International Maritime Dangerous Goods (IMDG) Code published by International Maritime Organization (IMO) is a mandatory instrument under The International Convention for the Safety of Life at Sea, 1974 (SOLAS) and The International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 (MARPOL).
The carriage of dangerous goods is prohibited except in accordance with the relevant provisions of chapter VII of SOLAS Convention and Regulation 1(2) of MARPOL Convention prohibits the carriage of harmful substances in ships except in accordance with the provisions of Annex III. These provisions are amplified in IMDG Code.
Regulation 1(3) of Chapter VII SOLAS states “Packaged form means the form of containment specified in the IMDG Code.” Further Regulation 1.1.2 of Annex III of MARPOL states “For the purposes of this Annex, “packaged form” is defined as the forms of containment specified for harmful substances in the IMDG Code.”
Above makes it a legal requirement for shippers to use only those packages authorized by IMDG Code for transporting Dangerous Goods and Harmful Substance by sea.
The rationale behind the packing instructions assigned to dangerous goods in IMDG Code varies from nature of hazard each goods pose and general hazard as per the common properties of dangerous goods.
Packing instructions are addressing the shipper or the person who prepares the package for dangerous goods transport and these instructions consist of (i) general instructions, (ii) specific instructions for particular hazards (iii) and for specialized dangerous goods.
General instructions consist of
- packagings in accordance with part 6.1 of IMDG Code,
- Pressure receptacles in accordance with part 6.2 of IMDG Code, packagings not subject to the provisions of parts 6.1, 6.2, 6.3, 6.5 or 6.6 of IMDG Code,
- Intermediate Bulk Containers (IBC) in accordance with part 6.5 of IMDG Code
- Large packagings in accordance with part 6.6 of IMDG Code
More specific instructions are based on certain general properties of dangerous goods.
Examples of General and Specific Packing instructions
P001 – Liquids
P002 – Solids
P003 – Articles
P004 – FUEL CELL CARTRIDGES
Class 1 (Explosives) – P100 series
Explosives may differ in classification if packages are changed. Which means classification of explosives takes into consideration how it is packed. Hence packing also takes into consideration the robustness in handling rather than their appropriateness in transport
Class 2 – P200 series
P200 – Compressed, Liquefied & Dissolved Gases and certain low boiling point substances not in Class 2
P201 – Gas Sample – Non Pressurized
P203 – Refrigerated Liquefied Gases
P205 – Hydrogen in Metal Hydride Storage System
P206 – Chemical Under Pressure
P207 – Aerosols
Class 3 – P300 series
P300 – Nitroglycerin Solution In Alcohol
P301 – Aircraft Hydraulic Power Unit Fuel Tank
P302 – Polyester Resin Kit
Class 4 – P400 series
P400 – Certain Class 4.2 substances
P401 – Certain Class 4.3 substances
Similarly, P402 to P411 is assigned to certain substances under Class 4
Class 5 – P500 series
P500 – Oxygen Generator, Chemical
P501 – Hydrogen Peroxide, Stabilized
P502 – Perchloric Acid
P520 – Organic Peroxides and Self-reactive substances under class 4.1
Class 6 – P600 series
P600 – Tear gas candles and toxic ammunitions
P601 – Certain highly toxic substances
P620, P621, P650 – Infectious Substances
No packing instructions are assigned to radioactive materials. Packaging is as per IAEA guidelines.
Class 8 –
P800 – Gallium and Mercury
P801 – Batteries
P802 – Highly corrosive substances
P803 – Bombs, Smoke, Non-Explosive
P804 – Bromine
Class 9 – P900 Series
P900 – Fishmeal
P901 – Chemical or First Aid Kit
P902 – SAFETY DEVICES, Electrically Initiated (Airbags/Seatbelts)
P903 – Lithium Batteries
P904 – Genetically Modified Microorganisms
P905 – Life-Saving Appliances, Self-Inflating/ Not Self-Inflating
P906 – Polychlorinated Biphenyls
It is imperative that shippers look into the IMDG Code in force for packing of dangerous goods and adhere strictly to the type of packages authorized and quantity limitations in respective packing instructions.
Any noncompliance to packaging may result in accidents jeopardizing lives at sea