Some provisions and exemptions of the ADR code are different in comparison to the IMDG code. Some key examples of this are: requirements for flashpoints, declaring consignments transported in limited quantities, technical names required for marine pollutants, a compliant container/vehicle packing certificate and additional conflicts between UN numbers, especially relating to acids and alkalis. It is important to note that, when a hazardous load is being transported by sea, the IMDG code takes precedence over the ADR code.
Over the past few months, an increase in the number of hazardous refusals has been highlighted.
In light of this, we have put together the below table that lists some of the common issues, we are presented with upon arrival to the Port, the requirements of the IMDG Code and possible solutions:
We work closely with the MCA, who are an Executive Agency of the Department of Transport. We share relevant compliant and non-compliant information with the MCA and work towards improving safety at Sea and Coastal areas. The MCA also assists us in providing support to our customers to ensure safe shipment of hazardous cargo at all times.
For further information and support please follow https://www.gov.uk/government/organisations/maritime-and-coastguard-agen...
Container/Vehicle Packing Certificate Not Completed
The minimum information required on the Packing Certificate is a name, date and signature. The person who packed and loaded the goods onto the vehicle must complete this.
The Container/Vehicle Packing Certificate must be completed by the person responsible for loading the goods into the vehicle.
Declaration Not Completed
The minimum information required on the Shippers Declaration is a date and signature.
The person who completed the Dangerous Goods Note (DGN) must complete this.
The consignor is responsible for ensuring the correct information is provided on the DGN and must complete and sign the Declaration.
Flashpoint too low for PGIII
Packing Group III normally has a minimum Flashpoint of 23C. However, if the viscosity of the product meets the requirements set out in IMDG 184.108.40.206, then we can accept a Flashpoint below 23C.
If the goods meet the requirements set out in 220.127.116.11, it must state 'In Accordance with IMDG 18.104.22.168' on the DGN. We will then be able to accept the load with a Flashpoint below 23C.
If the above is not stated on the DGN, or if the product does not meet the requirements set out in IMDG 22.214.171.124, then the load will be refused.
One weight for multiple UN numbers
Separate weights and packaging information must be listed for each different Proper Shipping Name, UN Number and Packing Group.
It is important that each different Proper Shipping Name, UN Number and Packing Group has its own weight and packaging information. If this cannot be determined, the load will be refused.
No Dangerous Goods Note
Unless the product is exempt from the IMDG Code, a fully completed and signed Dangerous Goods Note and Container/Vehicle Packing Certificate, that comply with Chapter 5.4 of the IMDG Code, must be provided for all hazardous items.
If it cannot be established that the product is non-hazardous, the load will be refused until a completed DGN can be provided.
Required Information Missing on the DGN
Each hazardous goods item must have the minimum required information, as per IMDG 126.96.36.199. This includes:
- UN number
- Proper Shipping Name (supplemented with the correct technical name of the product where necessary)
- Primary Class (including subdivision*)
- Any subrisk(s)*
- Packing Group*
- Technical Name*
- Packaging and weight information.
When any required information is missing, the load will be refused. A corrected DGN must be provided before shipment can be approved.
Shipment of Class 1.4 in a Closed Transport Unit
Class 1.4 shipments vary according to how they must be transported, especially Class 1.4C, 1.4G and 1.4D; they must be shipped in a closed transport unit and are limited to 10kg per vessel.
A Closed Transport Unit (CTU) form must be completed before shipment.
We hope that this guide is of interest to you and your customers and that you find this useful when pre-advising hazardous goods. We hope that this will reduce any potential unnecessary hazardous refusals upon arrival to the Port.
DFDS Freight Reservations Department