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UK P&I CLUBIS MANAGEDBY THOMASMILLER

UK P&I CLUB

Shipping dangerous goods incontainersAn introduction to the UK Club’s guidebooks on theworkings of the IMDG Code

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IntroductionThe Club, with the support of several Members, haslaunched Book it right and pack it tight – a set of fourguidebooks on the workings of the InternationalMaritime Dangerous Goods (IMDG) Code. They aredesigned to provide busy operational people, who arenot experts in the IMDG Code, with a quick referenceand practical everyday guidance to the IMDG Coderules.

Uniquely, each of the four guidebooks is dedicated tothe requirements of one of the principal parties involvedin consigning packaged dangerous goods:

● The shipper.

● The shipping line booking agency.

● The cargo consolidating companies (managers andsupervisors).

● The fork lift operators and cargo handlers – thosethat actually physically pack the containers.

Each of the parties above has key duties under theIMDG Code, and failure to carry out those duties maylead to undeclared dangerous goods being loaded in aship, an unsafe container load, or unsafe stowage, allof which lead to an unnecessary increase in the risk ofcarrying dangerous goods by sea.

IMDG Code training package

The guidebooks come in a boxed set of four. They arepart of a complete IMDG Code training package. Eachbook is supported by its own editable PowerPointtraining course. This enables training officers andmanagers who are not experts in the IMDG Code toteach staff their key duties under the Code, and how theguidebooks work. This is to raise awareness of theguidebooks in the workplace and overcome theperception of employees that the IMDG Code is toocomplex for them to understand.

Also in the package is a DVD – Any Fool Can Stuff aContainer. This DVD focuses on:

● Choosing a container.

● Checking the container.

● Making a packing plan.

● Packaging cargo.

● Packing containers.

● Container security.

● Receiving containers.

Before explaining the guidebooks in detail, it may be ofinterest to describe the causes of dangerous goodsincidents and non-compliance with the IMDG Code,

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and explain why the Club is taking direct action toimprove IMDG Code understanding and compliance.

What is the IMDG Code?The IMDG Code is acomprehensive set ofglobally accepted rulesthat enables packaged(ie non-bulk)dangerous goods andmarine pollutants to becarried safely by sea.

Around 10 per cent ofall container cargoes containdangerous goods, so virtually all container ship servicesfall within the scope of the rules of the Code.

Why is the IMDG Code so complex?

The Code has evolved from a set of brief facts andinstructions for mariners through more than six decadesof committee discussions by experts, to a two-volumedocument with a supplement, a total of over 800 pages.

The rules are now set about with exemptions andexceptions. Industries have successfully lobbied forspecial rules for particular products, such as paints,alcoholic beverages and aerosols, and rule makersmust make allowances to take advantage of benefitsfrom new technologies in products and packaging, aswell as more accurate technical information about thebehaviour of hazardous substances. As in all things, the

rules of the Code must be flexible, or the systembecomes commercially restrictive and discredited.

So, the Code must draw a balance between being easilyunderstandable for non-technical operational people,and at the same time comprehensive and technicalenough to take into account all manner of specialconsiderations.

The Code is wide-ranging and there will always besections that are not applicable to a particular party. It isnow so lengthy that some operational personnel are putoff from trying to understand it. In fact, the Code is awell-designed document, and ordinary operationalpeople just need guidance to understand its structureand their key duties. That is the purpose of the Book itright and Pack it tight guidebooks.

The scope of the Code

Many are surprised to learn that the bulk of the Codeapplies to activities carried out ashore by the shipper,consolidator and packer concerning the preparation anddocumentation of the load, not to shipboard activities.The Code is complex because it provides rules thatapply to activities taking place right at the start of thetransport chain and then throughout the carriage by sea.

The Code requires the shipper to provide a descriptionof the product and classification of any hazards. It setslimits on the type and size of packaging, specifieswarning marks and labels, establishes rules for the typesof hazards that can be co-loaded into one container, anddevises a documentation system that requires shippersand packers to certify in writing that they have followedthe rules of the Code.

Only when all of these things have been done does theCode turn its attention to stowage and segregationaboard ship. As examples of this, shipboard stowagedoes not appear until the last section of the maindocument, and the emergency instructions for dealingwith dangerous goods incidents aboard ship do notappear in the Code proper at all, but in the Supplementto the Code, (sometimes called Volume 3),

Daunting for new users

The length and density of the text is a psychologicalbarrier to learning for people whose first language isEnglish, or one of the main world languages into whichthe Code is translated. How much more difficult is thisfor users reading the Code in a second language?

Obstacles to knowledge

This problem can be overcome if the employer sponsorsIMDG Code training.

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The training problem is compounded if shippers andpackers operate hundreds of miles from the sea andhave no natural contact with maritime affairs. Thesituation is even more difficult if the operation is locatedin a state or region where business culture isundeveloped, and regulatory compliance is not a priority.

The Club recognises the existence of these knowledgegaps, and seeks to address them by making the newIMDG Code guidebooks available through shippinglines to their customers.

Causes of dangerous goodsincidentsBefore looking in detail at how the guidebooks work, itmay be useful to look at the nature of dangerous goods,and at the main factors that cause dangerous goodsincidents. Then the relationship of compliance with theIMDG Code to risk reduction becomes apparent.

The hazard and risk factors

The IMDG Code requires shippers to identify cargo asdangerous goods if it possesses a known hazard suchas flammability, toxicity etc.

✔✔✔✔✔

A typical illustration from the guidebook showing good practice for drum packing.

The IMDG Code rules enable the carriage of dangerousgoods to be acceptable under managed risk conditions.For example, the carriage of flammable liquid is neverwithout a fire hazard, but provided the ship is fully awareof the hazard, the packaging is adequate and intact, andthe stowage and segregation is done according to theIMDG Code rules, the ship should be able to deal withan unexpected incident. The risk is recognised,measurable, minimised and commercially acceptable.

Unplanned risk factors

The substances below are examples of commonlycarried dangerous goods with a history of causingserious incidents on ships. Remember, it is not theproduct but the failure to comply with the IMDG Codethat causes incidents.

● Calcium hypochlorite, widely used for watertreatment, has a bad reputation for spontaneouslyigniting in a ferocious way.

● Barbeque charcoal has done the same in a lessviolent way, resulting in smouldering block stows ondeck.

● Thiourea dioxide, a substance widely used in thepaper, leather and textile industries, was not listed asdangerous goods until a number of shipboardincidents caused the experts to classify it as a self-reactive substance.

Why do incidents onboard occur?

Events and circumstances far from the ship can sow theseeds of incidents arising from:

1 Mis-declaration or non-declaration by shippers.

2 Quality and selection of the packaging.

3 Provision and accuracy of documentation.

4 Professionalism of the container packing.

Hanjin Pennsylvania

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5 The completely unexpected.

6 Human factors – regional and company attitudes.

1 Mis-declaration or non-declaration byshippers

There are many ways in which chemicals can becombined to make new substances. Dangerous goodsnot listed by name in the IMDG Code DangerousGoods List must be tested by the shipper to check forhazardous properties, then shipped under a generichazard classification.

It is possible for hazards to not be declared under thesecircumstances, either because of lack of time to test,lack of test facilities, making false assumptions, lack ofproduct knowledge, lack of knowledge of therequirement to make an IMDG Code declaration orhow to make one, or even wilful withholding ofinformation to avoid dangerous goods surcharges.

Photos above: These allegedly UN standard drums failedbecause of a steel manufacturing fault. Examination showedalso that the internal surfaces of the drums were not paintedand were heavily corroded before filling.

Top photo: When mechanical handling systems dropcontainers, cargo can be badly damaged while the containerremains unmarked.

Lower photo: When this container was dropped, severaldrums were badly distorted. If the container had not beeninspected but simply loaded to the ship, the likelihood is thatmany drums would have burst during the sea voyage.

2 Quality and selection of packaging

Like a time bomb, defective or incompatible packagingmay fail and release product at any point in a voyage.Defects are difficult to spot until the package fails.

In the example illustrated, new UN standard steel drumsfailed because small pieces of clinker (mill scale) wererolled into the sheet steel from which the drums weremade. During the voyage, the mill scale broke out leavingholes in the drums. The IMDG Code specifies the qualityof packaging, and failure to meet that standard was thecause of this incident. Fortunately the cargo wasdeclared and stowed according to IMDG rules and thecrew were able to deal with the problem appropriately.

Beware of reconditioned drums

There is a market in low-cost second hand andreconditioned steel and plastic drums. They are oftenused for low value, low profit substances such as tar oilsand creosotes. Reconditioned steel drums have beenknown to fail because of brittle metal fracture. The

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process of cleaning and reconditioning, which mayinvolve fitting new top and bottom heads, puts stresson the materials that was not anticipated during originaldrum manufacture. Much depends on quality control.

The IMDG Code does not require shippers to notify theship of use of reconditioned drums for dangerousgoods. Beware, they are another unknown risk factor.

3 Provision and accuracy of documentation

The IMDG Code requires shippers to provide self-certified documentation describing the identity of thedangerous goods, the nature of the hazard, the quantityand the type of packaging. This data from thedangerous goods manifest is used to stow the ship andis available for dealing with onboard incidents.

There is a serious lack of knowledge about the contentand purpose of dangerous goods documentation in thetransport chain between the shipper and the ship. Theknowledge gap may be expected to grow in proportionto the distance from a port, with shippers being leastwell informed, but regional attitudes also have a stronginfluence.

Photo: Who signed for this one? A container packingcertificate has to be signed by the person responsible forpacking and securing the load as safe for sea.

This was the condition of a stow of plastic drums of corrosiveproduct after a 50 kilometre road journey to the port. The seajourney had not yet started.

However, the maritime industry must face the fact thatmany employees of shipping companies, forwardingagents and container packers are not as well informedabout dangerous goods hazards and IMDG Code

Typical information required in an IMDG Codedeclaration (other products may requiredifferent data)

Packaging data required for each substance:

Number and typeof packages: 180 x 200 litre steel drums

Quantity data required for each substance:

Net mass/volume: 17,600 kg

Gross mass/volume: 18,600 kg

Identification data required for each substance:

Proper Shipping Name: Acetyl Chloride

Class: Class 3 Flammable liquid

UN Number: 1717

Supplementary identification data that may berequired for some substances:

Packing group: PG II

Sub-risk: Class 8 Corrosive

Flashpoint: (5ºC c.c.)

Marine pollutant: (not applicable for this substance)

Control temperature: (not applicable for this substance)

Emergency temperature: (not applicable for this substance)

The shipper isrequired to providethis standard ofdetail in a certifieddocument for eachdangerous goodssubstance heoffers for shipment

The shipper signs adeclaration confirming tothe line that all the productsare correctly described,packaged and presentedaccording to the IMDGCode and all applicableregulations �

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Shipper’s Declaration

I hereby declare that the contents of thisconsignment are fully and accurately describedby the Proper Shipping Name, and are classified,packaged, marked and labelled/placarded andare in all respects in proper condition fortransport according to the applicableinternational and national governmentalregulations.

Company name of shipper: ABC ChemicalCompany

Name/status of declarant: Sam Shipper/Export supervisor

Place and date: Manchester19.08.2005

Signature of declarant: Sam Shipper

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requirements as is consistent with riskreduction. Unfortunately, it is the shipthat bears the additional risk, and oncethe container is loaded, the ship cando nothing to correct the mistakes ofothers.

Many dangerous goods documents ofvery poor quality pass through thetransport chain. How is this so? Eitherthe parties who should identify theerrors are instructed to wilfully ignoreany problems, or they simply don’tknow any better.

4 Professionalism of thecontainer packer

Cargo securing inside containers isstill as fundamental now to successfulmaritime transport as it ever was ingeneral cargo ships. The lack ofproper securing of cargo in containersremains a significant cause ofdamage, and dangerous goodsleaking from broken packages is an alltoo frequent additional risk factor.

The IMDG Code requires the packer to sign a packingcertificate stating that any dangerous goods have beensafely secured for sea. Despite this, out-turn reports atcontainer cargo spillage incidents produce a familiarroll call of defects in cargo stowing and securing:

● Unsecured packages rolling and tumbling to self-destruction inside void spaces in the container.

● Cargo crushed and collapsed by being overstowedby heavier cargo.

● Point-loading damage to cargo by pallets caused bylack of horizontal support between tiers.

● Collapse of flimsy and badly made pallets causingstow instability.

● Penetration of cargo, particularly drums, fromprotruding nails in floors, pallets, dunnage andbroken pallets.

● Direct physical damage to packages caused by forklift trucks.

● Ram-loaded packages split by forcing them into thecontainer by fork lift.

5 The completely unexpected

From time to time people do unusual things tocontainers – tip them from road trailers, shunt them intorailway buffers, or drop them from cranes. After such anevent, in an ideal world IMDG Code dangerous goodswarning placards would compel conscience toovercome carelessness and check the cargo beforeloading on a ship, but this is not always the case.

6 Human factors – regional and companyattitudes

IMDG Code rules, like any laws and regulations, only

Photo: Containers subjected to handling methods such asthis should be opened and inspected for damage beforeloading to a ship – does it happen?

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Container/vehicle packing declaration

I hereby declare that the goods described above have beenpacked/loaded into the container/vehicle identified above inaccordance with the applicable provision.

Must be completed and signed for all container/vehicle loads byperson responsible for packing/loading

Name of Company: XYZ Cargo Packing Co.

Name/status of declarant: Peter Packer / Supervisor

Place and date: Southampton 22.08.2005

Signature of declarant: PPPPPeter Peter Peter Peter Peter Packerackerackerackeracker

Packing certificates

When dangerous goods are packed into containers for sea, theIMDG Code requires a signed certificate from the packer,confirming that the packages were sound and the load waspacked, secured, marked, labelled and placarded all according tothe IMDG Code rules.

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have meaning in proportion to the degree to whichpeople respect and comply with them. We have lookedat the physical failures that create problems, but it ispeople who drive policy, manage companies, operateproduction plants, create documents and loadcontainers.

Why do people fail to comply withthe IMDG Code?Individual actions are influenced by organisationalprocedures and cultures, and vice versa. Here are justsome important areas:

● Company rules, standards and resourcesA large multi-national company can apply ready-made templates for operational safety standards thatinclude the IMDG Code, and have complianceofficers to plan training and maintain standards. Bycontrast, managers of small companies often havelimited resources, and these are directed towardsmanaging productivity and everyday problems.

● Business ethicsThere are employers in all societies that encourageemployees to regard regulations as ‘red tape’ andbarriers to productivity. Operators with this mindsetfind it easy to push aside the IMDG Code, when it isconvenient to do so, by simply not declaring cargoas dangerous goods. Again it is the ship that isbearing the risk, not them. This is primitive businessthinking, but often prevails, particularly in smallcompanies.The container packing industry is vulnerable to thisattitude. Consider container packing at its mostbasic. It only requires the rental of a fork lift truck, theconstruction of a simple container access ramp anduse of a piece of land by a roadside to set upbusiness as a container packer. There is not even arequirement for a building. It is an easy entry-levelbusiness for a budding entrepreneur with limitedfunds, and he may not even be aware of the IMDGCode.

In newly emerging industrial societies workers maytransfer, overnight, from traditional agricultural workto industrial processing involving dangerouschemicals. There will be a time lag before suchsocieties develop the instinctive understanding ofindustrial and chemical hazards that comes fromexperience. The IMDG Code has evolved over sixdecades, but it is a new concept to many companiesnow manufacturing and packing dangerous goodsin newly developing regions. They will need help andtraining to assimilate the IMDG Code into theirindustrial cultures.

● CommunicationIn addition to coping with the industrial culture gap,many developing regions are doing business withthe world in a second language, usually English.This adds another barrier to perfect understanding.Consider the extract from a safety data sheet below,which is taken from a Far Eastern manufacturer’swebsite. In the list of hazardous properties it says“Danger of Explosion: Not applicable,” but in thenext line under “Fire Hazards” it says, “Material isshock sensitive and potentially explosive.” Lost intranslation? The company had a highly technicalwebsite advertising sophisticated specialitychemicals but made an error in translation of the sortthat can easily be made on a shipping document.

The quickest way to get intobusiness:

1 Hire a fork lift truck

2 Make a ramp

3 Rent some land by theside of the road

4 You’re in business as acontainer packer!

Illustration from Book it right andpack it tight, of a typical damagescenario.

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● Individual skills and attitudesIt should not be forgotten that individual employeesmake decisions that affect outcomes, albeit againsttheir organisational background. Many people aretrained to perform a narrow set of technical skillsrepetitively, quickly and semi-automatically toachieve business productivity – for example tocreate dangerous goods documents on a computer,process a cargo booking, pack a container or bookcontainers through a dock gate.

For such individuals it is more difficult to apply theIMDG Code rules than to ignore them. Employeeswho are disaffected, poorly trained, or poorlysupervised will take short cuts and break the rules toget the job done with least effort. That may meanignoring the IMDG Code.

IMDG compliance should meanless incidentsWe have seen that there are many potential hiddencauses of dangerous goods incidents, and manyobstacles to the observance of the IMDG Code. Whilethis situation prevails, the risk to ships from hazardouscargo will remain unnecessarily high.

However, if all dangerous goods are shipped under theIMDG Code rules, the risks will be considerably lower.If ships know the nature, the hazard and the identity ofthe cargo, it can be stowed and segregatedappropriately, and incidents handled confidently.Dealing with a deck fire involving a known commodity isaltogether different from dealing with an unknowncommodity burning below deck.

Accepting that increasing IMDG Code compliance is atthe heart of the solution, how can this be achieved? TheClub believes that a significant improvement can bebrought about if shippers and container packers in allregions could be provided with practical IMDG Code

training aimed specifically at their operationalrequirements. The result is the Book it right and pack ittight guidebooks and training set.

Book it right and pack it tight

The Club hopes to make a contribution to boostingglobal understanding and use of the IMDG Code withthe Book it right and pack it tight pack of guidebooksand training material.

The guidebooks look at the role of the shipper, theshipping line booking agent, the freight consolidator(manager or supervisor), and the fork lift operator andcargo handler who physically loads the container, andidentify the key duties of each. The party concerned,instead of having to search through the 800 pages ofthe Code looking for his instructions, starts byconsulting his guidebook.

The guidebooks explain in simple terms what duties theIMDG Code requires, with colour illustrations andphotographs. Each duty described in the guidebooksincludes a reference that takes the reader directly to thetext in the Code where the full technical details arefound.

What the guidebooks contain

Guidebook 1 in the series is for shippers. It explainsthe shipper’s key duties such as:

● Classifying the hazard – the guidebook explains howthe UN classification system identifies all thedangerous goods details about a particularhazardous substance.

● Documenting the hazard – indicates the details thatthe IMDG Code requires be notified aboutdangerous substances, and how the IMDG Codedraws them together into a common global format fordocumentation. The guidebook includes examples ofhow the shipper must make out a shipper’sdeclaration for different types of dangerous goods,and how they should be presented on the document,

Lost in translation?

Extract from manufacturers’ Product Safety Data Sheet

Flashpoint: Not applicable

Flammability: Not applicable

Ignition Temperature: Not applicable

Danger of Explosion: Not applicable

Fire Hazards: Material isshock sensitiveand potentiallyexplosive!

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together with an example of a completed dangerousgoods document

● Documentation checklist – this book includes achecklist for use by shippers and others to ensurethat all the required details have been included on adangerous goods shipping declaration.

● Legal obligation – the guidebook explains themeaning of the legal text that appears on eachdangerous goods declaration, and the commitmentthe shipper is making when he presents dangerousgoods for shipment by sea.

● Package selection – the guidebook outlines theIMDG Code rules that shippers must follow whenselecting packaging that is suitable for dangerousgoods, and an illustration of the type of UN code thatappears on packages that have been tested andapproved for filling with dangerous goods.

● Use of different types of packages – the guidebookhas colour illustrations of different types ofpackaging used for dangerous goods including theconstruction of combination packages made up ofinner receptacles contained within outer wrappers.

● Marking and labelling – the guidebook explains andillustrates the shipper’s prime duty to apply specificwarning marks and labels to each package to giveclear and decisive information about the contents ofeach package.

It summarises the shipper’s duties in less detail, andconcentrates on the additional factors that come intoplay when packing dangerous goods into freightcontainers. Examples of additional key factors forconsolidators explained in Guidebook 3 include:

● Segregation of dangerous goods within a container– the guidebook explains how both the hazard andthe risk of an incident are escalated if the containerpacker ignores IMDG Code segregation rules andpacks incompatible dangerous goods in the samecontainer. The guidebook then shows how thesegregation should be checked either manually orelectronically using internet or proprietary computer-aided systems.

Guidebook 2 covers similar ground from the point ofview of shipping line employees. Its purpose is to assistcargo booking staff to check the information providedby shippers at the earliest stage, by asking shippers theright questions, and to help shippers to get the basicsright.

Guidebook 3 is aimed towards managers andsupervisors of cargo consolidation depots wheredangerous goods are packed into freight containers.

Illustration of packagemarks and labels that mustbe applied by the shipper

CORROSIVE LIQUIDACIDIC, ORGANICN.O.S. (caprylyl chloride)

UN 3265

ETHANOL

UN 1170

.

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▲

▲

▲

Taken from an illustration on blocking and bracing technique

● Securing cargo against movement inside containers– the conventional methods of blocking and bracingpackages of cargo inside freight containers areillustrated in a series of drawings covering drumstacking, use of pallets, stacking intermediate bulkcontainers (IBCs) and using timber and othermaterials to prevent cargo from moving.

● Marking and placarding of containers – theguidebook explains the packer’s duties regardingthe application of warnings to freight containers.

● Packing certificate – the guidebook explains thelegal responsibilities of the packer that areencapsulated in the packing certificate.

Guidebook 4 explains the problems, responsibilitiesand techniques of packing dangerous goods intocontainers from the point of view of the fork lift truckoperator and cargo handler. It includes photographs ofdamaged packages to illustrate what happens to cargothat is not effectively secured for transport by sea.

Each book also has a common reference section thatbriefly explains classification, technical terms andcommon ‘problem areas’ such as limited quantities andrules for aerosols.

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Simple guidance

There are over 800 pages of the IMDG Code, so thedetails in the guidebooks are selective. Each topic has atleast one reference to a part, chapter, section or sub-section of the main body of the IMDG Code text, takingthe reader directly to the full details of that topic. The aimis to enable the reader to identify his key requirement inthe guidebook, see an example of what is required, thenif he needs more information easily locate full technicaldetails in the Code, using the guidebooks as a chart.

Practical and accessible

The guidebooks are not intended as a replacement forthe IMDG Code, but as everyday guides for ordinaryoperational staff to find their way around it. It is notintended that these guidebooks sit on bookshelves inthe company library, but that they are issued as everydayoperational guides on desks in the manufacturer’sshipping office, the freight booking office, thewarehouse supervisor’s pocket, and the fork liftoperator’s mess room.

With this in mind the guidebooks are robustly made tosurvive heavy handling and spiral bound so they openflat for photocopying.

Operational checklists

The books include three checklists, one for completingshippers declarations, one for identifying trainingrequirements in container packing facilities, and one forpacking containers.

Serious purpose

Each book ends with a series of photographs of the fireaboard the Hanjin Pennsylvania, intended to graphicallybring home to shore side people that even the mostmodern container ships are vulnerable to undeclareddangerous goods incorrectly and inaccessibly stowedbelow deck. The message is that the IMDG Code is notred tape, or pointless regulations, but a seriousdocument whose sole purpose is to protect shipper’scargo, ships and mariner’s lives.

Also in the training package:

● Four PowerPoint trainingpresentations on CDThe guidebooks are supplied in a training packageconsisting of the four guidebooks in a slip case, andPowerPoint training presentations, one for eachguidebook. The purpose of these is to enablecompany managers with only a passing knowledge ofthe IMDG Code to confidently introduce employeesto key aspects of the IMDG Code, and theguidebooks themselves and how to use them.

● DVDAlso included is aDVD version ofAny Fool CanStuff a Container

The Club together with several Members has made amajor commitment to ship safety by producing thispackage. We believe that the pack will be of greatassistance to shippers and packers looking for practicalIMDG Code guidance, and to shipping lines seeking ameans to provide such assistance to their customers.Especially those operating in the developing regionsbeyond the reach of normal IMDG Code training, andnewcomers to dangerous goods everywhere.

OrderingMembers may order copies of the above direct from theClub and non-members through Marisec Publications,www.marisec.org.

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P&

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Do you know who receives dangerousgoods into your site?

Are they trained to checkdocumentation and package marking?

Does anyone keep a record ofdangerous goods on your site?

Is the record kept up-to-date?

Is the location recorded?

Do your personnel palletise/re-package/shrink-wrap dangerousgoods packages, or put put them intooverpacks?

Have they been trained to mark andlabel the packages to IMDG rules?

Are shipping container load plansprepared?

Do you know who controls loading ofdangerous goods into shippingcontainers?

Do they have access to the IMDG Coderules?

Have they been trained to understandIMDG Code segregation?

Do you know who supervises theloading of dangerous goods intoshipping containers?

Do they have access to the IMDG Coderules?

Have they been trained to understandthe IMDG Code?

Is anyone responsible for checkingshipping containers before loading?

Have they been trained in what tocheck for?

Have fork lift operators been trained inIMDG Code segregation?

Have fork lift operators receivedtraining in loading dangerous goods andnon-hazardous cargo into containers?

Is anyone responsible for ensuring thatpackages have been secured inside theshipping container?

Have they been trained to secure cargo?

Are timber, plywood sheet and securingmaterials available?

Are tools available for cutting timberand plywood sheets?

Are people trained to use them?

Are container manifests prepared?

Are manifests checked to include all thedangerous goods?

Do you know who is responsible forapplying hazard warning placards?

Have they been trained?

Is the stock of placards adequate?

Are seals applied and seal numbersrecorded?

Are packing certificates completed andsigned?

Do you know who signs them?

Have they been trained and do theyunderstand the legal significance ofpacking certificates?

This is a checklist to confirm that you havesound operating procedures.

Tick ✔ as appropriate:

Consolidator’s dangerous goods training andprocedure checklist

Dangerous Goods is written by Richard Mastersand was first produced as a supplement to LP News 18, March 2006

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UK P&I CLUBIS MANAGEDBY THOMASMILLER

For further information please contact:Loss Prevention Department, Thomas Miller P&I LtdTel: +44 20 7204 2307. Fax +44 20 7283 6517Email: lossprevention.ukclub@thomasmiller.com