As of 1 January 2012, Amendment 35-10 of the IMDG (International Maritime Dangerous Goods) Code entered full legal force. What impact does this have?

In September 2010 a survey by TT Club demonstrated that not all businesses had procedures in place to comply with the Code.

• 15% of logistics and terminal operators had not implemented an effective training programme within their own organisation

• 45% of respondents confirmed that they had clearly informed their customers of the detail of the training requirements in the Code.

• Only 30% had received documentary evidence that all relevant employees of the customer had been trained.

Amendment 35-10 is more specific than previously in requiring that employees ‘shall be trained’ and that training records have to be kept by the employer. If that is not now your position, you may face penalties for non-compliance and additional liabilities if an accident happens. The Club would reiterate its tripartite advice:

• Ensure all your own relevant employees are effectively trained;

• Inform all your customers of their obligations under the Code; and
• Seek documentary evidence that all relevant employees of your customer are trained.

Where effective training is not already in place and not easily available to you, the Club continues to recommend the e-learning system developed by Exis Technologies. Their certified course, developed by a dedicated team of specialists, is tailored to the IMDG Code requirements for both general awareness and function specific training.

Details of the course can be found in their brochure and for TT Club Members a 15% discount is available off the cost of each course.

Furthermore, you may also be interested in ‘Hazcheck Systems’ from Exis Technologies, designed for companies shipping dangerous goods in the sea transport chain. System functionality includes validation of products against the IMDG Code requirements, from packing to segregation, marking and placarding to documentation.

For additional support TT Club have also produced, in collaboration with ICHCA, an IMDG Code pocket card as a support aid for people dealing with the documentation and markings on packaging and cargo transport units. The cards do not purport to satisfy the Code's training requirements but are aimed at assisting the checks that are required to ensure that packaged dangerous goods are safely conveyed. Printed copies of these cards are available and can be obtained from your usual contact.

There is also a wealth of information on the IMDG Code available from our website.