IMDG (IMO) Shipping by Vessel: The DG Journal Part 3 of 6, IMDG Non Bulk by Ocean Process

Welcome to this week’s installment of the DG Journal! Today we will explore the 14 essential steps in the IMDG (IMO) Shipping by Vessel process. This shipping by vessel/ocean guide will walk you through the IMDG non-limited quantity shipping guidelines step-by-step. This information is invaluable for when you are preparing your next dangerous goods shipment for ocean transport. This can be used as a reference point while on the job, or simply as a quick reminder document if it’s been a while since you trained with us. We will break down crucial details you need to know about the shipping process to include; classification, identification, packing, marking, labeling, and documentation of your next DG ocean shipment. While this guide is full of valuable information to correctly prepare dangerous goods shipments for ocean transport, it is NOT meant to replace the regulations.  We always recommend that you check official regulatory references to see if they affect your shipment. 

The 14 Essential Steps in the IMDG (IMO) Shipping by Vessel Process

1. Determine if the substance is CLASSIFIED as a dangerous good in transportation.  Most shippers will use section 14 on the material’s Safety Data Sheet (SDS). If the material is a dangerous good, the UN number and proper shipping name most likely will be found there.  It may also be provided in the company’s shipping system.
   1. If the information is not listed on an SDS or in the shipping system, the hazard class/division must be determined by comparing the physical characteristics of the materials with the classification criteria found in IMDG Part 2.
   2. If the information on the physical characteristics of the material is not available, testing must be performed to determine the hazard class(es).
   3. This section may also provide information about whether the material is a HAZARDOUS SUBSTANCE.  Check 49 CFR 172.101 Appendix A to see if the material or its components are listed.  If the material is being shipped at a quantity equal or above the listed RQ, the material is a hazardous substance and must be identified as such on the package and shipping document. It may also be identified as a Marine Pollutant (MP).
2. Check the Dangerous Goods List (IMDG 3.2 Columns 1 and 2) for the UN NUMBER and PROPER SHIPPING NAME listed in all caps.  This is the name used to identify the material on the package when required and the dangerous goods documentation (transport document).  If special provision 274 or 318 is listed in Column 6, the technical name must be shown in parenthesis with the proper shipping name. 
   1. The Dangerous Goods List in the IMDG Code is sorted by UN Number.  If the UN number is not provided, look up the proper shipping name in the index at the end of Volume 2, then look up the UN number in the Dangerous Goods List.
3. Note the PRIMARY AND SUBSIDIARY HAZARD CLASSES/DIVISIONS (Columns 3 and 4) and PACKING GROUP (Column 5) of the material.  If more than one packing group is listed, check the SDS to determine which packing group to apply.
4. Determine if the material is FORBIDDEN from transported by ocean. (IMDG 1.1.3)
5. Determine if the material is a MARINE POLLUTANT by checking Column 4 (“P”), IMDG Chapter 2.10, and the List of Marine Pollutants 49 CFR 172.101 Appendix B. If the material is a marine pollutant, it must be identified as such on the package and shipping document.  
6. Note the PACKING INSTRUCTION number in Column 8 and special packing provisions in Column 9. 
7. Read all SPECIAL PROVISIONS listed in Column 6.  Special provisions are found in IMDG 3.3.
8. Ensure the packaging complies with the general packing provisions and the specific provisions found in the packing instruction (IMDG Chapter 4.1).
9. Prepare the PACKAGING following the packing instruction and the manufacturer’s closure instructions.
10. MARK AND LABEL the package as required. (IMDG Chapter 5.2)
11. If preparing an OVERPACK, make sure to:
    1. Check Table 7.2.4 for segregation requirements, 
    2. Duplicate all labels and markings on the outside of the overpack, 
    3. Mark the outside of the overpack with the OVERPACK marking if required.
    4. If shipping more than one hazard class and sub-hazard within container transport unit, verify segregation requirements as per Table 7.2.4.
12. Complete the DANGEROUS GOODS DOCUMENTATION. (IMDG Chapter 5.4)
13. Provide appropriate EMERGENCY RESPONSE INFORMATION.  (49 CFR 171.22(g)(1))
14. Offer PLACARDS to carrier as required by IMDG Chapter 5.3 and/or 49 CFR 172 Subpart F.

Hazmat University Puts Compliance Within Reach

There is much to consider when preparing a dangerous goods/hazardous material shipment for transport of any kind. Failure to comply with key steps in the regulatory process can put everyone in the supply chain at risk. Here at Hazmat University, we make staying up to date with DG compliance easy with our wide array of easy-to-access online courses. Whether training is for yourself and/or your staff for IMDG (IMO) shipping by vessel, air or ground, we have a course that is ready to meet your needs. Let our team of seasoned Hazmat professionals guide you through best practices no matter the means of transportation so that you and your organization can be confident, be competent, and be compliant. Contact us today to get started.

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