As years go by, serious incidents caused by or involving dangerous goods continue to occur, not only on ships but also in ports.
Errors, misunderstandings, misdeclarations and inadequate packing and securing lie at the heart of many incidents. As ultra-large container ships and the marine terminals they call at increase in size and capacity, the potential for economic, human and environmental accidents rise in proportion.
The guide has provided an overview on the key provisions and considerations of the IMDG Code when shipping dangerous goods by sea, and provides guidance if common errors are to be avoided.
Much depends on the skill and awareness of the personnel packing the shipping containers – skills that are often under-rated and under-valued. Any person or organisation offering dangerous goods or packing cargo transport units that do not comply with the IMDG Code, or follow the guidance provided in the CTU Code, is in a precarious position if that non-compliance leads to an incident.
It can put lives at risk, and lead to property and environmental damage. The party responsible will be liable to prosecution, fines by national maritime enforcement agencies and to civil court actions to compensate other actors for costs incurred arising from damage to the ship, cargo and environment, injury and loss of earnings, etc.
IMDG Code training for shore-based personnel
Depending on their role, your staff may be required to understand the following:
- The legal responsibility to identify dangerous goods accurately
- Where to locate required information in the IMDG Code
- How to identify different classes of dangerous goods
- How dangerous goods data should be presented on a transport document and what that data means
- How packages should be marked and labelled
- How to make up, mark and label dangerous goods in palletised unit loads
- The IMDG Code segregation rules for the separating of dangerous goods that have the potential to react with each other
- How to stow and secure packages of different types and sizes in cargo transport units so the packages will not slide, roll or collapse under the weight of over-stowed cargo during the sea journey
- The rules for placarding and marking shipping containers
- The legal responsibility accepted by the packer by signing a packing certificate.
Full operational competence can only be achieved by providing appropriate training consistent with the employee’s level of control and responsibility in the transport chain. It is essential that supervisory employees are trained to understand the IMDG Code rules, and have access to the rules for reference, as different substances require different handling; that those with the responsibility for compliance must be given the knowledge and authority to maintain procedures that ensure the provisions of the IMDG Code are carried out operationally.
IMDG Code dangerous goods training guide for shore-based staff IMDG Chapter 1.3 indicates that shore-based personnel involved with dangerous goods should have training appropriate to their job role and level of responsibility in one or more key areas. Records of all training should be kept by the employer.
- General awareness/familiarisation training – all persons should be trained to be familiar with the general provisions of the transport of dangerous goods, including the classes, labelling, marking, placarding, packing, segregation and compatibility, the purpose of the dangerous goods transport document and the container/vehicle packing certificate.
- Function-specific training – persons must be trained in the specific dangerous goods transport provisions that are applicable to the function(s). A guide to what provisions is applicable to specific job functions is provided in the table in IMDG 1.3.1.6.
- Safety training – commensurate to the risk of exposure in the event of a release of dangerous substances and the functions involved, persons involved in the handling of dangerous goods, or located in the vicinity of where they are handled, should be trained in:
- Procedures for accident avoidance such as proper control of cargo handling equipment and appropriate stowage of packages
- Available emergency response information and how to obtain it
- General dangers presented by the various classes of dangerous goods, how to avoid exposure and where applicable, how to use or wear appropriate Personal Protective Equipment (PPE)
- Immediate procedures to be followed in the event of an unintentional release of dangerous goods to protect self and others.
Security of dangerous goods
Shippers and shipping line staff should be aware that ships, ports and container terminals are key infrastructure elements and are potential terrorist targets. They are subject to the provisions of the International Ship and Port Facility Security (ISPS) Code that requires ship and port operators to take precautionary measures to defend against acts of terrorism.
High Consequence Dangerous Goods (HCDG)
Certain types of dangerous goods have been identified as having significant potential for misuse by terrorists intending to instigate an event leading to mass casualties or mass destruction. Shore-based staff employed by organisations handling HCDG should be aware of the increased risk factor, and maintain a security plan to defend against terrorists taking advantage of the destructive potential of such dangerous goods.
The security plan should include security training to ensure employees adopt practical measures to identify, report and reduce security risks, and to keep critical transport information confidential. High consequence dangerous goods include some of the higher risk substances and articles in Classes 1, 2, 3, 4, 5.1, 6 and 8. The list of specific items and details of the type of defensive measures to be taken are found in IMDG 1.4.3.
General and non-IMDG restrictions on dangerous goods cargo
Not all bookings for all dangerous goods can be accepted on all ships and all routes. Full details will be required from the shipper in the first instance. Many ships are restricted as to the types and volume of dangerous goods they can carry because of ship design or insurance restrictions, particularly so in the case of explosives and radioactive materials which also often have special stowage requirements.
Most ports restrict handling and transit of explosives and radioactive materials where safety, security, social and political factors are weighed beyond the practicalities of marine transport. Volumes shipped of these commodities are relatively low, and carried out by specialists.
Therefore, only the basic IMDG Code requirements of both explosives and radioactive materials will be dealt with in this guide. Many ports restrict other types of dangerous goods (e.g. ammonium nitrate) for safety reasons.
To determine whether the line can accept the dangerous goods booking, and whether any special conditions or volume restrictions will apply, the shipper will need to consider and supply the information contained in the following sections. Based on the type of dangerous cargo, the rules of the ports of transit and discharge, and the class of ship available, the booking will be either rejected or accepted and passed on to the next stage.
As the industry adapts to Amendment 42-24 of the IMDG Code, let us use this opportunity not just to update procedures, but to recommit ourselves to the fundamental goal: ensuring that dangerous goods are handled without incident, and that accidents at sea are prevented before they can occur.