Summary of the main changes to the IMDG Code in the Amendment 37-14 update
Headlines
The next update to the IMDG Code (Amendment 37-14) will be published by the International Maritime Organisation towards the end of this year. Compliance is optional from 1 January 2015 and mandatory on 1 January 2016.
A summary of the key changes is as follows:
There is a new section setting out conditions when specified types of lamp are exempt from the IMDG Code’s provisions.
There is a new paragraph 1.1.2.3 referencing the International Convention for Safe Containers, 1972, as amended.
Throughout the new Amendment there are updates to provisions concerning class 7 primarily to reflect the changes to the IAEA "Regulations for the Safe Transport of Radioactive Material, 2012 Edition, IAEA Safety Standards Series No. SSR–6, IAEA, Vienna (2012).
There are several changes to the classification provisions in Part 2, including changes to PSNs for several class entries.
For marine pollutants there is a new 2.10.2.7 which provides conditional exemptions from the majority of the IMDG Code’s provisions.
There are numerous updates to the Dangerous Goods List (DGL) in 3.2 including the addition of 20 new UN Numbers from UN 3507 to UN 3526.
Column 16 of the DGL is now split into columns 16a and 16b and stowage and segregation requirements are now coded, stowage and handling codes in 16a; segregation codes in 16b.
There are many revisions to the packing instructions, including those for IBCs and large packagings and a number of new packing instructions: P208, P505, P805, P908, P909, LP903, LP904.
Clarifications on the design and dimensions of various package marks, labels and placards have been provided including the ‘marine pollutant’ and ‘limited quantity’ markings.
There are a few changes to documentation requirements in Chapter 5.4 e.g. clarification of the requirements for ‘marine pollutant’ endorsements.
There are several changes to Part 6 of the Code, particularly to the provisions for packagings for class 7 (chapter 6.4) and pressure receptacles, aerosol dispensers and gas cartridges (chapter 6.2).
In chapter 6.6, ‘large salvage packagings’ are added.
There are numerous changes to Part 7 to reflect the new columns 16a and 16b in the DGL.
There are new explanatory notes in 7.1.5, 7.1.6 and 7.2.8 respectively for the stowage (SW), handling (H) and segregation codes (SG) now appearing in columns 16a and 16b.
There is a new segregation requirement in 7.2.4. Flammable gases (class 2.1) and flammable liquids (class 3) must now be ‘separated from’ substances which, in contact with water, emit flammable gases (class 4.3). This reflects the changes adopted for these classes in the DGL.
There is also a new segregation requirement provided by SG26 which states
'. This applies to almost all class 4.3s (including sub-risks) and also covers metal powders and peroxides etc. in other classes.
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classes 2.1 and 3 when stowed on deck of a containership a minimum distance of two container spaces athwartship shall be maintained, when stowed on ro-ro ships a distance of 6 m athwartship shall be maintained.
Detail
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Part 1 – General Provisions, Definitions and Training
Part 2 – Classification
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Part 3 - Dangerous Goods List (DGL), Special Provisions and Exemptions
Here we highlight significant changes in more detail looking at each Part of the IMDG Code in turn:
There is a new section 1.1.1.9 which sets out conditions for when lamps are not subject to the IMDG Code’s provisions; the conditions relate to the type of lamp, quantity of dangerous goods, packing arrangements etc.
There is a new 1.1.2.3 covering the International Convention for Safe Containers, 1972, as amended, which deals with the testing, inspection, approval and maintenance of containers. This reproduces regulations 1 and 2 of Annex 1 to this Convention which covers safety approval plates and container maintenance and examinations.
Definitions in 1.2 are revised: there are amendments to several existing definitions and new definitions for ‘large salvage packaging’, ‘management system’, ‘neutron radiation detector’, and ‘radiation detection system’.
There are several changes to the general provisions concerning class 7 in chapter 1.5. These provisions are now based on IAEA "Regulations for the Safe Transport of Radioactive Material, 2012 Edition, IAEA Safety Standards Series No. SSR–6, IAEA, Vienna (2012).
In 2.0.1.2 radioactive materials of class 7 are no longer deemed to be possible marine pollutants.
For explosives in chapter 2.1 there is a minor change to the introductory note.
Chapter 2.2 (gases) includes new entries for ‘adsorbed gases’ with new UN numbers (UN 3510 to UN 3518) being added accordingly.
For class 3 (flammable liquids) the assignment of packing group for viscous liquids as covered in 2.3.2.2 and 2.3.2.3 is updated.
There are amendments to the classification procedures for solid substances of class 5.1 (2.5.2.2.1) and the methods for assigning packing groups to such substances (2.5.2.2.2).
In chapter 2.6 there are amendments to the exemptions provided for specified infectious substances.
In chapter 2.7 there are numerous amendments to the classification provisions for class 7 (radioactive material).
In chapter 2.9 there is an amendment to ‘Note 2’ which confirms that the criteria for environmentally hazardous substances (aquatic environment) apply to all hazard classes, except for class 7.
There are changes to proper shipping names for a number of class 9 items. For example, UN 3268 now only has one entry, SAFETY DEVICES, electrically initiated.
The lithium batteries section in 2.9.4 has been amended.
In chapter 2.10, 2.10.2.4 has been amended to clarify that the absence of the letter ‘P’ in column 4 of the DGL does not preclude the substance from being classified as a marine pollutant.
There is a new paragraph 2.10.2.7 in chapter 2.10 which exempts marine pollutants from the IMDG Code’s provisions when packed in single or combination packagings of 5 L or 5 KG or less meeting specified packing requirements. The exemption does apply to substances meeting the criteria of any other hazard class.
The structure of the DGL has been amended to accommodate new columns 16a and 16b. Column 16a provides stowage and handling codes, whereas column 16b contains segregation codes. Section 3.2.1 has been updated to reflect this.
There are numerous changes to dangerous goods entries to reflect updates to packing provisions, marine pollutant status, special provisions and the addition of codes in columns 16a and 16b to replace the previous phrases.
There are 20 new UN Numbers as follows:
UN 3507 - URANIUM HEXAFLUORIDE, RADIOACTIVE MATERIAL, EXCEPTED PACKAGE, less than 0.1 kg per package, non-fissile or fissile-excepted
UN 3508 – CAPACITOR, ASYMMETRIC (with an energy storage capacity greater than 0.3Wh) UN 3509 – PACKAGING DISCARDED,EMPTY, UNCLEANED
UN 3510 – ADSORBED GAS, FLAMMABLE, N.O.S.
UN 3511 - ADSORBED GAS, N.O.S.
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UN 3512 – ADSORBED GAS, TOXIC, N.O.S.
UN 3513 – ADSORBED GAS, OXIDIZING, N.O.S.
UN 3514 – ADSORBED GAS, TOXIC, FLAMMABLE, N.O.S.
UN 3515 – ADSORBED GAS, TOXIC, OXIDIZING, N.O.S.
UN 3516 – ADSORBED GAS, TOXIC, CORROSIVE, N.O.S.
UN 3517 – ADSORBED GAS, TOXIC, FLAMMABLE, CORROSIVE, N.O.S.
UN 3518 – ADSORBED GAS, TOXIC, OXIDIZING, CORROSIVE, UN 3519 – BORON TRIFLUORIDE, ADSORBED
UN 3520 – CHLORINE, ADSORBED
UN 3521 - SILICON TETRAFLUORIDE, ADSORBED UN 3522 – ARSINE, ADSORBED
UN 3523 - GERMANE, ADSORBED
UN 3524 - PHOSPHORUS PENTAFLUORIDE, ADSORBED UN 3525 – PHOSPHINE, ADSORBED
UN 3526 - HYDROGEN SELENIDE, ADSORBED
Note that UN 3509 – PACKAGING DISCARDED, EMPTY, UNCLEANED, be used for sea transport. Any uncleaned, empty packaging still has to be declared and handled according to the substance it previously contained.
In chapter 3.3 there are numerous changes to special provisions. Several are amended, a few are deleted and 12 new ones added: 367, 368, 369, 370, 371, 372, 373, 376, 377, 968, 969, 970.
In the ‘limited quantities’ and ‘excepted quantities’ chapters, 3.4 and 3.5 respectively, there are minor changes, mainly concerned with the limited quantities and excepted quantities markings - with both now showing dimensions.
Appendix A, which provides the list of generic and N.O.S. proper shipping names, has been updated to reflect the applicable new PSNs in the DGL.
There are minor amendments to the glossary of terms in Appendix B and the changes in the DGL are reflected in the Alphabetical index.
There is a new 4.1.1.5.2 which provides for the use of supplementary packagings within combination packages.
There are many revisions to existing packing instructions, including those for IBCs and large packagings and a number of new packing instructions: P208, P505, P805, P908, P909, LP903, LP904.
In 4.1.9 there are several changes to the special packing provisions for class 7 (with class 7 now being referred to as ‘radioactive material’)
For tanks there are a few amendments to the tank instructions and special tank provisions.
In 5.1.2.1 there is a new size requirement for the marking of the word ‘Overpack’ – this is applicable from 1 January 2016.
The wording in 5.1.3.2 for empty, uncleaned packagings or units has been revised.
There are several amendments to section 5.1.5 concerning the general provisions for class 7 with several new paragraphs added.
In 5.2.1.3 the lettering of the ‘SALVAGE’ marking on packages must be at least 12 mm high – this is applicable from 1 January 2016.
In 5.2.1.5 there are a few changes to the marking provisions for class 7; similarly, for labelling there are changes in 5.2.2.1.12, and for placarding in 5.3.1.1.5.
For marine pollutants the existing 5.2.1.6.1 is now replaced and refers to the exceptions now mentioned in 2.10.2.7. Also, there is clarification of the dimensional requirements for the mark with a transition through to 31 December 2016 for marks that don’t comply.
In 5.2.2.2 the general provisions for labels have been amended to include a diagram to show the label configuration with some requirements not applicable until 31 December 2016. Also, there is a new Note under the specimen labels stating that similar labels with minor variations used in other modes of transport are acceptable and that some of the symbols in the Code should be replaced by those used in the United Nations Recommendations. The differences in these are minor.
There are revisions to the placarding requirements in 5.3.1.1: portable tanks with a capacity of less than 3,000 litres must be placarded or labelled on two opposite sides.
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Part 4 - Packagings including IBC and Large Packagings
Part 5 - Consignment Procedures
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There is also clarification on the dimensions for the elevated temperature and marine pollutant marks in 5.2.2.2 and 5.3.2.2 respectively.
There are revisions to documentation requirements for marine pollutants in 5.4.1.4.3 which now refers to the exceptions in 2.10.2.7. If a marine pollutant is shipped in a single or inner packaging not exceeding 5 L or 5 KG it no longer needs to be described as such on the DGN
There is an update to the requirement to identify dangerous goods transported in bulk on the DGN in 5.4.1.5.12.
There are revisions to the dangerous goods manifest requirements aligning the Resolution FAL.10(35), adopted on 16 January 2009.
In the special provisions in 5.5 there are various changes in documentation and fumigation and coolant/conditioning warning marks with both now showing the required dimensions.
There are minor changes to the general provisions in 6.1.3.
There are several amendments to chapter 6.2 concerning pressure receptacles, aerosol dispensers and gas cartridges including the adoption of updated ISO standards.
There is a new 6.2.2.10 concerned with the marking of bundles of cylinders.
There are numerous updates and revisions in chapter 6.4 pertaining to class 7 radioactive materials.
In 6.5.2.2 the minimum dimensional requirements for the IBC stacking load symbol are clarified.
There is a change in 6.6.2.2, 6.6.3.2 and a new 6.6.5.1.9 to reflect the addition of ‘salvage large packagings’. Similar to IBCs, the requirements for the stacking load symbol are clarified.
There are numerous reference changes throughout this Part to reflect the new columns 16a and 16b in the DGL
The stowage requirements for class 7 are amended in 7.1.4.5.
There are new explanatory notes in 7.1.5, 7.1.6 and 7.2.8 respectively for the stowage (SW), handling (H) and segregation codes (SG) now appearing in columns 16a and 16b.
There is a new segregation requirement in 7.2.4. Flammable gases (class 2.1) and flammable liquids (class 3) must now be ‘separated from’ substances which, in contact with water, emit flammable gases (class 4.3). This reflects the changes adopted for these classes in the DGL.
There is also a new segregation requirement provided by ‘SG26’ which states
'. This applies to almost all class 4.3s (including sub-risks) and also covers metal powders and peroxides etc. in other classes.
The requirement for those class 4.3 items which could only be loaded in dry weather conditions and stowed under deck in a mechanically ventilated space is removed. Now they need to be kept ‘as dry as reasonably practical’ and may be on deck.
There will be updates to the competent authority contact details in 7.9.3 but these have not yet been finalised.
There is a new 7.3.7.2.4.1 concerning the replacement of refrigerant gases.
There are no significant changes currently planned for the Supplement other than adding the new UN Numbers in this Amendment to the spillage and fire schedules as appropriate.
However, one thing to note is that the IMO/ ILO/ UN ECE Guidelines for Packing of Cargo Transport Units (CTUs) will be replaced by a new Code of Practice. The Code is currently undergoing approval and should be finalised after November 2014. It is not yet known whether the IMDG Supplement will be updated with this new Code when Amendment 37-14 is released.
Part 6 - Construction and testing of packagings
Part 7 - provisions concerning transport operations
IMDG Code Supplement
‘In addition: from goods of classes 2.1 and 3 when stowed on deck of a containership a minimum distance of two container spaces athwartship shall be maintained, when stowed on ro-ro ships a distance of 6 m athwartship shall be maintained.
This summary was produced by , leading supplier of compliance systems for the management of dangerous goods in sea transport and e-learning courses for IMDG Code and container packing training www.existec.com, and IMO distributor www.imdgsupport.com
Updated: 28 July 2014
Note: These changes were current at the time of production. They may be subject to further changes as the Amendment 37-14 update is finalised prior to release.
Exis Technologies
This is a guide only. Users must check with official sources before relying on the information.
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