IMDG Code in Denmark: dangerous goods by sea
Dangerous goods shipped from Denmark by sea must comply with the IMDG Code, and with ADR for the road leg to the port. iSikkerhed.dk ApS advises shippers, freight forwarders and terminals on segregation, container packing and documentation, with practical experience from the ports of Fredericia and Aarhus.
Segregation
Segregation is the process of separating dangerous goods that are mutually incompatible (IMDG Code 7.2.2.1). To determine the requirements, the segregation table in 7.2.4 and column 16b of the Dangerous Goods List must be consulted; where they conflict, column 16b takes precedence (7.2.3.1). Where a single subsidiary hazard has stricter segregation provisions than the primary hazard, those provisions apply (7.2.3.3).
When a segregation term applies, the goods may not be packed in the same outer packaging or transported in the same cargo transport unit (CTU), except as provided in 7.2.6 and 7.3.4 (7.2.3.2). Goods that must be segregated “away from” each other may share a CTU only with the approval of the competent authority (7.3.4.1).
IMDG Code 7.3.4.2.1: dangerous goods with a primary or subsidiary hazard of class 2.3, 6.1, 6.2, 7 (with the exception of UN 2908, 2909, 2910 and 2911) or 8, and goods assigned segregation code SG29 or SG50, must not be transported in the same CTU as foodstuffs.
Container packing and the packing certificate
Before packing, the CTU must be checked for fitness and inspected inside and out for damage (IMDG Code 7.3.3.1 and 7.3.3.2). Damaged, leaking or sifting packages must not be packed (7.3.3.3), drums must be stowed upright unless otherwise authorised (7.3.3.4), and packages must be secured against movement (7.3.3.6).
Those responsible for packing the container or vehicle must provide a container/vehicle packing certificate stating its identification number and certifying that the conditions in 5.4.2.1 are met, including segregation, securing, placarding and receipt of a transport document for each consignment. When a road leg in a container precedes sea transport, ADR 5.4.2 requires the certificate to be handed to the maritime carrier.
IMDG Code 5.4.2.2: if the packing certificate is combined with the transport document, the document must include a signed and dated declaration that the packing has been carried out in accordance with the applicable provisions, and the person signing must be identified. A packing certificate is not required for portable tanks (note to 5.4.2.1).
Dangerous goods declaration
The consignor must give the carrier the information required by the Code, either on a dangerous goods transport document or, with the carrier’s agreement, by EDP or EDI (IMDG Code 5.4.1.1.1). The document must show the names and addresses of the consignor and consignee and the date (5.4.1.3).
The dangerous goods description consists of the UN number, the proper shipping name (with the technical name where applicable), the class, any subsidiary hazard and the packing group, in that order and with no other information in between (5.4.1.4.1 and 5.4.1.4.2). Additional entries may be required, for example “MARINE POLLUTANT” and the minimum flashpoint for class 3 liquids with a flashpoint of 60 °C or below (5.4.1.4.3).
IMDG Code 5.4.1.6.1: the document must include the consignor’s certification that the consignment is fully and accurately described, classified, packaged, marked and labelled and in proper condition for transport, signed and dated by the consignor. The consignor and the carrier must keep a copy for at least three months (5.4.6.1).
Common errors we see
- No documented segregation check before mixed loads are packed, or reliance on the ADR mixed-loading rules (ADR 7.5.2) where IMDG segregation (chapter 7.2) applies
- Wrong proper shipping name, for example a trade name instead of the upper-case name from the Dangerous Goods List (IMDG Code 3.1.2.1), or a missing technical name for n.o.s. entries (3.1.2.8)
- Missing signature on the packing certificate, or a certificate signed without checking the points it confirms
- Marine pollutants not identified in the declaration
Use a short checklist at the loading bay that follows the items in IMDG Code 5.4.2.1, so that the person responsible for packing can sign the certificate on an informed basis. Contact us if you would like help setting up such a checklist.