Supplement - Dangerous Goods
Introduction
The Club, with the support of several Members, has launched Book it right and pack it tight – a set of four guidebooks on the workings of the International Maritime Dangerous Goods (IMDG) Code. They are designed to provide busy operational people, who are not experts in the IMDG Code, with a quick reference and practical everyday guidance to the IMDG Code rules.
Uniquely, each of the four guidebooks is dedicated to the requirements of one of the principal parties involved in consigning packaged dangerous goods:
- The shipper
- The shipping line booking agency
- The cargo consolidating companies (managers and supervisors)
- The fork lift operators and cargo handlers – those that actually physically pack the containers.
Each of the parties above has key duties under the IMDG Code, and failure to carry out those duties may lead to undeclared dangerous goods being loaded in a ship, an unsafe container load, or unsafe stowage, all of which lead to an unnecessary increase in the risk of carrying dangerous goods by sea.
IMDG Code training package
The guidebooks come in a boxed set of four. They are part of a complete IMDG Code training package. Each book is supported by its own editable PowerPoint training course. This enables training officers and managers who are not experts in the IMDG Code to teach staff their key duties under the Code, and how the guidebooks work. This is to raise awareness of the guidebooks in the workplace and overcome the perception of employees that the IMDG Code is too complex for them to understand.
Also in the package is a DVD – Any Fool Can Stuff a Container. This DVD focuses on:
- Choosing a container
- Checking the container
- Making a packing plan
- Packaging cargo
- Packing containers
- Container security
- Receiving containers.
Before explaining the guidebooks in detail, it may be of interest to describe the causes of dangerous goods incidents and non-compliance with the IMDG Code, and explain why the Club is taking direct action to improve IMDG Code understanding and compliance.
What is the IMDG Code?
The IMDG Code is a comprehensive set of globally accepted rules that enables packaged (i.e. non-bulk) dangerous goods and marine pollutants to be carried safely by sea.
Around 10 per cent of all container cargoes contain dangerous goods, so virtually all container ship services fall within the scope of the rules of the Code.
Why is the IMDG Code so complex?
The Code has evolved from a set of brief facts and instructions for mariners through more than six decades of committee discussions by experts, to a two-volume document with a supplement, a total of over 800 pages.
The rules are now set about with exemptions and exceptions. Industries have successfully lobbied for special rules for particular products, such as paints, alcoholic beverages and aerosols, and rule makers must make allowances to take advantage of benefits from new technologies in products and packaging, as well as more accurate technical information about the behaviour of hazardous substances. As in all things, the rules of the Code must be flexible, or the system becomes commercially restrictive and discredited.
So, the Code must draw a balance between being easily understandable for non-technical operational people, and at the same time comprehensive and technical enough to take into account all manner of special considerations.
The Code is wide-ranging and there will always be sections that are not applicable to a particular party. It is now so lengthy that some operational personnel are put off from trying to understand it. In fact, the Code is a well-designed document, and ordinary operational people just need guidance to understand its structure and their key duties. That is the purpose of the Book it right and Pack it tight guidebooks.
The scope of the Code
Many are surprised to learn that the bulk of the Code applies to activities carried out ashore by the shipper, consolidator and packer concerning the preparation and documentation of the load, not to shipboard activities. The Code is complex because it provides rules that apply to activities taking place right at the start of the transport chain and then throughout the carriage by sea.
The Code requires the shipper to provide a description of the product and classification of any hazards. It sets limits on the type and size of packaging, specifies warning marks and labels, establishes rules for the types of hazards that can be co-loaded into one container, and devises a documentation system that requires shippers and packers to certify in writing that they have followed the rules of the Code.
Only when all of these things have been done does the Code turn its attention to stowage and segregation aboard ship. As examples of this, shipboard stowage does not appear until the last section of the main document, and the emergency instructions for dealing with dangerous goods incidents aboard ship do not appear in the Code proper at all, but in the Supplement to the Code, (sometimes called Volume 3).
Daunting for new users
The length and density of the text is a psychological barrier to learning for people whose first language is English, or one of the main world languages into which the Code is translated. How much more difficult is this for users reading the Code in a second language?
Obstacles to knowledge
This problem can be overcome if the employer sponsors IMDG Code training.
The training problem is compounded if shippers and packers operate hundreds of miles from the sea and have no natural contact with maritime affairs. The situation is even more difficult if the operation is located in a state or region where business culture is undeveloped and regulatory compliance is not a priority.
The Club recognises the existence of these knowledge gaps, and seeks to address them by making the new IMDG Code guidebooks available through shipping lines to their customers. | |
Causes of dangerous goods incidents
Before looking in detail at how the guidebooks work, it may be useful to look at the nature of dangerous goods, and at the main factors that cause dangerous goods incidents. Then the relationship of compliance with the IMDG Code to risk reduction becomes apparent.
The hazard and risk factors
The IMDG Code requires shippers to identify cargo as dangerous goods if it possesses a known hazard such as flammability, toxicity etc.
The IMDG Code rules enable the carriage of dangerous goods to be acceptable under managed risk conditions. For example, the carriage of flammable liquid is never without a fire hazard, but provided the ship is fully aware of the hazard, the packaging is adequate and intact, and the stowage and segregation is done according to the IMDG Code rules, the ship should be able to deal with an unexpected incident. The risk is recognised, measurable, minimised and commercially acceptable.
Unplanned risk factors
The substances below are examples of commonly carried dangerous goods with a history of causing serious incidents on ships. Remember, it is not the product but the failure to comply with the IMDG Code that causes incidents.
- Calcium hypochlorite, widely used for water treatment, has a bad reputation for spontaneously igniting in a ferocious way
- Barbeque charcoal has done the same in a less violent way, resulting in smouldering block stows on deck
- Thiourea dioxide, a substance widely used in the paper, leather and textile industries, was not listed as dangerous goods until a number of shipboard incidents caused the experts to classify it as a self-reactive substance.
Why do incidents onboard occur?
Events and circumstances far from the ship can sow the seeds of incidents arising from:
- Misdeclaration or non-declaration by shippers
- Quality and selection of the packaging
- Provision and accuracy of documentation
- Professionalism of the container packing
- The completely unexpected
- Human factors – regional and company attitudes.
1. Misdeclaration or non-declaration by shippers
There are many ways in which chemicals can be combined to make new substances. Dangerous goods not listed by name in the IMDG Code Dangerous Goods List must be tested by the shipper to check for hazardous properties, then shipped under a generic hazard classification.
It is possible for hazards to not be declared under these circumstances, either because of lack of time to test, lack of test facilities, making false assumptions, lack of product knowledge, lack of knowledge of the requirement to make an IMDG Code declaration or how to make one, or even wilful withholding of information to avoid dangerous goods surcharges.
2. Quality and selection of packaging
Like a time bomb, defective or incompatible packaging may fail and release product at any point in a voyage. Defects are difficult to spot until the package fails.
In the example illustrated, new UN standard steel drums failed because small pieces of clinker (mill scale) were rolled into the sheet steel from which the drums were made. During the voyage, the mill scale broke out leaving holes in the drums. The IMDG Code specifies the quality of packaging, and failure to meet that standard was the cause of this incident. Fortunately the cargo was declared and stowed according to IMDG rules and the crew were able to deal with the problem appropriately.
Beware of reconditioned drums
There is a market in low-cost second hand and reconditioned steel and plastic drums. They are often used for low value, low profit substances such as tar oils and creosotes. Reconditioned steel drums have been known to fail because of brittle metal fracture. The process of cleaning and reconditioning, which may involve fitting new top and bottom heads, puts stress on the materials that was not anticipated during original drum manufacture. Much depends on quality control.
The IMDG Code does not require shippers to notify the ship of use of reconditioned drums for dangerous goods. Beware, they are another unknown risk factor.
3. Provision and accuracy of documentation
The IMDG Code requires shippers to provide self-certified documentation describing the identity of the dangerous goods, the nature of the hazard, the quantity and the type of packaging. This data from the dangerous goods manifest is used to stow the ship and is available for dealing with onboard incidents.
There is a serious lack of knowledge about the content and purpose of dangerous goods documentation in the transport chain between the shipper and the ship. The knowledge gap may be expected to grow in proportion to the distance from a port, with shippers being least well informed, but regional attitudes also have a strong influence.
However, the maritime industry must face the fact that many employees of shipping companies, forwarding agents and container packers are not as well informed about dangerous goods hazards and IMDG Code requirements as is consistent with risk reduction.
Unfortunately, it is the ship that bears the additional risk, and once the container is loaded, the ship can do nothing to correct the mistakes of others.
Many dangerous goods documents of very poor quality pass through the transport chain. How is this so? Either the parties who should identify the errors are instructed to wilfully ignore any problems, or they simply don't know any better. |  | 
A container packing certificate has to be
signed by the person responsible for packing and
securing the load as safe for sea.
This was the condition of a stow of plastic drums of corrosive product after a 50 kilometre road journey to the port. The sea journey had not yet started. |
Typical information required in an IMDG Code declaration
(other products may require different data)
Packaging data required for each substance: |
| Number and type of packages: | 180 x 200 litre steel drums |
| Quantity data required for each substance: |
| Net mass/volume: | 17,600 kg |
| Gross mass/volume: | 18,600 kg |
| Identification data required for each substance: |
| Proper Shipping Name: | Acetyl Chloride |
| Class: | Class 3 Flammable liquid |
| UN Number: | 1717 |
| Supplementary identification data that may be required for some substances: |
| Packing group: | PG II |
| Sub-risk: | Class 8 Corrosive |
| Flashpoint: | (5°C c.c.) |
| Marine pollutant: | (not applicable for this substance) |
| Control temperature: | (not applicable for this substance) |
| Emergency temperature: | (not applicable for this substance) |
|
The shipper is required to
provide this standard of
detail in a certified document
for each dangerous goods
substance he offers for
shipment
|
4. Professionalism of the container packer
Cargo securing inside containers is still as fundamental now to successful maritime transport as it ever was in general cargo ships. The lack of proper securing of cargo in containers remains a significant cause of damage, and dangerous goods leaking from broken packages is an all too frequent additional risk factor.
The IMDG Code requires the packer to sign a packing certificate stating that any dangerous goods have been safely secured for sea. Despite this, out-turn reports at container cargo spillage incidents produce a familiar roll call of defects in cargo stowing and securing:
- Unsecured packages rolling and tumbling to self-destruction inside void spaces in the container
- Cargo crushed and collapsed by being overstowed by heavier cargo
- Point-loading damage to cargo by pallets caused by lack of horizontal support between tiers
- Collapse of flimsy and badly made pallets causing stow instability
- Penetration of cargo, particularly drums, from protruding nails in floors, pallets, dunnage and broken pallets
- Direct physical damage to packages caused by fork lift trucks
- Ram-loaded packages split by forcing them into the container by fork lift.
5. The completely unexpected
From time to time people do unusual things to containers – tip them from road trailers, shunt them into railway buffers, or drop them from cranes. After such an event, in an ideal world IMDG Code dangerous goods warning placards would compel conscience to overcome carelessness and check the cargo before loading on a ship, but this is not always the case.
for damage before loading to a ship – does it happen?
6. Human factors – regional and company attitudes
IMDG Code rules, like any laws and regulations, only have meaning in proportion to the degree to which people respect and comply with them. We have looked at the physical failures that create problems, but it is people who drive policy, manage companies, operate production plants, create documents and load containers.
Why do people fail to comply with the IMDG Code?
Individual actions are influenced by organisational procedures and cultures, and vice versa. Here are just some important areas:
- Company rules, standards and resources
A large multi-national company can apply ready-made templates for operational safety standards that include the IMDG Code, and have compliance officers to plan training and maintain standards. By contrast, managers of small companies often have limited resources, and these are directed towards managing productivity and everyday problems.
- Business ethics
There are employers in all societies that encourage employees to regard regulations as 'red tape' and barriers to productivity. Operators with this mindset find it easy to push aside the IMDG Code, when it is convenient to do so, by simply not declaring cargo as dangerous goods. Again it is the ship that is bearing the risk, not them. This is primitive business thinking, but often prevails, particularly in small companies.
 The container packing industry is vulnerable to this attitude. Consider container packing at its most basic. It only requires the rental of a fork lift truck, the construction of a simple container access ramp and use of a piece of land by a roadside to set up business as a container packer. There is not even a requirement for a building. It is an easy entry-level business for a budding entrepreneur with limited funds, and he may not even be aware of the IMDG Code.
In newly emerging industrial societies workers may transfer, overnight, from traditional agricultural work to industrial processing involving dangerous chemicals. There will be a time lag before such societies develop the instinctive understanding of industrial and chemical hazards that comes from experience. The IMDG Code has evolved over six decades, but it is a new concept to many companies now manufacturing and packing dangerous goods in newly developing regions. They will need help and training to assimilate the IMDG Code into their industrial cultures.
- Communication
 In addition to coping with the industrial culture gap, many developing regions are doing business with the world in a second language, usually English. This adds another barrier to perfect understanding. Consider the extract from a safety data sheet below, which is taken from a Far Eastern manufacturer's website. In the list of hazardous properties it says "Danger of Explosion: Not applicable," but in the next line under "Fire Hazards" it says, "Material is shock sensitive and potentially explosive." Lost in translation? The company had a highly technical website advertising sophisticated speciality chemicals but made an error in translation of the sort that can easily be made on a shipping document.
- Individual skills and attitudes
It should not be forgotten that individual employees make decisions that affect outcomes, albeit against their organisational background. Many people are trained to perform a narrow set of technical skills repetitively, quickly and semi automatically to achieve business productivity – for example to create dangerous goods documents on a computer, process a cargo booking, pack a container or book containers through a dock gate.
For such individuals it is more difficult to apply the IMDG Code rules than to ignore them. Employees who are disaffected, poorly trained, or poorly supervised will take short cuts and break the rules to get the job done with least effort. That may mean ignoring the IMDG Code.
IMDG compliance should mean fewer incidents
We have seen that there are many potential hidden causes of dangerous goods incidents, and many obstacles to the observance of the IMDG Code. While this situation prevails, the risk to ships from hazardous cargo will remain unnecessarily high.
However, if all dangerous goods are shipped under the IMDG Code rules, the risks will be considerably lower. If ships know the nature, the hazard and the identity of the cargo, it can be stowed and segregated appropriately, and incidents handled confidently. Dealing with a deck fire involving a known commodity is altogether different from dealing with an unknown commodity burning below deck.
Accepting that increasing IMDG Code compliance is at the heart of the solution, how can this be achieved? The Club believes that a significant improvement can be brought about if shippers and container packers in all regions could be provided with practical IMDG Code training aimed specifically at their operational requirements. The result is the Book it right and pack it tight guidebooks and training set. | |  |
 Book it right and pack it tight
The Club hopes to make a contribution to boosting global understanding and use of the IMDG Code with the Book it right and pack it tight pack of guidebooks and training material.
The guidebooks look at the role of the shipper, the shipping line booking agent, the freight consolidator (manager or supervisor), and the fork lift operator and cargo handler who physically loads the container, and identify the key duties of each. The party concerned, instead of having to search through the 800 pages of the Code looking for his instructions, starts by consulting his guidebook.
The guidebooks explain in simple terms what duties the IMDG Code requires, with colour illustrations and photographs. Each duty described in the guidebooks includes a reference that takes the reader directly to the text in the Code where the full technical details are found.
What the guidebooks contain
Guidebook 1 in the series is for shippers. It explains the shipper's key duties such as:
- Classifying the hazard – the guidebook explains how the UN classification system identifies all the dangerous goods details about a particular hazardous substance
- Documenting the hazard – indicates the details that the IMDG Code requires be notified about dangerous substances, and how the IMDG Code draws them together into a common global format for documentation. The guidebook includes examples of how the shipper must make out a shipper's declaration for different types of dangerous goods, and how they should be presented on the document, together with an example of a completed dangerous goods document
- Documentation checklist – this book includes a checklist for use by shippers and others to ensure that all the required details have been included on a dangerous goods shipping declaration
- Legal obligation – the guidebook explains the meaning of the legal text that appears on each dangerous goods declaration, and the commitment the shipper is making when he presents dangerous goods for shipment by sea
- Package selection – the guidebook outlines the IMDG Code rules that shippers must follow when selecting packaging that is suitable for dangerous goods, and an illustration of the type of UN code that appears on packages that have been tested and approved for filling with dangerous goods
- Use of different types of packages – the guidebook has colour illustrations of different types of packaging used for dangerous goods including the construction of combination packages made up of inner receptacles contained within outer wrappers
- Marking and labelling – the guidebook explains and illustrates the shipper's prime duty to apply specific warning marks and labels to each package to give clear and decisive information about the contents of each package.
Guidebook 2 covers similar ground from the point of view of shipping line employees. Its purpose is to assist cargo booking staff to check the information provided by shippers at the earliest stage, by asking shippers the right questions, and to help shippers to get the basics right.
Guidebook 3 is aimed towards managers and supervisors of cargo consolidation depots where dangerous goods are packed into freight containers. It summarises the shipper's duties in less detail, and concentrates on the additional factors that come into play when packing dangerous goods into freight containers. Examples of additional key factors for consolidators explained in Guidebook 3 include:
- Segregation of dangerous goods within a container – the guidebook explains how both the hazard and the risk of an incident are escalated if the container packer ignores IMDG Code segregation rules and packs incompatible dangerous goods in the same container. The guidebook then shows how the segregation should be checked either manually or electronically using internet or proprietary computer-aided systems
- Marking and placarding of containers – the guidebook explains the packer's duties regarding the application of warnings to freight containers
- Packing certificate – the guidebook explains the legal responsibilities of the packer that are encapsulated in the packing certificate
- Securing cargo against movement inside containers – the conventional methods of blocking and bracing packages of cargo inside freight containers are illustrated in a series of drawings covering drum stacking, use of pallets, stacking intermediate bulk containers (IBCs) and using timber and other materials to prevent cargo from moving.
| | 
|
Guidebook 4 explains the problems, responsibilities and techniques of packing dangerous goods into containers from the point of view of the fork lift truck operator and cargo handler. It includes photographs of damaged packages to illustrate what happens to cargo that is not effectively secured for transport by sea.
Each book also has a common reference section that briefly explains classification, technical terms and common 'problem areas' such as limited quantities and rules for aerosols.
Simple guidance
There are over 800 pages of the IMDG Code, so the details in the guidebooks are selective. Each topic has at least one reference to a part, chapter, section or sub-section of the main body of the IMDG Code text, taking the reader directly to the full details of that topic. The aim is to enable the reader to identify his key requirement in the guidebook, see an example of what is required, then if he needs more information easily locate full technical details in the Code, using the guidebooks as a chart.
Practical and accessible
The guidebooks are not intended as a replacement for the IMDG Code, but as everyday guides for ordinary operational staff to find their way around it. It is not intended that these guidebooks sit on bookshelves in the company library, but that they are issued as everyday operational guides on desks in the manufacturer's shipping office, the freight booking office, the warehouse supervisor's pocket, and the fork lift operator's mess room.
With this in mind the guidebooks are robustly made to survive heavy handling and spiral bound so they open flat for photocopying.
 Operational checklists
The books include three checklists, one for completing shipper's declarations, one for identifying training requirements in container packing facilities, and one for packing containers.
Serious purpose
Each book ends with a series of photographs of the fire aboard the Hanjin Pennsylvania, intended to graphically bring home to shore side people that even the most modern container ships are vulnerable to undeclared dangerous goods incorrectly and inaccessibly stowed below deck. The message is that the IMDG Code is not red tape, or pointless regulations, but a serious document whose sole purpose is to protect shipper's cargo, ships and mariner's lives.
Also in the training package:
- Four PowerPoint training presentations on CD
The guidebooks are supplied in a training package consisting of the four guidebooks in a slip case, and PowerPoint training presentations, one for each guidebook. The purpose of these is to enable company managers with only a passing knowledge of the IMDG Code to confidently introduce employees to key aspects of the IMDG Code, and the guidebooks themselves and how to use them.
- DVD
Also included is a DVD version of Any Fool Can Stuff a Container
The Club together with several Members has made a major commitment to ship safety by producing this package. We believe that the pack will be of great assistance to shippers and packers looking for practical IMDG Code guidance, and to shipping lines seeking a means to provide such assistance to their customers. Especially those operating in the developing regions beyond the reach of normal IMDG Code training, and newcomers to dangerous goods everywhere.
Dangerous Goods is written by Richard Masters
For further information contact:
Karl Lumbers, Loss Prevention Director
Thomas Miller P&I Ltd
International House, 26 Creechurch Lane
London EC3A 5BA
Tel: +44 (0)20 7204 2307
Fax: +44 (0)20 7283 6517
e-mail: karl.lumbers@thomasmiller.com
|  |
|
|
