Undeclared dangerous goods mean any goods which are listed in the IMDG Code by name or meeting any of the classification criteria of the IMDG Code but not declared by the shipper as dangerous goods.

Misdeclared dangerous goods means any dangerous goods not declared correctly as per the requirement of IMDG Code. Which may include incorrect or misleading description of dangerous goods in dangerous goods declaration, misleading Marking, Labeling and placarding.

Misdeclaration or non-declaration of dangerous goods is posing great threat to safety of life at sea.

An undeclared or misdeclared dangerous good container may be placed anywhere on the ship without considering stowage and segregation required for the goods packed within.   

Shipping lines have started imposing penalties if any container is detected as not declared or mis declared. However, the possibility of detection is only when the goods ends up in an incident or accident or subjected to random inspection.

An online survey conducted by us received 142 responses from 20 countries. Majority of the respondents were shippers, forwarders & shipping lines.

Four questions were asked in the survey

  1. Reason for misdeclaration or non-declaration  
  2. What promotes willful default of misdeclaration or non-declaration?         
  3. How shippers mis-declare dangerous goods?        
  4. How do you think we can eliminate misdeclared dangerous goods?

Reason for misdeclaration

67% respondents said ignorance as the reason for misdeclaration 33% said willful default by shippers.

What promotes misdeclaration

On factors promoting wilful default majority said

  • High hazardous surcharge
  • Restriction/prohibition by carrier but high demand in the market

How shippers’ mis declare dangerous goods?

Almost equally respondents chose below four options for mis declaring dangerous goods

  • Take advantage of special provisions
  • Altering Safety Data Sheets
  • Using less used synonyms
  • Changing cargo name

How to eliminate misdeclaration of dangerous goods?

Most respondents agreed with below priorities

  1. Random audit by national competent authorities
  2. More awareness campaigns
  3. Mandatory Training verification by authorities
  4. Know your customer

Views & Suggestions

40+ respondents submitted their views & suggestions for eliminating misdeclaration and non-declaration of dangerous goods. This is categorized as below.

Category of ViewAny other views or suggestions?
AwarenessMore awareness about the Dangerous goods and regulations across the globe
AwarenessToo many people believe that if you can buy it in a grocery store or pharmacy then it cannot be Dangerous Goods.  Too many people believe that if you can put it in your luggage on an airplane then it cannot be Dangerous Goods.
So, of course, when they are at work, they don’t think twice about a container load of hand sanitizer or flammable perfume or batteries or drain cleaner or filters or aerosols or household insecticide or pool chlorine.
We can’t do much about fraud, but with outreach we can do a lot of about eliminating ignorance.
SurchargeI have always been of the firm belief that honest declaration of the dg should never be penalised by way of surcharges instead these should be encouraged and a nominal charge may be levied if a special stow is required. These are all my personal views.
IT SystemIT system like hapag Lloyd watchdog
ScanningIn my point of view misdeclarations are voluntarily doing by shipper or consignee for gaining more profit. Switching to 100% scanning system will be the only option to reduce misdeclaration .
AwarenessWe needs guidance if any changes in provisions etc..for our knowledge only.
 If Shipper gives proper details like correct UN no PG Label Etc….to carrier. Carrier should accept the cargoes…
DG Desk vettingEach and very carrier should have at least one DG desk which should have adequate knowledge on IMDG and all the DG bookings should be verified through that desk prior accepting DG cargo to avoid misdeclaration and any misshaping during in transit.
 The radar is put off, applicable for certain cargoes & Check the packaging is weather tight.
IT SystemThe export clearance procedure should be more stringent and systems should prompt whenever any variances in the cargo details to curb misdeclaration
Awareness/Surcharge1.Less subject knowledge about dangerous or hazardous goods also leads to misdeclaration of the cargo
2.High surcharges is also one of the reasons
3.ignoring expert (dangerous cargo consulting service) advices
4. Illegal carriage of goods
HS Codeif cargo is factory stuff ask for Factory Stuffing Permission copy with HS code as it is given with that only so you can avoid – rest Dock / CFS stuff can be push to CFS to take care.
HS CodeWe can actually take the example of South Korea’s Ministry of Ocean Affairs and Fisheries (MOF) who will establish a computer system that identifies dangerous goods in containers that may be undeclared, in order to eliminate the risk of fires and explosions.  This will help when the haz container enters the port as Non haz cargo . The shippers should not declare the cargo as non haz just to save the haz surcharge and to skip the approval procedure .
KYCDetailed root cause analysis of misdeclaration/KYC
 We all should probe customer for the cargo and also should ask for proper documents.Should be rest assured with the commodity and then proceed with booking the cargo.
InspectionArrange inspection of containers with cargo “looks like dangerous” in order to check right declaration of proper shipping name in cargo documents.
AwarenessI get the feeling that companies aren’t fully aware of their obligations and choose not to adhere to these regulations
KYCWe should not accept cargo from unknown shipper. Chances of misdeclaration of cargo is less with well known shipper
TrainingMandatory DG certification programme
Publicize defaultersPublication of possible penalties or legal interventions
 now most of the shipping lines have become tough on the dangerous cargo pertaining to the IMDG regulations as the accidents happening in the sea waters are becoming more frequent.
Penaltymisdeclaration will continue until statutory organizations world wide will not penalize shippers for such misdeeds.
AwarenessNeed proper awareness about DG goods,maintain proper document can restrict this
InspectionRandom inspection of containers with heavy penalties
 It is always better to ship cargo with correct IMDG code.
Surchargeone of main reason i found in last 14 years of my tenure in DG is, to avoid DG surcharge applied by carrier ,customer wilfully misdeclared cargo by modifying MSDS and their documents, and sometimes they are taking help of special provisions to avoid shipping it as DG. ex – 119 for imo 2, SP 188, 238 for battery, SP216 for IMO 3. as they are that we cant check exact weight for gas as per SP 119, 191 of IMDG.
Scanningcontainer scanning / checking at port may reduce misdeclaration or non declaration
ScanningDetection of undeclared lithium batteries is achievable using properly trained visual x-ray screeners and also through automation
TrainingForwarders must be trained before accepting DG shipment
Safety Data SheetMSDS should be mandatory from authorized center
Carrier policyWhole industry must exercise Uniform code of acceptance and maintain uniform standard of safety. Abolish the term high safety standard because it indicates luxury and brings affordability in the equation. Never restrict a demand but imposing difficult procedures before agreeing to supply. Supply it in a regulated manner rather than restricting manner and meet the demand. Otherwise demand will be met through mis-declaration as by nature demand meets supply, for this is the universal balance.
 Reason of Misdeclaration could be both Wilful default and Lack of awareness
InspectionI think carriers must do more inspections and advise the client and if it occurs again, should declare the incident to competent authorities when a non declared or misdeclared shipment occurs once more.
Safety Data SheetYes, check carefully data of SDS vs Shipping Papers
AwareMore awareness of the Dangerous Goods across all stakeholders and the implications of not using the correct regulations.
TrainingMisdeclared / Undeclared Dangerous Goods are in the forefront in the last few years. Big mistake done by most shippers / cargo agents across the globe is cost cutting in two areas – 1. Training and 2. Staffing. Most shippers save cost in training, which is a mandatory requirement, by having a just culture. Also they equip very few staff who do most of the tasks beyond their limits. This leads to incompetence in working.

Solution –
1. Safety Data Sheet for every cargo being presented must be taken from shipper. For Non DG cargo, a Non – DG Certificate in the shipper’s official letterhead stating that in any case of incident, accident, mis-declaration or undeclared, the shipper is fully responsible and liable to all penalties and contravenes as per applicable national law.
2. Copy of training certificate of the shipper who is actually signing the Shipper’s Declaration for Dangerous Goods and offering it to the shipping line.
 : In addition to aware ness campaigns,
Like for exporting any food product , APEDA and/or FSSAI NOC is must,
Similarly some process to be devised where in all Hazardous chemical exporters or who intend to export must be registered first with some parent body /authority and MSDS should be approved by that body before sending it to shipping lines, VOA etc , so that first check is done by competent authority.
then acceptance or rejection by Shipping lines /VOA will be taken care .
DG cargo acceptance or prohibited by particular PORT, ICD, Terminal custodian & customs in India should be closely co-ordinated , No such data is published on TC’s Or customs portals which would help in ” ease of doing business”
Enforcement/TrainingCentral enforcement agency across shipping lines, common policies across shipping lines, better laws at countries for prosecution, more education around what is dangerous cargo and what is not
 Query- from point of view of shipping agency how to know customer misdeclared dg
 Be vigilant, look for suspicious and vague cargo and packing descriptions
Awareness/TrainingMore Awareness and Training on IMDG code and Strict Policy in place for Shipper/Shipping Line

By shashi kallada

25 years in Merchant Shipping, Last 13 years working on Packaged Dangerous Goods Sailor, Ex Manager Global Dangerous Goods Maersk Line * Freelance Photographer *Amateur Cyclist

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