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Transport of dangerous goods at sea
The MS (Dangerous Goods and Marine Pollutants) Regulations 1997 (SI 1997/2367) (regulation 11) specifies a shipper must not offer packaged dangerous goods for carriage unless:
• all the conditions relating to their declaration, classification, marking, packaging, labelling, placarding and
prior notification to competent authority or consignee, as specified in the IMDG Code, have been complied
with; and
• in the case of goods in a portable tank or tank container or vehicle the goods have been properly and safely
prepared for carriage by sea and comply with applicable tank requirements in accordance with the IMDG
Code.
An operator or master must not accept for carriage or take or receive on board any packaged goods where he has
reasonable cause to suspect that the shipper has not complied with the above requirements.
Inpreparing any goods for shipment the shipper must identify and classify any dangerous goods or marine
pollutants in order to ensure that the proper transport precautions and preparations can be made.
“Dangerous goods” as “goods classified in the IMDG Code or in any other IMO
publication referred to as dangerous for carriage by sea, and any other substance or article
which the shipper has reasonable cause to believe might meet the criteria for such classification”. The
expression also includes “residues in empty receptacles, empty tanks or cargo holds previously used for
carrying dangerous goods unless cleaned, dried, purged, gas freed or ventilated as appropriate or, in the case of
radioactive materials, have been both cleaned and adequately closed; and goods labelled, marked or declared as
dangerous goods. dangerous goods do not include ship’s equipment or stores”.
The following classes and divisions are listed in the IMDG Code 2008 edition:
Class 1: Explosives
Division 1.1: substances and articles which have a mass explosion hazard
Division 1.2: substances and articles which have a projection hazard but not a mass explosion hazard
Division 1.3: substances and articles which have a fire hazard and either a minor blast hazard or a minor
projection hazard or both, but not a mass explosion hazard
Division 1.4: substances and articles which present no significant hazard
Division 1.5: very insensitive substances which have a mass explosion hazard
Division 1.6: extremely insensitive articles which do not have a mass explosion hazard
Class 2: Gases
Class 2.1: flammable gases
Class 2.2: non-flammable, non-toxic gases
Class 2.3: toxic gases
Class 3: Flammable liquids
Class 4: Flammable solids; substances liable to spontaneous combustion; substances which, in contact with
water, emit flammable gases
Class 4.1: flammable solids, self-reactive substances and desensitized explosives
Class 4.2: substances liable to spontaneous combustion
Class 4.3: substances which, in contact with water, emit flammable gases
Class 5: Oxidising substances and organic peroxides
Class 5.1: oxidising substances
Class 5.2: organic peroxides
Class 6: Toxic and infectious substances
Class 6.1: toxic substances
Class 6.2: infectious substances
Class 7: Radioactive material
Class 8: Corrosive substances
Class 9: Miscellaneous dangerous substances and articles
The numerical order of the classes and divisions is not that of the degree of danger.
Declaration
No packaged dangerous goods may be offered for carriage or taken aboard any ship unless a dangerous goods
declaration or marine pollutants declaration (or a combined declaration) has been given to the master or operator as per the
the MS (Dangerous Goods and Marine Pollutants) regulations 1997 (SI 1997/2367)(regulation 10(1)).
The declaration must accurately identify the date the document was prepared and the name, status and company or
organisation of the signatory (regulation 10(2)).
No packaged goods may be offered for carriage or taken on board unless the master or operator has been provided
with a document showing the following details:
• the proper shipping name;
• the class and division where applicable;
• the UN Numbers where allocated by the IMDG Code;
• where relevant the packaging or packing group;
• the number and kind of packages;
• the total quantity of dangerous goods or net explosive mass of the contents;
• the words MARINE POLLUTANT where appropriate; and
• any other information required by the IMDG Code (regulation 10(3)).
This document (which is usually known as a “Dangerous Goods Note”) must be combined with the dangerous
goods declaration, marine pollutants declaration or combined dangerous goods/marine pollutants declaration as the
case may be (regulation 10(4)). A correctly completed SITPRO19 Dangerous Goods Note will fulfil these
requirements.
Where the goods are delivered direct to the ship or its agent, the shipper must deliver the declaration to the operator
or master (regulation 10(5)).
In consigning the goods for carriage by sea, the shipper must make proper provision to ensure the onward delivery
of the required declaration and document to the ship or its agent (regulation 10(6)).
Where the goods are not sent direct to the ship or agent, but are sent to another person (e.g a freight forwarder) for
onward delivery or for consolidation (groupage) with other goods or cargoes for eventual delivery, responsibility for
delivering the declaration and document is on the forwarder and each person responsible for onward transfer and
delivery. This responsibility does not, however, extend to persons solely engaged in loading of the goods onto the
ship or moving the goods (regulation 10(7)). These requirements are without prejudice to the duties of the shipper in
regulations 11 and 12 (regulation 10(8)).
An offence is committed under regulation 10(9) if a shipper, forwarder or other person:
• fails to provide the operator or master with a declaration; or
• provides a declaration which he knows to be false or recklessly makes a declaration which is false in a material
particular.
An offence is committed by the operator or master under regulation 10(10) if he accepts for carriage or takes or
receives on board any packaged goods without a document and declaration where these are required by the
Regulations.
The MS (Dangerous Goods and Marine Pollutants) Regulation 1997 (SI 1997/2367) (regulation 21) specifies the shipper of any bulk dangerous goods or marine pollutants must give the operator or master written
notification of the nature of the goods, specifying:
• their correct technical name;
• their UN number, if any;
• for any solid bulk dangerous goods, the classification as listed in the IMDG Code; and
• for liquid dangerous goods with a flashpoint below 60°C (closed cup), the flashpoint.
The shipper of any bulk dangerous goods or marine pollutants commits an offence if he fails to provide the operator
or master with a written notification, or provides a notification which is false in a material particular.
The master of a ship carrying any bulk dangerous goods or marine pollutants must ensure that a specific list,
manifest or stowage plan is carried in the ship for the current voyage. This document must set out the details,
obtained from the shipping documents submitted by the shipper, of the dangerous goods or marine pollutants carried
including:
• the correct technical name of the goods;
• their mass or volume;
• where the dangerous goods are shown in Appendix B of the Bulk Cargoes Code, the classification as shown in
the IMDG Code; and
• the stowage location in the ship.
The master must also carry in the ship any additional special documents (e.g. a bulk coal Declaration by Shipper,
a Certificate of Test of Solid Bulk Cargo, a Certificate of Fitness, etc.) where required for dangerous goods or
marine pollutants by the Bulk Cargoes Code, the BCH Code, the IBC Code, the IGC Code or the Gas Carrier
Code.
The list, manifest or stowage plan and any additional special documents must be kept available for reference or
inspection on board until the goods have been discharged.
The MS (Reporting Requirements for Ships Carrying Dangerous or Polluting Goods) Regulations 1995 (SI
1995/2498) require the operator and master to arrange, before the ship departs from a port, for a copy of the list,
manifest or stowage plan to be kept on shore. It is the duty of the operator to retain it there until the goods are
discharged from the ship or for 6 months from loading, whichever is the shorter period.
The operator must furnish the list, manifest or stowage plan on demand:
• where the port of departure is in the UK, to any person or authority designated for this purpose by the MCA; or
• where the port of departure is not in the UK, to the port State.
Dangerous goods packed in containers for transport at sea regulation
The MS (Dangerous Goods and Marine Pollutants) Regulation 1997 (SI 1997/2367) 12(1)(a) provides that where packaged goods are to be packed or shipped in or on a cargo transport
unit, the person responsible for packing such goods therein must ensure that the stowage, segregation and securing
of the goods is adequate and in accordance with the IMDG Code.
Regulation 12(2) provides that regulation 12 does not apply in relation to goods packaged within a portable tank,
road tank vehicle, rail tank wagon or tank container.
Where packaged goods are to be packed or shipped in or on a cargo transport unit, the person responsible for
packing the goods in the unit must provide the operator or master or shipper or forwarder with a signed Packing
Certificate complying with the requirements of the IMDG Code, indicating the cargo transport unit, identification
number or numbers and identifying the place and date of the operation, the name of the person responsible for the
packing and his status, and company or organisation. This regulation does not apply to goods packaged in a portable
tank, road tank vehicle, rail tank wagon or tank container (regulation 12(1)(b)).
The Packing Certificate is a declaration that:
• the goods are, if required, properly packaged and have been securely packed and adequately braced for the
intended voyage;
• that the container or vehicle was clean, dry and appeared fit to receive the goods;
• that no incompatible substances have been packed except where permitted by the DG Regulations;
• that where packages or receptacles have been packed into a container or vehicle they are in a sound
condition; and
• that the labelling or other appropriate marking on the packages and on the container or vehicle complies with
the DG Regulations.
The shipper or forwarder commits an offence if he fails to provide the operator or master of the ship with a signed
Packing Certificate (regulation 12(3)(b)).
An operator or master must not accept on any ship any cargo transport unit with packaged dangerous goods in it
without a signed Packing Certificate (regulation 12(4)).
A Packing Certificate is an integral part of a SITPRO Dangerous Goods Note. The Packing Certificate and the
dangerous goods declaration must each be signed for a shipment of packaged dangerous goods or marine
pollutants.
MARPOL Annex III contains the regulations for the prevention of pollution by harmful substances carried by sea in packaged form. And came into force on 1 July 1992 and had (at May 2002) 101 Contracting States (which include the UK),representing 81.46% of world tonnage.
The MS (Dangerous Goods and Marine Pollutants) Regulations 1997 (SI 1997/2367) -
define (in regulation 2) “dangerous goods” as “goods classified in the IMDG Code or in any other IMO
publication referred to in these Regulations as dangerous for carriage by sea, and any other substance or article which the shipper has reasonable cause to believe might meet the criteria for such classification”. The expression also includes “residues in empty receptacles, empty tanks or cargo holds previously used for carrying dangerous goods unless cleaned, dried, purged, gas freed or ventilated as appropriate or, in the case of radioactive materials, have been both cleaned and adequately closed; and goods labelled, marked or declared as dangerous goods. dangerous goods do not include ship’s equipment or stores”.
The regulation define a “marine pollutant” as a substance classified as such in the IMDG Code, or as a noxious liquid
substance in the IBC Code, and any other substance, material or article that the shipper has reasonable cause to
believe might meet the criteria for such classification.
It apply (under regulation 5) to all UK ships anywhere, and other ships in UK waters, carrying:
• dangerous goods in bulk or packaged form; or
• marine pollutants in packaged form.
It contain general provisions in Part I, including regulations relating to interpretations (regulation 2),
exemptions (regulation 4), application (regulation 5), general duties of operators and employers (regulation 6), general duties of employees aboard ship (regulation 7), misconduct endangering a UK ship or persons
aboard (regulation 8), and onus of proving what is reasonably practicable (regulation 9).
Contain in Part II provisions for the carriage of packaged goods including regulations relating to Declaration
(regulation 10), Preparation of goods for transport (regulation 11), Container or Vehicle Packing
Certificates (regulation 12), Documentation by electronic data processing or electronic data interchange
(regulation 13), List, manifest or stowage plan (regulation 14), Marking and labelling (regulation 15),
Stowage on board ship (regulations 16 and 17), Cargo securing documentation (regulation 18) and
Operational requirements (regulation 19).
Contain in Part III two regulations: Carriage of Dangerous Goods or Marine Pollutants in Bulk (regulation
20) and Documentation (regulation 21).
Contain in Part IV one regulation relating to Spaces for carriage of packaged goods and dangerous goods in
solid form in bulk (regulation 22).
Contain in Part V provisions relating to Enforcement including regulations on Power to detain (regulation
23), Penalties (regulation 24) and Offences due to fault of another person (regulation 25).
Refer to certain codes, e.g. the Bulk Cargoes Code, BCH Code, Gas Carrier Code, Gas Carrier Code for Existing
Ships, IBC Code, IGC Code, IMDG Code and to IMO Recommendations. Where the Regulations require
carriage to be in accordance with a Code or Recommendation, and the MCA specify in MSN 1705 or MSN
1706 conditions in relation to the carriage, the Code or Recommendations must also be complied with.
Provide that the general duties of operators and employers of persons aboard a ship and every shipmaster
include ensuring, as far as reasonably practicable, that nothing in the manner in which dangerous goods are
handled, stowed or carried is such as might create a significant risk to the health or safety of any person.
Provide in regulation 6 that matters to which the duty of the operator and employer extend include:
• provision and maintenance of ship’s structure, fittings and equipment for the handling, stowage and
carriage of dangerous goods; and
• provision of such information, instruction, training and supervision to all employees in connection with
the handling, stowage and carriage of dangerous goods in the ship.
Provide in regulation 7 that general duties of employees aboard ship are to take reasonable care for the health
and safety of themselves and of others who may be affected by their acts or omissions in connection with the handling, stowage and carriage of dangerous goods in the ship, and to co-operate with the shipowner or
employer in carrying out their statutory duties under the Merchant Shipping Act 1995 and the Regulations.
Provide in regulation 8 that in connection with the handling, stowage or carriage of dangerous goods, it is an
offence to intentionally or recklessly interfere with or misuse anything provided on board under merchant
shipping legislation in the interests of health, safety or welfare. The onus of proving what is “reasonably
practicable” is on the accused, if charged with an offence of failing to comply with something “so far as is
reasonably practicable”.
Incorporate certain MSNs (which should be read in conjunction with the Regulations), e.g. MSN 1705 and
MSN 1706.
Where a ship fails to comply with the Regulations, she is liable to be detained (regulation 23).
Cargo ships guideline for List, manifest or stowage plan of dangerous goods
The MS (Dangerous Goods and Marine Pollutants) Regulation 1997 (SI 1997/2367) specifies the master of any ship carrying packaged goods (i.e. dangerous goods or marine pollutants) must ensure that a
special list, manifest or stowage plan is carried in the ship (regulation 14(1)). This document must set out details,
obtained from the shipping documents submitted by the shipper, of the packaged goods on board including:
• the correct technical name of the goods;
• their classification in accordance with the IMDG Code;
• their mass or volume; and
• details of the stowage location in the ship.
The information may be in one combined document relating to both dangerous goods and marine pollutants, or in
separate lists (regulation 14(2)). Combined lists must show clearly which goods are dangerous goods and which are
marine pollutants.
The master must also carry in the ship any additional special documents where required by the IMDG Code for the
carriage of packaged dangerous goods (regulation 14(3)).
Any list, manifest or stowage plan and any additional special documents required for the acceptance of goods for
carriage in the ship must be kept on board and available for reference or inspection until the goods have been
discharged (regulation 14(4)).
Marking or labelling (regulation 15)
Packaged dangerous goods or marine pollutants may not be taken on any ship for carriage in that ship unless they
are marked, labelled and placarded, and display a fumigation warning sign, as appropriate, as specified in the IMDG
Code. The shipper commits an offence if this requirement is breached.
An operator or master is guilty of an offence if he accepts dangerous goods or marine pollutants on board in any
packaged which is not marked, labelled, placarded or displaying a fumigation warning sign as required.
Stowage on board ship (regulations 16 and 17)
Packaged goods must not be accepted on board if their stowage is prohibited by the IMDG Code (regulation 16).
Packaged goods must not be accepted on board unless any necessary additional safety equipment is provided in
accordance with the IMDG Code (regulation 16).
Packaged goods must be adequately stowed, segregated and secured in accordance with the IMDG Code (regulation
16).
Where the vessel carries a Cargo Securing Manual in compliance with regulation 18, cargo transport units,
including containers, must be loaded, stowed and secured throughout any voyage in accordance with that manual
(regulation 17).
Cargo securing documentation (regulation 18)
No packaged goods may be carried on:
• any ship on an international voyage;
• any passenger ship on a domestic voyage; and
• any cargo ship of 500gt and above on a domestic voyage -
- without carrying a Cargo Securing Manual conforming to the standard in IMO circular MSC/Circ.745 and
approved by or on behalf of the flag State Administration.
Operational requirements (regulation 19)
The operator and master must ensure that all employees are familiar with the essential actions to be taken in an
emergency involving any packaged goods carried on the ship.
Other useful articles :
- Transport of dangerous goods at sea
No packaged dangerous goods may be offered for carriage or taken aboard any ship unless a dangerous goods
declaration or marine pollutants declaration (or a combined declaration) has been given to the master or operator as per the
the MS (Dangerous Goods and Marine Pollutants) regulations 1997 .
More .....
-
Hazardous cargoes -loading precautions /monitoring
Check the details of the goods including the
labelling, the respective UN Number, the condition of the package,
together with any special stowage requirements prior to loading the
cargo.
More .....
-
IMDG code
IMDG code brief guideline & regulatory requirement
More .....
- The documents of compliance (DOC)for carrying dangerous goods
Document of Compliance (regulation 22)
applies to:
• passenger ships built on or after 1 September 1984;
• cargo ships of 500gt or over built on or after 1 September 1984; and
• cargo ships of less than 500gt built on or after 1 February 1992.
More .....
- Gas detection equipment
An appropriate instrument for measuring the concentration of
gas or oxygen in the air must be provided together with detailed instructions for its use. The instrument must be of
a type approved by a Certifying Authority, and the crew must be trained in its use..
More .....
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