[Editor’s Note: Lion Technology Inc. instructor Roseanne Bottone is blogging from the Dangerous Goods Advisory Council (DGAC) Conference & Hazardous Materials Transportation Exposition. Daily, she will provide her observations and insights from the conference in order to keep our members up–to–date with the latest regulatory news.]
Today’s blog is a continuation of the discussion of international issues that were addressed at the second day of the DGAC Conference (November 9, 2011). This installment specifically addresses the future of the International Maritime Dangerous Goods rules.
International Maritime Dangerous Goods (IMDG) Code
Lt. Beth Newton from the U.S. Coast Guard talked about the 2010 amendments to the IMDG Code (amendment 35–10) that will become mandatory on January 1, 2012. The regulations will be a little more user–friendly now that they include reference marks (i.e., squares, triangles, and circles with an “x”) in the left margin similar to the existing marks in the IATA/ICAO air rules. This will make it easier to compare the new edition to the previous (2008) version, and to see what rules have been added, amended, or removed. For access to the full text of the amendments visit: http://gisis.imo.org
Here are some upcoming key changes to the IMDG Code:
- The new limited quantity markings will be mandatory. In addition to an exception for marine pollutant markings and Proper Shipping Names, limited quantity packages won’t require the material’s UN identification number. As it is no longer necessary, the special exception that was provided for “consumer commodities” has been removed.
- Provisions for fumigating containers have been consolidated in section 5.5.2 of the IMDG Code. They include mandatory training for fumigators, marking and placarding requirements, and the need for a fumigation certificate for UN 3359 in transit.
- Engines, vehicle flammable liquid/gas powered (UN 3166) are now fully regulated unless specifically excluded under the new Special Provision (SP) 961.
- SP 961 provides exceptions for roll–on/roll–off ships, empty or near–empty fuel tanks, and wet or dry electrical battery–powered vehicles.
- SP 962 provides the carriage requirements for UN 3166. These include limiting liquid fuel tanks to ¼ full or 250 L max; documentation; visual inspections of fuel tanks and batteries; and an exception for marks, labels, and placards.
- There are even some new Proper Shipping Names: toxic inhalation hazards (UN 3488–3493), Petroleum sour crude (UN 3494), Iodine (UN 3495), and Batteries, nickel–metal hydride (UN 3496).
As maritime and dangerous goods security has evolved, shippers and carriers have taken to affixing tracking devices and alarms to shipping containers. To acknowledge this relatively new practice the IMDG Code now includes a new section 7.5.4 in Chapter 7.4 (Packing of Cargo Transport Units) to cover how these devices may be used safely to monitor dangerous goods shipments. In the future, the International Maritime Organization (IMO) will be working on developing guidelines for packing cargo transport units, including a a stand–alone non–mandatory volume of regulations and a checklist and set of guidelines for CTU inspectors.
The next set of amendments to the IMDG Code (amendment 36–12) is in development now and will be published in late 2012, but will not become mandatory until January 1, 2014. The 2012 edition of the IMDG Code will incorporate changes from the 17th (2011–2012) Revised Edition of the UN Model regulations, new criteria for hazardous substances from the Globally Harmonized System of Chemical Classification and Labeling(GHS), and a complete revision of Part 7 (Stowage, Separation, and Segregation) of the IMDG Code.