The regulations involving the transportation of hazardous materials by vessel can often appear somewhat complex; however one area specific to the packaging and/or loading of these materials continues to be overlooked by some parties involved in the movement of these commodities. Each cargo transport unit containing a hazardous material such as a freight container, flat trailer or other vehicle intended for transport by sea must be packed and/or loaded in accordance with the regulations defined in the International Maritime Dangerous Goods (IMDG) Code.
It is important that those involved in the packaging and/or loading operations of these materials fully understand and comply with the container packing certification requirements outlined below.
As defined in the IMDG Code, Section 126.96.36.199, those responsible for the packaging/loading of a cargo transport unit should provide a “container/vehicle packing certificate” which specifies the container/vehicle as well as the cargo transport unit identification number(s). This certification is provided to insure that compliance with these requirements has been properly met.
This certification can be in checklist format and must define the following conditions:
- The cargo transport unit was clear, dry and apparently fit to receive the goods
- If the consignments include goods of Class 2, other than Division1.4, the cargo transport unit is structurally serviceable in conformity with 7.4.6
- Goods which should be segregated have not been packed together onto or in the cargo transport unit (unless approved by the competent authority concerned in accordance with 188.8.131.52).
- All packages have been externally inspected for damage, leakage or sifting, and only sound packages have been loaded.
- Drums have been stowed in an upright position, unless otherwise authorized by the competent authority
- All packages have been properly packed onto or in the cargo transport unit and secured.
- When dangerous goods are transported in bulk packaging, the cargo has been evenly distributed.
- The cargo transport unit and the packages therein are properly marked, labeled and placarded.
- When solid carbon dioxide (CO2- dry ice) is used for cooling purposes, the cargo transport unit is externally marked or labeled in a conspicuous place, which as at the door end, with the words “Dangerous CO2 Gas (Dry Ice) Ventilate thoroughly before entering.”
- The dangerous goods transport document required in 5.4.1 has been received for each dangerous goods consignment packed onto or in the cargo transport unit.
It is additionally; recommended that the following be incorporated on the packing certificate: “It is declared that the packing of the goods into the unit has been carried out in accordance with the provisions of 184.108.40.206 of the IMDG Code.”
The container packing certificate must be signed by the person who prepares this statement. IMDG Code, Section 220.127.116.11 requires the person who affixes the signature also be identified on the document.
The intended purpose of the container packing certificate is to convey a statement that the container has been properly inspected and packages containing the hazardous materials inside the container are in good condition and properly secured.
Although the container packing certificate is often missing during shipment, it would only make sense that the person who prepares the container for shipment is ultimately responsible to insure that the goods, as well as the container, are properly prepared for safe transportation.
Therefore, proper education of all parties involved with these requirements is paramount. Understanding the intent of these regulations, as well as complying with them, will only help to reduce many of the current identification and safety problems associated with hazardous material transported by vessel.