Consignment procedures of dangerous goods is nothing but procedures for communicating hazard involved in dangerous goods while in transport. The potential hazard, specific nature of goods requiring segregation, stowage conditions etc. are communicated through marks, labels, placards and document.
A dangerous goods which is correctly classified, identified with proper shipping name and appropriately packed but not consigned as per part 5 of IMDG Code will fail to meet the objective of IMDG Code, ‘enhance the safe carriage of dangerous goods while facilitating the free unrestricted movement of such goods and prevent pollution to the environment’.
Apart from risking lives at sea and those who handle such goods, a wrongly consigned dangerous goods may also experience delays and detentions at ports.
Part 5 of IMDG Code starts with the two most important aspects of consignment procedures
- No one must offer dangerous goods for transport unless the goods are marked, labelled, placarded and documented according to part 5 of IMDG Code, and
- A Carrier must not accept dangerous goods unless a copy of dangerous goods declaration is provided
Above two requirements are directly evolved from the application and regulations of SOLAS 1974, as amended, Chapter VII Part A and MARPOL, 1973/78, Annex III; the two most important conventions of International Maritime Organisation for enhancing safety of life at sea and prevention of marine pollution.
However there are exceptions, all dangerous goods need not require labeling, placarding or document. What is required and when not required can only be determined by referring to part 5 and the individual entries in part 3, chapter 3.2.
- A dangerous goods declaration is not required for excepted packages of radioactive material when UN Number preceded by the letters “UN”, and the name and address of the consignor and the consignee is legibly and durably marked on the package and mentioned in a transport document, which can be a bill of lading, air waybill or other similar document.
- Nickel-metal hydride cells or batteries loaded in a container with total gross mass 100 kg or more need not be marked, labelled or placarded but a transport document issued, manifested and additionally protected from sources of heat when stowed on board vessel.
Marking and Labeling of packages including IBCs
A package must be marked with UN Number, Proper Shipping name and technical name when assigned with special provisions 274 or 318. Example” UN 2902 PESTICIDE, LIQUID, TOXIC, N.O.S. (drazoxolon). The letters “UN” shall be at least 12 mm high, for packagings of 30 ℓ or 30 kg capacity or less at least 6 mm in height.
IBCs of more than 450 ℓ capacity and large packagings shall be marked on two opposing sides.
- Marine Pollutant
When a substance, material or article is identified as Marine Pollutant by IMDG Code or when it possesses the properties that meet the criteria of MARPOL Annex III but not identified as a Marine Pollutant by IMDG Code the same must be consigned as Marine Pollutant. Document must identify this with words MARINE POLLUTANT or MARINE POLLUTANT / ENVIRONMENTALLY HAZARDOUS.
Additionally the package must bear the Marine Pollutant Mark which shall be at least 100 mm × 100 mm unless the package size can only bear smaller marks.
Exception – single packagings and combination packagings where such single packings or inner packagings of such combination packagings have a net quantity of 5 ℓ or less for liquids; or a net mass of 5 kg or less for solids need not require a Marine Pollutant mark however the container carrying this package must display Marine Pollutant Mark one on each side and one on each end of the unit.
Specification of Labels
In terms of colour, symbols, numbers and general format the labels must meet the specifications mentioned in section 220.127.116.11.2 of IMDG Code.
- Labels shall be in the form of a square set at an angle of 45° (diamond-shaped) with minimum dimensions of 100 mm by 100 mm
- Shall have a line 5 mm inside the edge and running parallel with it
- The upper half of a label the line shall have the same colour as the symbol and in the lower half it shall have the same colour as the figure in the bottom corner
- Shall be displayed on a background of contrasting colour, or shall have either a dotted or solid outer boundary line.
Colour of the label is very important as the colour together with the symbols directly communicate the type of hazard involved. Those who are printing their own label may use PANTONE ® formula guide for accurate colour.
While using PANTONE ® formula guide following colour standards may be used.
- For Red— PANTONE® 186 U
- For Orange— PANTONE® 151 U
- For Yellow— PANTONE® 109 U
- For Green— PANTONE® 335 U
- For Blue— PANTONE® 285 U
Or refer to corresponding Munsell notations or International Commission of Illumination standards. A spectrophotometer or other instrumentation may be used to check whether the colour of printed labels match the standards.
Durability of Marking and Labeling shall be such that this information will still be identifiable on packages surviving at least three months’ immersion in the sea. British standard BS 5609 for printed pressure-sensitive, adhesive-coated labels meets this requirement. This standard tests the labels for print permanence, adhesive performance, abrasion resistance etc.
When a package is containing more than one dangerous goods it shall be marked and labelled for all the dangerous goods contained within.
An overpack must additionally be marked with word OVERPACK and the size of this marking must be at least 12 mm high from 1st January 2016.