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IMDG Code 38-16 – Update 4 – Vehicles and Engines

Fourth in this series is changes to Vehicles and Engines, under new entry, in IMDG Code 38-16.

Since 35th amendment of IMDG Code regulated Vehicles and Engines for sea transport mandatory from 1st Jan 2012 the biggest change to carriage conditions is brought by 38th amendment of IMDG Code which may be used this year and will become mandatory from 1st Jan 2018.

Changes includes separating  engines from UN 3166, by allocating new UN Numbers for engines and machineries which require labels and placards depending on fuel it contains or the capacity of fuel tanks.

Below are the highlights of changes to vehicles and engines in 38th amendment of IMDG Code and UN 3166 in 37th Amendment in nutshell.

 

IMDG CODE 37-14 

 
UN No. 3166
Class 9
Proper Shipping Name ENGINE, FUEL CELL, FLAMMABLE GAS POWERED
ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED
ENGINE, INTERNAL COMBUSTION
VEHICLE, FLAMMABLE GAS POWERED
VEHICLE, FLAMMABLE LIQUID POWERED
VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED
VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED
Packing Instruction       Nil
Special Provisions         312  356  961  962  970
 (Engines are deleted from 3166 in 38th amendment of IMDG Code)
Both Vehicles or machinery powered by a fuel cell engine and other vehicles which contain an internal combustion be consigned under UN 3166 with appropriate Proper Shipping name. Include hybrid electric vehicles powered by both an internal combustion engine and wet batteries, sodium batteries, lithium metal batteries or lithium ion batteries, transported with the batteries installed.
Vehicles may be exempted from the provisions of IMDG Code if liquid fuel tank is empty or gas powered is having its tank empty or positive pressure in the tank does not exceed 2 bar, see special provision 961.
Vehicles consigned as UN 3166 must meet Special Provision 962 which includes limit for liquid fuel, flammable gas powered the fuel shut-off valve closed etc. must accompany dangerous goods declaration however, not require marking labelling or placarding.

IMDG CODE 38-16 

 
UN No. 3166
Class 9
Proper Shipping Name VEHICLE, FLAMMABLE GAS POWERED
VEHICLE, FLAMMABLE LIQUID POWERED
VEHICLE, FUEL CELL,FLAMMABLE GAS POWERED
VEHICLE, FUEL CELL,FLAMMABLE LIQUID POWERED
Packing Instruction      Nil
Special Provisions         312  356  380   385  961  962
This entry applies to vehicles powered by flammable liquid or gas internal combustion engines or fuel cells. Engines must not be consigned under this entry.
If a vehicle is powered by a flammable liquid and a flammable gas internal combustion engine, it shall be assigned to UN 3166 VEHICLE, FLAMMABLE GAS POWERED.
Vehicles are self-propelled apparatus designed to carry one or more persons or goods. Examples of such vehicles are cars, motorcycles, trucks, locomotives, scooters, three- and four-wheeled vehicles or motorcycles, lawn tractors, self-propelled farming and construction equipment, boats and aircraft.
 
Vehicles powered by flammable liquid fuel with a flashpoint of 38°C or above, there are no leaks in any portion of the fuel system, the fuel tank(s) contains 450 L of fuel or less and vehicles powered by a flammable liquid fuel with a flashpoint less than 38°C, the fuel tank(s) are empty and installed batteries are protected from short circuit can be transported without subject to IMDG Code reqrueiments. See Special Provision 961.
Vehicles consigned under UN 3166 must meet the requirements of Special Provision 962 which includes
for liquid fuel, flammable gas powered the fuel shut-off valve closed.
Provisions of IMDG Code related to marking, labelling, placarding and marine pollutants are not applicable.

 
UN No. 3528
Class 3
Proper Shipping Name ENGINE, INTERNAL COMBUSTION, FLAMMABLE LIQUID POWERED
ENGINE,FUEL CELL, FLAMMABLE LIQUID POWERED
MACHINERY,INTERNAL COMBUSTION,FLAMMABLE LIQUID POWERED
MACHINERY, FUEL CELL,FLAMMABLE LIQUID POWERED
Packing Instruction       P005
Special Provisions        363  972

UN No. 3529
Class 2.1
Proper Shipping Name ENGINE, INTERNAL COMBUSTION, FLAMMABLE GAS POWERED
ENGINE,FUEL CELL, FLAMMABLE GAS POWERED
MACHINERY,INTERNAL COMBUSTION,FLAMMABLE GAS POWERED
MACHINERY, FUEL CELL,FLAMMABLE GAS POWERED
Packing Instruction       P005
Special Provisions        363  972

UN No. 3530
Class 9
Proper Shipping Name ENGINE, INTERNAL COMBUSTION
MACHINERY,INTERNAL COMBUSTION
Packing Instruction       P005
Special Provisions        363  972
Marine Pollutant           YES

 

UN Numbers 3528, 3529 and 3530 are for engines or machinery, powered by fuels classified as dangerous goods via internal combustion systems or fuel cells (e.g. combustion engines, generators, compressors, turbines, heating units, etc.), excluding those assigned under UN 3166 and UN 3363

Engines and machinery containing fuels meeting the classification criteria of;

  • Class 3 must be consigned under UN 3528, with appropriate proper shipping name
  • Class 2.1 must be consigned under UN 3529, with appropriate proper shipping name
  • By both a flammable gas and a flammable liquid shall be consigned under the appropriate UN 3529 entry, with appropriate proper shipping name
  • By fuels which are meeting the requirement of marine pollutant and not meeting the criteria of any other class must be consigned under UN 3530, with appropriate proper shipping name

Marking and Labelling

Depending on the quantity of the fuel it contains and the capacity of the fuel tank engines and machinery may require labels according to part 5.2.2 of IMDG Code and may require placarding as per part 5.3 of IMDG Code.

UN 3528 and UN 3530

  • contains more than 60 L of liquid fuel and has a capacity of not more than 450 L = Label required
  • contains more than 60 L of liquid fuel and has a capacity of more than 450 L but not more than 3,000 L = Label required on two sides
  • contains more than 60 L of liquid fuel and has a capacity of more than 3,000 L = Placard required on two sides
  • UN 3530 = Marine Pollutant Mark required

UN 3529

  • fuel tank has a water capacity of not more than 450 L = Label required
  • fuel tank has a water capacity of more than 450 L but not more than 1,000 L = Label required on two sides
  • fuel tank has a water capacity of more than 1,000 L = Placard required on two sides

Dangerous Goods Declaration

Must contain the words “Transport in accordance with special provision 363”.

Engines or machinery which are empty of liquid or gaseous fuels and which do not contain other dangerous goods, are not subject to the provisions of IMDG Code.

Engines or Machineries empty of fuel

An engine or machinery is considered to be empty of liquid fuel when the liquid fuel tank has been drained and the engine or machinery cannot be operated due to a lack of fuel. Engine or machinery components such as fuel lines, fuel filters and injectors do not need to be cleaned, drained or purged to be considered empty of liquid fuels. In addition, the liquid fuel tank does not need to be cleaned or purged.

How we can consider engines or machineries with gaseous fuel as empty?

An engine or machinery is considered to be empty of gaseous fuels when the gaseous fuel tanks are empty of liquid (for liquefied gases), the positive pressure in the tanks does not exceed 2 bar and the fuel shut-off or isolation valve is closed and secured.

Further reading

IMDG Code 38-16 – Update 3 – POLYESTER RESIN KIT

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