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:
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
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:
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
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.
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.
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).
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?
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.
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 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.
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.
Events and circumstances far from the ship can sow the seeds of incidents arising from:
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.
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.