As years go by, serious incidents caused by or involving dangerous goods continue to occur, not only on ships but also in ports. Errors, misunderstandings, misdeclarations and inadequate packing and securing lie at the heart of many of these incidents. As ultra-large container ships and the marine terminals they call at increase in size and capacity, the potential for economic, human and environmental accidents rise in proportion.

This guide is intended to support shippers, forwarders, shipping line booking staff and those who pack dangerous goods into cargo transport units for carriage by sea in the technical aspects of the IMDG Code.

It is projected that by assisting parties to understand their own duties and the duties of other actors in the transport chain, both communications and compliance can be enhanced.

This edition reflects the position in the IMDG Code Amendment 41-22 which is mandatory from 1 January 2024 and follows all the steps required when booking and packing a consignment of dangerous goods with a shipping line.

The guide presents the operational steps in Part A, supported by a general reference section in Part B.

Part A of the guide breaks down the process of preparing and booking the cargo into the following steps, and looks at the roles and requirements for the parties involved in each step:

Step 1: Classification of dangerous goods

Step 2: Selection of packaging

Step 3: Marking and labelling the packages

Step 4: Preparing the transport document for booking with the shipping line

Step 5: Applying the segregation rules

Step 6: Packing the cargo transport unit

Step 7: Producing the cargo transport unit packing certificate

Part B provides background to the IMDG Code and references to further materials.

The IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code) has been adopted as non-mandatory international law and is a referenced from the IMDG Code. This guide will refer to the CTU Code as the definitive industry guidance document on how to pack and secure cargo of all types in cargo transport units.

This guide is intended to help shippers, shipping line booking staff, and those who pack dangerous goods into cargo transport units to get an overview of their key practical duties under the IMDG Code and does not seek to meet the mandatory training requirements.

This guide consists of Part A and Part B

Part A

This covers the operational processes and documentation involved in preparing and presenting a consignment of dangerous goods for shipment. Part A uses terms from the IMDG Code that are explained in the reference section, Part B.

Part B

This is a reference section that explains the basic principles of the UN classification system, the technical terms used in the IMDG Code, and provides useful background information on common IMDG issues such as Limited Quantities procedures.

The IMDG Code is a lengthy manual set out in the same UN intermodal documentary format as other UN transport model regulations based on part, chapter, section, and sub-section numbers to identify the location of information within the document. IMDG Code text references appear in this guide to take readers to the relevant place in the IMDG Code text where the full details will be found. For example, reference IMDG 5.4.1.4. refers to Part 5, Chapter 4, Section 1, Sub-section 4, titled “Information required on the dangerous goods transport document.”

The International Maritime Dangerous Goods (IMDG) Code governs the processes by which dangerous cargoes may be transported by sea. It was first published by the International Maritime Organization (IMO) in 1965. Since January 2004 the Code has been mandatory for SOLAS (Safety of Life at Sea Convention) signatory states, effectively making it a global rulebook for the sea transport of dangerous goods.

Although it is directed primarily at sea transport, the provisions of the Code affect a broader range of industries and services – manufacturers, packers, shippers, inland transport operators (road, rail and inland waterway), port authorities and terminal operators. The IMDG Code is based on the same ‘Orange book’ (UN Recommendations on the Transport of Dangerous Goods – Model Regulations) as other modal dangerous goods regulations. IMDG provides authoritative advice on classification, stowage, segregation, packing, labelling, terminology and emergency response action.

Unfortunately, the number of incidents involving dangerous goods worldwide tells us that the rules are not universally followed. Factors such as desire to save cost, lack of knowledge and training, and failure in communications between geographically distant actors in the transport chain, conspire to create the potential for errors.

This guide provides an overview on the key provisions and considerations of the IMDG Code when shipping dangerous goods by sea, and provides guidance if common errors are to be avoided. Much depends on the skill and awareness of the personnel packing the shipping containers – skills that are often under-rated and under-valued.

Any person or organisation offering dangerous goods or packing cargo transport units that do not comply with the IMDG Code, or follow the guidance provided in the CTU Code, is in a precarious position if that non-compliance leads to an incident. It can put lives at risk, and lead to property and environmental damage. The party responsible will be liable to prosecution, fines by national maritime enforcement agencies and to civil court actions to compensate other actors for costs incurred arising from damage to the ship, cargo and environment, injury and loss of earnings, etc. See the case study from ‘MSC Flaminia’ incident – pages 97-98.

International standard for safe packing of cargo transport units

Properly known as “The 2014 IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units”, the CTU Code was developed by the IMO (International Maritime Organization), the ILO (International Labour Organization) and UNECE (United Nations Economic Commission for Europe) to provide global non-mandatory recommendations on best practice for handling and packing cargo transport units for transport by road and sea. The CTU Code and accompanying materials were approved by the UN agencies during 2014.

Poor packing practices and improperly secured loads give rise to a majority of incidents along the international transport supply chain, resulting in damage, loss and injuries on land and at sea.

It is recognised that there has been a lack of guidance and training materials for personnel at the “sharp end” of the cargo handling industry, and the CTU Code sets out to address this.

Within the CTU Code, comprehensive information and references on all aspects of packing and securing of cargo in containers and other intermodal transport units are provided, taking account of the requirements of sea and land transport modes. The CTU Code applies to transport operations throughout the entire intermodal transport chain and provides guidance not only to those responsible for packing and securing cargo, but also to those who receive and unpack such units. The Code of Practice also addresses issues such as training and the packing of dangerous goods.

The CTU Code and related material is freely available from the UNECE searchable website at

https://wiki.unece.org/display/TransportSustainableCTUCode/CTU+Code

and the IMO at

https://www.imo.org/en/OurWork/Safety/Pages/CTU-Code.aspx

Cargo Integrity Group

A group of industry entities is collaborating to improve standards for the safe and secure packing of cargoes in cargo transport units and the avoidance of contamination by invasive pests. Since January 2022 the group comprises Bureau International des Containers et du Transport Intermodal (BIC), Container Owners Association (COA), International Federation of Freight Forwarders Associations (FIATA), Global Shippers Forum (GSF), International Cargo Handling Co-ordination Association (ICHCA International), TT Club and World Shipping Council (WSC).

This group published ‘CTU Code – a quick guide’ as a route-map for the broad industry to engage more successfully with the CTU Code and to assist wider understanding of good packing practices. A complementary Container Packing Checklist sequences the main check-points from a container packer’s perspective, supporting sound decision-making. Successful completion facilitates safe and secure dispatch of a container, and avoidance of pest contamination based on CTU Code.

Further information can be found at:

https://www.ttclub.com/loss-prevention/cargo-integrity/

If you are responsible for classifying, packaging, declaring and documenting dangerous goods, or packing them into a cargo transport unit, you have a legally binding duty to do so in accordance with the rules of the IMDG Code.

To assist with packing and securing all types of cargo into cargo transport units extensive practical guidance is now freely available in the CTU Code.

If you are the packer it is your responsibility to ensure that any dangerous goods dispatched by you for maritime transport are correctly identified, labelled and segregated, and secured inside the cargo transport unit so that they cannot move, that packages will not collapse or otherwise be damaged, allowing product to leak or escape from the packaging during carriage, and you must certify that you have complied with this responsibility by issue of a signed packing certificate.

Failure by packers to carry out this safety critical operation in compliance with the IMDG Code will have serious financial and legal consequences for those responsible in the event of that non-compliance being the cause of an incident.

Duties to train employees

If your organisation is involved in packaging or shipping dangerous goods, preparing or processing dangerous goods transport documents, or packing dangerous goods into cargo transport units, your personnel must understand the provisions in the International Maritime Dangerous Goods (IMDG) Code. To follow these provisions your personnel need to be trained to understand them and the reasons for them. Chapter 1.3 of the IMDG Code has detailed guidance on what training is required for specific job functions.

In addition to specific IMDG Code requirements, most countries also have domestic legislation that creates an employer’s duty of care to provide training in safety critical operations for the safety of their employees and others, which of course includes the handling and packing of dangerous goods for maritime and other modes of transport.

Training is a key requirement of the IMDG Code (see IMDG Chapter 1.3 for the training requirements)

Depending on their role, your staff may be required to understand the following:

• The legal responsibility to identify dangerous goods accurately
• Where to locate required information in the IMDG Code
• How to identify different classes of dangerous goods
• How dangerous goods data should be presented on a transport document and what that data means
• How packages should be marked and labelled
• How to make up, mark and label dangerous goods in palletised unit loads
• The IMDG Code segregation rules for the separating of dangerous goods that have the potential to react with each other
• How to stow and secure packages of different types and sizes in cargo transport units so the packages will not slide, roll or collapse under the weight of over-stowed cargo during the sea journey
• The rules for placarding and marking shipping containers
• The legal responsibility accepted by the packer by signing a packing certificate.

Full operational competence can only be achieved by providing appropriate training consistent with the employee’s level of control and responsibility in the transport chain. It is essential that supervisory employees are trained to understand the IMDG Code rules, and have access to the rules for reference, as different substances require different handling; that those with the responsibility for compliance must be given the knowledge and authority to maintain procedures that ensure the provisions of the IMDG Code are carried out operationally.

IMDG Code dangerous goods training guide for shore-based staff

IMDG Chapter 1.3 indicates that shore-based personnel involved with dangerous goods should have training appropriate to their job role and level of responsibility in one or more key areas. Records of all training should be kept by the employer.

1. General awareness/familiarisation training¹

   – all persons should be trained to be familiar with the general provisions of the transport of dangerous goods, including the classes, labelling, marking, placarding, packing, segregation and compatibility, the purpose of the dangerous goods transport document and the container/vehicle packing certificate.

2. Function-specific training²

   – persons must be trained in the specific dangerous goods transport provisions that are applicable to the function(s). A guide to what provisions are applicable to specific job functions is provided in the table in IMDG 1.3.1.6.

3. Safety training³

   – commensurate to the risk of exposure in the event of a release of dangerous substances and the functions involved, persons involved in the handling of dangerous goods, or located in the vicinity of where they are handled, should be trained in:

•  Procedures for accident avoidance such as proper control of cargo handling equipment and appropriate stowage of packages
• Available emergency response information and how to obtain it
• General dangers presented by the various classes of dangerous goods, how to avoid exposure and where applicable, how to use or wear appropriate Personal Protective Equipment (PPE)
• Immediate procedures to be followed in the event of an unintentional release of dangerous goods to protect self and others.

IMDG Recommendations for training shore-based personnel

There is a useful table in IMDG 1.3.1.5 which identifies functions that shore-based personnel carry out, and provides specific training recommendations for those engaged in that function.

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¹ IMDG Code, 2022 Edition Amendment 41-22, Section 1.3.1.2.1

² IMDG Code, 2022 Edition Amendment 41-22, Section 1.3.1.2.2

³ IMDG Code, 2022 Edition Amendment 41-22, Section 1.3.1.4

Shippers and shipping line staff should be aware that ships, ports and container terminals are key infrastructure elements and are potential terrorist targets. They are subject to the provisions of the International Ship and Port Facility Security (ISPS) Code that requires ship and port operators to take precautionary measures to defend against acts of terrorism.

High Consequence Dangerous Goods⁴ (HCDG)

Certain types of dangerous goods have been identified as having significant potential for misuse by terrorists intending to instigate an event leading to mass casualties or mass destruction.

Shore-based staff employed by organisations handling HCDG should be aware of the increased risk factor, and maintain a security plan to defend against terrorists taking advantage of the destructive potential of such dangerous goods.

The security plan should include security training to ensure employees adopt practical measures to identify, report and reduce security risks, and to keep critical transport information confidential.

High consequence dangerous goods include some of the higher risk substances and articles in Classes 1, 2, 3, 4, 5.1, 6 and 8. The list of specific items and details of the type of defensive measures to be taken are found in IMDG 1.4.3.

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⁴ IMDG Code, 2022 Edition Amendment 41-22, Chapter 1.4

Not all bookings for all dangerous goods can be accepted for all ships and all routes. Full details will be required from the shipper in the first instance.

Many ships are restricted as to the types and volume of dangerous goods they can carry because of ship design or insurance restrictions, particularly so in the case of explosives and radioactive materials which also have special stowage requirements.

Most ports restrict handling and transit of explosives and radioactive materials where safety, security, social and political factors are weighed beyond the practicalities of marine transport. Volumes shipped of these commodities are relatively low and carried out by specialists. Therefore, only the basic IMDG Code requirements of both explosives and radioactive materials will be dealt with in this guide.

Many ports restrict other types of dangerous goods (e.g. ammonium nitrate) for safety reasons. To determine whether the line can accept the dangerous goods booking, and whether any special conditions or volume restrictions will apply, the shipper will need to supply the information contained in the following sections. Based on the type of dangerous cargo, the rules of the ports of transit and discharge, and the class of ship available, the booking will be either rejected or accepted and passed on to the next stage.