Compliance Blog


IMO Changes Effective Janurary 1, 2014

IMDG Code Amendment 36-12 overview of changes from Amendment 35-10 IMDG Code Amendment 36-12 may be used from 1 January 2013 (subject to national administration adoption) and is mandatory from 1 January 2014. There are new UN Numbers up to 3506 and some new packing instructions, as well as many detailed changes to the chapters and the Dangerous Goods List entries. There are also significant changes to: Stowage and Segregation Part 7 has been completely reorganised according to job function. Chapters 7.1 and 7.2 contain general stowage and segregation rules. Chapter 7.3 is now about loading goods into a CTU. Chapters 7.4, 7.5, 7.6 and 7.7 apply to container ships, ro-ro ships, general cargo ships and shipborne barges, respectively. As before, a ship may comprise several types of stowage space and the appropriate chapters refer to how each space is used. Sources of heat The various requirements for 'away' from all or any sources of heat, shaded from radiant heat or direct sunlight (except for calcium hypochlorite), sparks (except for UN 1327 HAY) and flame, are replaced by a general “Protected from sources of heat”, the meaning of which is given in 7.1.2. This includes being at least 2.4 m from heated ship structures and for packages on deck, not in CTUs, to be shaded from direct sunlight. Depending on the substance and the planned voyage, it may be necessary to reduce an on-deck CTU's exposure to direct sunlight. Foodstuffs Segregation from foodstuffs (which is now defined in 1.2.1) has changed. 'Away from' foodstuffs and ‘Separated from’ foodstuffs are no longer mentioned. Generally, a class or subrisk of 2.3, 6.1, 6.2, 7 and 8, plus a few specific entries in the DGL, shall not be in the same CTU as foodstuffs. However, some class 6.1 or 8 items, plus a few specific entries in the DGL, will be allowed in the same CTU as food, provided they are at least 3 m apart, without needing competent authority approval. On container and ro-ro ship spaces, no segregation requirements exist between CTUs because of food. Currently classes 2.3, 6.1, 6.2, 7 and 8 need it. In conventional stowage spaces, class 6.2 will still require segregation value 3 from food, but now reducing to 2 if either is in a closed CTU; the other classes and DGL-specific items remain as segregation value 2, but reducing to 1 if one item is in a closed CTU, or 0 if both are in closed. The current relaxation to segregation value 1 for class 8 and class 6.1 pg III is removed. Rules for segregation from odour-absorbing cargoes are not changed by this. Limited quantities When in limited quantities, class 8 packing group II liquids in glass or similar inners also need rigid intermediate packaging. Other substances in LQ in fragile inners will need suitable intermediate packaging when in shrink- or stretch-wrapped trays. Three UN Numbers of class 1.4S explosives may be consigned as limited quantities, but are still subject to the rules of section 4.1.5. Explosives Fireworks, UN 0333-7 now need a classification reference issued by the competent authority. There are now only five stowage categories for explosives, and these are not the same as the present 01 to 05. If explosives are to be put into a CTU it must be a closed CTU for class 1. All explosives on deck must be in a closed CTU. The stowage categories 01 (the least restrictive) to 05 relate to whether they are also allowed under deck, whether in closed CTUs or otherwise. All explosives of a particular division and compatibility group are allocated the same stowage category.

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