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This means you: Changes to the IMDG Code

June 5 / 2014    12:00 pm

TT Club risk management director, Peregrine Storrs-Fox looks at the implications of the amendments to the IMDG Code that became mandatory on 1 January.

Safety is increasing important in our industry.  Everyone involved in packing, marking, declaration, stowage and securing of freight internationally is responsible for the safe movement of cargo.  It is vital to be aware of the mandatory regulations that safeguard such moves, particularly those for ‘dangerous goods’.

Anecdotal information suggests that some in the maritime supply chain are using out of date dangerous goods data and inspections prove that non-compliance continues to be too high – and accidents and incidents involving the transport of dangerous goods demonstrate the serious implications.  TT Club strongly recommends the consistent implementation of the new IMDG amendments that became mandatory on 1 January to ensure that goods are properly classified, marked, packed and declared for carriage by sea.

The detail of the amendments to the code should be studied carefully – in particular the ‘stowage’ and ‘segregation’ of cargo in Part 7 of the Code entitled ‘Provisions Concerning Transport Operations’.  There are now, for instance, separate regulations covering different types of ships (container, ro-ro, barge carriers and general cargo) whereas previously all types were covered together.

The requirements for the segregation of cargo have also been extended to certain perishable goods not normally designated as dangerous.  The TT Club has seen examples of severely damaged containers after cargoes such as butter and cheese have been exposed to heat. There are also changes to the shipment of explosives and some commodities have been added to the Dangerous Goods List, including some fish-meals, various chemicals and electrical capacitors.

Results of non-compliance

Many may think that the details of the Code are irrelevant to their business.  In some cases this will be true, but take care to be doubly sure that a cargo that falls under your responsibility is not in some way regulated, in order to protect the safety of others in the supply chain.  The potential consequences can be demonstrated to  be extreme and even fatal.

The liner operators’ Cargo Incident Notification System (CINS) reports that over 80% of incidents relate to cargo that is dangerous; 25% are caused by mis-declaration of cargo and a further 35% relate to poor or incorrect packaging.  CINS has a liner carrier membership that accounts for about 60% of maritime container movements.  It has been commonly established that ship casualties arising from explosions and fires are either as a result of dangerous cargoes not declared or that dangerous cargo has in some way exacerbated the loss.

Clearly, the IMDG Code alone will not address these continuing issues of non-compliance and the TT believes that recently concluded work to produce the ILO/IMO/UNCECE Code of Practice on Packing of Cargo Transport Units (CTUs) will also go a long way to help – but only if it can be successfully promulgated in an easy to understand format to provide good practice guidance to all packers and shippers.

So TT Club has commissioned expert e-learning course designer Exis Technologies to develop the CTUpack(TM) e-learning course.  The course ( is an online training tool for those involved in the packing and unpacking of cargo transport units, comprising freight containers, swap bodies, trailers and suchlike used in intermodal transport.

Whether it’s IMDG Code compliance or good practice for packing, every party involved in the logistics supply chain needs to be aware of their responsibilities in the flow of cargo around the world.

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