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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
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International Legislation
Maritime transport International Maritime Dangerous Goods Code
(IMDG Code) (developed by the International Maritime Organization -
IMO)
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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,
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. .
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
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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.
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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
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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
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,
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
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, ,
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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Training of shore-based personnel
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;
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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
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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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Training of shore-based personnel
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
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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,
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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;
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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;
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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
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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.
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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.
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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
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. .
(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
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* 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
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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;
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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
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,
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
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,
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
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,
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
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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.
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