It is a continuous learning process through experience of exposures/accidents and technological advance which makes the Safety Regulations safest. Let us take a brief look at the origin of International Maritime Dangerous Goods (IMDG) Code and where it stands today protecting lives at sea and preventing marine pollutions.
Even before SOLAS came into force in 1914 concerns were raised and discussed for the need for a regulation for safe transport of dangerous goods by sea. While submitting the proposal at the “Eighth International congress of Applied Chemistry, conducted at Washington/New York, September, 1912, Dr. Julius Abby from Antwerp said;
“I have mentioned at the beginning of this report that the importance of the question of the transportation of dangerous merchandise can no longer be ignored. If I cite a few examples hereafter, it is only because nothing else would more forcibly justify the conclusions and resolutions which I desire to put before this Congress …..It is desirable that this Congress should appoint an international commission of representatives of the chemical industry, in order to establish, and keep up to date, a list of dangerous goods; to centralize all communications on this subject; to study the special literature; to collect and examine samples; and, perhaps, organize an information service for governments, shipping companies, insurance companies, etc.”.
1948 SOLAS Chapter VI came out first time with requirements for safe carriage of Grain and Dangerous Goods. Further SOLAS 1960 brought out Chapter VII dedicated for Carriage of Dangerous Goods.
Since its inception in 1965, IMDG Code has evolved revising its regulations for safety of life at sea and the provisions to prevent marine pollution. From four volumes, running through more than 10,000 pages, the Code changed the format and became more user friendly two volumes from 30th amendment published in the year 2000.
Most of the provisions of IMDG Code has to be done ashore before loading on vessel. Every step involved in Classification, Packaging, Marking, Labelling, Placarding, Documentation, Segregating incompatible goods, Packing of container has to be in accordance with the relevant provisions of IMDG Code.
Various sections in IMDG Code prescribes the action but does not specifically point out the party or person who is responsible for that action. The shoulder(s) which need to bear the responsibilities of actions set out in IMDG Code may vary according to the individual countries laws. It remains the prerogative of each government to assign the respective responsibilities.
Shipper, Carrier and Competent Authority have differing responsibilities for consigning and carrying dangerous goods and implementing the IMDG Code. Deviation from the prescribed responsibilities may jeopardize safety and endanger lives of people especially those on board vessel.
Classification of Dangerous Goods, being the first step, carries much weightage for the correctness. Assigning the Proper Shipping Name for mixtures and solutions can be confusing at times however a simple mistake can cause disaster. The explosion of an aluminium cylinder containing ethyl chloride at Dubai airport triggered amendment to mixtures and solutions classification with more clarity in wordings.
Technical names declared influences the emergency response and medical first aid. Technical names required through special provisions 220, 274 & 318 is for medical emergencies and correct extinguishing media for firefighting. A miss declaration in this can lead to administering wrong medicines or applying wrong fire extinguishing media increasing the hazard to unlimited consequences. When the security is more a concern than accidental exposure during transport, the declaration of technical names are not needed. For example MEDICINE, LIQUID, TOXIC, N.O.S. , MEDICINE, LIQUID, FLAMMABLE, TOXIC, N.O.S need not declare the name of the constituent which makes it toxic to prevent disclosing the names of controlled medicinal substances which may lead to theft and or unauthorized usage.
With total 2826 entries in 37th Amendment, IMDG Code, ensures safety of life and prevention of Marine Pollution implementing the requirements of SOLAS Chapter VII Part A and MARPOL Annex III. Though less than 3000 entries the Generic and N.O.S. entries assist the industry to correctly declare and consign more than hundred thousand different dangerous goods.
IMDG Code applicable to transport of dangerous goods and marine pollutants in packaged form limits the size of package for different goods perceiving the threat it may pose during transport. Interestingly more than 1700 entries are assigned with tank codes allowing them to be transported by Portable Tanks. That’s more than 50% of the listed entries allowed in bulk packaging. Transport of bulk liquid dangerous goods is increasing globally and the provisions for tanks and the tank industry is meeting up the safety standard with lesser incidents and accidents to their records.
IMDG Code prohibits only certain goods. These are substance or article which, as presented for transport, is liable to explode, dangerously react, produce a flame or dangerous evolution of heat or dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport and certain substances which are forbidden for transport are listed in chapter 3.3, special provisions 349, 350, 351, 352, 353 and 900. Above this carriers may have their own prohibition list to reduce the possibility of exposing themselves to risks. This may involve risks from accidents, like carrying explosives, exposure to radioactive materials and risks for causing delay to vessel schedule. A sailing schedule can be interrupted when carrying goods which are highly restricted through ports, example Cobalt-60 or waste requiring BASEL notification, and cause economical loss to carriers disproportionate to the freight charges earned.
Apart from the concerns of safety and prevention of pollutions transport of dangerous goods also need to be looked under the glasses of security. Chapter 1.4 of IMDG Code identifies High consequence dangerous goods as those
which have the potential for misuse in a terrorist event and which may, as a result, produce serious consequences such as mass casualties, mass destruction or, particularly for Class 7, mass socio-economic disruption. The indicative list in section 126.96.36.199.2 does not preclude the application of security measures when deemed fit. An example is the need of security concern for transporting potassium nitrate in non-friable prills or granules as non-dangerous goods.
Among the amplified sections of SOLAS IMDG Code stands unique in its regulations referred and applied by experts and laymen together. A trader who is not an expert in chemistry can find the requirement for authorized packaging, quantity limit per package and subsequent provisions for offering to transport dangerous goods by Sea. This at times create ambiguity in understanding and interpretation by various parties involved in transport and has cause disasters too. To ensure the appreciation of hazard involved and the details understanding of regulations IMDG Code made training of shore side personnel mandatory from 1st Jan 2010.
Today, in the year 2015, we are shipping dangerous goods where either 36th or 37th amendment can be applied.
Below are the major changes to IMDG Code 37th amendment:
* New section for Lamps containing dangerous goods in application and implementation sets out conditions for lamps which are not subject to the provisions of IMDG Code.
* Addition of International Convention for Safe Containers, 1972, as amended covering Regulations for the testing, inspection, approval and maintenance of containers.
* Changes in general provisions concerning radioactive material
* Addition of Adsorbed gas under class 2
* Changes to assignment of packing group of viscous flammable liquids
* Changes to text in Classification of solid substances of class 5.1
* Amendments to exemptions under Infectious substances
* Various changes in chapter 2.7 for radioactive materials
* Changes to proper shipping names for some goods under class 9 and clarification of absence of letter P in column 4 of dangerous goods list. ( Airbags, Seat Belts, Capacitors)
* Column 16 stowage and segregation now replaced with column 16a and 16b, Stowage and handling & segregation
* Various changes to dangerous goods entries with respect to packing instructions, marine pollutant, special provisions and complete change of column 16 being replaced by stowage, handling and segregation codes.
* Addition of new UN Numbers from 3507 to 3526
* Changes to many existing and addition of 12 new special provisions
* Amendment of limited quantity marking and placarding
* Amendment to excepted quantity marking
* Amendment to some packing instructions and addition of new packing instructions
* New size requirement of OVERPACK marking from 1st Jan 2016
* Various changes to labels and placards
* Various changes in documentation and fumigation & Coolant/conditioning warning mark
* Changes in construction and testing of packagings