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Challenges for IMDG Hazmat Shipping Papers

Posted on 4/21/2015 by Scott Dunsmore

In most cases, hazmat/dangerous goods shipments must be accompanied by a shipping paper when transported by ground, air, vessel, or rail. While the US DOT oversees all domestic hazmat shipments, the 49 CFR Hazardous Materials Regulations (HMR) authorize shippers to follow the International Maritime Dangerous Goods (IMDG) Code when offering hazmat for vessel transport.

In some ways, the IMDG Code shipping paper requirements are similar to the DOT rules at 49 CFR 172, Subpart C. To avoid confusion and rejected shipments, though, shippers must be familiar with the key differences between these two sets of regulations.

IMDG Code Sample Multimodal Dangerous Goods Form

Neither the DOT HMR nor the IMDG Code require hazmat shippers to use a specific form as shipping paper. At IMDG 5.4.5, shippers can find a sample Multimodal Dangerous Goods Form that includes sections for all required elements and applicable hazmat shipping certification statements. Use of this sample form is voluntary.

The International Maritime Organization (IMO) makes a copy of the sample Multimodal Dangerous Goods Form available on IMO.org, in Word format. Click here to download.

IMDG dangerous goods shipping papers

Writing the Hazmat Basic Description

When indicating the hazard class in the basic description, the DOT HMR allows shippers to add the word "Class" or "Division" in front of the class or division number. The HMR also allows the hazard class name to follow the number (e.g., UN 1090; Acetone; Class 3 Flammable Liquid; PG II). [49 CFR 172.202(a)(3)(iii)]

Under the IMDG Code regulations, however, shippers may only add the word "Class" or "Division" before the hazard class number (e.g., UN 1090; Acetone; Class 3; PG II). [IMDG] Adding the hazard class name is not permitted under IMDG rules.

Indicating Hazardous Substances on Shipping Papers

When shipping a hazardous substance (as defined in 49 CFR 171.8) by ground or vessel, shippers must indicate on the shipping paper that the shipment contains a hazardous substance. [49 CFR 171.23(b)(5)] The shipping papers must also include the letters "RQ," for Reportable Quantity, next to the basic description for each hazardous substance listed.

The DOT HMR allows the placement of the letters "RQ" before or after the basic description. Under the IMDG Code, shippers must include all additional information (including RQ, when appropriate) after the basic description. [IMDG]

Marking Quantity for International Shipments

Neither the DOT HMR nor the IMDG Code explicitly require shippers to use metric versus US (or imperial) measurements to describe quantity on a shipping paper. That said, because vessel shipments are often transported internationally, it may be beneficial to exclusively use metric units. [IMDG 1.2.2]

Adding Technical Names to the Basic Description

In certain cases under DOT and IMDG regulations, shippers must include the technical names of their materials in the shipping description. DOT requires technical names be added when:
  • The shipper uses a "generic" Proper Shipping Name to describe the materials,
  • The material is an environmental hazard, or
  • The material is a hazardous waste.
The DOT shippers must place the technical name(s) in parentheses, either immediately following the Proper Shipping Name or at the end of the basic description.

Instead of providing specific scenarios in which a technical name is required, the IMDG Code indicates that a technical name is required by placing Special Provision 274 or 318 in Column 6 of the Dangerous Goods List. [IMDG] Additionally, the technical names may only be placed immediately following the Proper Shipping Name in the basic description. Placing the technical name after the basic description is a violation of IMDG shipping paper rules.

Flash Point

For vessel shipments of materials with a flash point at or below 60°C, the IMDG Code requires an indication of the flash point after the basic description. The flash point must be indicated for materials with a primary or subsidiary Class 3 hazard. After the basic description, shippers must add the material's flash point with the unit of measure and followed by "c.c." to indicate that the flash point is a closed cup test value (e.g., -10°C c.c.). [IMDG]

Limited Quantity Hazmat Shipments

Limited quantity hazmat shipments, except for shipments of hazardous wastes, marine pollutants, and hazardous substances, do not require shipping papers under US DOT rules. When shipping papers are required, the shipper must include the words "Limited quantity" or "LTD QTY" in association with the basic description.

The IMDG Code, on the other hand, requires shipping papers for all limited quantity hazmat shipments and therefore, the use of the entry "Limited quantity" or "LTD QTY" at the end of the basic description. [IMDG]

Segregation Group

When a material is assigned to an N.O.S. entry that does not fall into one of the segregation groups listed in IMDG, it must be assigned a segregation group by the shipper. The segregation group is required to be indicated on the shipping paper at the end of the basic description in the following format: IMDG Code Segregation Group, the group number, and the group name, e.g., IMDG Code Segregation Group 1 - Acids. [IMDG] Segregation groups are not part of 49 CFR and so are not required by DOT.

Certification Statement

When certifying the shipping paper, the DOT HMR allows for the use of either statement at 49 CFR 172.204(a)(1) or 49 CFR 172.204(a)(2). The IMDG Code requires the use of only the statement at IMDG, which includes as part of the statement "and are in all aspects in proper condition for transport according to applicable international and national government regulations."

Shipping Paper Retention

The IMDG Code requires the retention of all documentation associated with the shipment for 3 months. The DOT HMR requires all non-waste shipping papers to be kept a minimum of 2 years, and all waste manifests are required to be retained for a minimum of 3 years. [49 CFR 172.201(e)]

Complying with the regulations for different modes of transport can be a challenge. But, as with any other part of the hazardous materials shipping process, attention to detail is the key to compliance. Mandatory compliance with the 2014 edition of the IMDG Code starts January 1, 2016. To help hazmat vessel shippers prepare for compliance with the latest vessel shipping rules—including new marking specifications for hazmat packages—a Lion instructor will present the Hazmat Vessel Shipper Certification Webinar live on June 9.

Tags: DOT, hazmat shipping, IMDG, Recordkeeping and Reporting

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