities. [IMDG 5.3.2.4]

• Excepted packages of Class 7 radioac-tives. [IMDG 5.3.1.1.5]

In addition, only placards indicating the highest hazard need to be affixed to cargo transport units carrying dangerous goods of more than one division in Class 1.

Display of Placards [IMDG 5.3.1.1.4.1]

Cargo transport units containing danger-ous goods (or residues of dangerous goods) must clearly display placards on their exterior surfaces as follows:

Type of Cargo Transport Unit Location of Placards

Freight containers, semi-trailers, and portable tanks > 3,000 L

One on each side and each end of the unit

Portable tanks ≤ 3,000 L

On two opposing sides

Railway wagons At least one on each side

Multiple-compart-ment tanks contain-ing more than one dangerous substance or their residues

Along each side at the positions of the relevant compart-ments

Flexible bulk containers

At least two oppos-ing sides

Any other cargo transport unit

At least on both sides and on the back of the unit

Specifications for Placards [IMDG 5.3.1.2]

Except for Class 7 placards, a placard must:

• Be no smaller than 250 × 250 mm in size, with a line running 12.5 mm in-side the edge and parallel with it that is the same color as the symbol and/or number.

• Correspond to the label for the class of the dangerous goods with respect to color and symbol.

• Display the number of the class or division of the dangerous goods in the same manner as for labels (as described at IMDG 5.2.2.2). Digits on placards should be no less than 25 mm high.

NOTE: Since placards must conform to the same requirements as labels, text is not spe-cifically required on placards. Text that relates to the “nature of the hazard and precautions to be taken in handling” may be shown in the bottom half of the placard.

IMDG Placarding Specifications vs. DOT Placarding Specifications

In general, requirements for IMDG plac-ards and DOT placards are very similar. In fact, the requirements for symbols and class or division numbers are virtually identical. The main differences are:

• IMDG placards are required to conform to the same standards of color and sym-bols as IMDG labels. The DOT has sep-arate design requirements for labels and placards.



Notes:

Page 158

Placarding Cargo Transport Units, continued

• Text is not specifically required on IMDG placards. If provided, it can be in any language.

Placarding for Fully Regulated Lithium Batteries

When a Class 9 placard is required for shipments of fully regulated lithium batteries, the “generic” Miscellaneous Class 9 placard is used. There is no Class 9 Lithium Battery plac-ard that corresponds to the Class 9 Lithium Battery label.

Placarding Requirements for Radioactives (Class 7)

Specific requirements for placarding ship-ments of radioactives can be found at IMDG 5.3.1.1.5 and 5.3.1.2.2.

Placarding Requirements for Poison Gases and Poison Inhalation Hazards [49 CFR 171.23(b)(10)]

The US DOT hazardous materials regula-tions have special placarding rules for poison gases and poison inhalation hazards that must be followed, even when shipping a material under IMDG provisions.

Packages must be labeled or placarded with “POISON GAS” or “POISON INHALA-TION HAZARD” as required under 49 CFR 172, Subpart F, unless:

• The package is labeled or placarded with the appropriate Class 2.3 or Class 6.1 IMDG label or placard.

• The package is transported in a closed transport vehicle or freight container.

• The transport vehicle or freight contain-er is marked with the UN number of the hazardous material, as described at 49 CFR 172.313(c) (regardless of the total quantity of dangerous goods actually present).

• The transport vehicle or freight container is placarded as required under 49 CFR 172, Subpart F.

NOTE: Packages, freight containers, or trans-port vehicles may be placarded under the IMDG Code placard specifications for Class 2.3 or Class 6.1 in place of the DOT requirements for “POISON GAS” or “POISON INHALA-TION HAZARD” placards when moving within a single port area, including contiguous harbor. [49 CFR 171.25(d)(1)]



Notes:

Page 159

MARKING CARGO TRANSPORT UNITSIMDG 5.3.1 and 5.3.2

General Marking Provisions [IMDG 5.3.1.1.1]

Marks, signs, and orange panels must be affixed to the exterior of a cargo transport unit to provide a warning about the contents of the unit UNLESS the marks affixed to the pack-ages are clearly visible from the exterior of the cargo transport unit.

Marks, signs, and orange panels on cargo transport units must be able to withstand at least three months immersion in the sea and still remain identifiable.

NOTE: Marks, signs, and orange panels must be removed from the cargo transport unit as soon as the dangerous goods or their residues that triggered the requirements for them are removed from the unit.

Marking Tanks and Bulk Containers [IMDG 5.3.2.0 and 5.3.2.1]

Tanks and bulk containers are technically defined as cargo transport units. However, they are marked with the same two elements that all fully regulated packages need to have:

• The Proper Shipping Name

• The UN number

Marking Proper Shipping Names on Cargo Transport Units [IMDG 5.3.2.0]

In addition to tanks and bulk containers, any cargo transport unit containing packaged dangerous goods of a single commodity for which no placard, UN number, or marine pol-lutant mark is required must be marked with the Proper Shipping Name. Alternatively, cargo transport units containing packages of a single commodity may be marked with the commodity’s UN number in lieu of the Proper Shipping Name.

NOTE: When marking CTUs, generic and n.o.s. Proper Shipping Names do NOT need to be supplemented with technical names.

Specifications for Displaying Proper Shipping Names [IMDG 5.3.2.0.2]

Proper Shipping Names must be on a constrasting background and a minimum of 65 mm (~2.6 in.) high. On portable tanks with capacities ≤ 3,000 L, this may be reduced to 12 mm (~0.5 in.).



Notes:

Page 160

Marking Cargo Transport Units, continued

Marking UN Numbers on Cargo Transport Units [IMDG 5.3.2.1]

In addition to tanks and bulk containers, the UN number shall be displayed on the fol-lowing cargo transport units (except for dan-gerous goods of Class 1):

• Packaged dangerous goods that have been loaded into a cargo transport unit in excess of 4,000 kg gross mass, when only one UN number has been assigned to the goods and they are the only dangerous goods in the unit.

• Unpackaged LSA-I or SCO-I material of Class 7 in or on a vehicle or in a freight container or a tank.

• Packaged radioactives with a single UN number under exclusive use in, or on, a vehicle or in a freight container.

Specifications for Displaying UN Numbers [IMDG 5.3.2.1.2]

The UN number must be displayed in black digits not less than 65 mm (~2.6 in.) high, either:

• Against a white background in the lower half of the primary hazard class placard; or

NOTE: Under DOT regulations, when the UN ID number is displayed on a placard, the box in which the number is displayed is essentially in the middle of the placard. In addition, DOT requirements do not allow the UN ID number to be placed on “Explosive” or “Radioactive” placards, while the IMDG requirements allow the UN number to be placed on ANY placard.

• On an orange rectangular panel not less than 120 mm high and 300 mm wide.

– The panel must be placed immediate-ly adjacent to each placard or marine pollutant mark. When no placard or marine pollutant mark is required, then the UN number must be displayed im-mediately adjacent to the Proper Ship-ping Name.

NOTE: When used on portable tanks with capacities ≤ 3,000 L, the orange panel may be of an “appropriately reduced size” and have characters not less than 25 mm high.



Notes:

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Marking Requirements for Units Containing Limited Quantities [IMDG 5.3.2.4 and 3.4.5.5]

Cargo transport units containing only dangerous goods packaged in limited quanti-ties must be marked on their exteriors with the “LIMITED QUANTITY” mark where placards would otherwise be displayed (as described at IMDG 5.3.1.1.4.1). This mark must have mini-mum dimensions of 250 × 250 mm.

Cargo transport units containing only dangerous goods packaged in limited quan-tities DO NOT need to be marked with the Proper Shipping Name, or the UN number, of the dangerous goods they contain.

Marking Requirements for Units Containing Marine Pollutants [IMDG 5.3.2.3]

Cargo transport units containing marine pollutants must clearly display the marine pollutant mark in the same locations as any required placards, UNLESS the unit contains packages that are exempted from the marine pollutant mark.

The marine pollutant mark must conform to the specifications at IMDG 5.3.2.3.2 and have sides at least 250 mm long, except that on portable tanks with a capacity of ≤ 3,000 L, the mark must be at least 100 mm on each side.

Exceptions for Small Packages [IMDG 2.10.2.7]

The marine pollutant mark is not required for:

• Dangerous goods packed in limited or excepted quantities.

• Single packages containing less than or equal to 5 L or 5 kg.

• Combination packages with inner pack-agings that contain less than or equal to 5 L or 5 kg.



Notes:

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Marking Requirements for Fumigated Units [IMDG 5.5.2.1 and 5.5.2.3]

The Proper Shipping Name (FUMI-GATED CARGO TRANSPORT UNIT) and the UN number (UN 3359) are NOT required on fumigated units that contain no other danger-ous goods.

If a fumigated unit is loaded with danger-ous goods IN ADDITION to the fumigant, any marks, placards etc. required for those contents by IMDG 5.3.1 through IMDG 5.3.2.4 must be marked on the outside of the fumigated unit.

The Fumigation Warning Sign

Closed fumigated units must be marked with the “fumigation warning mark,” affixed in a location where it will be easily seen by anyone attempting to enter the interior of the unit. The sign must be removed when the fumigated unit has been ventilated to remove harmful concentrations of the fumigant gas and the fumigated goods or materials have been unloaded.

The fumigation warning sign must be rect-angular and not less than 400 mm wide and 300 mm high. The outer line must be at least 2 mm wide. The marks must be in black print on a white background, with the lettering not less than 25 mm high. The marks must be able to survive at least three months immersed in the sea and still be identifiable.

Marking Requirements for Units Containing Elevated-temperature Substances [IMDG 5.3.2.2]

Cargo transport units containing elevated-temperature substances shall bear the elevated-temperature mark on each side and on each end. The triangular mark must have sides of at least 250 mm and must be in red. On a portable tank with a capacity of ≤ 3,000 L, the mark can be reduced to 100 mm a side.

In addition to the elevated-temperature mark, the maximum temperature that the substance is expected to reach during transport must be durably marked on both sides of the portable tank or insulation jacket. The temperature should be marked immediately adjacent to the elevated-temperature mark in characters at least 100 mm high.



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Marking Requirements for Units Containing Asphyxiants Used for Cooling or Conditioning [IMDG 5.5.3]

The IMDG Code has special rules for mark-ing CTUs that contain substances that pose a risk of asphyxiation when used for cooling or con-ditioning purposes. Common examples of these kinds of materials would be:

• UN 1845, Carbon dioxide, solid (dry ice)

• UN 1977, Nitrogen, refrigerated liquid

• UN 1951, Argon, refrigerated liquid

Cargo transport units containing danger-ous goods used for cooling or conditioning must be marked with a specific warning mark.

The warning mark must be at least 150 mm wide and 250 mm high. It must include:

• The word “WARNING” in red or white lettering at least 25 mm high.

• The Proper Shipping Name of the materi-al in place of the “*”:

– In capital letters,

– All on one line,

– In lettering at least 25 mm (~0.5 in.) high. (The size of the Proper Shipping Name may be reduced to fit on one line.)

• The words “AS COOLANT” or “AS CONDITIONER” in place of the “**” as appropriate:

– In capital letters,

– All on one line,

– In lettering at least 25 mm high.

The mark must be able to survive at least three months immersed in the sea and still be identifiable. It must remain in place until the CTU has been ventilated to remove harmful concentrations of the substance and the cooled or conditioned goods have been unloaded.



CONTENTS

Step 7—Transport Operations ..........................................................................................165

Packing Cargo Transport Units ........................................................................................166

Dangerous Goods Segregation .........................................................................................170

Dangerous Goods Stowage ...............................................................................................173



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STEP 7—TRANSPORT OPERATIONSHow Do We Get the Stuff to Its Destination Safely?



IMDG 3.2 Dangerous Goods List

IMDG 5.1

Consignment procedures: general provisions

IMDG 7.1 General stowage

IMDG 7.2 General segregation

IMDG 7.3 Cargo transport units

IMDG 7.4

Stowage and segregation on containerships

IMDG 7.5

Stowage and segregation on ro-ro ships

IMDG 7.6

Stowage and segregation on general cargo ships

IMDG 7.7 Shipborne barges on barge-carrying ships

IMDG Supplement

Guidelines for packing CTUs

IMDG 1.1.3, 3.3.1, and 7.1.3 Forbidden dangerous goods

49 CFR 173, Subparts C, D,

and I

Classifying hazardous materials

49 CFR 173.21, 173.24, and

173.54

Forbidden hazardous materials

49 CFR 174 Carriage by rail

49 CFR 177 Carriage by highway


The IMDG Code includes detailed require-ments for:

• Consolidating dangerous goods.

• Segregating dangerous goods.

• Loading and unloading dangerous goods.

• Stowing dangerous goods.

The DOT regulations at 49 CFR 171.25(b)(2) allow hazardous materials to be “stowed and segregated” according to the IMDG Code in lieu of applicable 49 CFR rules. The DOT still requires compliance with such rules as 49 CFR Part 174 (rail carriers) and Part 177 (motor vehicle carriers) for the actual transpor-tation by modes other than vessel.

Shipper vs. Carrier Responsibility

In general, compliance with segrega-tion, stowage, and other requirements is the responsibility of the vessel operator. However, these rules may influence and be influenced by shippers’ activities, particularly where ship-pers pack their hazardous material in cargo transport units or otherwise pack two or more materials together. Packing two materials with different stowage or segregation require-ments together can limit or even eliminate the options for stowing that shipment on board a ship. Ignoring these issues could cause delay or rejection of shipments by vessel carriers.



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Page 166

PACKING CARGO TRANSPORT UNITS

Consolidating Dangerous Goods Packages

There are generally two types of devices that can be used to consolidate packages for vessel shipment:

1. Overpacks or unit load devices.

2. Cargo transport units.

Overpacks or Unit Load Devices

Overpacks or unit loads are units or devices that are used by a single shipper to consolidate packages in one particular shipment for the convenience of handling and stowage during transport. Examples of overpacks include:

• Packages stacked on a pallet and banded, tied, or stretch-wrapped in place.

• Complete IMDG packages placed in a protective outer package such as a crate or pallet-box.

• Packages secured together in a sling.

Cargo Transport Units (CTUs)

Cargo transport units are relatively per-manent, reusable devices that are used repeat-edly to consolidate shipments. Examples of cargo transport units include:

• Intermodal freight containers.

• Freight trucks or trailer bodies.

• Rail cars.

Packing Requirements for CTUs [IMDG 7.3.3]

Requirements for packing cargo transport units are found in Chapter 7.3 of the IMDG Code. Specific rules include:

• Packages within a cargo transport unit must be tightly packed and adequately braced and secured.

• Cargo must be uniformly distributed.

• In a mixed load of dangerous/non- dangerous goods, the dangerous goods should be accessible (e.g., near the doors).

• Locked CTUs must be able to be “opened without delay” in an emergency.

• The CTU must be examined for damage before loading.

• Packages must be examined for damage, leaking, or sifting before loading.



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Packing Cargo Transport Units, continued

Packing of CTUs Must Be Consistent With Guidelines in the IMO Supplement [IMDG 7.3.3]

The IMDG Code requires that the load-ing of cargo transport units be “consistent with” the IMO Guidelines for Packing of Cargo Transport Units (CTUs), which are found in the IMDG Code Supplement. These guidelines include details on:

• Special forces and conditions to which a shipment may be subject during transport by vessel, highway, or rail.

• Safe handling and securing of CTUs.

• Procedures for and elements to be exam-ined in inspecting various types of CTU.

• Advice on applying placards and other warnings.

• Safety precautions in loading, receiving, opening, and unloading CTUs.

• Specific considerations in distributing, blocking and bracing, and securing cargo in a CTU.

Distribution of Loads in CTUs

Guidelines for distributing loads in CTUs include:

• Before packing a CTU, the packer should think through all issues of compatibility, weight distribution, and blocking and bracing, etc.

• The center of gravity should be as close to the longitudinal midline as practicable. At a minimum, no more than 60% of the weight of the load may be in any one half of the unit.

• The center of gravity should be below the half-height level of the CTU.

• The weight should be evenly distributed over the floor of the container.

• The total weight of the material in the CTU should not be greater than the maxi-mum rated payload. If the weight will not be uniformly distributed over the floor of the unit (e.g., if there is one particularly heavy package), this maximum payload should be reduced.

Blocking and Bracing

If any empty space is present in a CTU, the load must be appropriately blocked and braced. Some of the options for blocking and bracing include:

• Staggering package heights, provided the packages are sufficiently different in height and rigid that they can hold each other in place.



Notes:

Page 168


• Raising one row of equal-height packages on a pallet to hold in place the packages behind it.

• Inserting a rigid separation between rows of packaging.

• Lashing one row of packages together vertically.

• Lashing packaging to a structural mem-ber of the CTU.

• Blocking packages in place with lumber or similar devices.

• Filling void space with empty pallets stood on edge, flattened corrugated fibre-board, or other similar material.



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Airbags

One popular option for filling void space is the use of airbags. Keep in mind, airbags have their own related precautions:

• Airbags can expand or pressurize as the temperature rises. Manufacturers’ recom-mended filling pressures should never be exceeded.

• If a CTU may be subject to unusual tem-perature changes, these should be taken into account.

• Airbags should not be used to fill void space between cargo and doorways unless precautions are taken to assure against violent opening of the doors when the locking bars are released.

Wooden Blocking and Bracing Material

Separate from the dangerous goods rules, most countries prohibit the entry of any wood products, including blocking and bracing material, to their country unless the wood is treated (with heat and/or fumigation) to protect against wood-damaging insect intro-ductions.

Tracking and Monitoring Equipment [IMDG 7.3.5]

When security devices or other monitor-ing and tracking equipment is used, it must be securely installed and certified to be compati-ble with the dangerous goods carried.



Notes:

Page 170

DANGEROUS GOODS SEGREGATIONWhat Can Ship With What?

Shippers’ Concerns

Dangerous goods segregation is gener-ally the responsibility of the vessel operators. However, shippers must be aware of segrega-tion rules for three reasons:

1. For Proper Shipping Names ending in N.O.S., shippers may be required to determine applicable IMDG “segregation groups” and document them on shipping paperwork. [IMDG 3.1.4.2 and 5.4.1.5.11]

2. Dangerous goods requiring segregation generally may not be shipped together in the same CTU.

Materials that must be kept “Away From” one another (the lowest level of segrega-tion) may be loaded in the same CTU, but only with the approval of the competent authority (e.g., the DOT). [IMDG 7.2.3.2.2]

3. Mixing dangerous goods with different segregation requirements in the same overpack or CTU may limit that ship-ment’s acceptability for transport.

For example, many high-hazard goods must be stowed above deck, while it is recommended to stow marine pollutants below deck.

Also, many dangerous goods must be stowed away from food or living quar-ters, and some must be stowed away from goods of another type. Some must be kept

dry, cool, vented, or shaded. Combining too many restrictions may make it impos-sible to find an acceptable stowage loca-tion on particular ships.

Three General Rules for Segregation

There are three general rules of segrega-tion under IMDG rules.

1. Materials of different hazard classes must be segregated according to the Segrega-tion Table at IMDG 7.2.4.

Materials posing one subsidiary hazard must be segregated according to the most stringent of the hazard class and subsidi-ary hazard restrictions.

2. Materials within specific chemical seg-regation groups at IMDG 7.2.5 must be identified as such (e.g., acids, cyanides, and alkalis) and assigned the applicable segregation group code (e.g., SGG1 for acids, SGG6 for cyanides, and SGG18 for alkalis).

NOTE: In most cases, a material is identified as belonging to a segregation group by the assign-ment of a segregation group code in Column 16b of the Dangerous Goods List. Additionally, certain materials shipped under N.O.S. entries are not assigned to a segregation group and the shipper must decide whether inclusion in a segregation group is appropriate and assign it to the applicable segregation group code when necessary.



Notes:

Page 171

Dangerous Goods Segregation, continued

3. Each item on the Dangerous Goods List must be segregated from other materials according to its segregation code in Col-umn 16b. Segregation requirements are identified at IMDG 7.2.8. For example:

• SG7 = Stow “away from” Class 3

• SG20 = Stow “away from” SGG1 – acids

• SG46 = Stow “separated from” chlorine

NOTE: Any material that is incompatible with another material or that could contribute to the hazards of another material must be segre-gated appropriately.

Five Sets of Segregation Rules [IMDG 7.2.1]

The rules for segregating dangerous goods from each other and from specific areas of the ship vary according to how the cargo is packed and the kind of ship on which they are trans-ported. The five sets of segregation rules are:

1. Packages—for segregating packaged dan-gerous goods located in cargo holds or on deck. [IMDG 7.2]

2. CTUs on container ships—for segregat-ing cargo transport units (such as freight containers, tank cars, and tank trucks) on board container ships. [IMDG 7.4]

3. CTUs on ro-ro ships—for segregating cargo transport units on roll-on/roll-off cargo ships, or on roll-on/roll-off cargo spaces in any ship. [IMDG 7.5]

4. Shipborne barges—for segregating barges on barge-carrying ships. [IMDG 7.7]

5. General cargo—for segregating danger-ous goods stowed conventionally. [IMDG 7.6]

Four Levels of Segregation [IMDG 7.6.3.2]

The IMDG Code specifies four different levels of segregation on board a ship. These levels are defined by how they would require packages of dangerous goods to be separated. The levels of segregation, from least stringent to most stringent, are described and illus-trated below.

NOTE: Full vertical lines represent transverse bulkheads between cargo spaces that are resis-tant to fire and liquids.

1. “Away from”—typically requires only spacial distance between incompatible materials. For packages within the same ship hold, three metres of horizontal sep-aration must be maintained.



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Dangerous Goods Segregation, continued

2. “Separated from”—requires that packag-es be stowed in separate cargo holds. If one hold is vertically above another, the separating deck must be resistant to fire and liquids.

3. “Separated by a complete compartment or hold from”—is similar to “separated from” but requires that another complete hold exist between those in which the incompatible materials are stowed.

4. “Separated longitudinally by an inter-vening complete compartment or hold from”—is similar to “separated by a complete compartment or hold from” but requires that the separation be horizontal.

Hazard-specific Segregation Requirements

There are special additional rules in the IMDG Code for the segregation of:

• Class 1 explosives. [IMDG 7.2.7]

• Class 7 radioactive materials. [IMDG 7.1.4.5]



Notes:

Page 173

DANGEROUS GOODS STOWAGEWhere Do You Want Me to Put This?

Vessel Operators’ Responsibility

Dangerous goods stowage is generally the responsibility of the vessel operators. How-ever, shippers must be aware of stowage rules because these will affect the type of vessel on which their materials may be transported.

Shippers should be aware that mixing dangerous goods with different stowage requirements may limit or prohibit that ship-ment’s acceptability for transport on a partic-ular vessel.

Stowage Categories

Each dangerous good is assigned a stowage category in Column 16a of the 3.2 Dangerous Goods List. The stowage category determines where on a ship that material may be stowed for transportation (on-deck, under-deck, etc.). Some stowage categories are prohibited alto-gether from certain passenger ships.

• For most dangerous goods, stowage categories are assigned uppercase letters, “A–E,” with “A” being the least and “E” being the most dangerous. General stow-age requirements by category are found at IMDG 7.1.3.2.

• Explosives are assigned numerical cate-gories, with “01” being the least and “05” being the most hazardous. Categorical stowage requirements for explosives are found at IMDG 7.1.3.1.

Stowage in Relation to Living Quarters [IMDG 7.1.2]

Some dangerous goods are required to be stowed “clear of living quarters.” These include:

• Materials identified with Stowage Code “SW2” in Column 16a of the IMDG 3.2 Dangerous Goods List.

• Volatile toxic or volatile corrosive substances.

• Substances that, in moist air, produce toxic or corrosive vapours.

• Substances that evolve strongly narcot-ic vapours.

• Class 2 flammable, toxic, or corrosive gases.

Segregation in Relation to Foodstuffs [IMDG 7.3.4.2]

Separated From

In general, the following dangerous goods must be stowed “separated from” foodstuffs:

• Substances for which toxicity is indicated by a Class 6.1 or 6.2 label.



Notes:

Page 174

Dangerous Goods Stowage, continued

• Substances for which toxicity is indicated by a Class 2.3 label.

• Materials for which radioactivity is indi-cated by a Class 7 label.

• Substances for which corrosivity is indi-cated by a Class 8 label.

Away From

The following dangerous goods must be stowed “away from” foodstuffs:

• Substances for which corrosivity is indi-cated by a Class 8 label, Packing Group II or III.

• Substances for which toxicity is indicated by a Class 6.1 label, Packing Group III.

• Substances of Packing Group III with a subsidiary hazard of Classes 6.1 or 8.

Separated by a Complete Compartment or Hold From

All infectious substances (Class 6.2) must be separated by a complete compartment or hold from both foodstuff and living quarters.

NOTE: Segregation Codes “SG29” and “SG50” in Column 16b indicate a dangerous good that must be segregated from food stuffs.

Stowage Requirements for Marine Pollutants [IMDG 7.1.4.2]

Where on-deck or under-deck stowage is allowed, marine pollutants should be stowed below deck.

Where on-deck storage is required, they must be stowed on the most protected or most inboard or sheltered areas.

NOTE: Shippers should avoid packing marine pollutants together with materials that require on-deck stowage as it may limit their shipping options.



CONTENTS

Step 8—Incidents and Security ........................................................................................175

Incident Reports .................................................................................................................177

Emergency Response Requirements ...............................................................................180

Dangerous Goods Cargo Security ...................................................................................181

Hazmat Cargo Security Plans ...........................................................................................182

Dangerous Goods Cargo Security Plans .........................................................................184



Notes:

Page 175

STEP 8—INCIDENTS AND SECURITYPreparing for the Worst



IMDG 1.4 Security provisions

IMDG 5.4.3.2

Emergency response informa-tion aboard ships

IMDG 7.8 Incident and fire precautions

49 CFR 171.15

Rules for immediate telephone notification for certain incidents

49 CFR 171.16

Rules for written reporting of certain incidents

49 CFR 130 Rules for oil spill prevention and response plans

40 CFR 172, Sub-

part G

Emergency response informa-tion

49 CFR 172,

Subpart I

Rules for hazmat cargo security planning

49 CFR 174–177

Carriers’ mode-specific rules for responding to emergencies

33/46 CFR US Coast Guard maritime vessel, facility, and outer conti-nental shelf security

ISPS Code Requirements for ship and port security officers and security plans


IMDG Supplement

– Emergency Response Proce-dures for Ships

– (EmS Guide) Medical First Aid Guide (MFAG)

– Reporting procedures under MARPOL

40 CFR 263 and 302

EPA reporting requirements for hazardous substances and hazardous waste


The IMDG Code is intended to prevent accidental damage or releases from danger-ous goods packages during conditions normal to vessel transportation; however, risks still remain. In addition, there is the possibility that people could attempt to steal or even inten-tionally sabotage dangerous goods shipments.

In addition to following applicable IMDG rules, within the United States, the US DOT regulations for incident and emergency report-ing and for hazmat security apply to all ship-ments and shippers.



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Page 176

Step 8—Incidents and Security, continued

What Is Required?

Both the IMDG Code and the Hazardous Materials Regulations have rules for:

• Reporting hazmat/dangerous goods– related incidents and emergencies.

• Providing and maintaining emergency information onboard ships and making it available in an emergency away from the actual dangerous goods.

• Responding to fires and other emergencies.

In addition, both the IMDG Code and the Hazardous Materials Regulations have rules on planning and training for hazmat security. However, the IMDG rules are recommenda-tory only. In addition, ships and port facilities are subject to the detailed rules of the Interna-tional Ship and Port Facility Security (ISPS) Code and to US Coast Guard rules for security on ships, at port facilities, and on outer conti-nental shelf facilities in Titles 33 and 46 of the Code of Federal Regulations.



Notes:

Page 177

INCIDENT REPORTS

A DOT “Extra”

Incident reporting is one of the DOT “extras” that must still be followed, even when shipping under the IMDG Code. Under DOT’s regulations, any person in physical possession of a hazardous material is required to report incidents occurring during the cycle of trans-portation (which includes loading, moving, unloading, and temporary storage) to the DOT. The form of the notification depends on the severity of the incident:

• “Serious incidents” must be reported by phone to the National Response Center as soon as practical (but no later than 12 hours).

• All “incidents” require a written report to be submitted to DOT within 30 days.

DOT “Serious Incidents” [49 CFR 171.15]

The DOT requires notice, either by phone or online, for any incident where, as a direct result of hazardous materials:

1. A person is killed.

2. A person requires hospitalization.

3. The general public is evacuated for an hour or more.

4. A major transportation artery or facility is shut down for an hour or more.

5. The operational flight pattern of an air-craft is altered.

6. The incident involves radioactive materi-als or etiologic agents.

7. More than 450 L of a liquid marine pollut-ant or more than 400 kg of a solid marine pollutant are released.

8. Any incident during transportation by aircraft involving a fire, violent rupture, explosion or dangerous evolution of heat that occurs as a direct result of a battery or battery powered device.

9. Any other situation that, in the judgment of the person in possession of the hazard-ous materials, warrants a report to the NRC (e.g., danger to life continues to be present at an incident).

Reporting Serious Incidents

Notifications of serious incidents must be made as soon as practical but no later than 12 hours after the incident to the National Response Center, either by telephone or online. The telephone number is 800-424-8802. The web address is http://www.nrc.uscg.mil.

Each report must include:

• The name of the reporter (the in-dividual).

• The name and address of the carrier (the company).



Notes:

Page 178

Incident Reports, continued

• A phone number where the reporter can be contacted.

• The date, time, and location of the incident.

• The extent of any injuries.

• The classification, name, and quantity of the hazardous material involved.

• The nature of the incident.

DOT “Incidents” [49 CFR 171.16]

The DOT requires a formal written report when any of the following occurs:

1. Any incident reported by telephone per 49 CFR 171.15.

2. Any incident where hazardous materials are unintentionally released from their packages.

3. A specification cargo tank with a capac-ity of 1,000 gallons or greater containing any hazardous material suffers structural damage to the lading retention system or damage that requires repairs to a system intended to protect the lading retention system (even if no release occurs).

4. Any undeclared shipment of hazardous material.

5. Any incident involving a fire, violent rup-ture, explosion, or dangerous evolution of heat that occurs as a direct result of a battery or battery-powered device.

Reporting Incidents [49 CFR 171.16(b)]

With certain exceptions, written reports of DOT incidents must be filed within 30 days of the incident using DOT Form F 5800.1.

The written report must be sent to:

Information Systems ManagerPHH-60Pipeline and Hazardous Materials Safety AdministrationDepartment of Transportation, East Building 1200 New Jersey Ave, SEWashington, DC 20590-0001

The report may alternatively be submitted electronically to http://www.phmsa.dot.gov.

Availability of Written Reports [49 CFR 171.16(b)(3)]

The person reporting must retain a writ-ten or electronic copy of the incident report for at least two years. If the written or electronic Hazardous Materials Incident Report is main-tained at other than the reporting person’s principal place of business, the report must be made available at the reporting person’s principal place of business within 24 hours of a request for the report by an authorized rep-resentative or special agent of the Department of Transportation.

Updating the Written Report [49 CFR 171.16(c)]

Written reports must be updated within one year of the incident date whenever:

• A death occurs.



Notes:

Page 179

Incident Reports, continued

• The original material or package informa-tion was misidentified.

• The damage, loss, or related costs that were not previously known are made known.

• The amount of damage, loss, or related costs changes by $25,000 or more, or 10% of the total (whichever is greater).

Additional Reporting

For incidents involving aircraft, the report must also to be sent to the FAA Civil Aviation Security Office nearest to the location of the incident.

There are additional reporting require-ments if the hazardous material released is a hazardous waste [40 CFR 263] or a hazardous substance [40 CFR 302].

Exceptions to Reporting [49 CFR 171.16(d)]

There are exceptions to the incident report-ing requirements for spills of minimal amounts of hazardous materials. These include normal releases from vents, pumps, compressors, etc.; packages shipped as limited quantity; and additional small packages that meet certain size and capacity limits.

International Maritime Dangerous Goods Rules

The IMDG Code leaves reporting of dan-gerous goods incidents to the discretion of individual states (countries). The IMDG Code Supplement includes recommendations for structuring and limiting reporting obligations of ships. However, individual countries are not bound to these recommendations.

MARPOL

The International Convention for the Pre-vention of Pollution from Ships (MARPOL) specifies requirements for reporting some spills under “Protocol I.” These reporting obli-gations apply to any discharge above permit-ted levels of:

• Oil.

• Noxious liquid substances.

• Marine pollutants.

Protocol I to MARPOL can be found in the “Reporting” section of the IMDG Code Supplement.



Notes:

Page 180

EMERGENCY RESPONSE REQUIREMENTS

Emergency Response Information

The emergency response information requirements of 49 CFR 172, Subpart G are one of the DOT “extras” that must still be fol-lowed, even when shipping under the IMDG Code. Under these rules:

• Shippers must provide emergency re-sponse information to carriers.

• Carriers must maintain the information throughout the cycle of transportation.

Responding to Emergencies

The DOT has basic requirements at 49 CFR 176 for dealing with spills and other emergen-cies that may occur during vessel transport.

The IMDG Code has requirements in Chap-ter 7.8 for dealing with incidents and fires that occur during transport. In addition, detailed recommendations for dealing with spills, fires, and other incidents are also found in The EmS Guide: Emergency Response Procedures for Ships Carrying Dangerous Goods.



Notes:

Page 181

DANGEROUS GOODS CARGO SECURITY

Security for Shore-based Operations Other Than Ports

The Hazardous Materials Regulations

The US DOT’s security standards are one of the DOT “extras” that must be followed, even when using the IMDG Code. The DOT requires that all hazmat employees receive cargo security awareness training. The DOT also requires cargo security plans and security plan training for shippers and carriers han-dling certain types of hazmat shipments.

The IMDG Code

The IMDG Code includes recommendatory standards for dangerous goods cargo security at IMDG 1.4. These requirements are similar to US requirements, but they are not as detailed, and they do include some substantive dif-ferences.

The IMDG Code recommends security awareness training for all shoreside person-nel subject to IMDG training. [IMDG 1.4.2.1] Although the wording of the IMDG rules dif-fers from the DOT’s, the security awareness training requirement is essentially the same.

The IMDG Code recommends that anyone shipping “high-consequence dangerous goods” should have a written cargo security plan. Both the types of shipments that trigger the need for a security plan and the contents of the plan itself differ from the DOT’s requirements.

Port and Vessel Security

US Rules

Most maritime security within the United States is under the authority of the US Coast Guard, which is part of the Department of Homeland Security. The Coast Guard’s respon-sibilities include:

• Overseeing grants for security research.

• Assembling best practices in security.

• Reviewing and approving ship and port facility security plans, which must be in accordance with the International Ship and Port Facility Security (ISPS) Code.

• Controlling access to US ports.

• Approving vessels for entry into US wa-ters and ports.

NOTE: For import shipments to the United States, the US Coast Guard requires notifica-tion of the nature of all cargo 24 hours before the cargo is loaded onto the vessel at the for-eign port.

International Rules

The ISPS Code provides detailed, man-datory security requirements that apply to all ships, port facilities, and ship operators. The security requirements of the ISPS Code require that there be a trained security officer at each port facility, as well as a formal security plan for each port.



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HAZMAT CARGO SECURITY PLANSDOT Requirements

Applicability [49 CFR 172.800(b)]

The US DOT’s security standards found in 49 CFR 172, Subpart I include the DOT “extras” that must be followed, even when using the IMDG Code. The DOT requires cargo security plans and security plan training for shippers and carriers handling certain types of hazmat shipments.

In general, a written hazmat security plan is required for any facility or organization that ships or transports:

• Any quantity of:

– Division 1.1, 1.2, or 1.3 explosives;

– A material poisonous by inhalation;

– Organic peroxide, Type B, liquid or solid, temperature-controlled;

– Select agents or toxins regulated by the Centers for Disease Control and Prevention of the United States Depart-ment of Agriculture; or

– Highway route controlled quantities and other high-consequence Class 7 materials.

• A “large bulk quantity,” i.e., a quantity greater than 3,000 kg (6,614 lbs.) for solids or 3,000 L (792 gallons) for liquids and gases in a single packaging, such as a car-go tank motor vehicle, portable tank, tank car, or other bulk container, of:

– Division 2.1 flammable gases;

– Division 2.2 compressed gases with a subsidiary hazard of 5.1;

– Class 3, PG I or II;

– Division 4.2, PG I or II;

– Division 5.1, PG I, PG II, and certain ammonium nitrate compounds;

– Division 6.1 poisons other than poison-ous by inhalation; or

– Class 8, PG I.

• A placarded load of:

– Division 1.4, 1.5, or 1.6 explosives;

– Desensitized explosives in Division 4.1 or Class 3;

– Uranium hexafluoride; or

– Division 4.3 dangerous when wet ma-terial.

Retention [49 CFR 172.802(c)]

The most recent version of a security plan, including the risk assessment, must be in writ-ing and retained for as long as it remains in effect.



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Hazmat Cargo Security Plans, continued

Revision [49 CFR 172.802(c)]

Security plans must be reviewed at least annually and revised and/or updated as necessary to reflect changing circumstances. When the security plan is revised, all employ-ees responsible for implementing it must be notified and receive any additional/revised training within 90 days of implementation of the revised plan.

Availability [49 CFR 172.802(d)]

Copies of the most recent version of the security plan, or appropriate portions of it, must be available to the employees responsi-ble for implementation.

All persons required to develop/imple-ment a security plan must maintain an acces-sible copy of the plan at their principal place of business. They must make this plan avail-able upon request to authorized officials of the Department of Transportation or the Depart-ment of Homeland Security.

Contents of a Cargo Security Plan [49 CFR 172.802]

The security plan must include an assess-ment of transportation security risks, including site-specific or location-specific risks associ-ated with facilities at which hazardous mate-rials are prepared for transportation, stored, or unloaded incidental to movement.

At a minimum, a security plan must include the following elements:

• Personnel Security—confirm information provided by job applicants who will be given access to or handle hazardous ma-terials above regulated thresholds.

• Unauthorized Access—prevent unautho-rized people from gaining access to the hazardous materials or transport vehicles above regulated thresholds.

• En Route Security—protect shipments of hazardous materials above regulated thresholds en route from origin to desti-nation, including during storage inciden-tal to movement.

Additionally, a security plan must include:

• The job title of the person responsible for overall development and implementation of the security plan.

• Security duties for each position or de-partment responsible for implementing the plan.

• The process of notifying employees when specific elements of the security plan must be implemented.

• A plan for training hazmat employees who will implement the security plan.



Notes:

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DANGEROUS GOODS CARGO SECURITY PLANSIMDG Requirements

Applicability

The IMDG Code includes recommendatory standards for dangerous goods cargo security in Section 1.4. These are similar to US require-ments but are not as detailed and include some substantive differences.

Dangerous Goods Security Plans [IMDG 1.4.3.1.2 and 1.4.3.2.2]

The IMDG mandate for written security plans applies to a completely different set of cir-cumstances than the DOT’s. Anyone shipping “high-consequence dangerous goods” should have a plan. These include any quantity of:

• Division 1.1, 1.2, and 1.5 explosives, Division 1.3 explosives in Compatibil-ity Group C, and certain Division 1.4 explosives.

• Class 2.3 toxic gases.

• Class 3 desensitized liquid explosives.

• Class 4.1 desensitized solid explosives.

• Class 6.1, PG I toxics.

• Class 6.2 Category A infectious substances.

• Class 7 radioactive materials above speci-fied radioactivity levels.

High-consequence dangerous goods would also include any of the following when shipped in bulk packages > 3,000 litres or > 3,000 kg:

• Class 2.1 flammable gases.

• Class 3 flammable liquids, PG I and II.

• Class 4.2, PG I.

• Class 4.3, PG I.

• Class 5.1 oxidizing liquids, PG I.

• Class 5.1 perchlorates, ammonium ni-trate, ammonium nitrate fertilizers, and ammonium nitrate emulsions or suspen-sions or gels.

• Class 8 corrosives, PG I.

Contents of a Cargo Security Plan

While the US DOT only requires written security plans to document final plans for personnel, facility, and en-route security, the IMDG Code recommends that the entire plan-ning process be documented, including:

• Allocation of responsibilities.

• Records of types of dangerous goods transported.

• Review of operations and assessment of vulnerabilities.



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Dangerous Goods Cargo Security Plans, continued

• Measures to be used to reduce secu-rity risks.

• Procedures for reporting and dealing with security threats.

• Procedures for evaluating, reviewing, and updating the plan.

• Measures to secure information in the plan itself.

• Measures to assure security of other transportation documentation.



CONTENTS

Step 9—Administrative Responsibilities ........................................................................187

IMDG Approvals and Exemptions ..................................................................................188

IMO Organization ..............................................................................................................190



Notes:

Page 187

STEP 9—ADMINISTRATIVE RESPONSIBILITIES



IMDG 7.9.1

Exemptions

IMDG 7.9.2

Approvals and certificates

IMDG 7.9.3

Competent authorities by state

49 CFR 107

Hazardous materials pro-gram procedures


Administrative issues related to transport-ing dangerous goods by vessel include:

• Regulatory provisions for approvals and exemptions. (NOTE: The DOT refers to exemptions as “special permits.”)

• Provisions for transboundary movement of wastes under the Basel Convention.

• Dealing with others, including ports, vessel operators, and enforcement au-thorities.

• DOT administrative rules that must be met, including registration and approvals.



Notes:

Page 188

IMDG APPROVALS AND EXEMPTIONSIMDG 7.9

Approvals vs. Exemptions

Approvals and exemptions are two dis-tinct permissions that a person may need to receive for shipping dangerous goods.

Approvals [IMDG 7.9.2]

An “approval” is an authorization issued by the appropriate national authority to be able to do a particular thing that is already provided for in the regulations, but only if you are individually approved to do so.

Some of the approvals required under the IMDG Code include:

• Use of certain alternative packagings. [IMDG 4.1.3.7]

• Approval that a shipment meets the “away from” standard for incompatible goods transported in the same cargo transport unit. [IMDG 7.3.4.1]

• Design approvals for portable tanks. [IMDG 6.7.2.18.1]

Generally, under the IMDG Code, approv-als from any one competent authority must be recognized by all other competent authorities. [IMDG 7.9.2.1]

Exemptions [IMDG 7.9.1]

An “exemption” is an authorization issued by an appropriate national authority that pro-vides relief from the provisions of a particular regulation. Exemptions may allow the trans-port of dangerous goods that are normally forbidden from transport by vessel or may remove or modify any provision of the IMDG Code. Any exemption is expected to include alternate provisions that ensure that the same overall level of safety in transport is main-tained as provided by the IMDG Code.

The IMDG Code does not require compe-tent authorities to accept exemptions issued by other competent authorities. If you wish to ship under an exemption, you must assure acceptance of that exemption by the port State of departure, the port State of arrival, and the flag State (registry) of the vessel on which the goods are shipped. [IMDG 7.9.1.1] For radio-active materials, the IMDG Code explicitly requires “multilateral approval,” (i.e., that all states issue the same exemption). [IMDG 1.5.4.2]

US DOT “Exemptions” Are Called “Special Permits”

In the United States, “special permits” authorize a person to perform a function that is not currently authorized or not perform a function currently required under DOT reg-ulations.



Notes:

Page 189

IMDG Approvals and Exemptions, continued

Shipping Under Exemptions

Shippers operating under an exemption should be aware of a few general rules:

• A copy of any applicable exemption must accompany all shipments made under that exemption.

• Whenever a competent authority issues an exemption from the IMDG Code, a copy of that exemption must be sent to the IMO, so that this organization:

– May make interested international bod-ies aware of each exemption issued, and

– May consider incorporating it into the IMDG Code.

• No exemption may be issued for more than five years. Expiring exemptions may be renewed (provided that they hav-en’t already been incorporated into the IMDG Code).

Approval/ Exemption Documents from the United States

For shipments generated in the United States, the approval/exemption documents must be requested through the Department of Transportation. [49 CFR 107.705 for approvals; 49 CFR 107.105 for special permits]



Notes:

Page 190

IMO ORGANIZATION

What Is the IMO?

The International Maritime Organization (IMO) is a specialized agency of the United Nations whose mandate is to improve mari-time safety and prevent pollution from ships.

Origin and Structure

The IMO came into being in 1959 as the Inter-Governmental Maritime Consultative Organization, or IMCO. Its name was changed

to IMO in 1982. The IMO is run by a Secretariat of professional employees, under the guidance of an executive Council of 40 national govern-ments, which is in turn elected from the 174 IMO member states (nations).

The IMO Secretariat’s operations are also overseen by five Committees: the Maritime Safety Committee (MSC), the Marine Environ-ment Protection Committee (MEPC), the Legal Committee, the Technical Cooperation Com-mittee, and the Facilitation Committee.

The MSC and MEPC are assisted in their work by nine sub-committees, which are also open to all member states. They deal with the following subjects:

• Bulk Liquids and Gases (BLG)

• Carriage of Dangerous Goods, Solid Car-goes, and Containers (DSC)

• Fire Protection (FP)

• Radio-communications and Search and Rescue (COMSAR)

• Safety of Navigation (NAV)

• Ship Design and Equipment (DE)

Marine EnvironmentProtection Committee

LegalCommittee

Technical CooperationCommittee

FacilitationCommittee

Maritime SafetyCommittee

IMO Council40 Members, elected from the Assembly.

Governs the IMO between meetings of the Assembly.

IMO AssemblyIncludes representatives from each

of the 172 member states.



Notes:

Page 191

IMO Organization, continued

• Stability and Load Lines and Fishing Ves-sels Safety (SLF)

• Standards of Training and Watch-keeping (STW)

• Flag State Implementation (FSI)

The technical work of the IMO is done by a Secretariat, which consists of the Sec-retary-General and nearly 300 personnel based at the headquarters of the organization in London.

Responsibilities

The IMO is responsible for many inter-national treaties on maritime safety issues. The three primary treaties that IMO adminis-ters are:

1. The International Convention for the Safety of Life at Sea (SOLAS), which addresses all aspects of marine safety.

2. The International Convention for the Pre-vention of Pollution from Ships (MARPOL 73/78), which addresses accidental and operational oil pollution, pollution by chemicals, goods in packaged form, sew-age, garbage, and air pollution.

3. The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), which establishes basic training, certification, and watch-keeping requirements on an international level.

Other Conventions

The complete list of conventions adminis-tered by IMO includes:

Maritime Safety

• Convention on the International Regu-lations for Preventing Collisions at Sea (COLREG), 1972

• Convention on Facilitation of Internation-al Maritime Traffic (FAL), 1965

• International Convention on Load Lines (LL), 1966

• International Convention on Maritime Search and Rescue (SAR), 1979

• Convention for the Suppression of Un-lawful Acts Against the Safety of Mari-time Navigation (SUA), 1988, and Proto-col for the Suppression of Unlawful Acts Against the Safety of Fixed Platforms located on the Continental Shelf (and the 2005 Protocols)

• International Convention for Safe Con-tainers (CSC), 1972

• Convention on the International Maritime Satellite Organization (IMSO C), 1976

• The Torremolinos International Con-vention for the Safety of Fishing Vessels (SFV), 1977, superseded by the The 1993 Torremolinos Protocol; Cape Town Agree-ment of 2012 on the Implementation of the Provisions of the 1993 Protocol relating to the Torremolinos Interna-tional Convention for the Safety of Fish-ing Vessels



Notes:

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IMO Organization, continued

• International Convention on Standards of Training, Certification and Watchkeep-ing for Fishing Vessel Personnel (ST-CW-F), 1995

• Special Trade Passenger Ships Agreement (STP), 1971 and Protocol on Space Re-quirements for Special Trade Passenger Ships, 1973

Marine Pollution

• International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Casualties (INTERVEN-TION), 1969

• Convention on the Prevention of Marine Pollution by Dumping of Wastes and Oth-er Matter (LC), 1972 (and the 1996 Lon-don Protocol)

• International Convention on Oil Pollution Preparedness, Response and Co-opera-tion (OPRC), 1990

• Protocol on Preparedness, Response and Co-operation to pollution Incidents by Hazardous and Noxious Substances, 2000 (OPRC-HNS Protocol)

• International Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS), 2001

• International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004

• The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009

Liability and Compensation

• International Convention on Civil Liabili-ty for Oil Pollution Damage (CLC), 1969

• 1992 Protocol to the International Con-vention on the Establishment of an Inter-national Fund for Compensation for Oil Pollution Damage (FUND 1992)

• Convention relating to Civil Liability in the Field of Maritime Carriage of Nuclear Material (NUCLEAR), 1971

• Athens Convention relating to the Car-riage of Passengers and their Luggage by Sea (PAL), 1974

• Convention on Limitation of Liability for Maritime Claims (LLMC), 1976

• International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Nox-ious Substances by Sea (HNS), 1996 (and its 2010 Protocol)

• International Convention on Civil Liabili-ty for Bunker Oil Pollution Damage, 2001

• Nairobi International Convention on the Removal of Wrecks, 2007

Other Subjects

• International Convention on Tonnage Measurement of Ships (TONNAGE), 1969

• International Convention on Salvage (SALVAGE), 1989

– Kenya

– Lesotho



CONTENTS

Step 10—Keeping Up With Changes ...............................................................................193

IMDG Regulatory Updates ...............................................................................................195

Training: 49 CFR vs. the IMDG Code ...............................................................................197

Training Your Hazmat Employees ...................................................................................199

Compliance Training Programs .......................................................................................200



Notes:

Page 193

STEP 10—KEEPING UP WITH CHANGESWhat’s Changed, What’s Coming, Are We Still Doing It Right?



IMDG 1.3 Training

IMDG 1.4 Security training

49 CFR 172, Subpart H

Training


You must take steps to assure that all employees affecting hazmat transportation compliance know how to do their job and are actually performing their function correctly. Keeping up with changes includes:

• Knowing any new or modified regulations.

• Knowing when your operations change, possibly changing the rules that apply.

• Performing continual update training for all personnel and all hazmat employees, as needed per job function.

You Are Expected to Know

As a general rule of law, any time you per-form a regulated action, you are expected to know that you’re regulated and what the reg-ulation requires and to do what it takes to be in compliance with the rules.

If you violate a rule because you have not learned it or not taught it to your employees, you have still violated the rule and can be sub-ject to fines and penalties. In fact, it is common for the US DOT to issue double citations: one for violating the rule and a second for failure to train the employee who did so. Therefore, it is essential that hazmat training be complete, accurate, and effective.

Tracking New Rules

Unlike US rules, international rule changes are scheduled and predictable. The IMDG Code changes only once every two years. New rules go into effect on January 1 of each odd-numbered year.

Very occasionally, the IMO may issue an interim correction or rule change. If any such addenda exist, they can be found either on the IMO website.

Hazmat Employee/Personnel Training

The DOT’s detailed Hazmat Employee training standard requires all hazmat employ-ees to be “instructed in the requirements of” the hazardous materials regulations that apply to the function they are performing. Hazmat employees may not perform any DOT-related hazmat function until they have received this training [see 49 CFR 172.702(b)].



Notes:

Page 194

Step 10—Keeping Up With Changes, continued

In addition, the IMDG Code requires train-ing of all “shore-based personnel.” IMDG training requirements are similar to the DOT’s, but not identical. Shippers following the IMDG Code may be subject to both training standards. This is particularly likely to be true when ship-ping internationally.



Notes:

Page 195

IMDG REGULATORY UPDATESKeeping Up With Changes

UN Committee of Experts

The United Nations Committee of Experts on the Transportation of Dangerous Goods (UNCOE) includes representatives from the regulatory authorities of 27 nations, as well as dangerous goods shippers and carriers. This is where new ideas originate and decisions are made.

The UNCOE meets twice each year to dis-cuss and vote on amendments to the United Nations Recommendations on the Transport of Dangerous Goods, the Manual of Tests and Crite-ria, and the UN Model Regulations. These three documents are the source of all international dangerous goods regulations.

You can track what is happening at the United Nations Economic Commission for Europe (UNECE) website:

www.unece.org/trans/danger/danger.html

The International Maritime Organization and the IMDG Code

Under the auspices of the United Nations, the International Maritime Organization (IMO) takes the UN recommendations and cre-ates the International Maritime Dangerous Goods (IMDG) Code. These are the official regulations that are enforced in international vessel trans-portation. The IMDG Code can be purchased directly from IMO in London, England.

Considerable information about the IMDG Code and related IMO issues is available online at:

http://www.imo.org/

Updates to the IMDG Code

The IMDG Code is updated once every two years. New rules are effective for a full calendar year (January 1–December 31). The new books are issued in even-numbered years and typically become available in October or November of that year. They become the “offi-cial” rules the following January 1st.

One Year Overlap in Editions of the Rules

The IMO allows a certain overlap for ship-pers and operators to adjust their compliance procedures. For the first year of each new edition, the previous IMDG Code may still be used. In addition, when the IMDG Code is first issued, the IMO allows shippers and operators to voluntarily begin using it even before Janu-ary 1st. So, for example:

• The 2018 edition was published at the end of 2018.

– In calendar year 2019, shippers were allowed to use either the 2016 or the 2018 edition to prepare their dangerous goods for shipment.

– Beginning January 1, 2020, the 2018 ver-sion became mandatory and the 2016 version could longer be used.



Notes:

Page 196

IMDG Regulatory Updates, continued

• The 2020 edition will be published at the end of 2020.

– In calendar year 2021, shippers will be allowed to use either the 2018 or the 2020 edition to prepare their dangerous goods for shipment.

– Beginning January 1, 2022, the 2020 version will become mandatory and the 2018 version will no longer be allowed to be used.

Caution: Wait for US DOT Adoption of Rules

US shippers of dangerous goods are only able to comply with the IMDG Code as an alter-native to the rules in 49 CFR 171–180 because the US DOT permits this in its regulations. However, the DOT adopts a specific version of the IMDG Code. The new version of the IMDG Code may not be used in the United States until the DOT updates its adoption by reference [49 CFR 171.7(b)] to the new edition. Usually, this is not done until shortly before the Jan-uary 1 date on which the new rules become official. Occasionally, it is not done until after January 1.

NOTE: As with all regulatory changes, the US DOT announces its adoption of the new edi-tion in the Federal Register.



Notes:

Page 197

TRAINING: 49 CFR VS. THE IMDG CODE

DOT Compliance Is Required

Although 49 CFR 171, Subpart C states that hazardous materials may be prepared for transportation and transported under the IMDG Code as an alternative to 49 CFR rules, the DOT’s training requirements are one of the DOT “extras” that must be followed, even when shipping under the IMDG Code. Therefore, the DOT’s training standards still apply to persons shipping by vessel under the IMDG Code.

The standard that the training must meet is 49 CFR 172, Subpart H. Under this standard, the DOT requires that all hazmat employees receive:

• General awareness training.

• Security awareness training.

• Function-specific training.

Function-specific Training

The DOT’s function-specific training stan-dard says that:

Each hazmat employee must be provided function-specific training concerning requirements... that are specifically applica-ble to the functions the employee performs. [49 CFR 172.704(a)(2)(i)]

If a shipper chooses to prepare hazardous materials for transportation under the IMDG Code, then the “requirements... specifically applicable to” that shipper’s hazmat employ-ees are those in the IMDG Code.

The DOT has explicitly stated that this is the case, whether you are shipping domesti-cally or internationally.

IMDG Compliance May Be Necessary

The IMDG Code does include explicit rules for training shore-based personnel at Chapter 1.3. These rules are recommendatory, meaning that the IMDG Code does not require training to conform to them, but it is encouraged.

Although the IMO and the US DOT do not require compliance with the IMDG training recommendations, vessel carriers may insist on seeing documentation that your employees are trained in accordance with these rules before they are willing to accept your shipments.



Notes:

Page 198

Training: 49 CFR vs. the IMDG Code, continued

Key Differences

Topic IMDG Code 49 CFR

Initial Training Upon employment. [§1.3.1.1] If not trained, can “perform func-tions... under the direct supervi-sion of a trained person”

Within 90 days after employment. [§172.704(c)(1)] Until trained, must work “under the direct supervision of a properly trained and knowledgeable hazmat employee”

Retraining Frequency As deemed appropriate by the competent authority [§1.3.1.1]

At least once every three years [§172.704(c)(2)]

Training Content General awareness, function-spe-cific [§1.3.1.2], safety [§1.3.1.4], security awareness [§1.4.2.3.], and security plan [§1.4.2.3]

Detailed recommendations for training content based on job functions are given at §1.3.1.5–6

General awareness, function-specific, and security awareness required for all, safety and security plan specifics required based on job functions and types of hazmat shipped [§172.704(a)]

Certification Unspecified The employer must certify that the hazmat employee has been trained and tested, as required [§172.704(d)(5)]

Training Records Recommends that records should be kept by the employer and made available to the employee or competent authority upon request [§1.3.1.3]

Requires the name and address of the “person” providing the training, which may be the organization or the individual [§172.704(d)(4)]

Record Retention As deemed appropriate by the competent authority [§1.3.1.3]

For as long as the employee is employed as a hazmat employee and for 90 days thereafter [§172.704(d)]



Notes:

Page 199

TRAINING YOUR HAZMAT EMPLOYEES49 CFR 172, Subpart H

Hazmat Training Topics [49 CFR 172.704(a)]

ALL hazmat employees must receive three kinds of training:

1. General awareness training

2. Function-specific training

3. Security awareness training

Depending on the hazmat employee’s spe-cific job functions, the employee may also need the following types of training:

1. Safety training

2. Security plan training

Testing and Recordkeeping [49 CFR 172.702(d) and 172.704(d)]

Each hazmat employee must be tested “by appropriate means” on the training sub-jects covered. Appropriate means may include written or oral tests or simply demonstrating the ability to do assigned tasks.

The hazmat employer must create and retain a “record of training” for each hazmat employee. The record shall include:

• The hazmat employee’s name.

• The most recent training completion date of the hazmat employee’s training.

• A description, copy, or the location of the training materials used to meet the re-quirements in paragraph (a) of §172.704.

• The name and address of the person pro-viding the training.

• Certification by the hazmat employer that the hazmat employee has been trained and tested.

Timing of Training [49 CFR 172.702(b) and 172.704(c)]

Initial Training

Initial training must be provided to employees prior to performing a job function or within 90 days for new employees working under the direct supervision of someone who is properly trained and knowledgeable.

Recurrent Training

All hazmat employees must be “retrained” no more than three years from the anniversary date of initial training.



Notes:

Page 200

COMPLIANCE TRAINING PROGRAMSA Suggested Strategy

Determine Whether Training Is Needed

Consider regulatory and technical require-ments against current operations; consider the knowledge level of current incumbents.

Assemble a Training Team

“Two heads are better than one.” Make training a cooperative effort. Assure that all needed disciplines are represented: Techni-cal, Regulatory, Management, and Personnel/Training.

Remember that training itself is both an expertise to be learned and a skill to be devel-oped. In larger companies, a training depart-ment can be of considerable value in organiz-ing your planning efforts and coaching the ultimate presenter of the training. In organiza-tions without such a resource, assure that your team includes at least one good trainer.

Identify Hazmat Jobs

Consider all jobs within your facility or jurisdiction. Do they participate in any hazmat-related functions? Group related tasks and related jobs at your facility into “hazmat job descriptions.” Give each a functional job title (e.g., packaging selector/specifier). These need not directly correspond to employee titles. For instance, “packaging specifiers” may

include a maintenance employee who selects drums for waste shipment, a packaging engi-neer, a shipping supervisor, and a purchasing agent who orders packaging. Each of these functional job descriptions will require a train-ing “module.” Some employees may have only one functional hazmat job description, some may have many.

Identify Goals and Objectives for Each Training Module

Training should be built around the tasks required in the specific job and existing com-pany procedures. This avoids training people on theory when what they need to know is practice. There are many systems to assist in developing task-based training. Most begin by defining goals and objectives of training—what you want a trainee to be able to DO at completion of the training. For instance, objec-tives for “packaging selector/specifier train-ing” could be:

• The employee will be able to explain the distinction between “specification” and “performance” packaging.

• The employee will be able to list the in-formation required to specify a 55-gallon drum for liquid hazardous materials.

• The employee will be able to recognize and interpret a specification mark on a packaging.



Notes:

Page 201

Compliance Training Programs, continued

Develop Learning Activities

Use the previously established goals and objectives as the outline for your training. Make use of appropriate training materials. Videos and slide shows are good for “aware-ness” training—to emphasize the importance of an issue. Booklets or manuals combined with lecture is still an option, but should include interactive discussion. Exercises are good for teaching procedures. Role-playing and demonstrations are effective in illustrating key points and issues. New technologies (e.g., computer-based training) should be assessed on the merits of their effectiveness.

Develop Post-Testing

All training programs should include a means of assessing attendee learning. This may be done through post-testing or other quantitative methods. A decision must be made as to criteria for successfully completing the training course.

Conduct the Training Program

Brief training programs (of an hour or two) may be conducted by one person. Longer pro-grams or programs using many exercises may require two or more presenters. It is always best to have an observer present for the first few sessions to make an objective assessment of the training effectiveness.

Evaluate Training Effectiveness

All training programs should be assessed periodically to assure that they are accom-plishing their intended purpose. Objective and subjective measures of effectiveness should be considered (e.g., test scores, training observa-tions, or actual employee performance). Peri-odic review should also be made to assure that stated training goals and objectives are still appropriate to current operations and current regulations.

Index


Page 203

INDEX

A

Approval........................................................ 188

Asphyxiation .......................................... 115, 163

Authorized packaging ............................. 78, 83

B

Basic description .......................................... 139Dangerous goods with flash points

at or below 60°C ................................ 143excepted quantity ................................... 146generic and n.o.s. shipping description 142infectious substance ............................... 146limited quantity ...................................... 143marine pollutant ..................................... 144optional modification ............................. 139salvage packaging .................................. 146

Bulk container ......................................... 73, 109additional provisions .............................. 113general provisions ................................... 112marking .................................................... 159regulations ................................................ 112

C

Cargo transport unit (CTU) .................. 74, 166distribution of load ................................. 167limited quantity ...................................... 161marine pollutant ..................................... 161marking ............................................ 155, 159packing requirements............................. 166placarding ........................................ 155, 156segregation ............................................... 170

Civil penalty ...................................................... 9

Classification ................................................... 21

Classification process ..................................... 34examples .................................................... 46material NOT specifically identified on

Dangerous Goods List ........................ 34material specifically identified on

Dangerous Goods List ........................ 34multiple-hazard material ......................... 38precedence of hazard ............................... 39

ComplianceDOT .......................................................... 197IMDG ........................................................ 197

Container/vehicle packing certificate ....... 152

Coolant ........................................................... 132

Cooled or conditioned ................................. 147

Criminal penalty .............................................. 9

D

Dangerous good ............................................... 1classification .............................................. 21overclassifying .......................................... 42

Dangerous goods description .................... 139excepted quantity ................................... 146flash points at or below 60°C ................ 143generic and n.o.s. shipping description 142infectious substance ............................... 146limited quantity ...................................... 143marine pollutant ..................................... 144optional modification ............................. 139salvage packaging .................................. 146

Dangerous Goods List ................................... 54columns ...................................................... 54packaging columns ................................... 77

Dangerous goods security plan ................. 184


Index, continued


Page 204

De minimis quantity ...................................... 108

Division ........................................................... 25

Documentation ..................................... 137, 139additional requirements ........................ 152aerosols ..................................................... 146certification .............................................. 148coolant ...................................................... 147DOT modification ................................... 147elevated-temperature material ............. 146empty uncleaned package ..................... 145empty uncleaned packaging ................. 145excepted quantity ................................... 146flash point ................................................ 143fumigated unit ......................................... 147generic and n.o.s. .................................... 142infectious substance ............................... 146limited quantity ...................................... 143marine pollutant ..................................... 144number and kind of packagings ........... 141other requirements ................................. 147retention ................................................... 154salvage ...................................................... 146segregation group ................................... 144stabilized .................................................. 146total quantity ........................................... 141viscous substance .................................... 146waste ......................................................... 145

DOT (Department of Transportation) ........... 1compliance ............................................... 197“extras”..................................................... 2, 3

E

Elevated-temperature substance ................ 162

Emergency responseinformation ...................................... 149, 180telephone number ................................... 150

Empty packaging .......................................... 115

Empty uncleaned packagingdocumentation ........................................ 145

Enforcement ...................................................... 9

Excepted quantity ........................................ 106de minimis ............................................... 108marking .................................................... 128modifying dangerous goods

description .......................................... 146Exemption ............................................. 188, 189

F

Fine ..................................................................... 9

Forbidden ........................................................ 44

Freight container ............................................ 74

Fumigated unit ............................................. 147marking .................................................... 162

G

General packing provision ............................ 78

generic and n.o.s. Proper Shipping Names ......................................................... 59

Generic and n.o.s. shipping descriptiondocumentation ........................................ 142

Generic Proper Shipping Name (PSN) ..... 124

H

Hazard class .............................................. 23, 25

Hazardousmaterial ........................................................ 1substance .................................................. 147waste ........................................................... 16

Index

Index, continued


Page 205

I

Identification codes for non-bulk packagings ................................................. 92marking ...................................................... 95specifications ............................................. 89

ID number ....................................................... 58

IMDG Code (International Maritime Dangerous Goods Code) ....................... 1, 2conditions for using .................................... 2Dangerous Goods List .............................. 54index ................................................. 6, 35, 56regulatory updates ................................. 195structure ....................................................... 5Supplement .................................................. 7symbols ........................................................ 5

IMDG compliance ........................................ 197

IMOSupplement .............................................. 167

Incident report .............................................. 177additional reporting ............................... 179exception .................................................. 179written report .......................................... 178

Incidents ........................................................ 175

Infectious substance ...................................... 115marking .................................................... 131modifying dangerous goods

description .......................................... 146Intermediate bulk container (IBC) ......... 97, 99

marking specification ......................... 97, 98marking specification codes .................... 99packing instruction ................................... 85

International Maritime Organization (IMO) .................... 1, 190, 195standards and publications ....................... 7

K

Keeping up with changes ........................... 195

L

Labelspecification ............................................. 120

Labeling .......................................................... 117general requirements............................... 119radioactive ............................................... 133requirements for fully

regulated packages ........................... 121special situations ..................................... 133

Large packaging ............................................. 73packing instruction ................................... 85

Limited quantitymarking ............................................ 126, 161packaging ................................................. 104

Lithium batterymarking ............................................ 129, 130

M

Marine pollutant....................................... 16, 41classification .............................................. 41documentation ........................................ 144exception for small package .................... 41hazard class ............................................... 41marking ............................................ 125, 161mixture ....................................................... 41naming........................................................ 63solution ....................................................... 41stowage .................................................... 174


Index, continued


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Markgeneral requirements............................... 118size ............................................................. 119

Marking .......................................................... 117asphyxiant ................................................ 163bulk container ......................................... 159cargo transport unit (CTU) .................... 159elevated-temperature substance ........... 162fumigated unit ......................................... 162general requirements............................... 118limited quantity ...................................... 161marine pollutant ..................................... 161non-bulk packaging ............................ 92, 95Proper Shipping Name (PSN) ............... 159radioactive ............................................... 133special situations ..................................... 133tank ........................................................... 159UN number .............................................. 160

Marking and labelingcoolant ...................................................... 132empty packaging .................................... 134excepted lithium battery ........................ 130excepted quantity ................................... 128fully regulated ......................................... 121generic Proper Shipping Name (PSN) . 124infectious substance ............................... 131limited quantity ...................................... 126lithium battery ........................................ 129marine pollutant ..................................... 125orientation arrows .................................. 122overpack ................................................... 135salvage packaging .................................. 136Unit load .................................................. 135

Mixturenaming........................................................ 61

Multi-element gas container (MEGC) ....... 109

Multiple-hazard material .............................. 38

N

Namingmarine pollutant ....................................... 63mixture ....................................................... 61solution ....................................................... 61

O

Orientation arrows ....................................... 122

Overclassifying ............................................... 42

Overpack ............................................... 135, 166segregation ............................................... 170

P

Packagenet quantity .............................................. 122

Index

Index, continued


Page 207

Packaging ........................................................ 59authorized ............................................ 78, 83basic packaging concerns ........................ 78closure ........................................................ 80composite ................................................... 94definitions .................................................. 71design and testing ..................................... 80empty ......................................................... 115excepted quantity ................................... 107expiration date .......................................... 81general packing provision ....................... 79IBC markings ........................................... 101infectious substance ................................ 115inspection requirements .......................... 81large ............................................................ 73limited quantity ...................................... 104marking specification ............................... 89non-bulk ..................................................... 95packing instruction ................................... 85requirements .............................................. 76salvage ................................................. 74, 114selecting ...................................................... 83specification markings ........................... 101types ............................................................ 71

Packing ............................................................ 69definitions .................................................. 71

Packing group ................................................. 33

Packing instruction ........................................ 82packaging, IBC, large packaging ............ 85

Penalty ............................................................... 9

Placarddisplay ...................................................... 157specification ............................................. 157

Placarding...................................................... 155cargo transport unit (CTU) .................... 156exception .................................................. 156special issues ........................................... 158

Portable tank ................................................. 109additional provisions .............................. 110general provisions ................................... 110

Port area ............................................................. 4security ..................................................... 181

Port security .................................................. 181

Precedence of hazard ..................................... 39

Precedence of Hazard Table ................... 39, 40

Proper Shipping Name (PSN) ...................... 53generic ...................................................... 124marking .................................................... 159modifying .................................................. 64selection ...................................................... 56

R

Radioactive ............................................. 116, 147labeling ..................................................... 133marking .................................................... 133

Recurrent training ........................................ 199

Reportable quantity (RQ) .............................. 16

Requirementsfor packaging ............................................. 76

S

Salvage packaging................................... 74, 114marking .................................................... 136modifying dangerous goods

description .......................................... 146Sample

assignment of packing group.................. 43classification .............................................. 43limitations .................................................. 43

Security .................................................. 175, 181dangerous goods security plan ............. 184hazmat cargo security plan ................... 182

Security planDOT requirements .................................. 182

Segregation .................................................... 170in relation to foodstuffs .......................... 173


Index, continued


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Segregation group .......................................... 67documentation ........................................ 144

Serious incident ............................................ 177

Shipper’s certification .................................. 148

Shipper’s certification .................................. 148

Shipping paper ............................................. 139indicating number and kind

of packages ......................................... 141indicating total quantity ........................ 141retention ................................................... 154

Solutionnaming........................................................ 61

Special permit ............................................... 188

Special provision .............................. 59, 78, 103

Specificationplacard ...................................................... 157

Stowage ......................................................... 173excepted quantity ................................... 108limited quantity ...................................... 105marine pollutant ..................................... 174

Subclassificationpacking group ........................................... 33

T

Tankmarking .................................................... 159

Ten Steps .......................................................... 10

Training .......................................................... 197recordkeeping .......................................... 199strategy ..................................................... 200testing ....................................................... 199timing ....................................................... 199topics ......................................................... 199

Transport by highway ..................................... 3

Transport document .................................... 139indicating number and type

of packages ......................................... 141indicating total quantity ........................ 141retention ................................................... 154

Transport operation ..................................... 165

U

Unit load ........................................................ 135

Unit load device ........................................... 166

UN number ..................................................... 58

V

Vessel security ............................................... 181

W

Waste ................................................................ 16documentation ........................................ 145