Consequences of including Non-Dangerous Goods in Dangerous Goods Manifest

For enabling effective Emergency Response Measures in the event of spillage and fire involving dangerous goods on board ships, regulation VII/ 4.2 of SOLAS 1974, as amended, and regulation 4.2 of Annex III of MARPOL 73/78 and section 5.4.3.1 of IMDG Code requires a special list, manifest or stowage plan with information of Dangerous Goods, Marine Pollutants and the locations of these goods on board the vessel.

 Section 5.4.3.2.1 of IMDG Code requires appropriate information, immediately available, at all times for use in emergency response to accidents; methods of this can be:

  • appropriate entries in the special list, manifest or dangerous goods declaration; or
  • provision of a separate document such as a safety data sheet; or
  • provision of separate documentation, such as the Emergency Response Procedures for Ships Carrying Dangerous Goods (EmS Guide) for use in conjunction with the transport document and the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods (MFAG).

 In general most shipping lines submit Dangerous Goods Declarations and Dangerous Goods Manifest to vessels. Some lines provide only Dangerous Goods Manifest, IMO FAL Form 7.

 

FAL Form 7 Dangerous Goods Manifest
FAL Form 7 Dangerous Goods Manifest

 

What may be the consequences if non-dangerous Goods are included in this manifest?

UN Numbers UN 1910, UN 2807, UN 2812, UN 3334 and  UN 3335 are assigned with Special Provision 960 which states “Not subject to the provisions of this Code but may be subject to provisions governing the transport of dangerous goods by other modes.”

Even though not dangerous for sea transport IMDG Code included these UN Numbers for harmonization purpose as they may be dangerous for other mode(s) of transport ( e.g. Air ).

In Dangerous Goods List (chapter 3.2 of IMDG Code)  there are no EmS Codes assigned for Emergency Response Measures in column 15  for these UN Numbers as they are  not dangerous goods for Sea transport and there are no specific requirement or guidance for handling spillage or firefighting involving these goods.

If a vessel operator includes any of these UN Numbers in the Dangerous Goods Manifest and if there is an emergency on board involving fire to containers including  these said non-dangerous UN Number(s) the Master and crew may look for emergency response measures in IMDG Code and will not find any information.

This may cause delay in effective firefighting and or other consequences due to loss of vital time spent for looking for EmS of non-dangerous goods.

 Keeping above in view we must urge the industry not to include NON Dangerous Goods in DG Manifest as it may cause delay in firefighting on board ships at sea.

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