International Maritime Dangerous Goods Code (IMDG) Update 2015

By the end of this year, the International Maritime Organization (IMO) will publish the next revision to the International Maritime Dangerous Goods Code (IMDG). This revision, to be known as Amendment 37-14, will be optional to comply with starting on January 1, 2015, and will become mandatory on January 1, 2016.

What changes will we expect to see in this new revision?

Perhaps not as many as in previous amendments, but there will be a number of significant issues addressed. These include:

• A clarification that lamps and light bulbs are not to be considered dangerous goods
• Significant revisions to the requirements for Class 7 radioactive substances
• Addition of shipping descriptions and packaging instructions for adsorbed gases
• Clarifications on classifying viscous flammable liquids
• Clarification on the design and dimensions of various marks, such as the marine pollutant and limited quantity markings, as well as the design and dimensions of labels and placards

The lettering of the OVERPACK marking must be at least 12 mm high (Mandatory January 1, 2016)

The Dangerous Goods List, Chapter 3.2, will be altered by dividing column 16 (Stowage and segregation) in two, creating column 16a, Stowage, and 16b, Segregation. Codes for appropriate stowage and segregation will be assigned for each shipping description (these codes will be explained in Chapter 7.2).

There will be a number of revisions to shipping descriptions. One important one affects the automotive industry – the shipping names AIR BAG MODULES, AIR BAG INFLATORS and SEAT-BELT PRETENSIONERS will be changed to SAFETY DEVICES, under the UN number 3268. Other changes include:

• Asbestos will be shipped under the shipping names ASBESTOS, AMPHIBOLE and ASBESTOS, CHRYSOTILE.
• The shipping description for CAPACITORS will be split into CAPACITOR, ELECTRIC DOUBLE LAYER (UN3499), and CAPACITOR, ASYMMETRIC (UN3508)
• A new entry will be found in the table, PACKAGING DISCARDED, EMPTY, UNCLEANED, UN3509. However, this entry will not apply for normal sea shipments if the packaging has been prepared for transport according to the requirements of section 4.1.1.11.
• A series of shipping names for various adsorbed gases will be assigned to UN3510 to UN3526.

A number of new special provisions will be created, including:

• Special Provision 367, which clarifies the use of the shipping names for PAINT RELATED MATERIALS in shipments that include both paint and paint thinners.
• New special provision 371, which applies to articles, containing a small pressure receptacle with a release device and indicates the standards that shall apply to them.
• Special Provision 373, which gives procedures for shipping neutron radiation detectors containing non-pressurized boron trifluoride gas.
• Clarifications have been made to Special Provisions 961 (exempted internal combustion engines, fuel cell engines, vehicles and battery-powered equipment) and 962 (non-exempted internal combustion engines, fuel cell engines, vehicles and battery-powered equipment).

While the changes for IMDG Amendment 37-14 will not take place immediately, shippers and carriers must take advantage of the transition period provided to ensure that shipments continue without interruption.