Amendment 34 to IMDG

7/30/2019 Amendment 34 to IMDG

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Amendment 34 to theAmendment 34 to the

International Maritime DangerousInternational Maritime DangerousGoods (IMDG) CodeGoods (IMDG) Code

Margaret FitzgeraldMargaret Fitzgerald

Senior SpecialistSenior Specialist ChemicalChemicalSafetySafety


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Dangerous goods legislation

Dangerous goods legislation has been developed over a number of

decades by various United Nations bodies to ensure that the same

safety standards are applied no matter what the mode of transport

We now have a harmonized system of legislation covering road, rail,

air and sea transport of dangerous goods

LLOYDS REGISTER EMEA


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International Legislation

Maritime transport International Maritime Dangerous Goods Code

(IMDG Code) (developed by the International Maritime Organization -

IMO)


Air transport Technical Instructions (developed by the

International Civil Aviation Organization ICAO)


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European wide legislation

Road transport ADR (developed by the United Nations Economic

Commission for Europe UN ECE)

Rail RID (developed by the Intergovernmental Organization forInternational Carriage by Rail (OTIF)

In addition, some countries have their own national legislation,


. .

in the United States


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Why the need to amend the IMDG Code?

The IMDG Code is amended on a continuous 2-yearly cycle.

This may seem excessive why the need for such a constant

revision of the Regulations?

The IMDG Code is revised for 2 reasons:

.1 to harmonise its requirements with those of the other


mo a regu a ons w c are a so up a e every years o

meet industry demand. This ensures seamless multimodal

transport from one mode of transport to another; and

.2 to respond to the needs of the international shipping

community in addressing safety issues, political issues,

commercial issues etc


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Entry into force of Amendment 34

Amendment 34 is the latest amendment to the IMDG Code

In order to facilitate the multimodal transport of dangerous goods, theprovisions of Amendment 34 to the IMDG Code may be applied from

1 January 2009 on a voluntary basis.


men men w ecome man a ory on anuary .


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The changes introduced in Amendment 34

The changes introduced in Amendment 34 may be divided into 2

categories:

Political; and

Technical



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The importance of land based activities in the

safe transport of dangerous goods by sea

IMO has over many years expressed concern about the high rate of

deficiencies and the lack of adherence to the provisions of the IMDG

Code, especially in the areas of classification, placarding andmarking, and documentation.

Maritime transport does not exist in isolation it is fed from land

transport


onward safety of the goods, particularly at sea, where any emergencyhas to be handled by the ships crew


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The importance of land based activities in the

safe transport of dangerous goods by sea

Training of shore-based personnel

The IMO Member Governments recognised that the safe transport ofdangerous goods by sea is dependent upon the appreciation, by all

persons involved, of the risks involved and on a detailed

understanding of the IMDG Code requirements


,

shore-side personnel were introduced for the first time

These requirements were only recommendatory


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The training requirements did not go far enough

However, despite IMOs best efforts, there was growing evidence that

the training requirements did not go far enough

At the last dangerous goods meeting in IMO the results of container

inspection programmes were submitted by Belgium, Canada, Chile,

Italy, the Republic of Korea, Sweden, and the United States


, ,

transport units inspected, 7,979 cargo transport units were found withdeficiencies, i.e. about 32%

A total of 8,574 deficiencies were found, i.e. a deficiency rate of

33.9%


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What was the answer?

At its 84th session in May 2008, IMOs most senior technical body, the

Maritime Safety Committee took one of the most important political

decisions it had ever taken with respect to the IMDG Code The existing training requirements were to become mandatory with

the entry into force of Amendment 34



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Let us take a look at these provisions

The IMDG Code specifies 4 types of training in relation to thetransport of dangerous goods:

General awareness/familiarization training;


Function-specific training; Safety training; and

Security training.


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Training of shore-based personnel (Chapter 1.3)

General awareness/familiarization training

Each person should receive training designed to provide familiarity

with the general provisions of dangerous goods transport provisions

Function-specific training


ac person s ou rece ve e a e ra n ng concern ng spec c

dangerous goods transport provisions which are applicable to thefunction that person performs


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Safety training

Commensurate with the functions performed, each person should

receive training on safety issues, including: methods and procedures for accident avoidance;

available emergency response information;

general dangers presented by the various classes of dangerous


goo s; an

immediate procedures to be followed in the event of an unintentional

release of dangerous goods


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Training of shore-based personnel (Chapter 1.4)

Security training

The training of shore-side personnel shall also include elements ofsecurity training

Security awareness training shall address the nature of security risks,


recogn s ng secur y r s s, me o s o a ress an re uce r s s an

actions to e taken in the event of a security breach


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Function-specific training of shore-based

personnel

The training requirements recommended in the IMDG Code for

shore-side personnel, take into account their responsibilities.

Such training is required for those who:

Classify dangerous goods and identify Proper Shipping Names of

dangerous goods;


ac angerous goo s n pac ages;

Mark, label or placard dangerous goods;

Pack/unpack CTUs;


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Function-specific training of shore-based

personnel

Prepare transport documents for dangerous goods;

Offerdangerous goods for transport;

Accept dangerous goods for transport; Handle dangerous goods for transport;

Prepare dangerous goods loading orstowage plans;

Load/unload dangerous goods into/from ships;


Carry dangerous goods in transport; Enforce orsurvey orinspect for compliance with applicable rules

and regulations; or

Are otherwise involved in the transport of dangerous goods, as

determined by the competent authority.


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Enforcing the new requirements

The key to ensuring that these new mandatory requirements bring

about a marked improvement in safety standards is enforcement

To date, there has been little response from the Flag Administrationson how they intend to enforce these requirements

Co-operation with national agencies carrying out other safety

enforcement activities is seen by many as key to ensuring the



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Other changes introduced by Amendment 34

Let us now take a brief look at the important technical changes

introduced by Amendment 34



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Chapter 2.7 Radioactive Material

The entire text of Chapter 2.7 has been replaced s a result of

harmonisation with the requirements of the IAEA, the lead body on

the development of legislation addressing the safe transport ofradioactive material



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Chapter 2.9 - Miscellaneous dangerous substances and

articles (Class 9) and environmentally hazardoussubstances (Marine Pollutants)

There has been a major re-write of the requirements for class 9 with

respect to the criteria for defining Marine Pollutants The detail of this text is only applicable to those who actually

classify Marine Pollutants and applying the criteria appears to be

have become more complex rather than simplified


Changes to Marine Pollutants

The use of the notation P to indicate a Marine Pollutant and PP to

indicate a severe Marine Pollutant has been amended. PP is no

longer used and P will now denote both marine pollutants and

severe marine pollutants.


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Changes to Marine Pollutants

The use of the notation P to indicate a Marine Pollutant and PP to

indicate a severe Marine Pollutant has been amended.

PP is no longer used and P will now denote both marine pollutants

and severe marine pollutants.


anges o mar ng

A new section 3.1.2.9 has been introduced to reflect the need to

supplement the Proper Shipping Name of Marine Pollutants with the

recognized chemical name of the marine pollutant


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The Marine Pollutant Mark

The Marine pollutant Mark has been

changed to bring it into line with the symbol

used by other modes of transport to denote

pollutants, not just marine pollutants

The Symbol is now a fish and tree;

black on white or suitable contrasting



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New Chapter 3.5 Excepted Quantities

As a result of harmonisation with other modes of transport, a new

Chapter 3.5 has been created which covers Dangerous goods

packed in excepted quantities. These are small amounts, up to 30g or 30ml per inner package, 1kg

per outer package

These are subject only to the rules of the new chapter 3.5, part 2


. .

(documentation) The Dangerous Goods Form shall state the words "dangerous goods

in excepted quantities" together with the description of the shipment


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New Chapter 3.5 Excepted Quantities

Excepted quantities will be labelled with an 'excepted quantity' label

and the class number.

Excepted quantities mark

Hatching and symbol of the same colour, black or red,

on white or suitable contrasting background


* The class shall be shown in this location.

** The name of the consignor or of the consignee

shall be shown in this location if not shown

elsewhere on the package.


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Changes to column 7 of the Dangerous Goods

List (DGL)

Column 7 has now been divided into

two;

Column 7a - Limited Quantities. This

column provides the maximum quantityper inner packaging or article for

transporting dangerous goods as limited

quantities in accordance with chapter 3.4

Column 7b - Excepted Quantities. This

column rovides an al ha numeric code

Limited and Excepted quantity

provisions


described in sub-section 3.5.1.2 which

indicates the maximum quantity per innerand outer packaging for transporting

dangerous goods as excepted quantities

in accordance with chapter 3.5

LQ(7a) EQ(7b)


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Changes to column 7 of the Dangerous Goods

List (DGL)

An entry E0 in column 7b indicates that a substance may not be

transported in excepted quantities

Codes E1 to E5 indicate different quantity limits according to a tablein chapter 3.5

The total number of excepted quantity packages in a CTU shall not

exceed 1000



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Changes to the Dangerous Goods List (DGL)

Column 12 - IMO tank instructions

The IMO tank instruction column disappears from the Dangerous

Goods List because the transitional provisions on their use will have

expired by the time this amendment becomes mandatory on 1/1/2010

Column 13 UN tanks has been renamed Tanks



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Class 5.2 label Organic Peroxides

The Hazard label for

class 5.2 has now changed

to more clearly differentiatebetween class 5.1 and 5.2

Symbol (flame): black or white

Background: upper half red;


lower half yellow Figure 5.2 in bottom corner


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Documentation Changes

Declaring a cargo as belonging to one of the Segregation

Groups

Paragraph 5.4.1.5.11.1 has been amended to permit a Shipper to

declare an N.O.S. entry not included in the segregation groups listed

in 3.1.4.4 under a Segregation Group if, in the opinion of the


,

The appropriate segregation group name preceded by the phraseIMDG Code segregation group shall be included in the transport

document after the dangerous goods description.

For example:

UN 1760 CORROSIVE LIQUID, N.O.S. (Phosphoric acid) 8 III IMDG

Code segregation group 1 Acids


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Documentation requirements for dangerous goods in

excepted quantities (new section 5.4.1.5.14)

The words dangerous goods in excepted quantities shall be included

on the transport document (5.4.1.5.14.1)



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Other documentation changes

Facsimile signatures are acceptable where applicable laws and

regulations recognize the legal validity of facsimile signatures(paragraph 5.4.2.2).

If the dangerous goods documentation is presented to the carrier by

means of electronic data processing (EDP) or electronic data


,

replaced by the name(s) (in capitals) of the person authorized to sign(paragraph 5.4.2.3)


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Lloyds Register Services

Lloyds Register is actively trying to protect the maritime industry from

unsafe practices and costly claims by focussing on the activities of

land-based personnel the clients of the shipping industry

Lloyds Register is providing dangerous goods advice, consultancy &

training in the requirements to assist shippers by ensuring that they


,

transport of dangerous goods and are capable of meeting theserequirements


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For more information, please contact:

Lloyds Register EMEA

71 Fenchurch StreetLondon, EC3M 4BS

T +44 (0)20 7709 9166


The Lloyds Register Group

works to enhance safety and

approve assets and systems at

sea, on land and in the air

because life matters.

Services are provided by members of the Lloyds Register Group Lloyds

Register, Lloyds Register EMEA and Lloyds Register Asia are exempt

charities under the UK Charities Act 1993.

+

E [email protected]

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Amendment 34 to IMDG

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