Q. How do you ensure that a freight container or a pallet is suitably packaged?
Ans. One of the most important of the documents on dangerous goods is the certificate or declaration that the shipment offered for carriage is properly packaged and marked, labeled or placarded, as appropriate, and is in proper condition for carriage. This is duly done in respect of a freight container also. The people responsible for the packing of dangerous goods in a freight container or road vehicle shall provide a signed container packing certificate or vehicle packing declaration stating that the cargo in the unit has been properly packed and secured meeting the transport requirements.
Q. What would you do if such certificate is not available?
Ans. Where there is a cause to suspect that a freight container or road vehicle in which dangerous goods are packed is not in compliance with above stated requirements, or where a container-packing certificate or vehicle packing declaration is not available, the freight container or vehicle shall not be accepted for shipment.
Q. Write a short note on packing requirements as per the IMDG Code.
Ans. Column 5 contains the packing group number (i.e. I, II or III) where assigned to the substance or article. If more than one packing group is indicated for the entry, the packing group of the substance to be transported shall be determined, based on its properties and through the hazard grouping criteria.
For packing purposes, substances other than those of classes 1, 2, 5.2, 6.2 and 7, and other than self-reactive substances of class 4.1, are assigned to three packing groups in accordance with the degree of danger they present:
Packing group I: substances presenting high danger;
Packing group II: substances presenting medium danger; and
Packing group III: substances presenting low danger.
All packagings intended to carry dangerous goods in transport must be certified to meet the United Nations performance requirement. Packing instructions are available from column 8. This column contains alpha-numeric codes which refer to the relevant packing instruction(s) in 4.1.4. A code including the letter “P” refers to packing instructions for the use of packagings. The details are described in chapters 6.1, 6.2 or 6.3, which also deal with the construction, strength and testing criteria.
A code including the letters “LP” refers to packing instructions for the use of large packagings described in chapter 6.6. When a code including the letter(s) “P” or “LP” is not provided, it means that the substance is not allowed in that type of packaging. A code including the letters “BP” refers to packing instructions for the use of bulk packagings described in Chapter 4.3.
When “N/R” is included in this column it means that the substance or article need not be packaged.
Column 9 is special packing provisions. This column contains alpha-numeric codes which refer to the relevant special packing provisions specified in 4.1.4. The special packing provisions indicate the packagings (including large packagings).
- A special packing provision including the letters “PP” relates to packing instruction bearing ‘P’ in Chapter 220.127.116.11.
- A special packing provision including the letter “L” relates to packing instruction code “LP” in Chapter 18.104.22.168.
- A special packing provision including the letter “B” relates to packing instruction bearing the code “BP” in Chapter 22.214.171.124.
From chapter 4.1.4
Following is part of the same table i.e.P130.
From chapter 6.1
The following numerals shall be used for the kinds of packaging: 1 Drum 2 [Reserved] 3 Jerrican 4 Box ….etc.
The following capital letters shall be used for the types of material: A Steel B Aluminium C Natural wood …..etc.
126.96.36.199 Steel, aluminium or other metal boxes
4A steel boxes
4B aluminium boxes
4N metal, other than steel or aluminium, boxes
188.8.131.52.1 The strength of the metal and the construction of the box shall be appropriate to the capacity of the box and to its intended use.
184.108.40.206.2 Boxes shall be lined with fibreboard or felt packing pieces or shall have an inner liner or coating of suitable material, as required. If a double-seamed metal liner is used, steps shall be taken to prevent the ingress of substances, particularly explosives, into the recesses of the seams.
220.127.116.11.3 Closures may be of any suitable type; they shall remain secured under normal conditions of transport. 18.104.22.168.4 Maximum net mass: 400 kg.
Following excerpt is from 4.1.4
Following is the part of the same table:
22.214.171.124 Specific provisions for metal large packagings 50A steel 50B aluminium 50N metal (other than steel or aluminium)
126.96.36.199.1 The large packaging shall be made of suitable ductile metal in which the weldability has been fully demonstrated. Welds shall be skillfully made and afford complete safety. Low-temperature performance shall be taken into account when appropriate.
Following is from chapter 6.1
Drop height for solids and liquids, if the test is performed with the solid or liquid to be carried or with another substance having essentially the same physical characteristics:
The leakproofness test shall be performed on all design types of packagings intended to contain liquids; however, this test is not required for the inner packagings of combination packagings.
Q. What is Inner packagings?
Ans. Inner packagings means packagings for which an outer packaging is required for transport.
Q. What is the provision in respect of Segregation?
Ans. Regulation 6.1 of part A of chapter VII, SOLAS, deals with segregation. The provisions regarding segregation apply to all cargo spaces on deck or under deck of all types of ships and to cargo transport units. Two articles packages or substances must be segregated when their stowage together may result in undue hazards in case of leakage or spillage, or any other accident, during the handling, carriage, etc. Seggregtion is inter class, rather than intra class as is in case of compatibility. Segregation is obtained by maintaining certain distances between incompatible dangerous goods or by requiring the presence of one or more steel bulkheads or decks between them, or a combination thereof. There is no restriction about filling up intermediate space by some neutral cargo. The following segregation table and associated terms and drawings explain the concept:
The numbers in the segregation table represent:
1 – away from
2 – separated from
3 – separated by a complete compartment or hold
4 – separated longitudinally by an intervening complete compartment
X – Dangerous Goods List (DGL) must be consulted to identify any specific segregation provisions. IMDG Code 188.8.131.52 must be seen for segregation provisions between Class 1 substances and articles.
Q. What do the alphabets and alphanumeric groups written in column 16a and 16b indicate?
Following excerpts are from chapter 7.1
Stowage categories for class 1
Dangerous goods of class 1 other than division 1.4, compatibility group S, packed in limited quantities shall be stowed as indicated in column 16a of the Dangerous Goods List in accordance with one of the categories 01 to 05
Stowage categories for classes 2 to 9
Dangerous goods of classes 2 to 9 and division 1.4, compatibility group S, packed in limited quantities shall be stowed as indicated in column 16a of the Dangerous Goods List in accordance with one of the categories specified below:
The Stowage codes given in column 16a of the Dangerous Goods List are as specified below:
Following exerpt is from chapter 7.2.
Q. What is Composite packaging?
Ans. Composite packagings means packagings consisting of an outer packaging and an inner receptacle so constructed that the inner receptacle and the outer packaging form an integral packaging. Once assembled, it remains thereafter an integrated single unit; it is filled, stored, transported and emptied as such.
Q. What are large packagings?
Ans. Large packagings means packagings consisting of an outer packaging which contains articles or inner packagings and which:
1 are designed for mechanical handling; and
2 exceed 400 kg net mass or 450 litre capacity but have a volume of not more than 3 m3.
Q. What are the general provisions for the packing of dangerous goods, other than goods of classes 2, 6.2 or 7, in packagings, including Intermediate Bulk Containers (IBCs) and large packagings?
Ans. Chapter 4.1 deals with this subject.
- Dangerous goods shall be packed in good quality packagings, including IBCs and large packagings, which shall be strong enough to withstand the shocks and loadings normally encountered:
- during transport, including trans-shipment between cargo transport units and between cargo transport units and warehouses; and
- during any removal from a pallet or overpack for subsequent manual or mechanical handling.
- Packagings, including IBCs and large packagings, shall be constructed and closed so as to prevent any loss of contents when prepared for transport which may be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure.
- Packagings, including IBCs and large packagings, shall be closed in accordance with the information provided by the manufacturer.
- No dangerous residue shall adhere to the outside of packages, IBCs and large packagings during transport. These provisions apply, as appropriate, to new, reused, reconditioned, etc
- Parts of packagings, including IBCs and large packagings, which are in direct contact with dangerous goods:
.1 shall not be affected or significantly weakened by those dangerous goods; and
.2 shall not cause a dangerous effect, such as catalysing; and
.3 shall not allow permeation of the dangerous goods.
Where necessary, they shall be provided with a suitable inner coating or treatment.
- When filling packagings, including IBCs and large packagings, with liquids, sufficient ullage (outage) shall be left to ensure that neither leakage nor permanent distortion of the packaging occurs as a result of an expansion of the liquid caused by temperatures likely to occur during transport.
- Inner packagings shall be packed in an outer packaging in such a way that, under normal conditions of transport, they cannot break, be punctured or leak their contents into the outer packaging. Inner packagings that are liable to break or be punctured easily, such as those made of glass, porcelain or stoneware or of certain plastics materials, etc., shall be secured in outer packagings with suitable cushioning material.
- Cushioning and absorbent material shall be inert and suited to the nature of the contents.
- The nature and the thickness of the outer packagings shall be such that friction during transport does not generate any heating likely to alter dangerously the chemical stability of the contents.
- Dangerous goods shall not be packed together in the same outer packaging, or in large packagings, with dangerous or other goods if they react dangerously with each other and cause:
.1 combustion and/or evolution of considerable heat;
.2 evolution of flammable, toxic or asphyxiant gases;
.3 the formation of corrosive substances; or
.4 the formation of unstable substances.
- The closures of packagings containing wetted or diluted substances shall be such that the percentage of liquid (water, solvent or phlegmatizer) does not fall below the prescribed limits during transport.
- Where two or more closure systems are fitted in series on an IBC, that nearest to the substance being transported shall be closed first.
- Unless otherwise specified in the Dangerous Goods List, packages containing substances which:
.1 evolve flammable gases or vapour;
.2 may become explosive if allowed to dry;
.3 evolve toxic gases or vapour;
.4 evolve corrosive gases or vapour; or
.5 may react dangerously with the atmosphere should be hermetically sealed.
- Where pressure may develop in a package by the emission of gas from the contents (as a result of temperature increase or other causes), the packaging or IBC may be fitted with a vent provided that the gas emitted will not cause danger on account of its toxicity, its flammability, the quantity released, etc. A venting device shall be fitted if dangerous overpressure may develop due to normal decomposition of substances. The vent shall be so designed that, when the packaging or IBC is in the attitude in which it is intended to be transported, leakages of liquid and the penetration of foreign substances are prevented under normal conditions of transport.
- Liquids may only be filled into inner packagings which have an appropriate resistance to internal pressure that may be developed under normal conditions of transport.
- New, remanufactured or re-used packagings, including IBCs and large packagings, or reconditioned packagings and repaired or routinely maintained IBCs shall be capable of passing the prescribed tests.
- Before being filled and handed over for transport, every packaging, including IBCs and large packagings, shall be inspected to ensure that it is free from corrosion, contamination or other damage and every IBC shall be inspected with regard to the proper functioning of any service equipment.
- Any packaging which shows signs of reduced strength as compared with the approved design type shall no longer be used or shall be so reconditioned that it is able to withstand the design type tests. Any IBC which shows signs of reduced strength as compared with the tested design type shall no longer be used or shall be so repaired or routinely maintained that it is able to withstand the design type tests.
- Liquids shall be filled only into packagings, including IBCs, which have an appropriate resistance to the internal pressure that may develop under normal conditions of transport. As the vapour pressure of low-boiling-point liquids is usually high, the strength of receptacles for these liquids shall be sufficient to withstand, with an ample factor of safety, the internal pressure likely to be generated.
- Empty packagings, including IBCs and large packagings, that have contained a dangerous substance shall be treated in the same manner as is required by this Code for a filled packaging, unless adequate measures have been taken to nullify any hazard.
- Every packaging intended to contain liquids shall successfully undergo a suitable leakproofness test. This test is part of a quality assurance programme.
- Packagings, including IBCs, used for solids which may become liquid at temperatures likely to be encountered during transport shall also be capable of containing the substance in the liquid state.
- Packagings, including IBCs, used for powdery or granular substances shall be sift-proof or shall be provided with a liner.
- For plastics drums and jerricans, rigid plastics IBCs and composite IBCs with plastics inner receptacles, unless otherwise approved by the competent authority, the period of use permitted for the transport of dangerous substances shall be five years from the date of manufacture of the receptacles, except where a shorter period of use is prescribed because of the nature of the substance to be transported.
- Where ice is used as a coolant it shall not affect the integrity of the packaging.
- Explosives, self-reactive substances and organic peroxides Unless specific provision to the contrary is made in this Code, the packagings, including IBCs and large packagings, used for goods of class 1, self-reactive substances of class 4.1 and organic peroxides of class 5.2 shall comply with the provisions for the medium danger group (packing group II).
- Damaged, defective, leaking or non-conforming packages, or dangerous goods that have spilled or leaked may be transported in salvage packagings. This does not prevent the use of a larger size packaging or large packaging of appropriate type and performance level. Appropriate measures shall be taken to prevent excessive movement of the damaged or leaking packages within a salvage packaging. When the salvage packaging contains liquids, sufficient inert absorbent material shall be added to eliminate the presence of free liquid. Appropriate measures shall be taken to ensure there is no dangerous build-up of pressure.
- In the case of damaged, defective, leaking or non-conforming pressure receptacles, salvage pressure receptacles. A salvage pressure receptacle may be used as an overpack. Pressure receptacles shall be placed in salvage pressure receptacles of suitable size. Measures shall be taken to prevent movement of the pressure receptacles within the salvage pressure receptacle, e.g. by partitioning, securing or cushioning.
- Salvage pressure receptacles shall be cleaned, purged and visually inspected internally and externally after each use. They shall be periodically inspected and tested at least once every five years.
- During transport, packagings, including IBCs and large packagings, shall be securely fastened to or contained within the cargo transport unit, so that lateral or longitudinal movement or impact is prevented and adequate external support is provided.
Additional general provisions for the use of IBCs
- When IBCs are used for the transport of liquids with a flashpoint of 60°C (closed cup) or lower, or of powders liable to dust explosion, measures shall be taken to prevent a dangerous electrostatic discharge.
- Every metal, rigid plastics and composite IBC shall be inspected and tested, as relevant:
.1 before it is put into service;
.2 thereafter at intervals not exceeding two and a half and five years, as appropriate; and
.3 after the repair or remanufacture, before it is re-used for transport.
- An IBC shall not be filled and offered for transport after the date of expiry of the last periodic test or inspection. However, an IBC filled prior to the date of expiry of the last periodic test or inspection may be transported for a period not to exceed three months beyond the date of expiry of the last periodic test or inspection. In addition, an IBC may be transported after the date of expiry of the last periodic test or inspection:
- after emptying but before cleaning, for purposes of performing the required test or inspection prior to refilling; and
- unless otherwise approved by the competent authority, for a period not to exceed six months beyond the date of expiry of the last periodic test or inspection in order to allow the return of dangerous goods or residues for proper disposal or recycling. Reference to this exemption shall be entered in the transport document.
(You may also visit my youtube videos @captsschaudhari.com)