Following the usual biennial cycle, the International Maritime Dangerous Goods (IMDG) Code has been updated and amended. This latest version, Amendment 42-24, entered transitional effect from 1 January 2025, meaning that stakeholders may start using the revised provisions. Amendment 41-22 will be mandatorily in force until 1 January 2026.

Amendment 42-24

While the new amendment may be used on an optional basis, TT Club is urging that industry and national regulators accelerate its application due to certain significant changes that have been implemented.

TT Club is urging that industry and national regulators accelerate its application due to certain significant changes that have been implemented

The high importance of the safe transport of dangerous goods through the entire freight supply chain, sadly demonstrated by incidents, both large and small, has led TT to be actively involved for many years in the technical debates leading to regulatory revisions. Such issues have also been a regular feature in TT Talk.

There have been a number of significant revisions made for this amendment. As ever in such cases, it is critical that all those having responsibility for the transport of dangerous goods by sea have access to and utilise the full text of the relevant regulatory text. However, NCB Hazcheck has provided a detailed summary of the changes, which is recommended reading.

Emerging risks

It will be seen that there are some key additions that signal ongoing work at the UN agencies. Of particular note are the various changes being ‘seeded’ relating to cells and batteries as the globe continues to drive away from reliance on fossil fuels and technologies advance. Thus, there are new entries relating to sodium ion batteries as well as electrically powered vehicles.

While such additions are broadly welcome, TT has previously expressed the concern that there has been insufficient independent and robust research into all the risks being presented by these emerged and emerging technologies. Regulatory provisions are inevitably playing catch-up; it would be preferable that they were accurately informed in advance of post-incident investigations.

TT has previously expressed the concern that there has been insufficient independent and robust research into all the risks

The most vexed question for any involved in the movement, handling and storage of any form of lithium-ion cell or battery is the cargo’s history. And history starts with a thorough and authentic testing process, closely followed by strict and auditable quality control. With the current scientific and regulatory uncertainties, initial and derivative manufacturers could do much to foster supply chain assurance.

From a generalist perspective, it is always worrying to see the introduction or continuance of any Special Provisions that have the effect of exempting any particular cargo. Experience would suggest that such provisions have a likely effect of focusing classification on the ability to take advantage of the exemption, most frequently resulting in poorer information being communicated through the supply chain. Commonly known as mis- or non-declaration, the consequence may be illegality, but certainly puts people and assets at greater risk.

Charcoal

A key reason why TT is urging early adoption of this amendment, prior to mandatory application, is due to the revisions of controls relating to charcoal shipments, which have caused multiple and frequently serious fires on containerships. The changes have been crafted to seek to combat improper preparation, packing and non-declaration that the previous provisions allowed.

TT has worked with other industry entities over recent months to provide good practice advice to all stakeholders concerning these changes. Most recently that has been with the World Shipping Council and the International Group in producing a one page reference guide in both English and Chinese. TT also worked with CINS in developing more detailed guidance on the end-to-end process of safe carriage of charcoal in containers.

The message is fairly simple: targeted at charcoal intended to be used as a fuel, the cargo has to be prepared and packed in specific ways and fully declared as dangerous goods. May safety be enhanced.

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