There are some items in ship’s stores which are listed by name in IMDG Code and some items meets the classification criteria of dangerous goods. Are ship’s stores dangerous goods?

IMO through Maritime Safety Committee circular MSC.1/Circ.1216 defines ship’s stores as “Ships’ stores means materials which are on board a ship for the upkeep, maintenance, safety, operation or navigation of the ship (except for fuel and compressed air used for the ship’s primary propulsion machinery or for fixed auxiliary equipment) or for the safety or comfort of the ship’s passengers or crew.  Materials which are intended for use in commercial operations by a ship are not to be considered as ships’ stores (e.g., materials used for diving, surveying and salvage operations).”

Some of the items in ship’s store which are listed by name in IMDG Code

1. Red Hand Flare ( UN 0191 SIGNAL DEVICES, HAND, Class 1.4G)
2. Buoyant Smoke Signal ( UN 0507, SIGNALS, SMOKE, Class 1.4S)
3. Line Throwing Appliance ( UN 0431, ARTICLES, PYROTECHNIC, Class 1.4G)
4. Life Raft (LIFE-SAVING APPLIANCES, SELF-INFLATING) ( UN 2990, Class 9)
5. Oxygen ( UN 1072, Class 2.2(5.1)
6. Acetylene ( UN 1001, Class 2.1)
7. Paint (UN 1263, Class 3)

International Maritime Organization’s The International Life-Saving Appliance (LSA) Code defines and sets forth criteria for life saving appliances.

Criteria for hand flares and buoyant smoke signals

The hand flare shall:

• be contained in a water-resistant casing,
• have brief instructions or diagrams clearly illustrating the use of the hand flare printed on its casing;
• have a self-contained means of ignition, and
• be so designed as not to cause discomfort to the person holding the casing and not endanger the survival craft by burning or glowing residues when used in accordance with the manufacturer’s operating instructions
• bum with a bright red colour,
• bum uniformly with an average luminous intensity of not less than 15,000 cd;
• have a burning period of not less than 1 minute and
• continue to bum after having been Immersed for a period of 10 seconds under 100 mm of water

The buoyant smoke signal shall

• be contained In a water-resistant casing,
• not ignite explosively when used in accordance with the manufacturer’s operating
• instructions: and
• have brief instructions or diagrams clearly illustrating the use of the buoyant smoke signal printed on its casing
• emit smoke of a highly visible colour at a uniform rate for a period of not less than 3 min when floating in calm water,
• not emit any flame during the entire smoke emission time;
• not be swamped in a seaway; and
• continue to emit smoke when submerged in water for a period of 10 seconds under 100 mm of water

Are such items in ship’s store considered as dangerous goods?

SOLAS Chapter VII Part A and MARPOL Annex III defines Dangerous Goods and Marine Pollutants in packaged form.

SOLAS Chapter VII Part A regulation 1 definition 2 states “Dangerous goods mean the substances, materials and articles covered by the IMDG Code”

MARPOL Annex III regulation 1 application 1.1 states “For the purpose of this Annex, “harmful substances” are those substances which are identified as marine pollutants in the International Maritime Dangerous Goods Code (IMDG Code) or which meet the criteria in the Appendix of this Annex.”

Further regulation 2.2 and 5 of above parts of SOLAS and MARPOL states “The provisions of this part do not apply to ships’ stores and equipment.”

Hence items in ship’s stores though listed in IMDG Code are not considered as dangerous goods and does not meet the provisions of IMDG Code when carried on board ships as ship’s store. However when these items are transported by sea from one location to another, not as ship’s store but as cargo, they must meet all applicable provisions of IMDG Code.

Dangerous goods which does not meet the definition of ship’s stores and carried on board ships must meet all the applicable provisions of IMDG Code.

For more information refer to IMDG Code, LSA Code, MSC Circular MSC.1/Circ.1216 and Marine Guidance Notice MGN 497 issued by Maritime Coast Guard Agency, U.K.