Cause and effect of incorrect hazardous declaration and what needs to be done to avoid it

In the IMDG Code, many actions are listed but the responsibility to carry out that action may not be specifically assigned to any particular person.

The IMDG Code does however assign responsibilities to named persons or entities in certain cases, such as;

1. Shipper: for classification, assigning proper shipping name, packaging, marking, labelling, placarding, dangerous goods declaration
2. Packer: for packing of CTU and related responsibilities.
3. Master: of the vessel- responsibilities under SOLAS Chapter VII Part A & MARPOL Annex III
4. Competent Authorities: for granting exemptions and approvals

No one knows what is inside the box; everyone depends on the dangerous goods declaration.

IMDG Code states “One of the primary requirements of a transport document for dangerous goods is to convey the fundamental information relative to the hazards of the goods.”

It is the communication which matters!

Hazardous communication is on which every decision is made from acceptance to carry, what precautions are needed during transport, where to load on board a ship, whether regular monitoring is required during transport, what actions has to be taken during an emergency involving spillage, fire or medical emergency etc.

We communicate hazardous information through visual and written form

• Visual – marks, labels, placards
• Written- Dangerous Goods Declaration & Manifest to Master

Manifest is prepared on the basis of shipper’s declaration.

 

What may cause incorrect hazardous cargo declarations and what may be the effects of same?

Lack of knowledge about the IMDG Code and its responsibilities are the primary causes of misdeclaration or non-declaration of hazardous goods which may result in incidents and accidents at sea including loss of lives.

Classification of hazardous goods is the 1^st step in IMDG Code, which decides whether goods are dangerous or not, if dangerous assign UN Number, Proper Shipping Name, Packing Group and Technical name when applicable, Marine Pollutant, flashpoint etc.

A change in UN Number will change the stowage and segregation of the cargo/container entirely and during an incident it will change emergency response too.

Sometimes one UN Number having different proper shipping names are basically looking at different effects & response during emergency.

Wrongly declared flashpoint may result in container being loaded in a wrong cargo hold or weather deck on board ships.

When shipper signs in box 22 of dangerous goods declaration s(h)e certifies as below

“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 objective of IMDG Code is to enhance safe carriage of dangerous goods, to facilitate free and unrestricted movement of such goods and to prevent harm to the marine environment.

This objective is greatly dependent on all those involved in dangerous goods transport to have awareness about the risks involved and detailed understanding of the Code with respect to their duties.

 

So how can this be achieved..??

TRAINING AND AWARENESS

These are the only ways in which this problem can be avoided and in line with this, as of the 1^st January 2010, training in IMDG Code is mandatory for shoreside personnel.

Who are the shoreside personnel and what they must be trained in?

Shoreside personnel are those who:

• classify dangerous goods and identify proper shipping names of dangerous goods;
• pack dangerous goods;
• mark, label or placard dangerous goods;
• load/unload Cargo Transport Units;
• prepare transport documents for dangerous goods;
• offer dangerous goods for transport;
• accept dangerous goods for transport;
• handle dangerous goods in transport;
• prepare dangerous goods loading/stowage plans;
• load/unload dangerous goods into/from ships;
• carry dangerous goods in transport;
• enforce or survey or inspect for compliance with applicable rules and regulations

What they must be trained in?

1. General Awareness (Mandatory)
2. Function Specific (Mandatory)
3. Security (Mandatory)
4. Safety (For those who physically handle dangerous goods)

Those who prepare dangerous goods declaration should be trained in depth in

• transport document
• container/vehicle packing certificate
• competent authorities’ approval
• waste transport documentation
• special documentation, where appropriate

A wrong declaration, even a missing minus “-“ symbol may result in seafarers losing lives at sea.

The IMDG Code Compliance Centre offers various levels of training in the safe handling and transportation of Hazardous goods from a practical and theoretical perspective.

Contact the author to find out more.

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About the author : Shashi Kallada started his career in merchant ships and sailed for more than a decade. Since coming ashore in 2003, Shashi worked with P&O Nedlloyd and Maersk as a Specialist in Dangerous Goods responsible for the carriage and safe handling of DG Cargo on board over 500+ships belonging to Maersk Line, MCC Transport, Mercosul Line and Safmarine.

Since leaving the corporate world in October 2010, Shashi has been conducting training, seminars and providing consultancy in dangerous goods by Rail, Road, River and Sea via his IMDG Code Compliance Centre with a view of “Simplifying IMDG Code” and making it understandable and accessible to all.

 

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