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Anyone shipping or transporting hazmat by vessel within the U.S. must follow either the Hazardous Materials Regulations required by the Pipeline and Hazardous Materials Safety Administration or the International Maritime Dangerous Goods Code for the Safe Transport of Dangerous Goods by vessel. Following the International Maritime Dangerous Goods Code allows for greater flexibility and fewer restrictions for those needing to transport hazmat by vessel domestically and internationally.
With multiple agencies weighing in on regulations for transporting hazardous materials by vessel, it’s important to understand the differences to make sure your shipments are properly prepared and transported.
Anyone shipping or transporting hazmat by vessel within the U.S. must follow the Hazardous Materials Regulations (HMR) required by the Pipeline and Hazardous Materials Safety Administration (PHMSA). However, PHMSA provides an alternative, allowing shippers and transporters to follow the International Maritime Dangerous Goods (IMDG) Code for the Safe Transport of Dangerous Goods by vessel.
Following the IMDG Code allows for greater flexibility and fewer restrictions for those needing to transport hazmat by vessel domestically and internationally. However, as required by the HMR, shipments offered under the IMDG Code must also conform to:
The International Maritime Dangerous Goods (IMDG) Code helps to ensure safety when dangerous goods are transported by sea.
The following explanations cover the IMDG Code at a high level. This information is designed to give a general understanding of the IMDG Code requirements and is not a replacement for the IMDG Code.
The most current and official IMDG Code must be consulted for full compliance. The IMDG Code is available by visiting www.imo.org.
The International Maritime Dangerous Goods (IMDG) Code was developed by the International Maritime Organization (IMO) to enhance and harmonize the safe carriage of dangerous goods in international waters. The IMO also developed the IMDG Code as a way to help prevent pollution to the environment.
The IMDG Code is based on the UN Model Regulations, but also includes additional requirements applicable to the maritime transport of dangerous goods (such as requirements for marine pollutants, freight container loading procedures, stowage and segregation, and other requirements applicable to shipboard safety and preservation of the marine environment) that are not covered by the UN Model Regulations.
The provisions of the IMDG Code are applicable to anyone shipping or transporting dangerous goods by vessel in international waters. Anyone shipping or transporting dangerous goods by vessel within U.S. waters has the choice to follow the IMDG Code or the 49 CFR Hazardous Materials Regulations as the Pipeline and Hazardous Materials Safety Administration (PHMSA) allows the use of the IMDG Code for transportation by vessel. In cases when it is unknown if the shipment will transit through international waters, it’s recommended to follow the provisions of the IMDG Code.
All aspects of the shipping process, such as packaging, marking, and labeling, are determined by how a dangerous good is classified. This makes the classification process the single most important step when shipping dangerous goods. This is also the reason the International Maritime Dangerous Goods (IMDG) Code requires shippers to classify dangerous goods before they can be offered for shipment.
Some dangerous goods are easy to classify because the material and their hazard(s) are well known. For example, gasoline is a well-known flammable liquid. Other materials, such as mixtures or new products, may be difficult to classify because the hazards are unknown. In this case you must have the material tested to determine the hazardous properties.
The IMDG Code also requires shippers to identify if the dangerous goods are a marine pollutant.
Dangerous goods must meet one or more of the hazard class definitions. There are nine hazard classes listed in the International Maritime Dangerous Goods (IMDG) Code — some of which are further subdivided into divisions. The definitions summarized below should be used as guidelines only.
Complete specifications for each hazard class and division can be found in Chapter 2 of the IMDG Code.
Some dangerous goods are further subdivided into packing groups. The packing group indicates the degree of danger presented by the dangerous goods.
Packing groups have been developed for dangerous goods in Class 3, Class 4, Division 5.1, Division 6.1 and Class 8 materials. Some hazardous materials are assigned more than one packing group. Because packing groups impact the type of packaging that can be used, it is critical that each material is assigned to the correct one. The criteria for determining packing groups are included in the IMDG Code as follows:
Some substances in Class 9, liquids in Division 5.1, and waste in Division 6.2 have been assigned packing groups according to the Dangerous Goods List in IMDG Code Chapter 3.2. Requirements for a specific packaging performance level can be found in the applicable packing instruction.
Marine pollutants
The IMDG Code requires shippers to also classify dangerous goods as a marine pollutant if:
UN numbers and proper shipping names
Once the hazard class and packing group have been determined, the shipper must select an appropriate UN number and proper shipping name from the Dangerous Goods List in Chapter 3.2. If the dangerous good is listed by name, that name must be used. If the dangerous good is not listed by name a generic or not otherwise specified (n.o.s.) name must be used.
Occasionally, there will be situations when dangerous goods meet the definition of more than one hazard class, and it’s not specifically listed by name in the Dangerous Goods List. In this case, you must determine which of the hazard classes will be the primary hazard. Typically, the hazard class that poses the greater hazard during transport would take precedence and become the primary hazard.
The hazard classes listed below in order take precedence:
Hazard classes not listed above must be classed according to the precedence of hazard table located in Chapter 2.0.3.
The International Maritime Dangerous Goods (IMDG) Code has provisions which allow a shipper to classify and ship unknown dangerous goods to a laboratory for analysis. The samples of unknown dangerous goods may be classified by the shipper and assigned a tentative shipping description, based on the:
Proper shipping name
When shipping samples of unknown dangerous goods the shipper must include the word “sample” in conjunction with the proper shipping name, for example:
When a “not otherwise specified” (n.o.s.) entry is used for the sample, the proper shipping name does not need to include the technical name.
The most severe packing group possible must be used for the selected proper shipping name.
Limitations
Samples using the exception must not be:
Self-reactive substances and organic peroxides samples must meet the conditions in sections 2.4.2.3.2.4.2 and 2.5.3.2.5.1, respectively.
All samples must be transported in combination packaging with a net weight not exceeding 2.5 kgs and not packed with any other goods.
The International Maritime Dangerous Goods (IMDG) Code is an international code for transport of dangerous goods by sea, intended to promote the safe carriage of dangerous goods and prevent pollution to the environment.
The code details requirements that apply to individual substances, materials, and articles, and covers packing, container traffic, and stowage, with particular attention paid to the segregation of incompatible substances.
The Dangerous Goods List in Part 3 comprises the core of the code, and provides packing, labeling, stowage, segregation, handling, and emergency response information for thousands of entries.
Scope of the Dangerous Goods List and general provisions
The Dangerous Goods List includes entries for the most commonly transported dangerous goods. Since it is impractical to include a separate entry for every existing chemical substance or article, the List also includes generic or “not otherwise specified” (n.o.s.) names for various mixtures and solutions (for example, FLAMMABLE LIQUID, N.O.S., UN 1993). This way, the List provides an appropriate name or entry for any dangerous good that may be transported.
When a dangerous good is specifically listed by name, it must be transported according to the requirements for that entry in the List. To use a generic or n.o.s. entry to transport substances, materials, or articles that do not appear specifically by name follow these steps:
A generic or n.o.s. name may only be used when:
The classification must be made by the shipper/consignor, or by the appropriate competent authority in some cases.
Once the class of the dangerous good is established, all conditions for transport must be met. Any dangerous good with explosive characteristics must first be considered for inclusion in Class 1.
Inherent instability in goods may take different dangerous forms, including:
Because of this potential for instability, the Dangerous Goods List prohibits certain dangerous goods, or dangerous goods in a specific form, concentration, or state, from transport by sea. These prohibited goods are not suitable for transport by sea under normal conditions of transport. In some cases, the inherent instability can be controlled by suitable packaging, dilution, stabilization, addition of an inhibitor, temperature control, or other measures to make transport by sea possible.
Precautionary measures required
If precautionary measures are shown in the Dangerous Goods List for a dangerous good (for example, that it must be stabilized or diluted), that dangerous good may not be transported without taking those measures. Exceptions to this may exist if the item in question is listed elsewhere (such as in class 1) without any indication of precautionary measures, or with different measures indicated.
Polymerization and dangerous reactions
Certain substances can polymerize or otherwise react in a dangerous manner under certain conditions of temperature or in contact with a catalyst. To mitigate this tendency:
Unless these products are sufficiently stabilized to prevent any dangerous reaction during the voyage, transport of the products is prohibited.
The proper shipping names of dangerous goods are listed in the Dangerous Goods List. The index to the List includes synonyms, secondary names, initials, abbreviations of names, etc., in alphabetical order, to facilitate the search for the proper shipping name.
The proper shipping name is the part of the entry that accurately describes the goods in the Dangerous Goods List. It is shown in upper-case characters along with other numbers or letters that are an integral part of the name. An alternative proper shipping name may be shown in brackets following the main proper shipping name.
Only the most appropriate proper shipping name must be shown in the transport document and package marks when:
Proper shipping names may be used in the singular or plural as appropriate.
Commercial or military names for goods of class 1 that contain the proper shipping name supplemented by additional text may be used.
Many substances have an entry for both the liquid and solid state or for the solid and solution. These are given separate UN numbers that are not necessarily adjacent to each other. Details can be found in the alphabetical index to the List.
If it is not already included in the proper shipping name, the word “MOLTEN” must be added when a substance that is solid is offered for transport in the molten state. Also check requirements for elevated temperature substances in 5.4.1.4.3.4.
Note that special requirements apply to proper shipping names for:
Except for self-reactive substances and organic peroxides, and unless it is already included in capital letters in the proper shipping name shown in the Dangerous Goods List, the word “STABILIZED” must be added to the proper shipping name of any substance that, without stabilization, would be forbidden from transport due to its potential to dangerously react under conditions normally encountered in transport (for example, TOXIC LIQUID, ORGANIC, N.O.S., STABILIZED).
When temperature control is used to stabilize these substances to prevent development of dangerous excess pressure or evolution of excessive heat, or when chemical stabilization is used in combination with temperature control, then:
Hydrates may be transported using the proper shipping name for the anhydrous substance.
Generic and “not otherwise specified” (n.o.s.) proper shipping names that are subject to special provision 274 or 318 in column 6 of the Dangerous Goods List must be supplemented with the technical or chemical group names. This does not apply if:
For explosives of class 1, descriptive text may be added to the proper shipping name to indicate commercial or military names. Technical and chemical group names must be entered in brackets immediately following the proper shipping name.
The technical name must be:
Trade names must not be used for this purpose. For pesticides, use only:
When mixtures or articles containing dangerous goods are described by one of the n.o.s. or generic entries subject to special provision 274, not more than the two constituents that most predominantly contribute to the hazard or hazards need to be shown. This requirement does not apply to controlled substances when their disclosure is prohibited by national law or international convention.
If a package containing a mixture is labeled with any subsidiary hazard label, one of the two technical names shown in brackets must be the name of the constituent that compels the use of the subsidiary hazard label.
For proper documentation for n.o.s. entries classified as marine pollutants, the recognized chemical name of the constituent that most predominantly contributes to the classification as marine pollutant must be added to the proper shipping name. Exceptions to this are found in special provision 274.
If a substance is specifically listed by name in the Dangerous Goods List, it must be identified in transport by the proper shipping name in the List. A substance listed by name that contains technical impurities or additives for stability or other purposes that affect its classification must be considered a mixture or solution.
A mixture or solution is not subject to the International Maritime Dangerous Goods (IMDG) Code if the characteristics, properties, form, or physical state of the mixture or solution are such that it does not meet the criteria for inclusion in any class.
If a mixture or solution meets the classification criteria of a single predominant substance identified by name in the List and has one or more substances not subject to the provisions of this Code and/or traces of one or more substances identified by name in the List, then assign the UN number and proper shipping name of the predominant substance named in the List.
This requirement does not apply if:
Qualifying words such as “MIXTURE” or “SOLUTION,” as appropriate, must be added as part of the proper shipping name. The concentration of the mixture or solution may also be indicated after the basic description.
For a mixture or solution composed of two or more dangerous goods, use the entry that most precisely describes the mixture or solution.
Dangerous goods with similar chemical properties are grouped together in segregation groups. Some substances, mixtures, solutions, or preparations falling within a segregation group are not listed in the International Maritime Dangerous Goods (IMDG) Code by name, but are shipped under n.o.s. entries. Although n.o.s. entries are not listed in the segregation groups, the consignor must decide whether including them under the segregation group is appropriate and, if so, must note that fact in the transport document.
The segregation groups in the IMDG Code do not cover substances that fall outside the classification criteria of the Code. Some non-hazardous substances have similar chemical properties as substances listed in the segregation groups. If the consignor or the person responsible for packing the goods into a cargo transport unit has knowledge of the chemical properties of those non-dangerous goods, they may voluntarily use the segregation provisions of a related segregation group.
The segregation groups are identified in the IMDG Code Section 3.1.4, and include:
The Dangerous Goods List is found in the International Maritime Dangerous Goods (IMDG) Code Chapter 3.2. The List is divided into 18 columns. Each column includes a reference to the appropriate section in the IMDG Code that provides additional information for that requirement.
Special provisions
When column 6 of the Dangerous Goods List indicates that a special provision applies to a dangerous good, the requirements of that special provision are listed in numerical order amid nearly a thousand entries in Chapter 3.3 of the Code.
If a special provision includes a requirement for package marking, the provisions of section 5.2.1.2 must be met. If the required mark is specific wording in quotation marks, the size of the mark must be at least 12 mm, unless otherwise indicated in the special provision or elsewhere in the Code.
The International Maritime Dangerous Goods (IMDG) Code Chapter 3.4 details the conditions that apply to transport of dangerous goods of certain classes packed in limited quantities. Dangerous goods that are packed in limited quantities and meet the requirements in this chapter are subject to reduced requirements.
For each substance in the Dangerous Goods List, the quantity limit for the inner packaging or article is specified in column 7a. The quantity “0” in this column indicates that the entry is not permitted to be transported under the provisions for limited quantities.
Limited quantities: Packing
Dangerous goods must be packed only in inner packagings that are placed in suitable outer packagings. Intermediate packagings may be used. Additional requirements apply to articles of division 1.4, compatibility group S. The use of inner packagings is not necessary for transport of certain articles containing aerosols or gas.
In some cases, shrink-wrapped or stretch-wrapped trays are acceptable as outer packagings for articles or inner packagings containing dangerous goods. Inner packagings that could break or be easily punctured, such as those made of glass, porcelain, stoneware or certain plastics, must be placed in suitable intermediate packagings, and must be designed to meet the construction requirements of the IMDG Code Section 6.1.4. The total gross mass of the package may not exceed 20 kg.
Liquid goods of class 8, packing group II in glass, porcelain, or stoneware inner packagings must be enclosed in a compatible and rigid intermediate packaging.
Limited quantities: Stowage
Dangerous goods packed in limited quantity are allocated stowage category A, which is defined in the IMDG Code Section 7.1.3.2. The other stowage provisions indicated in column 16a of the Dangerous Goods List do not apply.
Limited quantities: Segregation
Different dangerous substances in limited quantities may be packed in the same outer packaging, only if:
The segregation provisions of the IMDG Code Chapter 7.2 to 7.7 and the segregation provisions in column 16b of the Dangerous Goods List do not apply for packagings containing dangerous goods in limited quantities or in relation to other dangerous goods. However, articles of division 1.4, compatibility group S must not be stowed in the same compartment, hold, or cargo transport unit with dangerous goods of class 1 of compatibility groups A and L.
Limited quantities: Marking and placarding
Packages containing dangerous goods in limited quantities must bear the mark detailed in the IMDG Code Section 3.4.5.
The minimum dimension per side is 100 mm.
Packages of dangerous goods packed according to Part 3, Chapter 4 of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air may bear a “Y” in the center of the mark to certify conformity with the provisions (minimum 100 mm per side).
The mark must be:
The top and bottom portions and the surrounding line must be black. The center area must be white or a suitable contrasting background. Minimum dimensions apply, and all features must be in proportion. If the size of the package necessitates, the outer dimensions may be reduced to not less than 50 mm × 50 mm as long as the mark remains clearly visible.
Limited quantities: Multimodal recognition of marks
Packages containing dangerous goods bearing the “Y” mark for transport by air, with or without the additional labels and marks for air transport, meet the marking requirements and need not bear the mark without the “Y”.
Packages containing dangerous goods in limited quantities bearing the limited quantities mark and conforming with the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, including all necessary marks and labels specified in parts 5 and 6, meet the IMDG Code requirements for limited quantities.
When packages containing dangerous goods packed in limited quantities are placed in an overpack or in a unit load, the overpack or the unit load must be marked with the limited quantity mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. In addition, an overpack must be marked with the word “OVERPACK” unless required marks representative of all dangerous goods in the overpack are visible. The lettering of the “OVERPACK” mark must be at least 12 mm high. Other provisions for overpacks and unit loads apply if other dangerous goods not packed in limited quantities are contained in the overpack or in a unit load.
Limited quantities: Placarding and marking of cargo transport units
Cargo transport units containing dangerous goods packed in limited quantities with no other dangerous goods must not be placarded nor marked according to the marking requirements for dangerous goods. Instead, they must be marked on the exterior with the mark in the IMDG Code Section 3.4.5.5.4.
Cargo transport units containing dangerous goods and dangerous goods packed in limited quantities must be placarded and marked according to the provisions that apply to the dangerous goods that are not packed in limited quantities. However, if no placard or mark is required for the dangerous goods not packed in limited quantities, the cargo transport units must be marked with the mark in IMDG Code Section 3.4.5.5.4.
The mark must be readily visible, legible, and still be identifiable on cargo transport units surviving at least three months’ immersion in the sea. The mark must be at least 250 mm × 250 mm and displayed in locations specified in IMDG Code Section 5.3.1.1.4.1.
Limited quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “limited quantity” or “LTD QTY” must be included on the dangerous goods transport document, along with the description of the shipment
Excepted quantities of certain dangerous goods that meet the provisions of the International Maritime Dangerous Goods (IMDG) Code Chapter 3.5 are subject to reduced requirements.
For radioactive material, the provisions for excepted packages are found in IMDG Code Section 1.5.1.5.
Dangerous goods that may be carried as excepted quantities are indicated in column 7b of the Dangerous Goods List. The code in column 7b indicates the maximum net quantity allowed for the inner and outer packaging.
Excepted quantities: Packagings
Packagings used to transport dangerous goods in excepted quantities must comply with certain conditions.
There must be an inner packaging and each inner packaging must meet construction requirements detailed in IMDG Code Section 3.5.2. The closure of each inner packaging must be held securely in place by positive means. If a receptacle has a neck with screw threads, it must also have a leakproof threaded cap. The entire closure must be resistant to the contents.
Each inner packaging must be securely packed in intermediate packaging with cushioning material so that they cannot break, be punctured, or leak the contents under normal conditions of transport.
For liquids, the intermediate or outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packagings. The absorbent material may also serve as the cushioning material. Dangerous goods must not react dangerously with or reduce the integrity of the packaging materials. Regardless of its orientation, the package must completely contain the contents in the event of breakage or leakage.
The intermediate packaging must be securely packed in a strong, rigid outer packaging.
Each package must be large enough to apply all necessary marks.
Overpacks may be used and may also contain packages of dangerous goods or goods not subject to the IMDG Code.
Excepted quantities: Tests for packagings
The complete package as prepared for transport must be capable of withstanding the tests detailed in IMDG Code Section 3.5.3 without breaking or leaking and without a reduction in effectiveness. The testing must be appropriately documented.
Excepted quantities: Marking
Packages containing excepted quantities of dangerous goods must be marked with the mark shown in IMDG Code Section 3.5.4. The primary hazard class of each of the dangerous goods contained in the package must be shown in the mark. If the name of the consignor or consignee is not shown elsewhere on the package, this information must be included within the mark.
* The class or division number(s) must be shown in this location.
** The name of the consignor or of the consignee must be shown in this location if it does not appear elsewhere on the package.
The mark must be a square with the border hatching and symbol in black or red, on white or suitable contrasting background. The minimum dimensions are 100 mm × 100 mm. If dimensions are not specified for a feature, it must be in approximate proportion to those shown.
Overpacks and the unit loads containing excepted quantities must be marked with the excepted quantities mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. Overpacks must also be marked with the word “OVERPACK” unless marks representative of all dangerous goods in the overpack are visible.
Excepted quantities: Maximum per transport unit
A maximum of 1,000 packages containing dangerous goods packed in excepted quantities may be carried in any cargo transport unit.
Excepted quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “dangerous goods in excepted quantities” and the number of packages must be included on the dangerous goods transport document, along with the description of the shipment.
Excepted quantities: Stowage
Dangerous goods packed in excepted quantity are allocated stowage category A (defined in IMDG Code Section 7.1.3.2). The stowage provisions in column 16a of the Dangerous Goods List do not apply.
Excepted quantities: Segregation
The segregation requirements of IMDG Code Chapter 7.2 to 7.7 do not apply for:
Appendices
Appendix A to Part 3 of the IMDG Code contains the list of generic and n.o.s. proper shipping names. The name in the Dangerous Goods List that most appropriately describes the substance or article must be used as the proper shipping name. The main generic entries and all the n.o.s. entries given in the Dangerous Goods List appear in Appendix A.
General and n.o.s. names are grouped according to their hazard class or division. Within each hazard class or division, the names are in one of three groups, including:
Appendix B contains a glossary of terms applicable to Part 3 of the IMDG Code.
A consignor offering dangerous goods for transport must provide the carrier with the information that applies to those dangerous goods. The information may be provided on a dangerous goods transport document or, with the agreement of the carrier, by electronic data processing (EDP) or electronic data interchange (EDI) techniques.
When EDP or EDI techniques are used, the consignor must be able to produce the paper document, without delay, with the information in the sequence required by the International Maritime Dangerous Goods (IMDG) Code.
Document format
A dangerous goods transport document may be in any form, provided it contains all information required by the IMDG Code. If both dangerous and non-dangerous goods are listed in one document, the dangerous goods must be listed first, or be emphasized by another method. The document may be more than one page, provided the pages are consecutively numbered. The information on the document must be easy to identify, legible, and durable.
The dangerous goods transport document must include:
Records retention
The consignor and the carrier must retain a copy of the dangerous goods transport document and additional information and documentation specified in the IMDG Code for a minimum period of three months. When the documents are kept electronically or in a computer system, the consignor and the carrier must be able to reproduce them in a printed form.
Information required on the dangerous goods transport document begins with the dangerous goods description.
For each dangerous substance, material, or article offered for transport, the document must provide:
The five elements of the dangerous goods description must be shown in the order listed above, with no information interspersed, except as allowed by the International Maritime Dangerous Goods (IMDG) Code. Unless permitted or required by the Code, additional information being included must be placed after the dangerous goods description.
The proper shipping name in the dangerous goods description must be supplemented with the following information, when appropriate:
In addition to the dangerous goods description, the following information must be included after the dangerous goods description on the transport document:
Consignor certification
The dangerous goods transport document must include a certification or declaration that the consignment is acceptable for transport and that the goods are properly packaged, marked, and labeled, and in proper condition for transport according to the applicable regulations. The certification must be signed and dated by the consignor.
If the documentation is presented to the carrier via electronic data processing (EDP) or electronic data interchange (EDI) transmission techniques, the signature may be electronic or may be replaced by the name (in capital letters) of the person authorized to sign.
When the dangerous goods transport information is given to a carrier by EDP or EDI techniques and subsequently the dangerous goods are transferred to a carrier that requires a paper dangerous goods transport document:
When dangerous goods are packed or loaded into a container or vehicle, those responsible for packing the container or vehicle must provide a “container/vehicle packing certificate.” The certificate must specify the container/vehicle identification number and certify that the operation has been carried out according to certain conditions, including that:
Note that the container/vehicle packing certificate is not required for portable tanks.
The information required in the dangerous goods transport document and the container/vehicle packing certificate may be incorporated into a single document; if not, these documents must be attached.
If the information is incorporated into a single document, the document must include a signed declaration indicating that the packing of the goods into the container/vehicle has been carried out in accordance with the applicable provisions. This declaration must be dated and the person signing it must be identified on the document.
If the certificate is presented to the carrier via EDP or EDI transmission techniques, the signature may be electronic or may be replaced by the name (in capital letters) of the person authorized to sign.
If the certificate is given to a carrier by EDP or EDI techniques and subsequently the dangerous goods are transferred to a carrier that requires a paper container/vehicle packing certificate, the carrier must ensure that:
Each ship carrying dangerous goods and marine pollutants must have a special list, manifest, or stowage plan setting out the dangerous goods (except dangerous goods in excepted packages of class 7) and marine pollutants and the location of those goods on the ship.
This special list or manifest must be based on the documentation and certification required in the International Maritime Dangerous Goods (IMDG) Code. In addition to the information in the dangerous goods transport documents, it must contain the stowage location and the total quantity of dangerous goods and marine pollutants.
A detailed stowage plan that identifies by class and sets out the location of all dangerous goods and marine pollutants may be used in place of a special list or manifest.
Each ship carrying excepted packages of class 7 must have a special list, manifest, or stowage plan setting out these excepted packages and their location.
A copy of the documents must be made available before departure to the person or organization designated by the port State authority.
For consignments of dangerous goods, appropriate information must be immediately available at all times for use in emergency response to accidents and incidents involving dangerous goods in transport. The information must be:
Methods to comply with this requirement include:
In certain circumstances, special certificates or other documents are required when offering dangerous goods for transport.
A weathering certificate is required in some individual entries of the Dangerous Goods List.
A certificate exempting a substance, material, or article from the provisions of the International Maritime Dangerous Goods (IMDG) Code must accompany the consignment. For examples, see the individual entries for charcoal, fish meal, and seed cake.
New self-reactive substances and organic peroxides, or new formulation of currently assigned self-reactive substances and organic peroxides, must include a statement of the approved classification and conditions of transport.
Multimodal dangerous goods form
The Multimodal Dangerous Goods Form found in the IMDG Code Section 5.4.5 meets the requirements of SOLAS, chapter VII, regulation 4; MARPOL, Annex III, regulation 4; and the IMDG Code provisions for documentation.
The information required by the documentation provisions of the Code is mandatory, however, the layout of the form is not mandatory.
This form may be used as a combined dangerous goods transport document and container/vehicle packing certificate for multimodal carriage of dangerous goods.
Marking requirements in the International Maritime Dangerous Goods (IMDG) Code address the marking of dangerous goods according to their properties. Additional marks or symbols indicating precautions for handling or storing a package (such as a symbol indicating that a package must be kept dry) may be displayed on a package if appropriate.
Unless otherwise provided, the proper shipping name for the dangerous goods and the corresponding UN number, preceded by the letters “UN”, must be displayed on each package. The UN number and the letters “UN” must meet the minimum dimensions listed in the Code.
Example: CORROSIVE LIQUID, ACIDIC, ORGANIC, N.O.S. (caprylyl chloride) UN 3265.
For unpackaged articles, the mark must be displayed on:
For goods of division 1.4, compatibility group S:
All package marks required by the Code:
Salvage packagings, including large salvage packagings and salvage pressure receptacles, must also be marked with the word “SALVAGE” in lettering at least 12 mm high.
Intermediate bulk containers (IBCs) of more than 450 L capacity and other large packagings must be marked on two opposite sides.
Special marking for radioactive material
For radioactive materials, each package must be marked on the outside with an identification of the consignor, consignee, or both. Each overpack must be marked on the outside with an identification of the consignor, consignee, or both, unless these marks on all packages in the overpack are clearly visible. Excepted packages of class 7 radioactive material must be marked as required by International Maritime Dangerous Goods (IMDG) Code Section 5.1.5.4.1.
Each package with gross mass exceeding 50 kg must be marked with its permissible gross mass on the outside of the packaging.
Specific package types require additional marks as follows:
Each package that conforms to a design approved under one or more of paragraphs specified in IMDG Code Section 5.2.1.5.5 must be marked on the outside of the package with the following information:
For each package with a Type B(U), Type B(M) or Type C package design, the trefoil symbol must appear on the outside of the outermost receptacle that is resistant to the effects of fire and water. The symbol must be embossed, stamped, or otherwise resistant to the effects of fire and water.
Any mark on the package relating to the package type that does not relate to the UN number and proper shipping name assigned to the consignment must be removed or covered.
If LSA-I or SCO-I material is contained in receptacles or wrapping materials and transported under exclusive use provisions, the outer surface of these receptacles or wrapping materials may bear the mark “RADIOACTIVE LSA-I” or “RADIOACTIVE SCO-I”, as appropriate.
If international transport of packages requires competent authority approval of design or shipment, and different approval types apply in the different countries concerned by the shipment, marking must be according to the requirements of the country of origin of the design.
Special marking for marine pollutants
With limited exceptions, packages containing marine pollutants must be marked with the marine pollutant mark. The mark must be located adjacent to other required marks.
The mark must be in the form of a square set at an angle of 45° (diamond-shaped). The symbol of a fish and tree must be black on white or a suitable contrasting background. Minimum dimensions must be met. If the size of the package requires, the dimensions may be reduced, provided the mark remains clearly visible.
All labeling provisions of IMDG Code Section 5.2.2 apply in addition to the requirement for the marine pollutant mark.
Orientation arrows
With few exceptions, the following packagings must be legibly marked with package orientation arrows similar to those shown in IMDG Code Section 5.2.1.7 or meeting the specifications of ISO 780:1997:
The orientation arrows must appear on two opposite vertical sides of the package with the arrows pointing in the correct upright direction. They must be rectangular and large enough to be clearly visible considering the size of the package. A rectangular border around the arrows is optional.
Orientation arrows are not required on:
Arrows for purposes other than indicating proper package orientation must not be displayed on a package marked according to IMDG Code Section 5.2.1.7.
Excepted and limited quantities
Packages containing excepted quantities of dangerous goods must be marked according to IMDG Code Section 3.5.4. Packages containing dangerous goods packed in limited quantities must be marked according to IMDG Code Section 3.4.5.
Lithium battery mark
Packages containing lithium cells or batteries prepared according to special provision 188 must be marked as shown in IMDG Code Section 5.2.1.10.
The mark must indicate the UN number, preceded by the letters “UN”. If lithium cells or batteries are contained in or packed with equipment, the UN number preceded by the letters “UN” must be indicated. When a package contains lithium cells or batteries assigned to different UN numbers, all applicable UN numbers must be indicated.
*Place for UN number(s)
**Place for telphone number for additional information.
Minimum dimensions are 100 mm x 100 mm.
The mark must be a rectangle or a square with hatched edging and meet minimum dimensions. The symbol showing a group of batteries must be black on white or suitable contrasting background. The hatching must be red. If the size of the package so requires, the dimensions may be reduced to not less than 100 mm wide × 70 mm high.
Labeling requirements in the International Maritime Dangerous Goods (IMDG) Code address danger labels. Additional marks or symbols indicating precautions for handling or storing a package (such as a symbol indicating that a package must be kept dry) may be displayed on a package if appropriate.
Labels must identify primary and subsidiary hazards according to the models in IMDG Code Section 5.2.2.2.2, which define and illustrate requirements for:
For articles or substances specifically listed in the Dangerous Goods List, a danger class label must be affixed as indicated in:
A package containing a dangerous substance with a low degree of danger may be exempt from the labeling requirements. In this case, column 6 of the Dangerous Goods List will specify that no hazard label is required.
If a substance that meets the definition of more than one class is not specifically listed by name in the Dangerous Goods List, the provisions in chapter 2.0 must be used to determine the primary hazard class of the goods. In addition to the label required for that primary hazard class, subsidiary hazard labels must also be applied as specified in the List. However:
Three separate labels are provided for class 2:
Requirements for labels for class 2 gases with subsidiary hazards are defined in IMDG Code Section 5.2.2.1.4.
Label placement
Each label must be:
If a package is an irregular shape or small size and a label cannot be satisfactorily affixed, the label may be attached to the package by a securely affixed tag or other suitable means.
A placement exception may apply to cylinders for class 2. Due to their shape, orientation, and securing mechanisms for transport, these may bear labels that have been reduced in size, according to ISO 7225:2005, Gas cylinders, Precautionary labels, and displayed on the shoulder of the cylinders. Labels may overlap to the extent provided for by ISO 7225:2005; however, in all cases, the labels representing the primary hazard and the numbers appearing on any label must remain fully visible and the symbols recognizable.
Note: When the diameter of the cylinder is too small to permit the display of the reduced size labels on the shoulder of the cylinder, the reduced sized labels may be displayed on the cylindrical part. Intermediate bulk containers of more than 450 L capacity and large packagings must be labeled on two opposing sides.
Labels must be affixed on a surface of contrasting color.
Special provisions
Special labeling provisions apply to certain substances and materials, including:
Format of labels
Labels must comply with provisions in IMDG Code Section 5.2.2.2 in terms of color, symbols, numbers, and general format.
Labels must:
The label must be a square set at an angle of 45 degrees (diamond-shaped). The minimum dimensions must be 100 mm × 100 mm.
If the size of the package necessitates, the dimensions may be reduced proportionally, provided the symbols and other elements of the label remain clearly visible. Dimensions for cylinders must comply with IMDG Code Section 5.2.2.2.
With few exceptions, the upper half of the label must contain the pictorial symbol and the lower half must contain the class number.
On labels other than those for material of class 7, the insertion of any text (other than the class or division number) in the space below the symbol must be confined to particulars indicating the nature of the hazard and precautions to be taken in handling.
The symbols, text, and numbers must be shown in black on all labels except for:
When affixing labels or applying stencils of labels on packages containing dangerous goods, the method must be such that the labels or stencils will still be identifiable on packages surviving at least three months immersed in the sea.
The International Maritime Dangerous Goods (IMDG) Code general stowage provisions provide requirements for dangerous goods in various types of ships including container ships, general cargo ships, and barges.
Stowage categories
The IMDG Code specifies where dangerous goods must be stowed on a vessel, depending on dangerous goods hazard class.
Class 1 materials are stowed in different parts of a vessel than Classes 2 through 9.
Complete details on stowage categories are found in IMDG Code Section 7.1.3.
Special stowage provisions apply to certain types of dangerous goods, for example, empty, uncleaned packagings, including intermediate bulk containers (IBCs) and large packagings, marine pollutants, and limited quantities/excepted quantities. Special stowage instructions exist for Class 1 materials and Class 7 materials, depending on vessel type.
Packing and using CTUs
A cargo transport unit (CTU) must be fit for use and inspected before loading to ensure it isn’t damaged. Packages must be looked over prior to placing them into a CTU; if damaged or leaking, they must not be placed into the CTU.
Snow, water, and ice must be removed from packages prior to placing them in a CTU.
If drums are loaded into a CTU, they must be in an upright position.
Segregation requirements apply and details for CTUs can be found in the IMDG Code Section 7.3.4.
Packages within a CTU must be secured accordingly and not stacked unless designed for that purpose.
Cargo and packages must fit entirely within the CTU.
If security devices or tracking devices are used on the CTU, they must be securely installed or attached and compatible and safe for the dangerous goods transported in the CTU.
When a CTU must be unloaded, caution should be used when opening the doors. Unsafe conditions can exist, for example, leakages may have occurred which may create unsafe conditions. After the CTU is completely empty, dangerous goods placards and any other dangerous goods marking must be removed, covered, or obliterated.
When a CTU is under temperature control due to the dangerous goods it contains, care must be taken to ensure the requirements in the IMDG are met. The complete requirements for temperature-controlled CTUs can be found in the IMDG Code Section 7.3.7.
Complete details and requirements can be found in IMDG Chapter 7.3.
Segregation refers to the process of separating incompatible substances to avoid undue hazards should the packages leak or spill, or otherwise come in contact with one another in an accident.
The segregation table can be found in the International Maritime Dangerous Goods (IMDG) Code Section 7.2.4.
The codes listed in the table are as follows:
Additional segregation groups and special provisions and exceptions can be found in the IMDG Code Sections 7.2.5 and 7.2.6.
A helpful segregation flow chart can be found in the IMDG Code Chapter 7.2 Annex (for informational purposes only).
Segregation and stowage on containerships
Chapter 7.4 of the IMDG Code covers the stowage and segregation requirements on containerships. Containers meet the definition of a container in the International Convention for Safety Containers, 1972. These are containers transported on deck and in the cargo holds of containerships or on deck and in the cargo holds of other types of ships (provided the positions are fitted to give permanent stowage of containers during transport). If ships are not properly fitted for the permanent stowage of containers, then refer to IMDG Code Chapter 7.6.
Segregation and stowage on roll-on/roll-off ships
Chapter 7.5 of the IMDG Code covers the stowage and segregation of cargo transport units (CTUs) that are transported in roll-on/roll-off (ro-ro) cargo spaces. If a ro-ro ship has stowage positions that are fitted to give a permanent stowage of containers during transport, then the IMDG Code Chapter 7.5 applies. If the ro-ro ship has conventional cargo spaces, then refer to IMDG Code Chapter 7.6.
Segregation and stowage on general cargo ships
Chapter 7.6 of the IMDG Code covers the segregation and stowage of dangerous goods stored conventionally on board general cargo ships.
There are stowage and handling provisions based on class of dangerous goods. In general for all classes of dangerous goods:
Consult IMDG Code Chapter 7.6 for additional provisions specific to dangerous goods class.
Barges may contain packaged dangerous goods or solid bulk materials. Barges must be designed and maintained to handle dangerous goods transportation. Complete details on the requirements for shipborne barges on barge-carrying ships can be found in the International Maritime Dangerous Goods (IMDG) Code Chapter 7.7.
Leaking, damaged, or sifting packages cannot be loaded onto a shipborne barge.
Dangerous goods packages, cargo transport units (CTUs), or any other dangerous goods within a shipborne barge must be secured for the trip. Packages must be loaded so that the likelihood of damage is minimized. Fittings on packages or tanks must also be protected from damage.
Some types of dry dangerous goods may be transported in bulk on a shipborne barge. If allowed, it will show the code “BK2” in column 13 of the Dangerous Goods List. Bulk materials transported on shipborne barges must be evenly distributed and secured.
Shipborne barges must be visually examined to check for damage affecting the barges’ watertight integrity. If a barge is damage, it cannot be used to transport packaged or bulk dangerous goods.
Flexible bulk containers can be transported via barge, but they must be stowed in a way that there aren’t spaces in between the containers. If the containers do not completely fill the barge, then measures must be taken to ensure the cargo is completely secured against shifting. If these containers are stacked, they can be stacked no more than three high.
Segregation on barges is covered in the IMDG Code Section 7.7.5.
International Maritime Dangerous Goods (IMDG) Code Chapter 7.8 covers special requirements in the event of an incident or fire involving dangerous goods. The provisions of the chapter are not mandatory. If a ship is involved in an accident or is leaking while in port, port authorities should be contacted for appropriate procedures.
General fire precautions are as follows:
The International Maritime Dangerous Goods (IMDG) Code was developed as an international regulation for the transport of dangerous goods by vessel. The IMDG Code is designed to enhance and harmonize the safe transportation of dangerous goods and to prevent pollution to the aquatic environment. The Code sets out, in detail, the requirements applicable to all dangerous goods, covering matters such as stowage, with reference to the segregation of incompatible substances.
Stowage generally refers to the location on the vessel where cargo may be stowed. The Code contains various stowage categories, stowage codes, handling codes, and segregation requirements that detail where cargo can be stowed for dangerous goods. As you can imagine, not following proper stowage procedures and location requirements can have devastating results when a vessel is at sea.
The International Maritime Dangerous Goods (IMDG) Code uses stowage categories to identify if cargo can be stored On Deck, Under Deck, or Prohibited. Column 16a of the Dangerous Goods List displays the stowage category for each material. Stowage categories are split into two groups, Class 1 and Classes 2 - 9.
Stowage Category for Class 1 (Other than Division 1.4S packed in limited quantity)
Stowage Category 01 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck |
Passengers Ships | On deck in closed cargo transport unit or under deck |
Stowage Category 02 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck |
Passengers Ships | On deck in closed cargo transport unit or under deck in closed transport unit |
Stowage Category 03 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck |
Passengers Ships | Prohibited* |
Stowage Category 04 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck in closed transport unit |
Passengers Ships | Prohibited* |
Stowage Category 05 | |
Cargo Ships (Up to 12 passengers) | On deck only in closed cargo transport unit |
Passengers Ships | Prohibited* |
*- Except in accordance with Chapter 7.1.4.4.6 |
Stowage Category for Classes 2 – 9 (Including Division 1.4S packed in limited quantity)
Stowage Category A | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck or under deck |
Other passenger ships in which the limiting number of passengers transported is exceeded | On deck or under deck |
Stowage Category B | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck or under deck |
Other passenger ships in which the limiting number of passengers transported is exceeded | On deck only |
Stowage Category C | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck only |
Other passenger ships in which the limiting number of passengers transported is exceeded | On deck only |
Stowage Category D | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck only |
Other passenger ships in which the limiting number of passengers transported is exceeded | Prohibited |
Stowage Category E | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck or under deck |
Other passenger ships in which the limiting number of passengers transported is exceeded | Prohibited |
Always check IMDG Code Chapter 7 for any additional stowage requirements or provisions that may be required for the dangerous goods.
Stowage codes identify additional requirements for the stowage of dangerous goods and can be used with the stowage categories. Stowage codes are recognized by the “SW” before a number and are generally used for individual substances. Column 16a of the Dangerous Goods List also displays the stowage code for each material.
Stowage code | Description |
---|---|
SW1 | Protected from sources of heat. |
SW2 | Clear of living quarters. |
SW3 | Shall be transported under temperature control. |
SW4 | Surface ventilation is required to assist in removing any residual solvent vapor. |
SW5 | If under deck, stow in a mechanically vented place. |
SW6 | When stowed under deck, mechanical ventilation shall be in accordance with SOLAS regulations for flammable liquids with a flashpoint below 23 Celsius. |
SW7 | As approved by the competent authorities of the countries involved in the shipment. |
SW8 | Ventilation may be required. The possible need to open hatches in case of fire to provide maximum ventilation and to apply water in an emergency, and the consequent risk to the stability of the ship through flooding of the cargo spaces, shall be considered before loading. |
SW9 | Provide a good through ventilation for bagged cargo. Double strip stowage is recommended. During the voyage regular temperature readings shall be taken at varying depths in the hold and recorded. If the temperature of the cargo exceeds the ambient temperature and continues to increase, ventilation shall be closed. |
SW10 | Unless carried in closed cargo transport units, bales shall be properly covered by tarpaulins or the like. Cargo spaces shall be clean, dry, and free from oil or grease. Ventilator cowls leading into the cargo space shall have sparking-preventing screens. All other openings, entrances and hatches leading to the cargo space shall be securely closed. During temporary interruption of loading, when the hatch remains uncovered, a fire-watch shall be kept. During loading or discharge, smoking in the vicinity shall be prohibited and fire-fighting appliances kept ready for immediate operation. |
SW11 | Cargo transport units shall be shaded from direct sunlight. Packages in cargo transport units shall be stowed to allow for adequate air circulation throughout the cargo. |
SW12 | Taking account of any supplementary requirements specified in the transport documents. |
SW13 | Taking account of any supplementary requirements specified in the competent authority approval certificate(s). |
SW14 | Category A only if the special stowage provisions of 7.4.1.4 and 7.6.2.8.4 are complied with. |
SW15 | For metal drums, stowage category B. |
International Maritime Dangerous Goods (IMDG) Code Chapter 7 contains additional stowage codes.
Handling codes identify additional requirements for the stowage of dangerous goods and can be used with stowage codes and stowage categories. Handling codes are recognized by the “H” before a number and are generally used for individual substances. Column 16a of the Dangerous Goods List also displays the handling code for each material.
Handling code | Description |
---|---|
H1 | Keep as dry as reasonably practical. |
H2 | Keep as cool as reasonably practical. |
H3 | During transport, it should be stowed (or kept) in a cool ventilated place. |
H4 | If cleaning of cargo spaces must be carried out at sea, the safety procedures followed, and standard of equipment used shall be at least as effective as those employed as industry best practice in a port. Until such cleaning is undertaken, the cargo spaces in which the asbestos has been carried shall be closed and access to those spaces shall be prohibited. |
H5 | Avoid handling the packaging or large packaging or keep handling to a minimum. Inform the appropriate public health authority or veterinary authority where persons or animals may have been exposed. |
Dangerous goods, substances, or articles that are incompatible and may react violently with each other due to leakage, spillage, or any other accident must be segregated from one another for shipment by vessel. Segregation can be obtained by maintaining separation between incompatible dangerous goods or by requiring the presence of one or more steel bulkheads or decks between them, or a combination thereof.
Determining the segregation requirements between two or more substances requires referencing the Segregation Table in the International Maritime Dangerous Goods (IMDG) Code Chapter 7.2 and the segregation codes in Column 16b of the Dangerous Goods List. The segregation code description can be found in IMDG Code Chapter 7.2. If there are conflicting segregation requirements in the IMDG Code, the provisions of Column 16b of the Dangerous Goods List will always take precedence.
Segregation codes
A portion of the segregation codes given in Column 16b of the Dangerous Goods List are specified below:
Segregation Code | Description |
SG1 | For packages carrying a subsidiary hazard label of class 1, segregation as for class 1, division 1.3. However, in relation to goods of class 1, segregation as for the primary hazard. |
SG2 | Segregation as for class 1.2G. |
SG3 | Segregation as for class 1.3G. |
SG4 | Segregation as for class 2.1. |
SG5 | Segregation as for class 3. |
SG6 | Segregation as for class 5.1. |
SG7 | Stow “away from” class 3. |
SG8 | Stow “away from” class 4.1. |
SG9 | Stow “away from” class 4.3. |
SG10 | Stow “away from” class 5.1. |
SG11 | Stow “away from” class 6.2. |
SG12 | Stow “away from” class 7. |
SG13 | Stow “away from” class 8. |
SG14 | Stow “separated from” class 1 except for division 1.4S. |
SG15 | Stow “separated from” class 3. |
SG16 | Stow “separated from” class 4.1. |
SG17 | Stow “separated from” class 5.1. |
SG18 | Stow “separated from” class 6.2. |
SG19 | Stow “separated from” class 7. |
SG20 | Stow “away from” SGG1 – acids. |
IMDG Code Chapter 7 should always be referenced for complete segregation requirements, codes, and specifications.
Cargo Transport Units (CTU) are versatile so they can be used with different modes of transportation. The versatility of the CTU has made it one of the most used forms of packaging for vessel shipments.
All CTU must be constructed in a way to prevent the loss of contents. When appropriate, the CTU must have a means to facilitate securing and handling cargo inside the unit. CTU must be adequately maintained.
Packing CTU
In the past, there have been instances where CTU were not packed in a safe manner. As a result, the CTU was overloaded or contained loose cargo, which resulted in severe incidents. To prevent future incidents the International Maritime Dangerous Goods (IMDG) Code requires the following actions to be taken when packing a CTU:
Segregation and CTU
Dangerous goods that must be segregated from each other according to the International Maritime Dangerous Goods (IMDG) Code Chapter 7.2 segregation requirements must not be loaded in the same CTU. However, dangerous goods that must be segregated “away from” each other may be transported in the same CTU with approval from a competent authority.
Dangerous goods with primary or subsidiary hazard classes 2.3, 6.1, 6.2, 7, 8, and dangerous goods with a reference to the IMDG Code Section 7.3.4.2.1 in Column 16b of the Dangerous Goods List must not be loaded with foodstuffs in the same CTU.
Packing is not necessarily just the act of placing items in a package or container, but also about the package itself. In this case, the International Maritime Dangerous Goods (IMDG) Code considers packing to also include selecting the correct authorized package or packaging.
IMDG Code packing requirements vary depending on the type, class, and quantity of dangerous goods you are shipping, which makes the packing process difficult. The IMDG Code makes this task a little easier by listing all the requirements for the various dangerous goods and packages that are authorized to be used.
The International Maritime Dangerous Goods (IMDG) Code requires packagings, intermediate bulk containers (IBCs), and large packagings to follow certain provisions. The provisions are intended to ensure the dangerous goods are packed and shipped in a safe secure manner. The following general provisions apply to dangerous goods packagings, IBCs, and large packagings. The packagings must be:
The International Maritime Dangerous Goods (IMDG) Code provides packing instructions for dangerous goods in hazard classes 1 through 9. Packing instructions show the acceptable packagings that are authorized for a dangerous good. For combination packagings, the packing instructions list the acceptable outer packagings, inner packagings and when applicable, the maximum permitted quantity in each inner or outer packaging.
The packaging instructions are subdivided into three subsections according to the type of packaging being used and are designated by a code. The codes are alphanumeric, and the code prefix designates what package it is intended for. The packing instructions are detailed in IMDG Code Section 4.1.4.
Code Prefix | Description |
---|---|
P | Packagings other than IBCs and large packagings. Found in Column 8 of the Dangerous Goods List. |
IBC | Intermediate bulk container (IBC). Found in Column 10 of the of the Dangerous Goods List. |
LP | Large Packagings. Found in Column 8 of the Dangerous Goods List. |
Any packing instruction left blank or does not contain a code means that type of packaging is not authorized.
Special provisions may also be specified in the packing instruction for individual substances or articles. They provide additional guidance or requirements when packaging substances or articles. Special provisions are also designated by an alphanumeric code comprising the letters.
Code Prefix | Description |
---|---|
PP | Packagings other than IBCs and large packagings. Found in Column 9 of the Dangerous Goods List. |
B | Intermediate bulk container (IBC). Found in Column 11 of the of the Dangerous Goods List. |
L | Large Packagings. Found in Column 9 of the Dangerous Goods List. |
Typically, packing instructions do not provide guidance on compatibility. The shipper is responsible for checking that the substance is compatible with the packaging material selected (such as, most fluorides are unsuitable for glass receptacles). Where glass receptacles are permitted in the packing instructions, porcelain, earthenware, and stoneware packagings are also allowed.
Example: For UN1789, Hydrochloric Acid, PG II, the Dangerous Goods List shows packing instructions are P001 for single/combination packages, IBC02 for intermediate bulk containers and does not list any packing instruction for large packagings. The special provisions are B20.
The International Maritime Dangerous Goods (IMDG) Code requires portable tanks to follow certain provisions. The provisions are intended to ensure the dangerous goods are packed and shipped in a safe secure manner. The following general provisions apply to Class 1 and Classes 3-9 dangerous goods in portable tanks:
The International Maritime Dangerous Goods (IMDG) Code requires portable tanks to follow certain provisions. The provisions are intended to ensure the dangerous goods are packed and shipped in a safe secure manner. The following general provisions apply to Class 2 (non-refrigerated gases) dangerous goods in portable tanks:
Portable tank instructions and special provisions are applicable to dangerous goods authorized to be transported in portable tanks.
Each portable tank instruction is identified by an alpha-numeric designation (T1 to T75). Column 13 of the Dangerous Goods List indicates the portable tank instruction that must be used for each substance permitted for transport in a portable tank. When no portable tank instruction appears in the Dangerous Goods List, transport of the substance in portable tanks is not permitted unless a competent authority approval is granted.
Portable tank special provisions are assigned to specific dangerous goods in Column 14 of the Dangerous Goods List. They provide additional guidance or requirements when packaging substances or articles in portable tanks. Each portable tank special provision is identified by an alpha-numeric designation that always begin with “TP” (such as TP1). A listing of the portable tank special provisions is provided in International Maritime Dangerous Goods (IMDG) Code Section 4.2.5.3.
How dangerous goods are packaged can have a significant impact on how safely that material can be transported. Because of this, the International Maritime Dangerous Goods (IMDG) Code has very specific requirements for dangerous goods packages. These requirements are designed to ensure that the packaging is appropriate for the material and that it can withstand the conditions normally encountered during transport.
The IMDG Code requires most packages containing dangerous goods to meet UN specification standards. Packages meeting the UN specification standards also must pass various package testing requirements depending on the type of package being used. UN specification packages must also contain package markings that indicates what standards the package was manufactured to.
Understanding what the UN specification markings indicate is extremely important when selecting a package for your dangerous goods.
Package codes are alphanumeric characters that describe the type/kind of package and the material it is made of. Package codes are typically two or three digits long. However, they can be up to five digits long.
Codes that contain only one capital letter indicate a single package, and can be deciphered as follows:
The first numeral designates the kind of packaging:
The letter indicates the material of construction:
A second numeral indicates the category of packaging within the packaging:
Examples:
Codes that contain two capital letters indicate composite packages. The first letter designates the material for the inner receptacle, and the second, the material for the outer packaging.
Example:
Performance levels
Solids or inner packaging
Packages and containers for dangerous goods must pass rigorous performance testing prior to use. The UN specification marking is an indication that the package has met stringent requirements set forth by the United Nations.
The UN specification marking must include, in the following order:
All packages containing dangerous goods must meet general package requirements even if they are not a UN specification package. While the requirements may seem like common knowledge, they are often forgotten or overlooked.
Packages must be:
UN specification package testing is a series of tests and requirements used to determine the integrity and safety of the package when facing various situations. The tests are designed to simulate common conditions that are encountered during transportation. Not all packages are required to accomplish each type of test. For example, a package designed for solids does not need to have a leakage test.
Types of tests include:
A test report containing the following information must be made available to the users of the package:
The complete requirements for package specifications can be found in International Maritime Dangerous Goods (IMDG) Code Chapter 6. Chapter 6 should be referenced any time there are any requirements for package specifications.
The International Maritime Dangerous Goods (IMDG) Code addresses the transportation of radioactive materials by sea.
The primary goal of the IMDG’s radioactive materials requirements is to protect the general public, property, and the environment from radiation during transport by sea. This is done by ensuring the packaging is appropriate for the radioactive material, placing administrative controls on the transport of the radioactive material (and if appropriate, approvals by competent authorities), and ensuring emergency response procedures are in place prior to transport.
The International Maritime Dangerous Goods (IMDG) Code applies to the sea transport of radioactive materials. This includes packaging design and packaging manufacturing along with the preparation of a radioactive material for loading/unloading, offering a radioactive material for transportation, and in-transit storage of the material. All subsidiary hazards of the radioactive material must be taken into account when determining the documentation, markings and labels, segregation, and other requirements.
The IMDG Code requirements on radioactive materials do not apply to:
Specific provisions for excepted packages can be found in the IMDG Code, section 1.5.1.5.
Special arrangements, which are special provisions approved by competent authorities, can be made for radioactive materials shipments that do not conform to the regulatory standards but that provide an equivalent level of safety; see IMDG section 1.5.4 for details.
Shipment approvals for Class 7 materials are required in some circumstances. Multilateral approvals are required for the following:
Consult the IMDG Code section 5.1.5.1.2 for complete details on these required approvals.
Notifications to competent authorities is required for certain types of shipments, including but not limited to:
Consignors must notify the competent authorities of the country of origin of the shipment and the country through or into which the consignment will be transported. This notification must be done 7 days in advance of the shipment starting. The notification must include:
Competent authority certificates are required for certain types of package designs. See the International Maritime Dangerous Goods (IMDG) Code Section 5.1.5.2 for a listing. Consignors must be in possession of the applicable certificate.
Radioactive material transportation must be done under a radiation protection program, which must adequately address radiation protection measures. The program must address measures that will be taken to keep doses to persons below dose limits and to keep exposures as low as possible. These measures must be related to the significance and chances of radiation exposures. Finally, the program must address applicable emergency response procedures.
If the competent authority requests to see the program documents, then such documents must be available to the competent authority.
More details on the Radiation Protection Program can be found in the International Maritime Dangerous Goods (IMDG) Code Section 1.5.2.
A Management System, acceptable to the competent authority, must be in place to ensure compliance with the regulations is maintained. More details can be found in IMDG Code Section 1.5.3.
Packages must be marked with the identification of the consignor or consignee, or both. Overpacks must also contain the same information, unless the marks are visible through the package.
If the gross mass of a package exceeds 50 kilograms, then the permissible gross mass must be marked on the package.
Type IP-1, IP-2, and IP-3 package designs must be marked with “TYPE IP-1,” “TYPE IP-2,” and “TYPE IP-3,” as applicable. A Type-A package design must be marked with “TYPE-A.”
Type IP-2, Type IP-3, and Type-A packages must be marked with the international vehicle registration code of the country of origin of design. These packages must also be marked with the name of the manufacturer or other identification of the packaging identified by the competent authority of the country of origin and design.
Complete marking details for radioactive materials by sea can be found in the International Maritime Dangerous Goods (IMDG) Code Section 5.2.1.5.
Excepted packages of radioactive materials must be marked according to the IMDG Code Section 5.1.5.4.
Classification of radioactive materials, transport index (TI), and criticality safety index (CSI)
Details on the classification of radioactive materials can be referenced in the International Maritime Dangerous Goods (IMDG) Code, Chapter 2.7, Classification.
Details on determining the transport index (TI) and criticality safety index (CSI) can be found in the IMDG Code Section 5.1.5.3.
Fissile materials
Specific provisions for the consignment of fissile materials are referenced in the IMDG Code Section 5.1.5.5.
Package approvals for radioactive materials
See the IMDG Code Section 4.1.9. for special packing provisions for radioactive materials. This section covers excepted packages; Type IP-1, IP-2, and IP-3 packages; and Type A, B(U), B(M), and C packages. Fissile material packages and packages containing uranium hexafluoride are subject to additional requirements.
Before packages are used for radioactive materials, it must be confirmed that they meet the manufacturing and design standards.
Additionally, IMDG Code Chapter 6.4 covers the details on the construction, testing, and approval of packages for radioactive material and for the approval of such material.
Along with regulating the transportation of hazmat by highway, rail, and air, the Pipeline and Hazardous Materials Safety Administration (PHMSA), in conjunction with the U.S. Coast Guard (USCG), regulates the transport of hazmat by vessel in the U.S. The Hazardous Materials Regulations (HMR) provide guidance for all modes of transportation. However, each mode of transportation does differ from the others, and the differences must be considered when transporting hazmat by a specific mode. For transport by vessel, differences occur in the following areas:
Under Part 176.13, each carrier must ensure that its employees involved in the transportation of hazmat by vessel are trained in accordance with the Hazardous Materials Regulations (HMR), Part 172, Subpart H. This includes:
The employee’s hazmat training record must be kept on board the vessel while the crew member is in service on board the vessel. Also, section 176.7 requires the person in charge of the vessel to ensure that vessel personnel have the required license, certificate of registry, or merchant mariner’s document as mandated by Parts 10 and 12.
Unless excepted, carriers may not transport a hazardous material by vessel without the following documents:
Shipping papers
Section 176.24 requires shippers to provide a shipping paper that is prepared in accordance with Part 172 of the Hazardous Materials Regulations (HMR). The shipping paper, including emergency response information, must accompany the hazardous materials, unless the material is excepted from shipping paper requirements under the HMR.
Certification
Section 176.27 requires that, at the time a freight container or transport vehicle containing hazardous materials is offered for transportation by vessel, the person responsible for packing or loading it must give the vessel operator a signed container packing certificate stating:
The signed certification may appear on a shipping paper or on a separate document. Below are two examples of the certification statement:
“This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.”
“It is declared that the packing of the container has been carried out in accordance with the applicable provisions of 49 CFR.”
Dangerous cargo manifest, list, or stowage plan
The carrier, its agents, or any person designated by the carrier must prepare a dangerous cargo manifest, list, or stowage plan. The document must include all hazardous materials subject to the requirements of the HMR or the International Maritime Dangerous Goods (IMDG) Code, and must include:
The Dangerous Cargo Manifest must be kept on or near the vessel’s bridge, except when the vessel is docked in a U.S. port.
When docked at a U.S. port, this document may be kept in the vessel’s cargo office or another location designated by the master of the vessel, provided that a sign is placed beside the designated holder on or near the vessel’s bridge indicating the location of the dangerous cargo manifest, list, or stowage plan.
This document must always be in a location that is readily accessible to emergency response and enforcement personnel.
Special permit
If a hazardous material is being transported by vessel under the authority of an exemption or special permit, then a copy of the exemption or special permit is required to be on board the vessel and must be kept with the dangerous cargo manifest.
Hazardous materials may only be handled or stowed on board a vessel under the direction and observation of a responsible person who has been assigned this duty. A responsible person is considered:
Before hazardous materials can be loaded or stored on board a vessel, each hold or compartment must be free of debris. This requires examination of the bilges to ensure that residue from previous cargo has been removed.
The carrier and the master of the vessel are jointly responsible for posting “NO SMOKING” signs in locations when smoking is prohibited by the Hazardous Materials Regulations (HMR) during the loading, stowing, storing, transportation, or unloading of hazardous materials.
Inspection
After stowage, the carrier must inspect each hold or compartment containing hazardous materials to ensure that stowage has been accomplished properly and that there are no visible signs of damage to any packages or evidence of heating, leaking, or sifting.
For manned vessels, an inspection of the cargo must be made after stowage has been completed and at least once every 24 hours thereafter (weather permitting). However, freight containers or individual barges do not need to be opened.
Vessels equipped with smoke or fire detecting systems with an automatic monitoring capability need to be inspected only after stowage is completed and after periods of heavy weather. Each inspection of the stowage of hazardous materials must be recorded in the vessel’s deck logbook. For unmanned and magazine vessels, an inspection of the cargo must be made only after stowage has been completed.
This inspection must be made by the individual who is responsible to the carrier and who is in charge of loading and stowing the cargo on the unmanned vessels or the individual in charge in the case of a magazine vessel.
Stowage locations
Authorized vessel stowage locations can be found in Column 10 of the Hazardous Materials Table (HMT) in Part 172.101.
Column 10A contains alpha and numeric categories that specify the authorized stowage locations on board cargo and passenger vessels. The categories can be found in section 172.101(k). There are three physical locations given:
Hazardous materials offered for transport as limited quantities are allocated stowage category A and are not subject to any of the stowage requirements indicated in Column 10B of the HMT.
Column 10B specifies codes for vessel stowage requirements for specific hazardous materials. The meaning of each code found in Column 10B is defined in section 176.84(b) and section176.84(c) for explosives.
The segregation requirements in 176.83 apply to all cargo spaces on deck or under deck for vessels. The requirements also apply to hazardous materials in cargo transport units.
Segregation can be obtained by:
Spaces between hazardous materials that must be separated may be filled with other cargo that is compatible with the hazardous materials. The segregation of hazardous materials stowed together must always be in accordance with the most restrictive requirements for any of the hazardous materials concerned.
Segregation requirements for subsidiary hazards take priority when the segregation is more restrictive than segregation requirements for the primary hazard. In addition, two hazardous materials for which any segregation is required may not be stowed in the same cargo transport unit. The general requirements for segregation between the various classes of dangerous goods are shown in the segregation table.
Segregation table
To use the General Segregation Table in section 176.83(b), find one class of material in the vertical column, and then find another class in the horizontal row. The intersection of the vertical column and the horizontal row contains a number or symbol that represents the method of segregation that you must use between the two classes.
The meaning of the entry in the cell where the materials intersect is:
Away from - means that incompatible hazardous materials may be carried in the same compartment, hold, or deck provided they are horizontally separated by three meters (10 feet).
Separated from - means packages must be carried in different compartments or holds if “under deck,” and separated horizontally by six meters (20 feet) if “on deck.” Separated by a complete compartment or hold from - means packages may be separated between decks if one of the decks is resistant to fire and liquid or, if “on deck,” horizontally separated by 12 meters (39 feet).
Separated longitudinally by an intervening complete compartment or hold from - means for packages separated between “under deck” and “on deck,” a complete compartment must separate them, as well as a longitudinal distance of 24 meters (79 feet).
For “on deck” stowage, a separation of at least 24 meters (79 feet) longitudinally must be maintained.
X – means as shown in column 10 of the hazmat table in section 172.101.
Asterisk – means as stated in section 176.144.
The regulation at 176.45 outlines procedures that must be followed in case of an accident involving hazardous materials on board a vessel, which include:
When a fire or other hazardous condition exists on a vessel transporting hazardous materials, the master MUST notify the nearest Captain of the Port as soon as possible and must comply with any instructions given by the Captain of the Port.
If a package, portable tank, freight container, highway or railroad vehicle containing hazardous materials is jettisoned or lost, the master must notify the nearest Captain of the Port as soon as possible of the location, quantity, and type of the material.
The International Maritime Dangerous Goods (IMDG) Code was developed by the International Maritime Organization (IMO) to enhance and harmonize the safe carriage of dangerous goods in international waters. The IMO also developed the IMDG code to prevent pollution to the environment. The IMDG Code is based on the UN Model Regulations, but also includes additional requirements applicable to the maritime transport of dangerous goods (such as requirements for marine pollutants, freight container loading procedures, stowage and segregation, and other requirements applicable to shipboard safety and preservation of the marine environment) that are not covered by the UN Model Regulations.
While the Pipeline and Hazardous Materials Safety Administration (PHMSA) gives you the choice to use the Hazardous Materials Regulations (HMR) or IMDG Code for transportation in U.S. waters, dangerous goods being transported by vessel in international waters must be prepared according to the IMDG Code.
Part 1 of the International Maritime Dangerous Goods (IMDG) Code requires training for anyone performing a job function that affects the safe transportation of dangerous goods by vessel. The training must include:
The IMDG Code also contains a recommendation of training requirements based on the job function of shore-based personnel. Below are a few of the job functions and specific training requirements listed in paragraph 1.3.1.5:
Classify dangerous goods and identify proper shipping name
Pack dangerous goods
Mark, label, or placard dangerous goods
Recurrent training
The IMDG Code does not specify the frequency of when recurrent dangerous goods training must occur, just that training shall be periodically supplemented with refresher training to account for changes in the regulations. With that said, the IMDG Code does refer to competent authorities, such as the Pipeline and Hazardous Materials Safety Administration (PHMSA), and its authority to audit the employer to verify the effectiveness of its training system.
For dangerous goods employees operating under PHMSA’s jurisdiction, it’s recommended that recurrent training is accomplished at least once every three years.
The Dangerous Goods List in the International Maritime Dangerous Goods (IMDG) Code is found in part 3. The list, as in all other dangerous goods regulations, is a core section to identify the substances, mixtures, and relevant information in the regulations.
The Dangerous Goods List is divided into 18 columns for each of the individual dangerous goods listed. The list is arranged in numerical order by the UN/ID in columns 1 and 18.
Column 1 – UN/ID Number
This column displays the number assigned to the material under the United Nations Classification System. When this number is used, it must be prefixed by the letters “UN.”
Column 2 – Proper Shipping Names
This column contains the proper shipping names in uppercase characters followed by additional descriptive text in lowercase characters.
Column 3 – Class or Division
This column lists the class or division number assigned to the article or substance. In the case of Class 1 Explosives, the compatibility group is also shown.
Column 4 – Subsidiary Hazards
This column contains the class number of any subsidiary hazard that has been identified for the material. This column also identifies dangerous goods as marine pollutants with a P. The absence of the P does not mean the material is not a marine pollutant.
Column 5 – Packing Group (PG)
This column contains the UN Packing Group (I, II, III) where assigned to the material.
Column 6 – Special Provision
This column lists the special provision number which can be found in chapter 3.3. Special provision numbers that are specific to transportation by vessel start at 900.
Column 7a – Limited Quantities
This column provides the maximum quantity per inner packaging or article for transporting dangerous goods as a limited quantity in accordance with chapter 3.4.
Column 7b – Excepted Quantities
This column provides the alphanumeric code described in subsection 3.5.1.2, which indicates the maximum quantity per inner and outer packaging allowed when transporting dangerous goods as excepted quantities in accordance with chapter 3.5.
Column 8 – Packing Instructions
This column contains the alphanumeric codes that refer to the relevant packing instructions in section 4.1.4. The packing instructions indicate the packages that may be used to transport the dangerous goods.
Column 9 – Special Packing Provision
This column contains alphanumeric codes which refer to the relevant special packing provisions specified in section 4.1.4.
Column 10 – IBC Packing Instructions
This column contains alphanumeric codes that refer to the relevant IBC instruction, which indicates the type of IBC that shall be used for the transport of the substance. A code including the letters “IBC” refers to packing instructions for the use of IBCs described in chapter 6.5. When a code is not provided, it means the substance is not authorized in IBC.
Column 11 – IBC Special Provision
This column contains an alpha-numeric code, including the letter “B,” which refers to special packing provisions applicable to the use of packing instructions bearing the code “IBC” in 4.1.4.2.
Column 12 – Reserved
This column is reserved and does not contain any information.
Column 13 – Tank and Bulk Container Instructions
This column contains T codes (see 4.2.5.2.6) applicable to the transport of dangerous goods in portable tanks and road tank vehicles. When a T code is not provided in this column, it means that the dangerous goods are not authorized for transport in tanks unless specifically approved by a competent authority.
A code including the letters “BK” refers to the type of bulk containers used for the transport of bulk goods described in chapters 4.3 and 6.9.
The gases authorized for transport in MEGCs are indicated in the column “MEGC” in tables 1 and 2 of packing instruction P200 in 4.1.4.1.
Column 14 – Tank Special Provisions
This column contains TP notes (see 4.2.5.3) applicable to the transport of dangerous goods in portable tanks and road tank vehicles. The TP notes specified in this column apply to the portable tanks specified in column 13.
Column 15 – EmS
This column refers to the relevant emergency schedules for FIRE and SPILLAGE in “The EmS Guide Revised Emergency Response Procedures for Ships Carrying Dangerous Goods.” The provisions in this column are not mandatory.
Column 16a – Stowage and Handling
This column contains the stowage and handling codes as specified in 7.1.5 and 7.1.6.
Column 16b – Stowage and Handling
This column contains the segregation group codes as specified in 7.2.5.2 and the segregation codes as specified in 7.2.8.
Column 17 – Properties and Observations
This column contains properties of and observations on the dangerous goods listed. The provisions in this column are not mandatory.
Column 18 – UN/ID Numbers
This column is the same as column 1. Since the Dangerous Goods List expands across two pages, listing the UN/ID numbers on both pages makes it easier to reference information throughout the entire row.
A Cargo Transport Unit (CTU) is a transport vehicle, a freight container, a portable tank, or a multiple element gas container (MEGC). Because of their size and versatility, CTUs are commonly used when transporting dangerous goods by vessel.
General provisions CTUs must be:
If the CTU meets the definition of a “container” as defined by the International Convention for Safe Containers (CSC) 1972, the applicable provisions of the CSC must be followed. However, the CSC does not apply to offshore containers handled in open seas. Those must meet the requirements established by a competent authority, such as the Pipeline and Hazardous Materials Safety Administration (PHMSA). An offshore container designed to be handled in open seas shall be clearly marked with the words “OFFSHORE CONTAINER” on the safety approval plate.
Part 5 of the International Maritime Dangerous Goods (IMDG) Code contains the marking, labeling, and placarding requirements for transportation by vessel.
Markings
Unless otherwise stated, the proper shipping name and UN/ID number must be displayed on each package. In most cases, the UN/ID number must be at least 12 mm tall.
All package marks are required to be:
Additionally, the IMDG Code requires certain packages to contain the following marks:
Labels
A package containing a dangerous good must display the appropriate hazard class label. If column 4 indicates the dangerous good has a subsidiary hazard, the package must also display the subsidiary hazard label. Labels must be:
Placards
Most bulk packages or CTUs containing dangerous goods or residues of dangerous goods must clearly display placards on each side and each end. However, there are cases when you don’t need to placard on all four sides:
Chapter 5.4 of the International Maritime Dangerous Goods (IMDG) Code requires shippers to provide carriers with dangerous goods transport information. The information may be provided on a dangerous goods transport document or, with agreement from the carrier, electronically by electronic data processing (EDP) or electronic data imaging (EDI).
The information on the dangerous goods transport document must be easy to identify, legible, durable, and must contain the following information:
Emergency response information
For consignments of dangerous goods, appropriate information must be immediately available at all times for use in emergency response to accidents and incidents involving dangerous goods in transport. The information must be:
Container/vehicle packing certificate
When dangerous goods are packed or loaded into any container or vehicle, those responsible for packing the container or vehicle must provide a “container/vehicle packing certificate” specifying the container/vehicle identification number(s) and certifying that the operation has been carried out in accordance with the following conditions:
Multimodal dangerous goods form
The multimodal dangerous goods form may be used as a combined dangerous goods transport document and container/vehicle packing certificate for multimodal carriage of dangerous goods.
The International Maritime Dangerous Goods (IMDG) Code helps to ensure safety when dangerous goods are transported by sea.
The following explanations cover the IMDG Code at a high level. This information is designed to give a general understanding of the IMDG Code requirements and is not a replacement for the IMDG Code.
The most current and official IMDG Code must be consulted for full compliance. The IMDG Code is available by visiting www.imo.org.
The International Maritime Dangerous Goods (IMDG) Code was developed by the International Maritime Organization (IMO) to enhance and harmonize the safe carriage of dangerous goods in international waters. The IMO also developed the IMDG Code as a way to help prevent pollution to the environment.
The IMDG Code is based on the UN Model Regulations, but also includes additional requirements applicable to the maritime transport of dangerous goods (such as requirements for marine pollutants, freight container loading procedures, stowage and segregation, and other requirements applicable to shipboard safety and preservation of the marine environment) that are not covered by the UN Model Regulations.
The provisions of the IMDG Code are applicable to anyone shipping or transporting dangerous goods by vessel in international waters. Anyone shipping or transporting dangerous goods by vessel within U.S. waters has the choice to follow the IMDG Code or the 49 CFR Hazardous Materials Regulations as the Pipeline and Hazardous Materials Safety Administration (PHMSA) allows the use of the IMDG Code for transportation by vessel. In cases when it is unknown if the shipment will transit through international waters, it’s recommended to follow the provisions of the IMDG Code.
All aspects of the shipping process, such as packaging, marking, and labeling, are determined by how a dangerous good is classified. This makes the classification process the single most important step when shipping dangerous goods. This is also the reason the International Maritime Dangerous Goods (IMDG) Code requires shippers to classify dangerous goods before they can be offered for shipment.
Some dangerous goods are easy to classify because the material and their hazard(s) are well known. For example, gasoline is a well-known flammable liquid. Other materials, such as mixtures or new products, may be difficult to classify because the hazards are unknown. In this case you must have the material tested to determine the hazardous properties.
The IMDG Code also requires shippers to identify if the dangerous goods are a marine pollutant.
Dangerous goods must meet one or more of the hazard class definitions. There are nine hazard classes listed in the International Maritime Dangerous Goods (IMDG) Code — some of which are further subdivided into divisions. The definitions summarized below should be used as guidelines only.
Complete specifications for each hazard class and division can be found in Chapter 2 of the IMDG Code.
Some dangerous goods are further subdivided into packing groups. The packing group indicates the degree of danger presented by the dangerous goods.
Packing groups have been developed for dangerous goods in Class 3, Class 4, Division 5.1, Division 6.1 and Class 8 materials. Some hazardous materials are assigned more than one packing group. Because packing groups impact the type of packaging that can be used, it is critical that each material is assigned to the correct one. The criteria for determining packing groups are included in the IMDG Code as follows:
Some substances in Class 9, liquids in Division 5.1, and waste in Division 6.2 have been assigned packing groups according to the Dangerous Goods List in IMDG Code Chapter 3.2. Requirements for a specific packaging performance level can be found in the applicable packing instruction.
Marine pollutants
The IMDG Code requires shippers to also classify dangerous goods as a marine pollutant if:
UN numbers and proper shipping names
Once the hazard class and packing group have been determined, the shipper must select an appropriate UN number and proper shipping name from the Dangerous Goods List in Chapter 3.2. If the dangerous good is listed by name, that name must be used. If the dangerous good is not listed by name a generic or not otherwise specified (n.o.s.) name must be used.
Occasionally, there will be situations when dangerous goods meet the definition of more than one hazard class, and it’s not specifically listed by name in the Dangerous Goods List. In this case, you must determine which of the hazard classes will be the primary hazard. Typically, the hazard class that poses the greater hazard during transport would take precedence and become the primary hazard.
The hazard classes listed below in order take precedence:
Hazard classes not listed above must be classed according to the precedence of hazard table located in Chapter 2.0.3.
The International Maritime Dangerous Goods (IMDG) Code has provisions which allow a shipper to classify and ship unknown dangerous goods to a laboratory for analysis. The samples of unknown dangerous goods may be classified by the shipper and assigned a tentative shipping description, based on the:
Proper shipping name
When shipping samples of unknown dangerous goods the shipper must include the word “sample” in conjunction with the proper shipping name, for example:
When a “not otherwise specified” (n.o.s.) entry is used for the sample, the proper shipping name does not need to include the technical name.
The most severe packing group possible must be used for the selected proper shipping name.
Limitations
Samples using the exception must not be:
Self-reactive substances and organic peroxides samples must meet the conditions in sections 2.4.2.3.2.4.2 and 2.5.3.2.5.1, respectively.
All samples must be transported in combination packaging with a net weight not exceeding 2.5 kgs and not packed with any other goods.
The International Maritime Dangerous Goods (IMDG) Code is an international code for transport of dangerous goods by sea, intended to promote the safe carriage of dangerous goods and prevent pollution to the environment.
The code details requirements that apply to individual substances, materials, and articles, and covers packing, container traffic, and stowage, with particular attention paid to the segregation of incompatible substances.
The Dangerous Goods List in Part 3 comprises the core of the code, and provides packing, labeling, stowage, segregation, handling, and emergency response information for thousands of entries.
Scope of the Dangerous Goods List and general provisions
The Dangerous Goods List includes entries for the most commonly transported dangerous goods. Since it is impractical to include a separate entry for every existing chemical substance or article, the List also includes generic or “not otherwise specified” (n.o.s.) names for various mixtures and solutions (for example, FLAMMABLE LIQUID, N.O.S., UN 1993). This way, the List provides an appropriate name or entry for any dangerous good that may be transported.
When a dangerous good is specifically listed by name, it must be transported according to the requirements for that entry in the List. To use a generic or n.o.s. entry to transport substances, materials, or articles that do not appear specifically by name follow these steps:
A generic or n.o.s. name may only be used when:
The classification must be made by the shipper/consignor, or by the appropriate competent authority in some cases.
Once the class of the dangerous good is established, all conditions for transport must be met. Any dangerous good with explosive characteristics must first be considered for inclusion in Class 1.
Inherent instability in goods may take different dangerous forms, including:
Because of this potential for instability, the Dangerous Goods List prohibits certain dangerous goods, or dangerous goods in a specific form, concentration, or state, from transport by sea. These prohibited goods are not suitable for transport by sea under normal conditions of transport. In some cases, the inherent instability can be controlled by suitable packaging, dilution, stabilization, addition of an inhibitor, temperature control, or other measures to make transport by sea possible.
Precautionary measures required
If precautionary measures are shown in the Dangerous Goods List for a dangerous good (for example, that it must be stabilized or diluted), that dangerous good may not be transported without taking those measures. Exceptions to this may exist if the item in question is listed elsewhere (such as in class 1) without any indication of precautionary measures, or with different measures indicated.
Polymerization and dangerous reactions
Certain substances can polymerize or otherwise react in a dangerous manner under certain conditions of temperature or in contact with a catalyst. To mitigate this tendency:
Unless these products are sufficiently stabilized to prevent any dangerous reaction during the voyage, transport of the products is prohibited.
The proper shipping names of dangerous goods are listed in the Dangerous Goods List. The index to the List includes synonyms, secondary names, initials, abbreviations of names, etc., in alphabetical order, to facilitate the search for the proper shipping name.
The proper shipping name is the part of the entry that accurately describes the goods in the Dangerous Goods List. It is shown in upper-case characters along with other numbers or letters that are an integral part of the name. An alternative proper shipping name may be shown in brackets following the main proper shipping name.
Only the most appropriate proper shipping name must be shown in the transport document and package marks when:
Proper shipping names may be used in the singular or plural as appropriate.
Commercial or military names for goods of class 1 that contain the proper shipping name supplemented by additional text may be used.
Many substances have an entry for both the liquid and solid state or for the solid and solution. These are given separate UN numbers that are not necessarily adjacent to each other. Details can be found in the alphabetical index to the List.
If it is not already included in the proper shipping name, the word “MOLTEN” must be added when a substance that is solid is offered for transport in the molten state. Also check requirements for elevated temperature substances in 5.4.1.4.3.4.
Note that special requirements apply to proper shipping names for:
Except for self-reactive substances and organic peroxides, and unless it is already included in capital letters in the proper shipping name shown in the Dangerous Goods List, the word “STABILIZED” must be added to the proper shipping name of any substance that, without stabilization, would be forbidden from transport due to its potential to dangerously react under conditions normally encountered in transport (for example, TOXIC LIQUID, ORGANIC, N.O.S., STABILIZED).
When temperature control is used to stabilize these substances to prevent development of dangerous excess pressure or evolution of excessive heat, or when chemical stabilization is used in combination with temperature control, then:
Hydrates may be transported using the proper shipping name for the anhydrous substance.
Generic and “not otherwise specified” (n.o.s.) proper shipping names that are subject to special provision 274 or 318 in column 6 of the Dangerous Goods List must be supplemented with the technical or chemical group names. This does not apply if:
For explosives of class 1, descriptive text may be added to the proper shipping name to indicate commercial or military names. Technical and chemical group names must be entered in brackets immediately following the proper shipping name.
The technical name must be:
Trade names must not be used for this purpose. For pesticides, use only:
When mixtures or articles containing dangerous goods are described by one of the n.o.s. or generic entries subject to special provision 274, not more than the two constituents that most predominantly contribute to the hazard or hazards need to be shown. This requirement does not apply to controlled substances when their disclosure is prohibited by national law or international convention.
If a package containing a mixture is labeled with any subsidiary hazard label, one of the two technical names shown in brackets must be the name of the constituent that compels the use of the subsidiary hazard label.
For proper documentation for n.o.s. entries classified as marine pollutants, the recognized chemical name of the constituent that most predominantly contributes to the classification as marine pollutant must be added to the proper shipping name. Exceptions to this are found in special provision 274.
If a substance is specifically listed by name in the Dangerous Goods List, it must be identified in transport by the proper shipping name in the List. A substance listed by name that contains technical impurities or additives for stability or other purposes that affect its classification must be considered a mixture or solution.
A mixture or solution is not subject to the International Maritime Dangerous Goods (IMDG) Code if the characteristics, properties, form, or physical state of the mixture or solution are such that it does not meet the criteria for inclusion in any class.
If a mixture or solution meets the classification criteria of a single predominant substance identified by name in the List and has one or more substances not subject to the provisions of this Code and/or traces of one or more substances identified by name in the List, then assign the UN number and proper shipping name of the predominant substance named in the List.
This requirement does not apply if:
Qualifying words such as “MIXTURE” or “SOLUTION,” as appropriate, must be added as part of the proper shipping name. The concentration of the mixture or solution may also be indicated after the basic description.
For a mixture or solution composed of two or more dangerous goods, use the entry that most precisely describes the mixture or solution.
Dangerous goods with similar chemical properties are grouped together in segregation groups. Some substances, mixtures, solutions, or preparations falling within a segregation group are not listed in the International Maritime Dangerous Goods (IMDG) Code by name, but are shipped under n.o.s. entries. Although n.o.s. entries are not listed in the segregation groups, the consignor must decide whether including them under the segregation group is appropriate and, if so, must note that fact in the transport document.
The segregation groups in the IMDG Code do not cover substances that fall outside the classification criteria of the Code. Some non-hazardous substances have similar chemical properties as substances listed in the segregation groups. If the consignor or the person responsible for packing the goods into a cargo transport unit has knowledge of the chemical properties of those non-dangerous goods, they may voluntarily use the segregation provisions of a related segregation group.
The segregation groups are identified in the IMDG Code Section 3.1.4, and include:
The Dangerous Goods List is found in the International Maritime Dangerous Goods (IMDG) Code Chapter 3.2. The List is divided into 18 columns. Each column includes a reference to the appropriate section in the IMDG Code that provides additional information for that requirement.
Special provisions
When column 6 of the Dangerous Goods List indicates that a special provision applies to a dangerous good, the requirements of that special provision are listed in numerical order amid nearly a thousand entries in Chapter 3.3 of the Code.
If a special provision includes a requirement for package marking, the provisions of section 5.2.1.2 must be met. If the required mark is specific wording in quotation marks, the size of the mark must be at least 12 mm, unless otherwise indicated in the special provision or elsewhere in the Code.
The International Maritime Dangerous Goods (IMDG) Code Chapter 3.4 details the conditions that apply to transport of dangerous goods of certain classes packed in limited quantities. Dangerous goods that are packed in limited quantities and meet the requirements in this chapter are subject to reduced requirements.
For each substance in the Dangerous Goods List, the quantity limit for the inner packaging or article is specified in column 7a. The quantity “0” in this column indicates that the entry is not permitted to be transported under the provisions for limited quantities.
Limited quantities: Packing
Dangerous goods must be packed only in inner packagings that are placed in suitable outer packagings. Intermediate packagings may be used. Additional requirements apply to articles of division 1.4, compatibility group S. The use of inner packagings is not necessary for transport of certain articles containing aerosols or gas.
In some cases, shrink-wrapped or stretch-wrapped trays are acceptable as outer packagings for articles or inner packagings containing dangerous goods. Inner packagings that could break or be easily punctured, such as those made of glass, porcelain, stoneware or certain plastics, must be placed in suitable intermediate packagings, and must be designed to meet the construction requirements of the IMDG Code Section 6.1.4. The total gross mass of the package may not exceed 20 kg.
Liquid goods of class 8, packing group II in glass, porcelain, or stoneware inner packagings must be enclosed in a compatible and rigid intermediate packaging.
Limited quantities: Stowage
Dangerous goods packed in limited quantity are allocated stowage category A, which is defined in the IMDG Code Section 7.1.3.2. The other stowage provisions indicated in column 16a of the Dangerous Goods List do not apply.
Limited quantities: Segregation
Different dangerous substances in limited quantities may be packed in the same outer packaging, only if:
The segregation provisions of the IMDG Code Chapter 7.2 to 7.7 and the segregation provisions in column 16b of the Dangerous Goods List do not apply for packagings containing dangerous goods in limited quantities or in relation to other dangerous goods. However, articles of division 1.4, compatibility group S must not be stowed in the same compartment, hold, or cargo transport unit with dangerous goods of class 1 of compatibility groups A and L.
Limited quantities: Marking and placarding
Packages containing dangerous goods in limited quantities must bear the mark detailed in the IMDG Code Section 3.4.5.
The minimum dimension per side is 100 mm.
Packages of dangerous goods packed according to Part 3, Chapter 4 of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air may bear a “Y” in the center of the mark to certify conformity with the provisions (minimum 100 mm per side).
The mark must be:
The top and bottom portions and the surrounding line must be black. The center area must be white or a suitable contrasting background. Minimum dimensions apply, and all features must be in proportion. If the size of the package necessitates, the outer dimensions may be reduced to not less than 50 mm × 50 mm as long as the mark remains clearly visible.
Limited quantities: Multimodal recognition of marks
Packages containing dangerous goods bearing the “Y” mark for transport by air, with or without the additional labels and marks for air transport, meet the marking requirements and need not bear the mark without the “Y”.
Packages containing dangerous goods in limited quantities bearing the limited quantities mark and conforming with the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, including all necessary marks and labels specified in parts 5 and 6, meet the IMDG Code requirements for limited quantities.
When packages containing dangerous goods packed in limited quantities are placed in an overpack or in a unit load, the overpack or the unit load must be marked with the limited quantity mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. In addition, an overpack must be marked with the word “OVERPACK” unless required marks representative of all dangerous goods in the overpack are visible. The lettering of the “OVERPACK” mark must be at least 12 mm high. Other provisions for overpacks and unit loads apply if other dangerous goods not packed in limited quantities are contained in the overpack or in a unit load.
Limited quantities: Placarding and marking of cargo transport units
Cargo transport units containing dangerous goods packed in limited quantities with no other dangerous goods must not be placarded nor marked according to the marking requirements for dangerous goods. Instead, they must be marked on the exterior with the mark in the IMDG Code Section 3.4.5.5.4.
Cargo transport units containing dangerous goods and dangerous goods packed in limited quantities must be placarded and marked according to the provisions that apply to the dangerous goods that are not packed in limited quantities. However, if no placard or mark is required for the dangerous goods not packed in limited quantities, the cargo transport units must be marked with the mark in IMDG Code Section 3.4.5.5.4.
The mark must be readily visible, legible, and still be identifiable on cargo transport units surviving at least three months’ immersion in the sea. The mark must be at least 250 mm × 250 mm and displayed in locations specified in IMDG Code Section 5.3.1.1.4.1.
Limited quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “limited quantity” or “LTD QTY” must be included on the dangerous goods transport document, along with the description of the shipment
Excepted quantities of certain dangerous goods that meet the provisions of the International Maritime Dangerous Goods (IMDG) Code Chapter 3.5 are subject to reduced requirements.
For radioactive material, the provisions for excepted packages are found in IMDG Code Section 1.5.1.5.
Dangerous goods that may be carried as excepted quantities are indicated in column 7b of the Dangerous Goods List. The code in column 7b indicates the maximum net quantity allowed for the inner and outer packaging.
Excepted quantities: Packagings
Packagings used to transport dangerous goods in excepted quantities must comply with certain conditions.
There must be an inner packaging and each inner packaging must meet construction requirements detailed in IMDG Code Section 3.5.2. The closure of each inner packaging must be held securely in place by positive means. If a receptacle has a neck with screw threads, it must also have a leakproof threaded cap. The entire closure must be resistant to the contents.
Each inner packaging must be securely packed in intermediate packaging with cushioning material so that they cannot break, be punctured, or leak the contents under normal conditions of transport.
For liquids, the intermediate or outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packagings. The absorbent material may also serve as the cushioning material. Dangerous goods must not react dangerously with or reduce the integrity of the packaging materials. Regardless of its orientation, the package must completely contain the contents in the event of breakage or leakage.
The intermediate packaging must be securely packed in a strong, rigid outer packaging.
Each package must be large enough to apply all necessary marks.
Overpacks may be used and may also contain packages of dangerous goods or goods not subject to the IMDG Code.
Excepted quantities: Tests for packagings
The complete package as prepared for transport must be capable of withstanding the tests detailed in IMDG Code Section 3.5.3 without breaking or leaking and without a reduction in effectiveness. The testing must be appropriately documented.
Excepted quantities: Marking
Packages containing excepted quantities of dangerous goods must be marked with the mark shown in IMDG Code Section 3.5.4. The primary hazard class of each of the dangerous goods contained in the package must be shown in the mark. If the name of the consignor or consignee is not shown elsewhere on the package, this information must be included within the mark.
* The class or division number(s) must be shown in this location.
** The name of the consignor or of the consignee must be shown in this location if it does not appear elsewhere on the package.
The mark must be a square with the border hatching and symbol in black or red, on white or suitable contrasting background. The minimum dimensions are 100 mm × 100 mm. If dimensions are not specified for a feature, it must be in approximate proportion to those shown.
Overpacks and the unit loads containing excepted quantities must be marked with the excepted quantities mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. Overpacks must also be marked with the word “OVERPACK” unless marks representative of all dangerous goods in the overpack are visible.
Excepted quantities: Maximum per transport unit
A maximum of 1,000 packages containing dangerous goods packed in excepted quantities may be carried in any cargo transport unit.
Excepted quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “dangerous goods in excepted quantities” and the number of packages must be included on the dangerous goods transport document, along with the description of the shipment.
Excepted quantities: Stowage
Dangerous goods packed in excepted quantity are allocated stowage category A (defined in IMDG Code Section 7.1.3.2). The stowage provisions in column 16a of the Dangerous Goods List do not apply.
Excepted quantities: Segregation
The segregation requirements of IMDG Code Chapter 7.2 to 7.7 do not apply for:
Appendices
Appendix A to Part 3 of the IMDG Code contains the list of generic and n.o.s. proper shipping names. The name in the Dangerous Goods List that most appropriately describes the substance or article must be used as the proper shipping name. The main generic entries and all the n.o.s. entries given in the Dangerous Goods List appear in Appendix A.
General and n.o.s. names are grouped according to their hazard class or division. Within each hazard class or division, the names are in one of three groups, including:
Appendix B contains a glossary of terms applicable to Part 3 of the IMDG Code.
A consignor offering dangerous goods for transport must provide the carrier with the information that applies to those dangerous goods. The information may be provided on a dangerous goods transport document or, with the agreement of the carrier, by electronic data processing (EDP) or electronic data interchange (EDI) techniques.
When EDP or EDI techniques are used, the consignor must be able to produce the paper document, without delay, with the information in the sequence required by the International Maritime Dangerous Goods (IMDG) Code.
Document format
A dangerous goods transport document may be in any form, provided it contains all information required by the IMDG Code. If both dangerous and non-dangerous goods are listed in one document, the dangerous goods must be listed first, or be emphasized by another method. The document may be more than one page, provided the pages are consecutively numbered. The information on the document must be easy to identify, legible, and durable.
The dangerous goods transport document must include:
Records retention
The consignor and the carrier must retain a copy of the dangerous goods transport document and additional information and documentation specified in the IMDG Code for a minimum period of three months. When the documents are kept electronically or in a computer system, the consignor and the carrier must be able to reproduce them in a printed form.
Information required on the dangerous goods transport document begins with the dangerous goods description.
For each dangerous substance, material, or article offered for transport, the document must provide:
The five elements of the dangerous goods description must be shown in the order listed above, with no information interspersed, except as allowed by the International Maritime Dangerous Goods (IMDG) Code. Unless permitted or required by the Code, additional information being included must be placed after the dangerous goods description.
The proper shipping name in the dangerous goods description must be supplemented with the following information, when appropriate:
In addition to the dangerous goods description, the following information must be included after the dangerous goods description on the transport document:
Consignor certification
The dangerous goods transport document must include a certification or declaration that the consignment is acceptable for transport and that the goods are properly packaged, marked, and labeled, and in proper condition for transport according to the applicable regulations. The certification must be signed and dated by the consignor.
If the documentation is presented to the carrier via electronic data processing (EDP) or electronic data interchange (EDI) transmission techniques, the signature may be electronic or may be replaced by the name (in capital letters) of the person authorized to sign.
When the dangerous goods transport information is given to a carrier by EDP or EDI techniques and subsequently the dangerous goods are transferred to a carrier that requires a paper dangerous goods transport document:
When dangerous goods are packed or loaded into a container or vehicle, those responsible for packing the container or vehicle must provide a “container/vehicle packing certificate.” The certificate must specify the container/vehicle identification number and certify that the operation has been carried out according to certain conditions, including that:
Note that the container/vehicle packing certificate is not required for portable tanks.
The information required in the dangerous goods transport document and the container/vehicle packing certificate may be incorporated into a single document; if not, these documents must be attached.
If the information is incorporated into a single document, the document must include a signed declaration indicating that the packing of the goods into the container/vehicle has been carried out in accordance with the applicable provisions. This declaration must be dated and the person signing it must be identified on the document.
If the certificate is presented to the carrier via EDP or EDI transmission techniques, the signature may be electronic or may be replaced by the name (in capital letters) of the person authorized to sign.
If the certificate is given to a carrier by EDP or EDI techniques and subsequently the dangerous goods are transferred to a carrier that requires a paper container/vehicle packing certificate, the carrier must ensure that:
Each ship carrying dangerous goods and marine pollutants must have a special list, manifest, or stowage plan setting out the dangerous goods (except dangerous goods in excepted packages of class 7) and marine pollutants and the location of those goods on the ship.
This special list or manifest must be based on the documentation and certification required in the International Maritime Dangerous Goods (IMDG) Code. In addition to the information in the dangerous goods transport documents, it must contain the stowage location and the total quantity of dangerous goods and marine pollutants.
A detailed stowage plan that identifies by class and sets out the location of all dangerous goods and marine pollutants may be used in place of a special list or manifest.
Each ship carrying excepted packages of class 7 must have a special list, manifest, or stowage plan setting out these excepted packages and their location.
A copy of the documents must be made available before departure to the person or organization designated by the port State authority.
For consignments of dangerous goods, appropriate information must be immediately available at all times for use in emergency response to accidents and incidents involving dangerous goods in transport. The information must be:
Methods to comply with this requirement include:
In certain circumstances, special certificates or other documents are required when offering dangerous goods for transport.
A weathering certificate is required in some individual entries of the Dangerous Goods List.
A certificate exempting a substance, material, or article from the provisions of the International Maritime Dangerous Goods (IMDG) Code must accompany the consignment. For examples, see the individual entries for charcoal, fish meal, and seed cake.
New self-reactive substances and organic peroxides, or new formulation of currently assigned self-reactive substances and organic peroxides, must include a statement of the approved classification and conditions of transport.
Multimodal dangerous goods form
The Multimodal Dangerous Goods Form found in the IMDG Code Section 5.4.5 meets the requirements of SOLAS, chapter VII, regulation 4; MARPOL, Annex III, regulation 4; and the IMDG Code provisions for documentation.
The information required by the documentation provisions of the Code is mandatory, however, the layout of the form is not mandatory.
This form may be used as a combined dangerous goods transport document and container/vehicle packing certificate for multimodal carriage of dangerous goods.
Marking requirements in the International Maritime Dangerous Goods (IMDG) Code address the marking of dangerous goods according to their properties. Additional marks or symbols indicating precautions for handling or storing a package (such as a symbol indicating that a package must be kept dry) may be displayed on a package if appropriate.
Unless otherwise provided, the proper shipping name for the dangerous goods and the corresponding UN number, preceded by the letters “UN”, must be displayed on each package. The UN number and the letters “UN” must meet the minimum dimensions listed in the Code.
Example: CORROSIVE LIQUID, ACIDIC, ORGANIC, N.O.S. (caprylyl chloride) UN 3265.
For unpackaged articles, the mark must be displayed on:
For goods of division 1.4, compatibility group S:
All package marks required by the Code:
Salvage packagings, including large salvage packagings and salvage pressure receptacles, must also be marked with the word “SALVAGE” in lettering at least 12 mm high.
Intermediate bulk containers (IBCs) of more than 450 L capacity and other large packagings must be marked on two opposite sides.
Special marking for radioactive material
For radioactive materials, each package must be marked on the outside with an identification of the consignor, consignee, or both. Each overpack must be marked on the outside with an identification of the consignor, consignee, or both, unless these marks on all packages in the overpack are clearly visible. Excepted packages of class 7 radioactive material must be marked as required by International Maritime Dangerous Goods (IMDG) Code Section 5.1.5.4.1.
Each package with gross mass exceeding 50 kg must be marked with its permissible gross mass on the outside of the packaging.
Specific package types require additional marks as follows:
Each package that conforms to a design approved under one or more of paragraphs specified in IMDG Code Section 5.2.1.5.5 must be marked on the outside of the package with the following information:
For each package with a Type B(U), Type B(M) or Type C package design, the trefoil symbol must appear on the outside of the outermost receptacle that is resistant to the effects of fire and water. The symbol must be embossed, stamped, or otherwise resistant to the effects of fire and water.
Any mark on the package relating to the package type that does not relate to the UN number and proper shipping name assigned to the consignment must be removed or covered.
If LSA-I or SCO-I material is contained in receptacles or wrapping materials and transported under exclusive use provisions, the outer surface of these receptacles or wrapping materials may bear the mark “RADIOACTIVE LSA-I” or “RADIOACTIVE SCO-I”, as appropriate.
If international transport of packages requires competent authority approval of design or shipment, and different approval types apply in the different countries concerned by the shipment, marking must be according to the requirements of the country of origin of the design.
Special marking for marine pollutants
With limited exceptions, packages containing marine pollutants must be marked with the marine pollutant mark. The mark must be located adjacent to other required marks.
The mark must be in the form of a square set at an angle of 45° (diamond-shaped). The symbol of a fish and tree must be black on white or a suitable contrasting background. Minimum dimensions must be met. If the size of the package requires, the dimensions may be reduced, provided the mark remains clearly visible.
All labeling provisions of IMDG Code Section 5.2.2 apply in addition to the requirement for the marine pollutant mark.
Orientation arrows
With few exceptions, the following packagings must be legibly marked with package orientation arrows similar to those shown in IMDG Code Section 5.2.1.7 or meeting the specifications of ISO 780:1997:
The orientation arrows must appear on two opposite vertical sides of the package with the arrows pointing in the correct upright direction. They must be rectangular and large enough to be clearly visible considering the size of the package. A rectangular border around the arrows is optional.
Orientation arrows are not required on:
Arrows for purposes other than indicating proper package orientation must not be displayed on a package marked according to IMDG Code Section 5.2.1.7.
Excepted and limited quantities
Packages containing excepted quantities of dangerous goods must be marked according to IMDG Code Section 3.5.4. Packages containing dangerous goods packed in limited quantities must be marked according to IMDG Code Section 3.4.5.
Lithium battery mark
Packages containing lithium cells or batteries prepared according to special provision 188 must be marked as shown in IMDG Code Section 5.2.1.10.
The mark must indicate the UN number, preceded by the letters “UN”. If lithium cells or batteries are contained in or packed with equipment, the UN number preceded by the letters “UN” must be indicated. When a package contains lithium cells or batteries assigned to different UN numbers, all applicable UN numbers must be indicated.
*Place for UN number(s)
**Place for telphone number for additional information.
Minimum dimensions are 100 mm x 100 mm.
The mark must be a rectangle or a square with hatched edging and meet minimum dimensions. The symbol showing a group of batteries must be black on white or suitable contrasting background. The hatching must be red. If the size of the package so requires, the dimensions may be reduced to not less than 100 mm wide × 70 mm high.
Labeling requirements in the International Maritime Dangerous Goods (IMDG) Code address danger labels. Additional marks or symbols indicating precautions for handling or storing a package (such as a symbol indicating that a package must be kept dry) may be displayed on a package if appropriate.
Labels must identify primary and subsidiary hazards according to the models in IMDG Code Section 5.2.2.2.2, which define and illustrate requirements for:
For articles or substances specifically listed in the Dangerous Goods List, a danger class label must be affixed as indicated in:
A package containing a dangerous substance with a low degree of danger may be exempt from the labeling requirements. In this case, column 6 of the Dangerous Goods List will specify that no hazard label is required.
If a substance that meets the definition of more than one class is not specifically listed by name in the Dangerous Goods List, the provisions in chapter 2.0 must be used to determine the primary hazard class of the goods. In addition to the label required for that primary hazard class, subsidiary hazard labels must also be applied as specified in the List. However:
Three separate labels are provided for class 2:
Requirements for labels for class 2 gases with subsidiary hazards are defined in IMDG Code Section 5.2.2.1.4.
Label placement
Each label must be:
If a package is an irregular shape or small size and a label cannot be satisfactorily affixed, the label may be attached to the package by a securely affixed tag or other suitable means.
A placement exception may apply to cylinders for class 2. Due to their shape, orientation, and securing mechanisms for transport, these may bear labels that have been reduced in size, according to ISO 7225:2005, Gas cylinders, Precautionary labels, and displayed on the shoulder of the cylinders. Labels may overlap to the extent provided for by ISO 7225:2005; however, in all cases, the labels representing the primary hazard and the numbers appearing on any label must remain fully visible and the symbols recognizable.
Note: When the diameter of the cylinder is too small to permit the display of the reduced size labels on the shoulder of the cylinder, the reduced sized labels may be displayed on the cylindrical part. Intermediate bulk containers of more than 450 L capacity and large packagings must be labeled on two opposing sides.
Labels must be affixed on a surface of contrasting color.
Special provisions
Special labeling provisions apply to certain substances and materials, including:
Format of labels
Labels must comply with provisions in IMDG Code Section 5.2.2.2 in terms of color, symbols, numbers, and general format.
Labels must:
The label must be a square set at an angle of 45 degrees (diamond-shaped). The minimum dimensions must be 100 mm × 100 mm.
If the size of the package necessitates, the dimensions may be reduced proportionally, provided the symbols and other elements of the label remain clearly visible. Dimensions for cylinders must comply with IMDG Code Section 5.2.2.2.
With few exceptions, the upper half of the label must contain the pictorial symbol and the lower half must contain the class number.
On labels other than those for material of class 7, the insertion of any text (other than the class or division number) in the space below the symbol must be confined to particulars indicating the nature of the hazard and precautions to be taken in handling.
The symbols, text, and numbers must be shown in black on all labels except for:
When affixing labels or applying stencils of labels on packages containing dangerous goods, the method must be such that the labels or stencils will still be identifiable on packages surviving at least three months immersed in the sea.
The International Maritime Dangerous Goods (IMDG) Code general stowage provisions provide requirements for dangerous goods in various types of ships including container ships, general cargo ships, and barges.
Stowage categories
The IMDG Code specifies where dangerous goods must be stowed on a vessel, depending on dangerous goods hazard class.
Class 1 materials are stowed in different parts of a vessel than Classes 2 through 9.
Complete details on stowage categories are found in IMDG Code Section 7.1.3.
Special stowage provisions apply to certain types of dangerous goods, for example, empty, uncleaned packagings, including intermediate bulk containers (IBCs) and large packagings, marine pollutants, and limited quantities/excepted quantities. Special stowage instructions exist for Class 1 materials and Class 7 materials, depending on vessel type.
Packing and using CTUs
A cargo transport unit (CTU) must be fit for use and inspected before loading to ensure it isn’t damaged. Packages must be looked over prior to placing them into a CTU; if damaged or leaking, they must not be placed into the CTU.
Snow, water, and ice must be removed from packages prior to placing them in a CTU.
If drums are loaded into a CTU, they must be in an upright position.
Segregation requirements apply and details for CTUs can be found in the IMDG Code Section 7.3.4.
Packages within a CTU must be secured accordingly and not stacked unless designed for that purpose.
Cargo and packages must fit entirely within the CTU.
If security devices or tracking devices are used on the CTU, they must be securely installed or attached and compatible and safe for the dangerous goods transported in the CTU.
When a CTU must be unloaded, caution should be used when opening the doors. Unsafe conditions can exist, for example, leakages may have occurred which may create unsafe conditions. After the CTU is completely empty, dangerous goods placards and any other dangerous goods marking must be removed, covered, or obliterated.
When a CTU is under temperature control due to the dangerous goods it contains, care must be taken to ensure the requirements in the IMDG are met. The complete requirements for temperature-controlled CTUs can be found in the IMDG Code Section 7.3.7.
Complete details and requirements can be found in IMDG Chapter 7.3.
Segregation refers to the process of separating incompatible substances to avoid undue hazards should the packages leak or spill, or otherwise come in contact with one another in an accident.
The segregation table can be found in the International Maritime Dangerous Goods (IMDG) Code Section 7.2.4.
The codes listed in the table are as follows:
Additional segregation groups and special provisions and exceptions can be found in the IMDG Code Sections 7.2.5 and 7.2.6.
A helpful segregation flow chart can be found in the IMDG Code Chapter 7.2 Annex (for informational purposes only).
Segregation and stowage on containerships
Chapter 7.4 of the IMDG Code covers the stowage and segregation requirements on containerships. Containers meet the definition of a container in the International Convention for Safety Containers, 1972. These are containers transported on deck and in the cargo holds of containerships or on deck and in the cargo holds of other types of ships (provided the positions are fitted to give permanent stowage of containers during transport). If ships are not properly fitted for the permanent stowage of containers, then refer to IMDG Code Chapter 7.6.
Segregation and stowage on roll-on/roll-off ships
Chapter 7.5 of the IMDG Code covers the stowage and segregation of cargo transport units (CTUs) that are transported in roll-on/roll-off (ro-ro) cargo spaces. If a ro-ro ship has stowage positions that are fitted to give a permanent stowage of containers during transport, then the IMDG Code Chapter 7.5 applies. If the ro-ro ship has conventional cargo spaces, then refer to IMDG Code Chapter 7.6.
Segregation and stowage on general cargo ships
Chapter 7.6 of the IMDG Code covers the segregation and stowage of dangerous goods stored conventionally on board general cargo ships.
There are stowage and handling provisions based on class of dangerous goods. In general for all classes of dangerous goods:
Consult IMDG Code Chapter 7.6 for additional provisions specific to dangerous goods class.
Barges may contain packaged dangerous goods or solid bulk materials. Barges must be designed and maintained to handle dangerous goods transportation. Complete details on the requirements for shipborne barges on barge-carrying ships can be found in the International Maritime Dangerous Goods (IMDG) Code Chapter 7.7.
Leaking, damaged, or sifting packages cannot be loaded onto a shipborne barge.
Dangerous goods packages, cargo transport units (CTUs), or any other dangerous goods within a shipborne barge must be secured for the trip. Packages must be loaded so that the likelihood of damage is minimized. Fittings on packages or tanks must also be protected from damage.
Some types of dry dangerous goods may be transported in bulk on a shipborne barge. If allowed, it will show the code “BK2” in column 13 of the Dangerous Goods List. Bulk materials transported on shipborne barges must be evenly distributed and secured.
Shipborne barges must be visually examined to check for damage affecting the barges’ watertight integrity. If a barge is damage, it cannot be used to transport packaged or bulk dangerous goods.
Flexible bulk containers can be transported via barge, but they must be stowed in a way that there aren’t spaces in between the containers. If the containers do not completely fill the barge, then measures must be taken to ensure the cargo is completely secured against shifting. If these containers are stacked, they can be stacked no more than three high.
Segregation on barges is covered in the IMDG Code Section 7.7.5.
International Maritime Dangerous Goods (IMDG) Code Chapter 7.8 covers special requirements in the event of an incident or fire involving dangerous goods. The provisions of the chapter are not mandatory. If a ship is involved in an accident or is leaking while in port, port authorities should be contacted for appropriate procedures.
General fire precautions are as follows:
The International Maritime Dangerous Goods (IMDG) Code was developed as an international regulation for the transport of dangerous goods by vessel. The IMDG Code is designed to enhance and harmonize the safe transportation of dangerous goods and to prevent pollution to the aquatic environment. The Code sets out, in detail, the requirements applicable to all dangerous goods, covering matters such as stowage, with reference to the segregation of incompatible substances.
Stowage generally refers to the location on the vessel where cargo may be stowed. The Code contains various stowage categories, stowage codes, handling codes, and segregation requirements that detail where cargo can be stowed for dangerous goods. As you can imagine, not following proper stowage procedures and location requirements can have devastating results when a vessel is at sea.
The International Maritime Dangerous Goods (IMDG) Code uses stowage categories to identify if cargo can be stored On Deck, Under Deck, or Prohibited. Column 16a of the Dangerous Goods List displays the stowage category for each material. Stowage categories are split into two groups, Class 1 and Classes 2 - 9.
Stowage Category for Class 1 (Other than Division 1.4S packed in limited quantity)
Stowage Category 01 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck |
Passengers Ships | On deck in closed cargo transport unit or under deck |
Stowage Category 02 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck |
Passengers Ships | On deck in closed cargo transport unit or under deck in closed transport unit |
Stowage Category 03 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck |
Passengers Ships | Prohibited* |
Stowage Category 04 | |
Cargo Ships (Up to 12 passengers) | On deck in closed cargo transport unit or under deck in closed transport unit |
Passengers Ships | Prohibited* |
Stowage Category 05 | |
Cargo Ships (Up to 12 passengers) | On deck only in closed cargo transport unit |
Passengers Ships | Prohibited* |
*- Except in accordance with Chapter 7.1.4.4.6 |
Stowage Category for Classes 2 – 9 (Including Division 1.4S packed in limited quantity)
Stowage Category A | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck or under deck |
Other passenger ships in which the limiting number of passengers transported is exceeded | On deck or under deck |
Stowage Category B | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck or under deck |
Other passenger ships in which the limiting number of passengers transported is exceeded | On deck only |
Stowage Category C | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck only |
Other passenger ships in which the limiting number of passengers transported is exceeded | On deck only |
Stowage Category D | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck only |
Other passenger ships in which the limiting number of passengers transported is exceeded | Prohibited |
Stowage Category E | |
Cargo ships or passenger ships carrying up to 25 passengers or 1 passenger per 3-meter overall length, whichever is greater | On deck or under deck |
Other passenger ships in which the limiting number of passengers transported is exceeded | Prohibited |
Always check IMDG Code Chapter 7 for any additional stowage requirements or provisions that may be required for the dangerous goods.
Stowage codes identify additional requirements for the stowage of dangerous goods and can be used with the stowage categories. Stowage codes are recognized by the “SW” before a number and are generally used for individual substances. Column 16a of the Dangerous Goods List also displays the stowage code for each material.
Stowage code | Description |
---|---|
SW1 | Protected from sources of heat. |
SW2 | Clear of living quarters. |
SW3 | Shall be transported under temperature control. |
SW4 | Surface ventilation is required to assist in removing any residual solvent vapor. |
SW5 | If under deck, stow in a mechanically vented place. |
SW6 | When stowed under deck, mechanical ventilation shall be in accordance with SOLAS regulations for flammable liquids with a flashpoint below 23 Celsius. |
SW7 | As approved by the competent authorities of the countries involved in the shipment. |
SW8 | Ventilation may be required. The possible need to open hatches in case of fire to provide maximum ventilation and to apply water in an emergency, and the consequent risk to the stability of the ship through flooding of the cargo spaces, shall be considered before loading. |
SW9 | Provide a good through ventilation for bagged cargo. Double strip stowage is recommended. During the voyage regular temperature readings shall be taken at varying depths in the hold and recorded. If the temperature of the cargo exceeds the ambient temperature and continues to increase, ventilation shall be closed. |
SW10 | Unless carried in closed cargo transport units, bales shall be properly covered by tarpaulins or the like. Cargo spaces shall be clean, dry, and free from oil or grease. Ventilator cowls leading into the cargo space shall have sparking-preventing screens. All other openings, entrances and hatches leading to the cargo space shall be securely closed. During temporary interruption of loading, when the hatch remains uncovered, a fire-watch shall be kept. During loading or discharge, smoking in the vicinity shall be prohibited and fire-fighting appliances kept ready for immediate operation. |
SW11 | Cargo transport units shall be shaded from direct sunlight. Packages in cargo transport units shall be stowed to allow for adequate air circulation throughout the cargo. |
SW12 | Taking account of any supplementary requirements specified in the transport documents. |
SW13 | Taking account of any supplementary requirements specified in the competent authority approval certificate(s). |
SW14 | Category A only if the special stowage provisions of 7.4.1.4 and 7.6.2.8.4 are complied with. |
SW15 | For metal drums, stowage category B. |
International Maritime Dangerous Goods (IMDG) Code Chapter 7 contains additional stowage codes.
Handling codes identify additional requirements for the stowage of dangerous goods and can be used with stowage codes and stowage categories. Handling codes are recognized by the “H” before a number and are generally used for individual substances. Column 16a of the Dangerous Goods List also displays the handling code for each material.
Handling code | Description |
---|---|
H1 | Keep as dry as reasonably practical. |
H2 | Keep as cool as reasonably practical. |
H3 | During transport, it should be stowed (or kept) in a cool ventilated place. |
H4 | If cleaning of cargo spaces must be carried out at sea, the safety procedures followed, and standard of equipment used shall be at least as effective as those employed as industry best practice in a port. Until such cleaning is undertaken, the cargo spaces in which the asbestos has been carried shall be closed and access to those spaces shall be prohibited. |
H5 | Avoid handling the packaging or large packaging or keep handling to a minimum. Inform the appropriate public health authority or veterinary authority where persons or animals may have been exposed. |
Dangerous goods, substances, or articles that are incompatible and may react violently with each other due to leakage, spillage, or any other accident must be segregated from one another for shipment by vessel. Segregation can be obtained by maintaining separation between incompatible dangerous goods or by requiring the presence of one or more steel bulkheads or decks between them, or a combination thereof.
Determining the segregation requirements between two or more substances requires referencing the Segregation Table in the International Maritime Dangerous Goods (IMDG) Code Chapter 7.2 and the segregation codes in Column 16b of the Dangerous Goods List. The segregation code description can be found in IMDG Code Chapter 7.2. If there are conflicting segregation requirements in the IMDG Code, the provisions of Column 16b of the Dangerous Goods List will always take precedence.
Segregation codes
A portion of the segregation codes given in Column 16b of the Dangerous Goods List are specified below:
Segregation Code | Description |
SG1 | For packages carrying a subsidiary hazard label of class 1, segregation as for class 1, division 1.3. However, in relation to goods of class 1, segregation as for the primary hazard. |
SG2 | Segregation as for class 1.2G. |
SG3 | Segregation as for class 1.3G. |
SG4 | Segregation as for class 2.1. |
SG5 | Segregation as for class 3. |
SG6 | Segregation as for class 5.1. |
SG7 | Stow “away from” class 3. |
SG8 | Stow “away from” class 4.1. |
SG9 | Stow “away from” class 4.3. |
SG10 | Stow “away from” class 5.1. |
SG11 | Stow “away from” class 6.2. |
SG12 | Stow “away from” class 7. |
SG13 | Stow “away from” class 8. |
SG14 | Stow “separated from” class 1 except for division 1.4S. |
SG15 | Stow “separated from” class 3. |
SG16 | Stow “separated from” class 4.1. |
SG17 | Stow “separated from” class 5.1. |
SG18 | Stow “separated from” class 6.2. |
SG19 | Stow “separated from” class 7. |
SG20 | Stow “away from” SGG1 – acids. |
IMDG Code Chapter 7 should always be referenced for complete segregation requirements, codes, and specifications.
Cargo Transport Units (CTU) are versatile so they can be used with different modes of transportation. The versatility of the CTU has made it one of the most used forms of packaging for vessel shipments.
All CTU must be constructed in a way to prevent the loss of contents. When appropriate, the CTU must have a means to facilitate securing and handling cargo inside the unit. CTU must be adequately maintained.
Packing CTU
In the past, there have been instances where CTU were not packed in a safe manner. As a result, the CTU was overloaded or contained loose cargo, which resulted in severe incidents. To prevent future incidents the International Maritime Dangerous Goods (IMDG) Code requires the following actions to be taken when packing a CTU:
Segregation and CTU
Dangerous goods that must be segregated from each other according to the International Maritime Dangerous Goods (IMDG) Code Chapter 7.2 segregation requirements must not be loaded in the same CTU. However, dangerous goods that must be segregated “away from” each other may be transported in the same CTU with approval from a competent authority.
Dangerous goods with primary or subsidiary hazard classes 2.3, 6.1, 6.2, 7, 8, and dangerous goods with a reference to the IMDG Code Section 7.3.4.2.1 in Column 16b of the Dangerous Goods List must not be loaded with foodstuffs in the same CTU.
Packing is not necessarily just the act of placing items in a package or container, but also about the package itself. In this case, the International Maritime Dangerous Goods (IMDG) Code considers packing to also include selecting the correct authorized package or packaging.
IMDG Code packing requirements vary depending on the type, class, and quantity of dangerous goods you are shipping, which makes the packing process difficult. The IMDG Code makes this task a little easier by listing all the requirements for the various dangerous goods and packages that are authorized to be used.
The International Maritime Dangerous Goods (IMDG) Code requires packagings, intermediate bulk containers (IBCs), and large packagings to follow certain provisions. The provisions are intended to ensure the dangerous goods are packed and shipped in a safe secure manner. The following general provisions apply to dangerous goods packagings, IBCs, and large packagings. The packagings must be:
The International Maritime Dangerous Goods (IMDG) Code provides packing instructions for dangerous goods in hazard classes 1 through 9. Packing instructions show the acceptable packagings that are authorized for a dangerous good. For combination packagings, the packing instructions list the acceptable outer packagings, inner packagings and when applicable, the maximum permitted quantity in each inner or outer packaging.
The packaging instructions are subdivided into three subsections according to the type of packaging being used and are designated by a code. The codes are alphanumeric, and the code prefix designates what package it is intended for. The packing instructions are detailed in IMDG Code Section 4.1.4.
Code Prefix | Description |
---|---|
P | Packagings other than IBCs and large packagings. Found in Column 8 of the Dangerous Goods List. |
IBC | Intermediate bulk container (IBC). Found in Column 10 of the of the Dangerous Goods List. |
LP | Large Packagings. Found in Column 8 of the Dangerous Goods List. |
Any packing instruction left blank or does not contain a code means that type of packaging is not authorized.
Special provisions may also be specified in the packing instruction for individual substances or articles. They provide additional guidance or requirements when packaging substances or articles. Special provisions are also designated by an alphanumeric code comprising the letters.
Code Prefix | Description |
---|---|
PP | Packagings other than IBCs and large packagings. Found in Column 9 of the Dangerous Goods List. |
B | Intermediate bulk container (IBC). Found in Column 11 of the of the Dangerous Goods List. |
L | Large Packagings. Found in Column 9 of the Dangerous Goods List. |
Typically, packing instructions do not provide guidance on compatibility. The shipper is responsible for checking that the substance is compatible with the packaging material selected (such as, most fluorides are unsuitable for glass receptacles). Where glass receptacles are permitted in the packing instructions, porcelain, earthenware, and stoneware packagings are also allowed.
Example: For UN1789, Hydrochloric Acid, PG II, the Dangerous Goods List shows packing instructions are P001 for single/combination packages, IBC02 for intermediate bulk containers and does not list any packing instruction for large packagings. The special provisions are B20.
The International Maritime Dangerous Goods (IMDG) Code requires portable tanks to follow certain provisions. The provisions are intended to ensure the dangerous goods are packed and shipped in a safe secure manner. The following general provisions apply to Class 1 and Classes 3-9 dangerous goods in portable tanks:
The International Maritime Dangerous Goods (IMDG) Code requires portable tanks to follow certain provisions. The provisions are intended to ensure the dangerous goods are packed and shipped in a safe secure manner. The following general provisions apply to Class 2 (non-refrigerated gases) dangerous goods in portable tanks:
Portable tank instructions and special provisions are applicable to dangerous goods authorized to be transported in portable tanks.
Each portable tank instruction is identified by an alpha-numeric designation (T1 to T75). Column 13 of the Dangerous Goods List indicates the portable tank instruction that must be used for each substance permitted for transport in a portable tank. When no portable tank instruction appears in the Dangerous Goods List, transport of the substance in portable tanks is not permitted unless a competent authority approval is granted.
Portable tank special provisions are assigned to specific dangerous goods in Column 14 of the Dangerous Goods List. They provide additional guidance or requirements when packaging substances or articles in portable tanks. Each portable tank special provision is identified by an alpha-numeric designation that always begin with “TP” (such as TP1). A listing of the portable tank special provisions is provided in International Maritime Dangerous Goods (IMDG) Code Section 4.2.5.3.
How dangerous goods are packaged can have a significant impact on how safely that material can be transported. Because of this, the International Maritime Dangerous Goods (IMDG) Code has very specific requirements for dangerous goods packages. These requirements are designed to ensure that the packaging is appropriate for the material and that it can withstand the conditions normally encountered during transport.
The IMDG Code requires most packages containing dangerous goods to meet UN specification standards. Packages meeting the UN specification standards also must pass various package testing requirements depending on the type of package being used. UN specification packages must also contain package markings that indicates what standards the package was manufactured to.
Understanding what the UN specification markings indicate is extremely important when selecting a package for your dangerous goods.
Package codes are alphanumeric characters that describe the type/kind of package and the material it is made of. Package codes are typically two or three digits long. However, they can be up to five digits long.
Codes that contain only one capital letter indicate a single package, and can be deciphered as follows:
The first numeral designates the kind of packaging:
The letter indicates the material of construction:
A second numeral indicates the category of packaging within the packaging:
Examples:
Codes that contain two capital letters indicate composite packages. The first letter designates the material for the inner receptacle, and the second, the material for the outer packaging.
Example:
Performance levels
Solids or inner packaging
Packages and containers for dangerous goods must pass rigorous performance testing prior to use. The UN specification marking is an indication that the package has met stringent requirements set forth by the United Nations.
The UN specification marking must include, in the following order:
All packages containing dangerous goods must meet general package requirements even if they are not a UN specification package. While the requirements may seem like common knowledge, they are often forgotten or overlooked.
Packages must be:
UN specification package testing is a series of tests and requirements used to determine the integrity and safety of the package when facing various situations. The tests are designed to simulate common conditions that are encountered during transportation. Not all packages are required to accomplish each type of test. For example, a package designed for solids does not need to have a leakage test.
Types of tests include:
A test report containing the following information must be made available to the users of the package:
The complete requirements for package specifications can be found in International Maritime Dangerous Goods (IMDG) Code Chapter 6. Chapter 6 should be referenced any time there are any requirements for package specifications.
The International Maritime Dangerous Goods (IMDG) Code addresses the transportation of radioactive materials by sea.
The primary goal of the IMDG’s radioactive materials requirements is to protect the general public, property, and the environment from radiation during transport by sea. This is done by ensuring the packaging is appropriate for the radioactive material, placing administrative controls on the transport of the radioactive material (and if appropriate, approvals by competent authorities), and ensuring emergency response procedures are in place prior to transport.
The International Maritime Dangerous Goods (IMDG) Code applies to the sea transport of radioactive materials. This includes packaging design and packaging manufacturing along with the preparation of a radioactive material for loading/unloading, offering a radioactive material for transportation, and in-transit storage of the material. All subsidiary hazards of the radioactive material must be taken into account when determining the documentation, markings and labels, segregation, and other requirements.
The IMDG Code requirements on radioactive materials do not apply to:
Specific provisions for excepted packages can be found in the IMDG Code, section 1.5.1.5.
Special arrangements, which are special provisions approved by competent authorities, can be made for radioactive materials shipments that do not conform to the regulatory standards but that provide an equivalent level of safety; see IMDG section 1.5.4 for details.
Shipment approvals for Class 7 materials are required in some circumstances. Multilateral approvals are required for the following:
Consult the IMDG Code section 5.1.5.1.2 for complete details on these required approvals.
Notifications to competent authorities is required for certain types of shipments, including but not limited to:
Consignors must notify the competent authorities of the country of origin of the shipment and the country through or into which the consignment will be transported. This notification must be done 7 days in advance of the shipment starting. The notification must include:
Competent authority certificates are required for certain types of package designs. See the International Maritime Dangerous Goods (IMDG) Code Section 5.1.5.2 for a listing. Consignors must be in possession of the applicable certificate.
Radioactive material transportation must be done under a radiation protection program, which must adequately address radiation protection measures. The program must address measures that will be taken to keep doses to persons below dose limits and to keep exposures as low as possible. These measures must be related to the significance and chances of radiation exposures. Finally, the program must address applicable emergency response procedures.
If the competent authority requests to see the program documents, then such documents must be available to the competent authority.
More details on the Radiation Protection Program can be found in the International Maritime Dangerous Goods (IMDG) Code Section 1.5.2.
A Management System, acceptable to the competent authority, must be in place to ensure compliance with the regulations is maintained. More details can be found in IMDG Code Section 1.5.3.
Packages must be marked with the identification of the consignor or consignee, or both. Overpacks must also contain the same information, unless the marks are visible through the package.
If the gross mass of a package exceeds 50 kilograms, then the permissible gross mass must be marked on the package.
Type IP-1, IP-2, and IP-3 package designs must be marked with “TYPE IP-1,” “TYPE IP-2,” and “TYPE IP-3,” as applicable. A Type-A package design must be marked with “TYPE-A.”
Type IP-2, Type IP-3, and Type-A packages must be marked with the international vehicle registration code of the country of origin of design. These packages must also be marked with the name of the manufacturer or other identification of the packaging identified by the competent authority of the country of origin and design.
Complete marking details for radioactive materials by sea can be found in the International Maritime Dangerous Goods (IMDG) Code Section 5.2.1.5.
Excepted packages of radioactive materials must be marked according to the IMDG Code Section 5.1.5.4.
Classification of radioactive materials, transport index (TI), and criticality safety index (CSI)
Details on the classification of radioactive materials can be referenced in the International Maritime Dangerous Goods (IMDG) Code, Chapter 2.7, Classification.
Details on determining the transport index (TI) and criticality safety index (CSI) can be found in the IMDG Code Section 5.1.5.3.
Fissile materials
Specific provisions for the consignment of fissile materials are referenced in the IMDG Code Section 5.1.5.5.
Package approvals for radioactive materials
See the IMDG Code Section 4.1.9. for special packing provisions for radioactive materials. This section covers excepted packages; Type IP-1, IP-2, and IP-3 packages; and Type A, B(U), B(M), and C packages. Fissile material packages and packages containing uranium hexafluoride are subject to additional requirements.
Before packages are used for radioactive materials, it must be confirmed that they meet the manufacturing and design standards.
Additionally, IMDG Code Chapter 6.4 covers the details on the construction, testing, and approval of packages for radioactive material and for the approval of such material.
The International Maritime Dangerous Goods (IMDG) Code was developed by the International Maritime Organization (IMO) to enhance and harmonize the safe carriage of dangerous goods in international waters. The IMO also developed the IMDG Code as a way to help prevent pollution to the environment.
The IMDG Code is based on the UN Model Regulations, but also includes additional requirements applicable to the maritime transport of dangerous goods (such as requirements for marine pollutants, freight container loading procedures, stowage and segregation, and other requirements applicable to shipboard safety and preservation of the marine environment) that are not covered by the UN Model Regulations.
The provisions of the IMDG Code are applicable to anyone shipping or transporting dangerous goods by vessel in international waters. Anyone shipping or transporting dangerous goods by vessel within U.S. waters has the choice to follow the IMDG Code or the 49 CFR Hazardous Materials Regulations as the Pipeline and Hazardous Materials Safety Administration (PHMSA) allows the use of the IMDG Code for transportation by vessel. In cases when it is unknown if the shipment will transit through international waters, it’s recommended to follow the provisions of the IMDG Code.
All aspects of the shipping process, such as packaging, marking, and labeling, are determined by how a dangerous good is classified. This makes the classification process the single most important step when shipping dangerous goods. This is also the reason the International Maritime Dangerous Goods (IMDG) Code requires shippers to classify dangerous goods before they can be offered for shipment.
Some dangerous goods are easy to classify because the material and their hazard(s) are well known. For example, gasoline is a well-known flammable liquid. Other materials, such as mixtures or new products, may be difficult to classify because the hazards are unknown. In this case you must have the material tested to determine the hazardous properties.
The IMDG Code also requires shippers to identify if the dangerous goods are a marine pollutant.
Dangerous goods must meet one or more of the hazard class definitions. There are nine hazard classes listed in the International Maritime Dangerous Goods (IMDG) Code — some of which are further subdivided into divisions. The definitions summarized below should be used as guidelines only.
Complete specifications for each hazard class and division can be found in Chapter 2 of the IMDG Code.
Some dangerous goods are further subdivided into packing groups. The packing group indicates the degree of danger presented by the dangerous goods.
Packing groups have been developed for dangerous goods in Class 3, Class 4, Division 5.1, Division 6.1 and Class 8 materials. Some hazardous materials are assigned more than one packing group. Because packing groups impact the type of packaging that can be used, it is critical that each material is assigned to the correct one. The criteria for determining packing groups are included in the IMDG Code as follows:
Some substances in Class 9, liquids in Division 5.1, and waste in Division 6.2 have been assigned packing groups according to the Dangerous Goods List in IMDG Code Chapter 3.2. Requirements for a specific packaging performance level can be found in the applicable packing instruction.
Marine pollutants
The IMDG Code requires shippers to also classify dangerous goods as a marine pollutant if:
UN numbers and proper shipping names
Once the hazard class and packing group have been determined, the shipper must select an appropriate UN number and proper shipping name from the Dangerous Goods List in Chapter 3.2. If the dangerous good is listed by name, that name must be used. If the dangerous good is not listed by name a generic or not otherwise specified (n.o.s.) name must be used.
Occasionally, there will be situations when dangerous goods meet the definition of more than one hazard class, and it’s not specifically listed by name in the Dangerous Goods List. In this case, you must determine which of the hazard classes will be the primary hazard. Typically, the hazard class that poses the greater hazard during transport would take precedence and become the primary hazard.
The hazard classes listed below in order take precedence:
Hazard classes not listed above must be classed according to the precedence of hazard table located in Chapter 2.0.3.
The International Maritime Dangerous Goods (IMDG) Code has provisions which allow a shipper to classify and ship unknown dangerous goods to a laboratory for analysis. The samples of unknown dangerous goods may be classified by the shipper and assigned a tentative shipping description, based on the:
Proper shipping name
When shipping samples of unknown dangerous goods the shipper must include the word “sample” in conjunction with the proper shipping name, for example:
When a “not otherwise specified” (n.o.s.) entry is used for the sample, the proper shipping name does not need to include the technical name.
The most severe packing group possible must be used for the selected proper shipping name.
Limitations
Samples using the exception must not be:
Self-reactive substances and organic peroxides samples must meet the conditions in sections 2.4.2.3.2.4.2 and 2.5.3.2.5.1, respectively.
All samples must be transported in combination packaging with a net weight not exceeding 2.5 kgs and not packed with any other goods.
Dangerous goods must meet one or more of the hazard class definitions. There are nine hazard classes listed in the International Maritime Dangerous Goods (IMDG) Code — some of which are further subdivided into divisions. The definitions summarized below should be used as guidelines only.
Complete specifications for each hazard class and division can be found in Chapter 2 of the IMDG Code.
Some dangerous goods are further subdivided into packing groups. The packing group indicates the degree of danger presented by the dangerous goods.
Packing groups have been developed for dangerous goods in Class 3, Class 4, Division 5.1, Division 6.1 and Class 8 materials. Some hazardous materials are assigned more than one packing group. Because packing groups impact the type of packaging that can be used, it is critical that each material is assigned to the correct one. The criteria for determining packing groups are included in the IMDG Code as follows:
Some substances in Class 9, liquids in Division 5.1, and waste in Division 6.2 have been assigned packing groups according to the Dangerous Goods List in IMDG Code Chapter 3.2. Requirements for a specific packaging performance level can be found in the applicable packing instruction.
Marine pollutants
The IMDG Code requires shippers to also classify dangerous goods as a marine pollutant if:
UN numbers and proper shipping names
Once the hazard class and packing group have been determined, the shipper must select an appropriate UN number and proper shipping name from the Dangerous Goods List in Chapter 3.2. If the dangerous good is listed by name, that name must be used. If the dangerous good is not listed by name a generic or not otherwise specified (n.o.s.) name must be used.
Occasionally, there will be situations when dangerous goods meet the definition of more than one hazard class, and it’s not specifically listed by name in the Dangerous Goods List. In this case, you must determine which of the hazard classes will be the primary hazard. Typically, the hazard class that poses the greater hazard during transport would take precedence and become the primary hazard.
The hazard classes listed below in order take precedence:
Hazard classes not listed above must be classed according to the precedence of hazard table located in Chapter 2.0.3.
The International Maritime Dangerous Goods (IMDG) Code has provisions which allow a shipper to classify and ship unknown dangerous goods to a laboratory for analysis. The samples of unknown dangerous goods may be classified by the shipper and assigned a tentative shipping description, based on the:
Proper shipping name
When shipping samples of unknown dangerous goods the shipper must include the word “sample” in conjunction with the proper shipping name, for example:
When a “not otherwise specified” (n.o.s.) entry is used for the sample, the proper shipping name does not need to include the technical name.
The most severe packing group possible must be used for the selected proper shipping name.
Limitations
Samples using the exception must not be:
Self-reactive substances and organic peroxides samples must meet the conditions in sections 2.4.2.3.2.4.2 and 2.5.3.2.5.1, respectively.
All samples must be transported in combination packaging with a net weight not exceeding 2.5 kgs and not packed with any other goods.
The International Maritime Dangerous Goods (IMDG) Code is an international code for transport of dangerous goods by sea, intended to promote the safe carriage of dangerous goods and prevent pollution to the environment.
The code details requirements that apply to individual substances, materials, and articles, and covers packing, container traffic, and stowage, with particular attention paid to the segregation of incompatible substances.
The Dangerous Goods List in Part 3 comprises the core of the code, and provides packing, labeling, stowage, segregation, handling, and emergency response information for thousands of entries.
Scope of the Dangerous Goods List and general provisions
The Dangerous Goods List includes entries for the most commonly transported dangerous goods. Since it is impractical to include a separate entry for every existing chemical substance or article, the List also includes generic or “not otherwise specified” (n.o.s.) names for various mixtures and solutions (for example, FLAMMABLE LIQUID, N.O.S., UN 1993). This way, the List provides an appropriate name or entry for any dangerous good that may be transported.
When a dangerous good is specifically listed by name, it must be transported according to the requirements for that entry in the List. To use a generic or n.o.s. entry to transport substances, materials, or articles that do not appear specifically by name follow these steps:
A generic or n.o.s. name may only be used when:
The classification must be made by the shipper/consignor, or by the appropriate competent authority in some cases.
Once the class of the dangerous good is established, all conditions for transport must be met. Any dangerous good with explosive characteristics must first be considered for inclusion in Class 1.
Inherent instability in goods may take different dangerous forms, including:
Because of this potential for instability, the Dangerous Goods List prohibits certain dangerous goods, or dangerous goods in a specific form, concentration, or state, from transport by sea. These prohibited goods are not suitable for transport by sea under normal conditions of transport. In some cases, the inherent instability can be controlled by suitable packaging, dilution, stabilization, addition of an inhibitor, temperature control, or other measures to make transport by sea possible.
Precautionary measures required
If precautionary measures are shown in the Dangerous Goods List for a dangerous good (for example, that it must be stabilized or diluted), that dangerous good may not be transported without taking those measures. Exceptions to this may exist if the item in question is listed elsewhere (such as in class 1) without any indication of precautionary measures, or with different measures indicated.
Polymerization and dangerous reactions
Certain substances can polymerize or otherwise react in a dangerous manner under certain conditions of temperature or in contact with a catalyst. To mitigate this tendency:
Unless these products are sufficiently stabilized to prevent any dangerous reaction during the voyage, transport of the products is prohibited.
The proper shipping names of dangerous goods are listed in the Dangerous Goods List. The index to the List includes synonyms, secondary names, initials, abbreviations of names, etc., in alphabetical order, to facilitate the search for the proper shipping name.
The proper shipping name is the part of the entry that accurately describes the goods in the Dangerous Goods List. It is shown in upper-case characters along with other numbers or letters that are an integral part of the name. An alternative proper shipping name may be shown in brackets following the main proper shipping name.
Only the most appropriate proper shipping name must be shown in the transport document and package marks when:
Proper shipping names may be used in the singular or plural as appropriate.
Commercial or military names for goods of class 1 that contain the proper shipping name supplemented by additional text may be used.
Many substances have an entry for both the liquid and solid state or for the solid and solution. These are given separate UN numbers that are not necessarily adjacent to each other. Details can be found in the alphabetical index to the List.
If it is not already included in the proper shipping name, the word “MOLTEN” must be added when a substance that is solid is offered for transport in the molten state. Also check requirements for elevated temperature substances in 5.4.1.4.3.4.
Note that special requirements apply to proper shipping names for:
Except for self-reactive substances and organic peroxides, and unless it is already included in capital letters in the proper shipping name shown in the Dangerous Goods List, the word “STABILIZED” must be added to the proper shipping name of any substance that, without stabilization, would be forbidden from transport due to its potential to dangerously react under conditions normally encountered in transport (for example, TOXIC LIQUID, ORGANIC, N.O.S., STABILIZED).
When temperature control is used to stabilize these substances to prevent development of dangerous excess pressure or evolution of excessive heat, or when chemical stabilization is used in combination with temperature control, then:
Hydrates may be transported using the proper shipping name for the anhydrous substance.
Generic and “not otherwise specified” (n.o.s.) proper shipping names that are subject to special provision 274 or 318 in column 6 of the Dangerous Goods List must be supplemented with the technical or chemical group names. This does not apply if:
For explosives of class 1, descriptive text may be added to the proper shipping name to indicate commercial or military names. Technical and chemical group names must be entered in brackets immediately following the proper shipping name.
The technical name must be:
Trade names must not be used for this purpose. For pesticides, use only:
When mixtures or articles containing dangerous goods are described by one of the n.o.s. or generic entries subject to special provision 274, not more than the two constituents that most predominantly contribute to the hazard or hazards need to be shown. This requirement does not apply to controlled substances when their disclosure is prohibited by national law or international convention.
If a package containing a mixture is labeled with any subsidiary hazard label, one of the two technical names shown in brackets must be the name of the constituent that compels the use of the subsidiary hazard label.
For proper documentation for n.o.s. entries classified as marine pollutants, the recognized chemical name of the constituent that most predominantly contributes to the classification as marine pollutant must be added to the proper shipping name. Exceptions to this are found in special provision 274.
If a substance is specifically listed by name in the Dangerous Goods List, it must be identified in transport by the proper shipping name in the List. A substance listed by name that contains technical impurities or additives for stability or other purposes that affect its classification must be considered a mixture or solution.
A mixture or solution is not subject to the International Maritime Dangerous Goods (IMDG) Code if the characteristics, properties, form, or physical state of the mixture or solution are such that it does not meet the criteria for inclusion in any class.
If a mixture or solution meets the classification criteria of a single predominant substance identified by name in the List and has one or more substances not subject to the provisions of this Code and/or traces of one or more substances identified by name in the List, then assign the UN number and proper shipping name of the predominant substance named in the List.
This requirement does not apply if:
Qualifying words such as “MIXTURE” or “SOLUTION,” as appropriate, must be added as part of the proper shipping name. The concentration of the mixture or solution may also be indicated after the basic description.
For a mixture or solution composed of two or more dangerous goods, use the entry that most precisely describes the mixture or solution.
Dangerous goods with similar chemical properties are grouped together in segregation groups. Some substances, mixtures, solutions, or preparations falling within a segregation group are not listed in the International Maritime Dangerous Goods (IMDG) Code by name, but are shipped under n.o.s. entries. Although n.o.s. entries are not listed in the segregation groups, the consignor must decide whether including them under the segregation group is appropriate and, if so, must note that fact in the transport document.
The segregation groups in the IMDG Code do not cover substances that fall outside the classification criteria of the Code. Some non-hazardous substances have similar chemical properties as substances listed in the segregation groups. If the consignor or the person responsible for packing the goods into a cargo transport unit has knowledge of the chemical properties of those non-dangerous goods, they may voluntarily use the segregation provisions of a related segregation group.
The segregation groups are identified in the IMDG Code Section 3.1.4, and include:
The Dangerous Goods List is found in the International Maritime Dangerous Goods (IMDG) Code Chapter 3.2. The List is divided into 18 columns. Each column includes a reference to the appropriate section in the IMDG Code that provides additional information for that requirement.
Special provisions
When column 6 of the Dangerous Goods List indicates that a special provision applies to a dangerous good, the requirements of that special provision are listed in numerical order amid nearly a thousand entries in Chapter 3.3 of the Code.
If a special provision includes a requirement for package marking, the provisions of section 5.2.1.2 must be met. If the required mark is specific wording in quotation marks, the size of the mark must be at least 12 mm, unless otherwise indicated in the special provision or elsewhere in the Code.
The International Maritime Dangerous Goods (IMDG) Code Chapter 3.4 details the conditions that apply to transport of dangerous goods of certain classes packed in limited quantities. Dangerous goods that are packed in limited quantities and meet the requirements in this chapter are subject to reduced requirements.
For each substance in the Dangerous Goods List, the quantity limit for the inner packaging or article is specified in column 7a. The quantity “0” in this column indicates that the entry is not permitted to be transported under the provisions for limited quantities.
Limited quantities: Packing
Dangerous goods must be packed only in inner packagings that are placed in suitable outer packagings. Intermediate packagings may be used. Additional requirements apply to articles of division 1.4, compatibility group S. The use of inner packagings is not necessary for transport of certain articles containing aerosols or gas.
In some cases, shrink-wrapped or stretch-wrapped trays are acceptable as outer packagings for articles or inner packagings containing dangerous goods. Inner packagings that could break or be easily punctured, such as those made of glass, porcelain, stoneware or certain plastics, must be placed in suitable intermediate packagings, and must be designed to meet the construction requirements of the IMDG Code Section 6.1.4. The total gross mass of the package may not exceed 20 kg.
Liquid goods of class 8, packing group II in glass, porcelain, or stoneware inner packagings must be enclosed in a compatible and rigid intermediate packaging.
Limited quantities: Stowage
Dangerous goods packed in limited quantity are allocated stowage category A, which is defined in the IMDG Code Section 7.1.3.2. The other stowage provisions indicated in column 16a of the Dangerous Goods List do not apply.
Limited quantities: Segregation
Different dangerous substances in limited quantities may be packed in the same outer packaging, only if:
The segregation provisions of the IMDG Code Chapter 7.2 to 7.7 and the segregation provisions in column 16b of the Dangerous Goods List do not apply for packagings containing dangerous goods in limited quantities or in relation to other dangerous goods. However, articles of division 1.4, compatibility group S must not be stowed in the same compartment, hold, or cargo transport unit with dangerous goods of class 1 of compatibility groups A and L.
Limited quantities: Marking and placarding
Packages containing dangerous goods in limited quantities must bear the mark detailed in the IMDG Code Section 3.4.5.
The minimum dimension per side is 100 mm.
Packages of dangerous goods packed according to Part 3, Chapter 4 of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air may bear a “Y” in the center of the mark to certify conformity with the provisions (minimum 100 mm per side).
The mark must be:
The top and bottom portions and the surrounding line must be black. The center area must be white or a suitable contrasting background. Minimum dimensions apply, and all features must be in proportion. If the size of the package necessitates, the outer dimensions may be reduced to not less than 50 mm × 50 mm as long as the mark remains clearly visible.
Limited quantities: Multimodal recognition of marks
Packages containing dangerous goods bearing the “Y” mark for transport by air, with or without the additional labels and marks for air transport, meet the marking requirements and need not bear the mark without the “Y”.
Packages containing dangerous goods in limited quantities bearing the limited quantities mark and conforming with the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, including all necessary marks and labels specified in parts 5 and 6, meet the IMDG Code requirements for limited quantities.
When packages containing dangerous goods packed in limited quantities are placed in an overpack or in a unit load, the overpack or the unit load must be marked with the limited quantity mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. In addition, an overpack must be marked with the word “OVERPACK” unless required marks representative of all dangerous goods in the overpack are visible. The lettering of the “OVERPACK” mark must be at least 12 mm high. Other provisions for overpacks and unit loads apply if other dangerous goods not packed in limited quantities are contained in the overpack or in a unit load.
Limited quantities: Placarding and marking of cargo transport units
Cargo transport units containing dangerous goods packed in limited quantities with no other dangerous goods must not be placarded nor marked according to the marking requirements for dangerous goods. Instead, they must be marked on the exterior with the mark in the IMDG Code Section 3.4.5.5.4.
Cargo transport units containing dangerous goods and dangerous goods packed in limited quantities must be placarded and marked according to the provisions that apply to the dangerous goods that are not packed in limited quantities. However, if no placard or mark is required for the dangerous goods not packed in limited quantities, the cargo transport units must be marked with the mark in IMDG Code Section 3.4.5.5.4.
The mark must be readily visible, legible, and still be identifiable on cargo transport units surviving at least three months’ immersion in the sea. The mark must be at least 250 mm × 250 mm and displayed in locations specified in IMDG Code Section 5.3.1.1.4.1.
Limited quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “limited quantity” or “LTD QTY” must be included on the dangerous goods transport document, along with the description of the shipment
Excepted quantities of certain dangerous goods that meet the provisions of the International Maritime Dangerous Goods (IMDG) Code Chapter 3.5 are subject to reduced requirements.
For radioactive material, the provisions for excepted packages are found in IMDG Code Section 1.5.1.5.
Dangerous goods that may be carried as excepted quantities are indicated in column 7b of the Dangerous Goods List. The code in column 7b indicates the maximum net quantity allowed for the inner and outer packaging.
Excepted quantities: Packagings
Packagings used to transport dangerous goods in excepted quantities must comply with certain conditions.
There must be an inner packaging and each inner packaging must meet construction requirements detailed in IMDG Code Section 3.5.2. The closure of each inner packaging must be held securely in place by positive means. If a receptacle has a neck with screw threads, it must also have a leakproof threaded cap. The entire closure must be resistant to the contents.
Each inner packaging must be securely packed in intermediate packaging with cushioning material so that they cannot break, be punctured, or leak the contents under normal conditions of transport.
For liquids, the intermediate or outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packagings. The absorbent material may also serve as the cushioning material. Dangerous goods must not react dangerously with or reduce the integrity of the packaging materials. Regardless of its orientation, the package must completely contain the contents in the event of breakage or leakage.
The intermediate packaging must be securely packed in a strong, rigid outer packaging.
Each package must be large enough to apply all necessary marks.
Overpacks may be used and may also contain packages of dangerous goods or goods not subject to the IMDG Code.
Excepted quantities: Tests for packagings
The complete package as prepared for transport must be capable of withstanding the tests detailed in IMDG Code Section 3.5.3 without breaking or leaking and without a reduction in effectiveness. The testing must be appropriately documented.
Excepted quantities: Marking
Packages containing excepted quantities of dangerous goods must be marked with the mark shown in IMDG Code Section 3.5.4. The primary hazard class of each of the dangerous goods contained in the package must be shown in the mark. If the name of the consignor or consignee is not shown elsewhere on the package, this information must be included within the mark.
* The class or division number(s) must be shown in this location.
** The name of the consignor or of the consignee must be shown in this location if it does not appear elsewhere on the package.
The mark must be a square with the border hatching and symbol in black or red, on white or suitable contrasting background. The minimum dimensions are 100 mm × 100 mm. If dimensions are not specified for a feature, it must be in approximate proportion to those shown.
Overpacks and the unit loads containing excepted quantities must be marked with the excepted quantities mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. Overpacks must also be marked with the word “OVERPACK” unless marks representative of all dangerous goods in the overpack are visible.
Excepted quantities: Maximum per transport unit
A maximum of 1,000 packages containing dangerous goods packed in excepted quantities may be carried in any cargo transport unit.
Excepted quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “dangerous goods in excepted quantities” and the number of packages must be included on the dangerous goods transport document, along with the description of the shipment.
Excepted quantities: Stowage
Dangerous goods packed in excepted quantity are allocated stowage category A (defined in IMDG Code Section 7.1.3.2). The stowage provisions in column 16a of the Dangerous Goods List do not apply.
Excepted quantities: Segregation
The segregation requirements of IMDG Code Chapter 7.2 to 7.7 do not apply for:
Appendices
Appendix A to Part 3 of the IMDG Code contains the list of generic and n.o.s. proper shipping names. The name in the Dangerous Goods List that most appropriately describes the substance or article must be used as the proper shipping name. The main generic entries and all the n.o.s. entries given in the Dangerous Goods List appear in Appendix A.
General and n.o.s. names are grouped according to their hazard class or division. Within each hazard class or division, the names are in one of three groups, including:
Appendix B contains a glossary of terms applicable to Part 3 of the IMDG Code.
Inherent instability in goods may take different dangerous forms, including:
Because of this potential for instability, the Dangerous Goods List prohibits certain dangerous goods, or dangerous goods in a specific form, concentration, or state, from transport by sea. These prohibited goods are not suitable for transport by sea under normal conditions of transport. In some cases, the inherent instability can be controlled by suitable packaging, dilution, stabilization, addition of an inhibitor, temperature control, or other measures to make transport by sea possible.
Precautionary measures required
If precautionary measures are shown in the Dangerous Goods List for a dangerous good (for example, that it must be stabilized or diluted), that dangerous good may not be transported without taking those measures. Exceptions to this may exist if the item in question is listed elsewhere (such as in class 1) without any indication of precautionary measures, or with different measures indicated.
Polymerization and dangerous reactions
Certain substances can polymerize or otherwise react in a dangerous manner under certain conditions of temperature or in contact with a catalyst. To mitigate this tendency:
Unless these products are sufficiently stabilized to prevent any dangerous reaction during the voyage, transport of the products is prohibited.
The proper shipping names of dangerous goods are listed in the Dangerous Goods List. The index to the List includes synonyms, secondary names, initials, abbreviations of names, etc., in alphabetical order, to facilitate the search for the proper shipping name.
The proper shipping name is the part of the entry that accurately describes the goods in the Dangerous Goods List. It is shown in upper-case characters along with other numbers or letters that are an integral part of the name. An alternative proper shipping name may be shown in brackets following the main proper shipping name.
Only the most appropriate proper shipping name must be shown in the transport document and package marks when:
Proper shipping names may be used in the singular or plural as appropriate.
Commercial or military names for goods of class 1 that contain the proper shipping name supplemented by additional text may be used.
Many substances have an entry for both the liquid and solid state or for the solid and solution. These are given separate UN numbers that are not necessarily adjacent to each other. Details can be found in the alphabetical index to the List.
If it is not already included in the proper shipping name, the word “MOLTEN” must be added when a substance that is solid is offered for transport in the molten state. Also check requirements for elevated temperature substances in 5.4.1.4.3.4.
Note that special requirements apply to proper shipping names for:
Except for self-reactive substances and organic peroxides, and unless it is already included in capital letters in the proper shipping name shown in the Dangerous Goods List, the word “STABILIZED” must be added to the proper shipping name of any substance that, without stabilization, would be forbidden from transport due to its potential to dangerously react under conditions normally encountered in transport (for example, TOXIC LIQUID, ORGANIC, N.O.S., STABILIZED).
When temperature control is used to stabilize these substances to prevent development of dangerous excess pressure or evolution of excessive heat, or when chemical stabilization is used in combination with temperature control, then:
Hydrates may be transported using the proper shipping name for the anhydrous substance.
Generic and “not otherwise specified” (n.o.s.) proper shipping names that are subject to special provision 274 or 318 in column 6 of the Dangerous Goods List must be supplemented with the technical or chemical group names. This does not apply if:
For explosives of class 1, descriptive text may be added to the proper shipping name to indicate commercial or military names. Technical and chemical group names must be entered in brackets immediately following the proper shipping name.
The technical name must be:
Trade names must not be used for this purpose. For pesticides, use only:
When mixtures or articles containing dangerous goods are described by one of the n.o.s. or generic entries subject to special provision 274, not more than the two constituents that most predominantly contribute to the hazard or hazards need to be shown. This requirement does not apply to controlled substances when their disclosure is prohibited by national law or international convention.
If a package containing a mixture is labeled with any subsidiary hazard label, one of the two technical names shown in brackets must be the name of the constituent that compels the use of the subsidiary hazard label.
For proper documentation for n.o.s. entries classified as marine pollutants, the recognized chemical name of the constituent that most predominantly contributes to the classification as marine pollutant must be added to the proper shipping name. Exceptions to this are found in special provision 274.
If a substance is specifically listed by name in the Dangerous Goods List, it must be identified in transport by the proper shipping name in the List. A substance listed by name that contains technical impurities or additives for stability or other purposes that affect its classification must be considered a mixture or solution.
A mixture or solution is not subject to the International Maritime Dangerous Goods (IMDG) Code if the characteristics, properties, form, or physical state of the mixture or solution are such that it does not meet the criteria for inclusion in any class.
If a mixture or solution meets the classification criteria of a single predominant substance identified by name in the List and has one or more substances not subject to the provisions of this Code and/or traces of one or more substances identified by name in the List, then assign the UN number and proper shipping name of the predominant substance named in the List.
This requirement does not apply if:
Qualifying words such as “MIXTURE” or “SOLUTION,” as appropriate, must be added as part of the proper shipping name. The concentration of the mixture or solution may also be indicated after the basic description.
For a mixture or solution composed of two or more dangerous goods, use the entry that most precisely describes the mixture or solution.
Dangerous goods with similar chemical properties are grouped together in segregation groups. Some substances, mixtures, solutions, or preparations falling within a segregation group are not listed in the International Maritime Dangerous Goods (IMDG) Code by name, but are shipped under n.o.s. entries. Although n.o.s. entries are not listed in the segregation groups, the consignor must decide whether including them under the segregation group is appropriate and, if so, must note that fact in the transport document.
The segregation groups in the IMDG Code do not cover substances that fall outside the classification criteria of the Code. Some non-hazardous substances have similar chemical properties as substances listed in the segregation groups. If the consignor or the person responsible for packing the goods into a cargo transport unit has knowledge of the chemical properties of those non-dangerous goods, they may voluntarily use the segregation provisions of a related segregation group.
The segregation groups are identified in the IMDG Code Section 3.1.4, and include:
The Dangerous Goods List is found in the International Maritime Dangerous Goods (IMDG) Code Chapter 3.2. The List is divided into 18 columns. Each column includes a reference to the appropriate section in the IMDG Code that provides additional information for that requirement.
Special provisions
When column 6 of the Dangerous Goods List indicates that a special provision applies to a dangerous good, the requirements of that special provision are listed in numerical order amid nearly a thousand entries in Chapter 3.3 of the Code.
If a special provision includes a requirement for package marking, the provisions of section 5.2.1.2 must be met. If the required mark is specific wording in quotation marks, the size of the mark must be at least 12 mm, unless otherwise indicated in the special provision or elsewhere in the Code.
The International Maritime Dangerous Goods (IMDG) Code Chapter 3.4 details the conditions that apply to transport of dangerous goods of certain classes packed in limited quantities. Dangerous goods that are packed in limited quantities and meet the requirements in this chapter are subject to reduced requirements.
For each substance in the Dangerous Goods List, the quantity limit for the inner packaging or article is specified in column 7a. The quantity “0” in this column indicates that the entry is not permitted to be transported under the provisions for limited quantities.
Limited quantities: Packing
Dangerous goods must be packed only in inner packagings that are placed in suitable outer packagings. Intermediate packagings may be used. Additional requirements apply to articles of division 1.4, compatibility group S. The use of inner packagings is not necessary for transport of certain articles containing aerosols or gas.
In some cases, shrink-wrapped or stretch-wrapped trays are acceptable as outer packagings for articles or inner packagings containing dangerous goods. Inner packagings that could break or be easily punctured, such as those made of glass, porcelain, stoneware or certain plastics, must be placed in suitable intermediate packagings, and must be designed to meet the construction requirements of the IMDG Code Section 6.1.4. The total gross mass of the package may not exceed 20 kg.
Liquid goods of class 8, packing group II in glass, porcelain, or stoneware inner packagings must be enclosed in a compatible and rigid intermediate packaging.
Limited quantities: Stowage
Dangerous goods packed in limited quantity are allocated stowage category A, which is defined in the IMDG Code Section 7.1.3.2. The other stowage provisions indicated in column 16a of the Dangerous Goods List do not apply.
Limited quantities: Segregation
Different dangerous substances in limited quantities may be packed in the same outer packaging, only if:
The segregation provisions of the IMDG Code Chapter 7.2 to 7.7 and the segregation provisions in column 16b of the Dangerous Goods List do not apply for packagings containing dangerous goods in limited quantities or in relation to other dangerous goods. However, articles of division 1.4, compatibility group S must not be stowed in the same compartment, hold, or cargo transport unit with dangerous goods of class 1 of compatibility groups A and L.
Limited quantities: Marking and placarding
Packages containing dangerous goods in limited quantities must bear the mark detailed in the IMDG Code Section 3.4.5.
The minimum dimension per side is 100 mm.
Packages of dangerous goods packed according to Part 3, Chapter 4 of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air may bear a “Y” in the center of the mark to certify conformity with the provisions (minimum 100 mm per side).
The mark must be:
The top and bottom portions and the surrounding line must be black. The center area must be white or a suitable contrasting background. Minimum dimensions apply, and all features must be in proportion. If the size of the package necessitates, the outer dimensions may be reduced to not less than 50 mm × 50 mm as long as the mark remains clearly visible.
Limited quantities: Multimodal recognition of marks
Packages containing dangerous goods bearing the “Y” mark for transport by air, with or without the additional labels and marks for air transport, meet the marking requirements and need not bear the mark without the “Y”.
Packages containing dangerous goods in limited quantities bearing the limited quantities mark and conforming with the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, including all necessary marks and labels specified in parts 5 and 6, meet the IMDG Code requirements for limited quantities.
When packages containing dangerous goods packed in limited quantities are placed in an overpack or in a unit load, the overpack or the unit load must be marked with the limited quantity mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. In addition, an overpack must be marked with the word “OVERPACK” unless required marks representative of all dangerous goods in the overpack are visible. The lettering of the “OVERPACK” mark must be at least 12 mm high. Other provisions for overpacks and unit loads apply if other dangerous goods not packed in limited quantities are contained in the overpack or in a unit load.
Limited quantities: Placarding and marking of cargo transport units
Cargo transport units containing dangerous goods packed in limited quantities with no other dangerous goods must not be placarded nor marked according to the marking requirements for dangerous goods. Instead, they must be marked on the exterior with the mark in the IMDG Code Section 3.4.5.5.4.
Cargo transport units containing dangerous goods and dangerous goods packed in limited quantities must be placarded and marked according to the provisions that apply to the dangerous goods that are not packed in limited quantities. However, if no placard or mark is required for the dangerous goods not packed in limited quantities, the cargo transport units must be marked with the mark in IMDG Code Section 3.4.5.5.4.
The mark must be readily visible, legible, and still be identifiable on cargo transport units surviving at least three months’ immersion in the sea. The mark must be at least 250 mm × 250 mm and displayed in locations specified in IMDG Code Section 5.3.1.1.4.1.
Limited quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “limited quantity” or “LTD QTY” must be included on the dangerous goods transport document, along with the description of the shipment
Excepted quantities of certain dangerous goods that meet the provisions of the International Maritime Dangerous Goods (IMDG) Code Chapter 3.5 are subject to reduced requirements.
For radioactive material, the provisions for excepted packages are found in IMDG Code Section 1.5.1.5.
Dangerous goods that may be carried as excepted quantities are indicated in column 7b of the Dangerous Goods List. The code in column 7b indicates the maximum net quantity allowed for the inner and outer packaging.
Excepted quantities: Packagings
Packagings used to transport dangerous goods in excepted quantities must comply with certain conditions.
There must be an inner packaging and each inner packaging must meet construction requirements detailed in IMDG Code Section 3.5.2. The closure of each inner packaging must be held securely in place by positive means. If a receptacle has a neck with screw threads, it must also have a leakproof threaded cap. The entire closure must be resistant to the contents.
Each inner packaging must be securely packed in intermediate packaging with cushioning material so that they cannot break, be punctured, or leak the contents under normal conditions of transport.
For liquids, the intermediate or outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packagings. The absorbent material may also serve as the cushioning material. Dangerous goods must not react dangerously with or reduce the integrity of the packaging materials. Regardless of its orientation, the package must completely contain the contents in the event of breakage or leakage.
The intermediate packaging must be securely packed in a strong, rigid outer packaging.
Each package must be large enough to apply all necessary marks.
Overpacks may be used and may also contain packages of dangerous goods or goods not subject to the IMDG Code.
Excepted quantities: Tests for packagings
The complete package as prepared for transport must be capable of withstanding the tests detailed in IMDG Code Section 3.5.3 without breaking or leaking and without a reduction in effectiveness. The testing must be appropriately documented.
Excepted quantities: Marking
Packages containing excepted quantities of dangerous goods must be marked with the mark shown in IMDG Code Section 3.5.4. The primary hazard class of each of the dangerous goods contained in the package must be shown in the mark. If the name of the consignor or consignee is not shown elsewhere on the package, this information must be included within the mark.
* The class or division number(s) must be shown in this location.
** The name of the consignor or of the consignee must be shown in this location if it does not appear elsewhere on the package.
The mark must be a square with the border hatching and symbol in black or red, on white or suitable contrasting background. The minimum dimensions are 100 mm × 100 mm. If dimensions are not specified for a feature, it must be in approximate proportion to those shown.
Overpacks and the unit loads containing excepted quantities must be marked with the excepted quantities mark unless the marks representative of all dangerous goods in the overpack or the unit load are visible. Overpacks must also be marked with the word “OVERPACK” unless marks representative of all dangerous goods in the overpack are visible.
Excepted quantities: Maximum per transport unit
A maximum of 1,000 packages containing dangerous goods packed in excepted quantities may be carried in any cargo transport unit.
Excepted quantities: Documentation
In addition to the documentation requirements in chapter 5.4, the words “dangerous goods in excepted quantities” and the number of packages must be included on the dangerous goods transport document, along with the description of the shipment.
Excepted quantities: Stowage
Dangerous goods packed in excepted quantity are allocated stowage category A (defined in IMDG Code Section 7.1.3.2). The stowage provisions in column 16a of the Dangerous Goods List do not apply.
Excepted quantities: Segregation
The segregation requirements of IMDG Code Chapter 7.2 to 7.7 do not apply for:
Appendices
Appendix A to Part 3 of the IMDG Code contains the list of generic and n.o.s. proper shipping names. The name in the Dangerous Goods List that most appropriately describes the substance or article must be used as the proper shipping name. The main generic entries and all the n.o.s. entries given in the Dangerous Goods List appear in Appendix A.
General and n.o.s. names are grouped according to their hazard class or division. Within each hazard class or division, the names are in one of three groups, including:
Appendix B contains a glossary of terms applicable to Part 3 of the IMDG Code.
A consignor offering dangerous goods for transport must provide the carrier with the information that applies to those dangerous goods. The information may be provided on a dangerous goods transport document or, with the agreement of the carrier, by electronic data processing (EDP) or electronic data interchange (EDI) techniques.
When EDP or EDI techniques are used, the consignor must be able to produce the paper document, without delay, with the information in the sequence required by the International Maritime Dangerous Goods (IMDG) Code.
Document format
A dangerous goods transport document may be in any form, provided it contains all information required by the IMDG Code. If both dangerous and non-dangerous goods are listed in one document, the dangerous goods must be listed first, or be emphasized by another method. The document may be more than one page, provided the pages are consecutively numbered. The information on the document must be easy to identify, legible, and durable.
The dangerous goods transport document must include:
Records retention
The consignor and the carrier must retain a copy of the dangerous goods transport document and additional information and documentation specified in the IMDG Code for a minimum period of three months. When the documents are kept electronically or in a computer system, the consignor and the carrier must be able to reproduce them in a printed form.
Information required on the dangerous goods transport document begins with the dangerous goods description.
For each dangerous substance, material, or article offered for transport, the document must provide:
The five elements of the dangerous goods description must be shown in the order listed above, with no information interspersed, except as allowed by the International Maritime Dangerous Goods (IMDG) Code. Unless permitted or required by the Code, additional information being included must be placed after the dangerous goods description.
The proper shipping name in the dangerous goods description must be supplemented with the following information, when appropriate:
In addition to the dangerous goods description, the following information must be included after the dangerous goods description on the transport document:
Consignor certification
The dangerous goods transport document must include a certification or declaration that the consignment is acceptable for transport and that the goods are properly packaged, marked, and labeled, and in proper condition for transport according to the applicable regulations. The certification must be signed and dated by the consignor.
If the documentation is presented to the carrier via electronic data processing (EDP) or electronic data interchange (EDI) transmission techniques, the signature may be electronic or may be replaced by the name (in capital letters) of the person authorized to sign.
When the dangerous goods transport information is given to a carrier by EDP or EDI techniques and subsequently the dangerous goods are transferred to a carrier that requires a paper dangerous goods transport document:
When dangerous goods are packed or loaded into a container or vehicle, those responsible for packing the container or vehicle must provide a “container/vehicle packing certificate.” The certificate must specify the container/vehicle identification number and certify that the operation has been carried out according to certain conditions, including that:
Note that the container/vehicle packing certificate is not required for portable tanks.
The information required in the dangerous goods transport document and the container/vehicle packing certificate may be incorporated into a single document; if not, these documents must be attached.
If the information is incorporated into a single document, the document must include a signed declaration indicating that the packing of the goods into the container/vehicle has been carried out in accordance with the applicable provisions. This declaration must be dated and the person signing it must be identified on the document.
If the certificate is presented to the carrier via EDP or EDI transmission techniques, the signature may be electronic or may be replaced by the name (in capital letters) of the person authorized to sign.
If the certificate is given to a carrier by EDP or EDI techniques and subsequently the dangerous goods are transferred to a carrier that requires a paper container/vehicle packing certificate, the carrier must ensure that:
Each ship carrying dangerous goods and marine pollutants must have a special list, manifest, or stowage plan setting out the dangerous goods (except dangerous goods in excepted packages of class 7) and marine pollutants and the location of those goods on the ship.
This special list or manifest must be based on the documentation and certification required in the International Maritime Dangerous Goods (IMDG) Code. In addition to the information in the dangerous goods transport documents, it must contain the stowage location and the total quantity of dangerous goods and marine pollutants.
A detailed stowage plan that identifies by class and sets out the location of all dangerous goods and marine pollutants may be used in place of a special list or manifest.
Each ship carrying excepted packages of class 7 must have a special list, manifest, or stowage plan setting out these excepted packages and their location.
A copy of the documents must be made available before departure to the person or organization designated by the port State authority.
For consignments of dangerous goods, appropriate information must be immediately available at all times for use in emergency response to accidents and incidents involving dangerous goods in transport. The information must be:
Methods to comply with this requirement include:
In certain circumstances, special certificates or other documents are required when offering dangerous goods for transport.
A weathering certificate is required in some individual entries of the Dangerous Goods List.
A certificate exempting a substance, material, or article from the provisions of the International Maritime Dangerous Goods (IMDG) Code must accompany the consignment. For examples, see the individual entries for charcoal, fish meal, and seed cake.
New self-reactive substances and organic peroxides, or new formulation of currently assigned self-reactive substances and organic peroxides, must include a statement of the approved classification and conditions of transport.
Multimodal dangerous goods form
The Multimodal Dangerous Goods Form found in the IMDG Code Section 5.4.5 meets the requirements of SOLAS, chapter VII, regulation 4; MARPOL, Annex III, regulation 4; and the IMDG Code provisions for documentation.
The information required by the documentation provisions of the Code is mandatory, however, the layout of the form is not mandatory.
This form may be used as a combined dangerous goods transport document and container/vehicle packing certificate for multimodal carriage of dangerous goods.
Information required on the dangerous goods transport document begins with the dangerous goods description.
For each dangerous substance, material, or article offered for transport, the document must provide:
The five elements of the dangerous goods description must be shown in the order listed above, with no information interspersed, except as allowed by the International Maritime Dangerous Goods (IMDG) Code. Unless permitted or required by the Code, additional information being included must be placed after the dangerous goods description.