Plane Loaded in Cargo Hold of Container Ship - Photo by 2nd Mate Ashwin

Planes, Trains and Automobiles – IMDG Code 37-14

Ever since vehicles got reinserted into IMDG Code provisions for vehicles transported by sea have undergone many amendments. The latest IMDG Code, 37-14, coming into force from 1st January 2016, has revised the special provisions for carriage of vehicles and engines.

UN 3166 covers below:

  • ENGINE, FUEL CELL, FLAMMABLE GAS POWERED
  • ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED
  • ENGINE, INTERNAL COMBUSTION
  • VEHICLE, FLAMMABLE GAS POWERED
  • VEHICLE, FLAMMABLE LIQUID POWERED
  • VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED
  • VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED

Vehicles are defined as road vehicles (cars, trucks, motorcycles, ATVs, Jet skies, buses), boats, planes, tracked or wheeled farming construction equipment and other self-propelled apparatus designed to carry one or more persons or goods.

Plane Loaded in Cargo Hold of Container Ship - Photo by 2nd Mate Ashwin
Plane Loaded in Cargo Hold of Container Ship – Photo by 2nd Mate Ashwin

What are the conditions laid out in the regulations for shipping vehicles by sea?

  1. If vehicles are shipped on RO-RO vessels they are not subject to the regulations or limitations of IMDG Code because these vessels having cargo space, designated by the Administration (flag State) in accordance with SOLAS 74, chapter II-2, regulation 20, specifically approved for carrying vehicles, equipped to fight a fire if it happens.
  2. Other than vessels of above type, vehicles, loaded, containerized or not, may be considered as Dangerous Goods Class 9 or not.

In both cases there are conditions to be met for shipping vehicles by sea.

Let us cut apart the provisions of IMDG Code to find how we can ship a car by sea as dangerous goods or as non-dangerous goods.

Before stepping into the seemingly complicated rules we will try to understand what dangers are there in a car. Yes, the car we drive, travel, and hit out for holidays! A car, when burns, leaves nothing but its Skelton and emit toxic flames. It contains flammable fluid, gas, corrosive batteries, airbags, seat belts, may be extinguisher, air-conditioning gas, pneumatic or hydraulic components. Together when they go up in flame it can result in catastrophic fire, explosion and damage, especially in confined areas or in a shipping container.

Vehicles/Engines considered not dangerous must meet the conditions laid out in Special Provision 961 of IMDG Code.

Vehicles/Engines considered dangerous must meet the conditions laid out in Special Provision 962 of IMDG Code.

Non Dangerous Engines/Vehicles (SP 961)

  1. Vehicles solely powered by Lithium Batteries & hybrid vehicles powered by internal combustion engines and Lithium Ion Batteries: Batteries must be type approved as per United Nations Manual of Tests and Criteria, part III, subsection 38.3, or approved by Competent Authority
  2. Vehicles and internal combustion engines with flammable liquid fuel having flashpoint 38 Deg C or above: Not more than 450 L fuel in tank. No Leakage, Installed batteries protected from short-circuit.
  3. Vehicles and internal combustion engines with a fuel tank attached with flammable liquid fuel having flashpoint less than 38 Deg C: the tanks are empty, batteries protected from short-circuit.

Can consider empty: If the tank is drained and engine cannot be started due to lack of fuel.

No need to clean or purge: Fuel tanks, fuel lines, fuel filters and injectors.

  1. Vehicles and internal combustion engines with a fuel tank attached powered by a flammable gas: Tank empty, tank pressure not more than 2 Bar, fuel isolation or shut off valve closed and secured, batteries protected from short-circuit.
  2. Vehicles or equipment powered only by dry, wet or sodium battery: Battery protected from short-circuit.
  3. Internal combustion engines with flammable liquid or gas fuel: Fuel fully cleaned, drained or purged or engine sealed to prevent leakage of any residue.
  4. Fuel cell engines: Protected from inadvertent operation by closing fuel supply lines or by other means and the fuel supply reservoir has been drained and sealed. No need to clean or purge the thee fuel supply reservoir.

Dangerous Goods needed for the safety of the operator, passenger and operation of the engines or vehicles such as, airbags, seatbelts, battery, extinguishers, gas cylinders etc. must be properly mounted and secured. If there are other dangerous goods inside the vehicle, then such goods must meet the relevant provisions of IMDG Code. Same applies for fuel cell engines.

Dangerous Engines/Vehicles (SP962)

1.. Internal combustion engines, vehicles, fuel cell engines or battery powered equipment: No signs of leakage from batteries, engines, fuel cells, compressed gas cylinders or accumulators, or fuel tank(s);

2. Flammable liquid powered vehicles and internal combustion engines the fuel tank(s) must not be more than one fourth full and in any case the flammable liquid must not exceed 250 ℓ; if there is more fuel same must be approved by the competent authority;

3. Flammable gas powered vehicles and internal combustion engines: Fuel shut-off valve of the fuel tank(s) must be securely closed;

4. Installed batteries must be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries must be type approved as per United Nations Manual of Tests and Criteria, part III, subsection 38.3, or approved by Competent Authority;

5. Dangerous Goods needed for the safety of the operator, passenger and operation of the engines or vehicles such as, airbags, seatbelts, battery, extinguishers, gas cylinders etc. must be properly mounted and secured.

Not required to Mark, Label or Placard. Dangerous Goods Declaration is required.

Some shipping lines, for commercial reasons, may ask shippers to submit LOI while shipping hazardous or non-hazardous vehicles.

You may download sample format of LOI by clicking here

 

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