What is Dangerous Goods Declaration and who should submit it..??

Hazardous cargo or Dangerous Goods (DG) refers to

1. substances, materials and articles that are classified in the International Maritime Dangerous Goods (IMDG Code) as goods that are of a flammable, corrosive, poisonous nature or other properties ;
2. substances classified in chapter 17 of the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code) and chapter 19 of the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) ;
3. oils as defined in MARPOL Annex I ;
4. noxious liquid substances as defined in MARPOL Annex II ;
5. harmful substances as defined in MARPOL Annex III ; and
6. radioactive materials specified in the Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships (INF Code).

The safe carriage of Dangerous Goods requires several considerations, processes of approval, acceptance, carriage protocols and documentation..

IMDG Code (International Maritime Dangerous Goods) is a code adopted by the Maritime Safety Committee of the International Maritime Organization by resolution MSC.122(75) for the transportation of Dangerous Goods..

 

Dangerous Goods Classes

In the IMDG Code, substances are divided into 9 classes as below.. A substance with multiple hazards has one ‘Primary Class’ and one or more ‘Subsidiary Risks’..

• Class 1 – Explosives
• Class 2 – Gases; compressed, liquefied or dissolved under pressure
• Class 3 – Flammable liquids
• Class 4 – Flammable solids; substances liable to spontaneous combustion; substances which, in contact with water, emit flammable gases
• Class 5 – Oxidizing substances (agents) and organic peroxides
• Class 6 – Toxic and infectious substances
• Class 7 – Radioactive materials
• Class 8 – Corrosives
• Class 9 – Miscellaneous dangerous substances and articles non-classified materials

For the shipping line/carriers, while containerisation brought along ease of handling cargo, it also brought about the headache of not knowing WHAT IS INSIDE THE CONTAINER..

Carriers have no way of knowing what is inside the container and depend on the STC and SLAC information provided by the shipper..

For dangerous goods, prior to packing, this cargo information is provided to the carrier in the form of the Dangerous Goods Request (DGR) and after packing, in the form of Dangerous Goods Declaration (DGD – a.k.a MULTIMODAL DANGEROUS GOODS FORM) along with Dangerous Goods Labels..

The vessel only sees the Dangerous Goods Declaration on paper or on-screen and the labels on the container and have to use this information for purposes of stowage planning.. As very rightly emphasised by IMDG Code Compliance Centre,

In maritime transport the decision to place a container on a specific location on board vessel is purely taken from the information provided in Dangerous Goods Declaration. Majority of the stakeholders do not physically see the packages or containers with its labels, marks, or placards to make any decision to accept to load or where to place it viz on deck or under deck or the segregation from other containers. This sums up the prime importance of correctly filled dangerous goods declaration.

The DGD has VERY IMPORTANT INFORMATION for all to read, consider and understand..

 

What is a Dangerous Goods Declaration..??

A Dangerous Goods Declaration is the only document that contains all the information relating to the goods in terms of

• Vessel/Voyage
• Description
• Quantity of Dangerous Goods
• UN No.
• Hazard Class
• Proper shipping name and the technical name
• Packaging Group
• Type and make of packaging
• The container number in which these dangerous goods are packed

to name a few points of importance..

Apart from the DGD reflecting the ACTUAL details of the goods packed in the container, it should also match what was submitted to the carrier at the time of the DG Request..

Remember that the carrier approves the dangerous goods for carriage based on the information provided at the time of the request and if the information in the DGD is different, it will create problems for the shipper as they may be forced to unpack or rework the container to reflect the actual goods that were approved..

Worse still, if the carrier does not verify the DGD against the DGR and it turns out that the final cargo loaded was a prohibited item for the carrier and/or the port of load or destination, it could delay the ship operations which could turn out to be very costly for the erring party..

 

Who is responsible to submit the DGD..??

As I have explained previously, shipper and exporter are different entities and need not be the same.. There is also another entity in the picture and that is the manufacturer of the goods..

It is entirely possible that the manufacturer, exporter and shipper are all totally different but equally important parties..

At the time of approval of DGR, the carrier invariably requests for an MSDS = Material Safety Data Sheet..

The purpose of the MSDS is to provide elaborate information about

1. the physical and chemical properties of the cargo like the three main points such as flash, boiling and melting points
2. the nature of the cargo indicating its toxicity
3. effects on one’s health
4. the first aid that needs to be administered in case of adverse contact
5. possible reactions
6. methods of storage
7. methods of disposal
8. protective equipment to be used by people that come in contact with the material
9. spill-handling procedures

The manufacturer is the entity best suited to provide the MSDS to the exporter or shipper as they are manufacturing the cargo and will have all the detailed information relating to the dangerous goods..

The information in the MSDS is used to complete the DGR and the DGD..

Since the manufacturer may or may not be the actual shipper, the onus to provide the DGD rests on the shipper because the shipper is the entity who has entered into the contract of carriage with the carrier and is the entity responsible for the packing and delivery of the container to the carrier’s stack in the container terminal..

The DGD reflects a declaration from the shipper that reads

I hereby declare that the contents of this consignment are fully and accurately described below by the Proper Shipping Name, and are classified, packaged, marked and labelled/placarded and are in all respects in proper condition for transport according to the applicable international and national governmental regulations.

The shipper also signs Box 22 of the DGD certifying that they have prepared and provided the details for the DGD

As per IMDG Code section 5.4.1.6.1, “The certification on the dangerous goods transport document shall be signed and dated by the consignor” where consignor means shipper and not the manufacturer or the trader from whom the consignor procured the goods or the exporter..

 

While who submits the DGD may be more relevant for the identification of liability and responsibility, whoever prepares, completes, checks, signs and submits the DGD to the carrier, must ensure that the right information is provided because incorrect details could lead to maritime disasters including loss of lives..

 

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