Inspection of Dangerous Goods Containers & Checklist to Compliance

Inspection of Dangerous Goods Containers & Checklist to Compliance

Inspection of Dangerous Goods Containers & Checklist to Compliance

Mr Shashi Kallada, renowned Trainer/Consultant – Dangerous Goods By Rail, Road, River and Sea, is today engaged in providing training and consultancy in dangerous goods by sea, on chemical warehousing and related subjects. He has more than 1,600 hours of dangerous goods training experience. Having authoritative knowledge on the subject, he earlier handled dangerous goods for major lines like Maersk and P&O Nedlloyd during more than a decade of sailing experience on merchant ships.

Member countries of International Maritime Organization (IMO) conduct inspection of containers carrying dangerous goods and marine pollutants for compliance to IMDG Code and other applicable regulations. Inspection may be carried out on board ships or in port areas.

Maritime Safety Committee Circular MSC.1/Circ. 1442 lays down the scope of inspection and items to be inspected, and includes:

* Documentation

* International Convention for Safe Containers (CSC) Safety Approval Plate and plating in accordance the IMDG Code for portable tanks

* Placarding and marking of CTUs

* Marking and labelling of packages

* Packaging (inappropriate or damaged)

* Portable tank or road tank vehicles not covered by CSC (inappropriate or damaged)

* Stowage/securing inside the freight containers, vehicles and other CTUs

* Segregation of cargo

* Approved Continuous Examination Program (ACEP) or Periodic Examination Scheme (PES) label

* Serious structural deficiencies and tie-down attachments of road tank vehicles

When deficiencies are noted

Depending on types of deficiencies noted, a container may be put out of service, cargo may be put on hold and/or penalties may be imposed, and the inspecting authority will submit the report to IMO.

Notification to shippers’ country

Section 1.1.1.8 of IMDG Code states, “When a competent authority has reasons to believe that the safety of the transport of dangerous goods is compromised as a result of serious or repeated infringements of IMDG Code by an enterprise which has its headquarters on the territory of another competent authority, it should if necessary notify that competent authority of such infringements.”

This notification will be issued whenever such infringement is noticed and is not restricted to inspections as per Maritime Safety Committee Circular MSC.1/Circ.1442

Checklist to compliance

To ensure compliance to IMDG Code and other applicable rules, shippers can verify compliance to items which are subjected to inspection by authorities.

These items are not in chronological sequence of an actual inspection and shippers may verify compliance in any order as deemed practical. This checklist does not preclude compliance to other required provisions of IMDG Code and National/Regional Regulations with which the shipment may require compliance.

Condition of packaging

1. Is the type of packaging permitted by packing instructions in dangerous goods list of chapter 3.2 of IMDG Code

2. Is the packing design type approved as required by paragraph 4.1.1.3 of the IMDG Code

3. Does the approved packing group(s) of the design type (X, Y or Z) match with the packing group of the goods (I, II or III)

4. Is the single packaging used for liquids approved for liquids

5. Check whether plastic drums and jerricans, plastic inner receptacles of IBC, are not exceeding the five years period of use

6. Check for rigid IBCs, that the periods of inspections as required in paragraph 4.1.2.2.1 of the IMDG Code are not exceeded

7. Check the packages are sound and without serious damages (simple defects, e.g. traces of use, are insignificant under safety aspects and have no effects on the legally prescribed performance level of the package). Inspecting authority has the jurisdiction to decide what is simple defect and serious damages.

Marking and labelling of packages

These items are to be checked for marking and labelling of packages. Depending on the type of consignment, example, limited quantities or exemption from marking of marine pollutant mark as per 2.10.2.7/5.2.1.6.1 of IMDG Code, there may be variations. Check the individual schedule and special provisions for compliance.

1. Proper Shipping Name

2. Technical Name when required by special provisions 274 or 318

3. Hazardous Class Label

4. Subsidiary Risk Label

5. Marine Pollutant Mark

6. Orientation Mark

7. Limited Quantities Mark

8. Lithium Battery Mark

9. Excepted Quantities Mark

CSC Safety Approval Plate, Tank, Road Tank and MEGC Identification Plate marking, and serious structural deficiencies of cargo transport units

1. Container Safety Convention (CSC) Safety Approval Plate and its validity;

2. Approved Continuous Examination Program (ACEP); or

3. Periodic Examination Scheme (PES) label;

4. Serious structural deficiencies of frame elements including corner and intermediate fittings [refer to resolution MSC.310(88)] and, for portable tanks, the condition of tank accessories;

5. Tie-down attachments of road tank vehicles;

6. With respect of tanks and MEGCs, the metal plate as described in chapter 6 of the IMDG Code, its validity and periodic inspection and test dates, where appropriate

a) The metal plate on portable tanks as described in paragraphs 6.7.2.20, 6.7.3.16, and 6.7.4.15;

b) The metal plate on MEGCs as described in paragraph 6.7.5.13;

c) The metal plate on road tanks used for sea transport (IMO type 4) as described in paragraph 6.8.3.1.3.4;

d) The metal plate on road tanks used for sea transport (IMO type 6) as described in paragraph 6.8.3.2.3.4;

e) The metal plate on road tanks used for sea transport (IMO type 8) as described in paragraph 6.8.3.3.3.4; and

f) The metal plates on tanks may show markings required by other regulations.

Condition of the stowage/securing inside Cargo Transport Units

1. The mass of the cargo is evenly distributed over the floor; heavy packages are sufficiently supported

2. The centre of gravity is close to the mid-length of the CTU

3. Where appropriate, void spaces are filled with dunnage, cardboard, air bags or other suitable material to ensure a minimum likelihood of movement of packages/cargo during transport

4. The cargo is secured against movement towards the door

5. If the cargo is secured by blocking or lashing, the securing material is of appropriate strength and lashings are sufficiently tensioned

6. Packing should comply with CTU Code, and/or appropriate national legislation

Segregation of dangerous goods inside CTUs

Items to be checked for segregation when consolidating different dangerous goods:

1. The segregation table in paragraph 7.2.1.16 of the IMDG Code has been applied correctly for the hazard classes and subsidiary risks

2. Specific segregation requirements as indicated in column 16b of the dangerous goods list have been complied with

3. Specific segregation requirements for the different compatibility groups of class 1 have been complied with

4. Segregation requirements in relation to foodstuffs have been observed.

Placarding and marking of Cargo Transport Units Placards

1. Freight container, trailer or portable tank: one on each side and one on each end of unit

2. Railway wagon: at least on each side

3. Multiple-compartment tank containing more than one dangerous substance or their residue: along each side at the positions of the relevant compartments

4. Any other CTU: at least on both sides and on the back of the unit.

Proper Shipping Name

The Proper Shipping Name of contents shall be marked on at least both sides of:

1. Tank transport units containing dangerous goods

2. Bulk containers containing dangerous goods

3. Any other CTU containing packaged dangerous goods of a single commodity for which no placard, UN Number or marine pollutant mark is required

UN Number and other marks

The UN Number for the goods and, if required, other placarding and marking such as elevated temperature, marine pollutant, limited quantity and fumigation warning sign, as provided in IMDG Code.

Documentation

* Dangerous goods transport document

* Container/vehicle packing certificate

* Documentation for tanks used to transport dangerous goods

* Other information and documentation

Items to be checked for each dangerous goods for compliance with section 5.4.1 of IMDG Code:

1. UN number preceded by the letters “UN”

2. Proper Shipping Name: Proper shipping names that are assigned special provision 274 in column 6 of the dangerous goods list shall be supplemented with their technical or chemical group names as described in paragraph 3.1.2.8 of the IMDG Code

3. Primary hazard class or division of the goods

4. Subsidiary hazard class or division number(s)

5. Packing group for the substance or article that may be preceded by “PG” if provided

6. Other applicable information required by section 5.4.1 of the IMDG Code

7. Proper certification or declaration required by paragraph 5.4.1.6 of the IMDG Code

8. The classification of the goods is consistent with the properties of the material as described in the Material Safety Data Sheet

Documentation for Tanks

1. Suitability of portable tanks as per certificate mentioned in paragraph 4.2.1.8 of the IMDG Code

2. Suitability of road tanks used for class 3-9 substances as per the certificate mentioned in paragraph 6.8.3.1.3.2 of the IMDG Code

3. Suitability of road tanks for class 2 substances (IMO type 6), non-refrigerated liquefied gases as per the certificate mentioned in paragraph 6.8.3.2.3.2 of the IMDG Code

4. Suitability of road tanks for refrigerated liquefied gases (IMO type 8) as per the certificate mentioned in paragraph 6.8.3.3.3.2 of the IMDG Code

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