A visitor to this website asked “Is it mandatory to give the net mass and the gross mass of each package on the DG declaration?”
IMDG Code is a legal book subject to interpretation which sometimes leads to confusion.
Dangerous goods declaration as required by chapter 5.4 of IMDG Code requires shipper to declare the maximum quantity of dangerous goods as below
- Empty Uncleaned Packaging – Not required to mention quantity
- Class 1, Explosives – Net Explosive Mass
- Dangerous Goods in Salvage Packaging – An estimated quantity
- For Radioactive materials – See section 5.4.1.5.7.1 of IMDG Code
- All other Dangerous Goods – the total quantity of dangerous goods covered by the description (by volume or mass as appropriate)
For explosives, Net explosive mass (NEM) means the total mass of the explosive substances, without the packagings, casings, etc. (Net explosive quantity (NEQ), net explosive contents (NEC), or net explosive weight (NEW) are often used to convey the same meaning.)
Mass of Package
Section 1.2.2.3 of IMDG Code says Whenever the mass of a package is mentioned, the gross mass is meant unless otherwise stated. The mass of containers or tanks used for the transport of goods is not included in the gross mass.
We interpret that shipper is asked to declare the mass (gross mass) of dangerous goods and need not declare net mass separately.
Details of Inner Packing
When shipped in combination packaging the number, type and capacity of each inner packaging within the outer packaging of a combination packaging is also not required to be indicated.
Above declaration of the quantity is required for each item of dangerous goods bearing a different proper shipping name, UN number or packing group
Industry Practice
Most shipping lines insist the shippers to declare gross and net mass separately. U.S and Canadian exporters never declare net mass. Export shipments from North America declare only gross mass and all the shipping lines do accept same.
Readers are requested to submit their views about information required in dangerous goods declaration in the comment field of this article.
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It’s futile getting in to scrutinizing details that do not add value to knowledge or understanding of the RISK or enhances Response ability in times of Emergency if arises. Declaring correct Unit ( weight /volume etc) is understandable. Or if there is category of concentration or exposure to say Radio active material in which case Intensity could be important. BUt otherwise if the declaration of 15 tons included 1 ton wt of packaging or not is inconsequential to dealing with the emergency that may arise. And undermines the importance of declaration itself!!
Thanks for your inputs.
The requirement of the Code is
1. Dangerous goods description as required by section 5.4.1.4.1
2. Information which supplements the proper shipping name in the dangerous goods description as required by section 5.4.1.4.3
3. Total quantity of dangerous goods as required by section 5.4.1.5.1
4. and so forth.
The total quantity of dangerous goods must be declared for each item of dangerous goods bearing a different proper shipping
name, UN number or packing group
Examples
Example – difference in packaging type only
UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums
100 50 litres jerry cans
If the dangerous goods description differs then separate declaration is required.
Example – difference in packing group and flashpoint
UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums
UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG II (-24 Deg C.c.c.)
100 50 litres jerry cans
Example – difference in Technical name
UN 1993 FLAMMABLE LIQUID N.O.S (ABC) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums
UN 1993 FLAMMABLE LIQUID N.O.S (XYZ) Class 3 PG III (24 Deg C.c.c.)
10 150 litres steel drums
These information from individual dangerous goods declarations will be carried forwarded to IMO FAL FORM 7 columns 7. Number and kind of packages & 15. Mass (kg) Gross/Net