IMDG Code: What You Need to Know
The International Maritime Dangerous Goods Code, or IMDG Code, is the international standard for packing and shipping hazardous materials by vessel. The International Maritime Organization (IMO) creates and maintains the IMDG Code requirements. The IMO is a specialized agency of the United Nations. Hazmat vessel shippers in the US should be aware that these vessel shipping rules include unique requirements not found in the US DOT's 49 CFR Hazardous Materials Regulations.
IMDG Code Publication Schedule
Unlike the IATA DGR for air shippers, which is published annually, the IMDG Code is published once every 2 years. This unique publication schedule leads to "staggered" compliance requirements, which can cause confusion for vessel shippers.
The current edition of the IMDG Code is Amendment 37-14, also called the 2014 Edition. This edition was published in late 2014 for use in 2015 and throughout 2016. Any changes from the previous edition (2012) are indicated with symbols in the margins. Following is the explanation given in the current IMDG Code:
IMDG Code Voluntary Compliance Year
For the first year after a new edition of the IMDG Code is released, compliance with the new rules is voluntary. During a voluntary compliance year, hazmat shippers may use the current enforceable Code or the most recently published Code. In 2015, for example, shippers could have followed either the 2012 edition (still currently enforceable) or the new 2014 edition (published at the end of 2014).
IMDG Code Mandatory Compliance Year
The second year after a new edition is released, compliance with the new edition is mandatory. On January 1, 2016, for example, the 2012 edition of the IMDG Code becomes obsolete and you MUST comply with the 2014 edition. At the end of each mandatory compliance year, a new edition is published and the cycle begins again.
The one-year transition period between editions gives shippers time to prepare for changes that affect their operations, learn new regulations, and take the steps needed to comply. To ensure your shipping operations keep pace with updated packaging and shipping rules, a best management practice is to have a copy of the new edition of the IMDG Code well in advance of the mandatory compliance deadline. New and updated rules may require you to re-train personnel, change operating procedures, or possibly make adjustments to your hazmat shipping papers.
Significant Changes to the 2014 IMDG Code
Marine Pollutant Exclusions [IMDG 2.10.2.7]
In previous editions of the IMDG Code, marine pollutants packed in single or inner packagings with a capacity of not more than 5 L or 5 kg were excluded from marking requirements. Under the 2014 Code, marine pollutants packed in these amounts are not regulated as marine pollutants, which means they will not be described on shipping papers as marine pollutants either.
New and Revised Proper Shipping Names [IMDG 3.2]
The 2014 Edition of the IMDG Code made several additions and revisions to the Dangerous Goods List at IMDG 3.2, including:
The specifications (size, shape, color, etc.) for labels and placards in Chapter 5 of the IMDG Code have been rewritten to improve readability and reduce confusion. No substantive new requirements were created for the design of labels and placards. One new requirement filtering down from UN Model Regulations is that overpack markings must be at least 12mm high. [IMDG 5.1.2.1]
Portable Tanks With a Capacity of Not More Than 3,000 Liters
Various marking and placarding provisions for small portable tanks are relaxed in the new edition of the IMDG Code:
Column 16 of the Dangerous Goods List at Chapter 3.2, Stowage and Segregation, is now split into two columns. Column 16a is called Stowage and Handling, and Column 16b is called Segregation. Instead of appearing as text on the List, segregation and stowage instructions (e.g., "keep away from acids" or "stow apart from foodstuffs") now appear as alphanumeric codes. The meanings of the various codes are described in tables at the beginning of Chapter 7. [IMDG 7.1.5 and 7.2.8]
Revised Provisions for Class 7 Radioactives
In order to maintain harmonization with the International Atomic Energy Agency's regulations, packing instructions and other provisions for radioactive hazmat were extensively rewritten. [IMDG 1.5, 2.7, 4.1.9, 5.1.5.4.1, 5.2.1.5, 5.2.2.1.12, 5.4.1.5.7 and 6.4]
IMDG Code Workshop for Hazmat Vessel Shippers
Get up to speed with the latest hazmat/dangerous goods vessel shipping rules in the 2014 IMDG Code, and be confident your hazmat vessel shipments will reach your customers safely and on time! The Hazardous Materials Vessel Shipper Certification Workshop covers the unique IMDG Code requirements and is designed to help satisfy the training requirement for vessel shippers at IMDG 1.3.1.
IMDG Code Publication Schedule
Unlike the IATA DGR for air shippers, which is published annually, the IMDG Code is published once every 2 years. This unique publication schedule leads to "staggered" compliance requirements, which can cause confusion for vessel shippers.
The current edition of the IMDG Code is Amendment 37-14, also called the 2014 Edition. This edition was published in late 2014 for use in 2015 and throughout 2016. Any changes from the previous edition (2012) are indicated with symbols in the margins. Following is the explanation given in the current IMDG Code:
IMDG Code Voluntary Compliance Year
For the first year after a new edition of the IMDG Code is released, compliance with the new rules is voluntary. During a voluntary compliance year, hazmat shippers may use the current enforceable Code or the most recently published Code. In 2015, for example, shippers could have followed either the 2012 edition (still currently enforceable) or the new 2014 edition (published at the end of 2014).
IMDG Code Mandatory Compliance Year
The second year after a new edition is released, compliance with the new edition is mandatory. On January 1, 2016, for example, the 2012 edition of the IMDG Code becomes obsolete and you MUST comply with the 2014 edition. At the end of each mandatory compliance year, a new edition is published and the cycle begins again.
The one-year transition period between editions gives shippers time to prepare for changes that affect their operations, learn new regulations, and take the steps needed to comply. To ensure your shipping operations keep pace with updated packaging and shipping rules, a best management practice is to have a copy of the new edition of the IMDG Code well in advance of the mandatory compliance deadline. New and updated rules may require you to re-train personnel, change operating procedures, or possibly make adjustments to your hazmat shipping papers.
Significant Changes to the 2014 IMDG Code
Marine Pollutant Exclusions [IMDG 2.10.2.7]
In previous editions of the IMDG Code, marine pollutants packed in single or inner packagings with a capacity of not more than 5 L or 5 kg were excluded from marking requirements. Under the 2014 Code, marine pollutants packed in these amounts are not regulated as marine pollutants, which means they will not be described on shipping papers as marine pollutants either.
New and Revised Proper Shipping Names [IMDG 3.2]
The 2014 Edition of the IMDG Code made several additions and revisions to the Dangerous Goods List at IMDG 3.2, including:
- Amended Entries
- UN 3268: AIR BAG INFLATORS, AIR BAG MODULES, SEAT-BELT PRETENSIONERS are now called SAFETY DEVICES, electrically initiated
- UN 0503: AIR BAG INFLATORS, AIR BAG MODULES, SEAT-BELT PRETENSIONERS are now called SAFETY DEVICES, PYROTECHNIC
- UN 2212: BLUE ASBESTOS is now called ASBESTOS, AMPHIBOLE
- UN 2590: WHITE ASBESTOS is now called ASBESTOS, CHRYSOTILE
- New Entries
- UN3507, URANIUM HEXAFLUORUIDE RADIOACTIVE MATERIAL, EXCEPTED PACKAGE, 8, 7
- UN3508, CAPACITOR ASYMETRIC, 9
- UN3509, PACKAGING DISCARDED UNCLEANED, 9
- UN3510–3526 for various adsorbed gases in Class 2
The specifications (size, shape, color, etc.) for labels and placards in Chapter 5 of the IMDG Code have been rewritten to improve readability and reduce confusion. No substantive new requirements were created for the design of labels and placards. One new requirement filtering down from UN Model Regulations is that overpack markings must be at least 12mm high. [IMDG 5.1.2.1]
Portable Tanks With a Capacity of Not More Than 3,000 Liters
Various marking and placarding provisions for small portable tanks are relaxed in the new edition of the IMDG Code:
- Elevated-temperature and marine pollutant markings need only be 65 mm on each side, rather than 100 mm. [IMDG 5.3.2.2.1 and 5.3.2.3.2]
- Proper Shipping Name and ID number markings need only be 12 mm high, rather than 250 mm. [IMDG 5.3.2.0.2]
- Placards or labels are required only on two opposing sides instead of the usual four. [IMDG 5.3.1.1.4.1]
Column 16 of the Dangerous Goods List at Chapter 3.2, Stowage and Segregation, is now split into two columns. Column 16a is called Stowage and Handling, and Column 16b is called Segregation. Instead of appearing as text on the List, segregation and stowage instructions (e.g., "keep away from acids" or "stow apart from foodstuffs") now appear as alphanumeric codes. The meanings of the various codes are described in tables at the beginning of Chapter 7. [IMDG 7.1.5 and 7.2.8]
Revised Provisions for Class 7 Radioactives
In order to maintain harmonization with the International Atomic Energy Agency's regulations, packing instructions and other provisions for radioactive hazmat were extensively rewritten. [IMDG 1.5, 2.7, 4.1.9, 5.1.5.4.1, 5.2.1.5, 5.2.2.1.12, 5.4.1.5.7 and 6.4]
IMDG Code Workshop for Hazmat Vessel Shippers
Get up to speed with the latest hazmat/dangerous goods vessel shipping rules in the 2014 IMDG Code, and be confident your hazmat vessel shipments will reach your customers safely and on time! The Hazardous Materials Vessel Shipper Certification Workshop covers the unique IMDG Code requirements and is designed to help satisfy the training requirement for vessel shippers at IMDG 1.3.1.
Tags: hazmat shipping, IMDG Code, new rules
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