What’s new in the IMDG Code

CASTING OFF

MARITIME • THE NEW VERSION OF THE IMDG CODE INCLUDES SOME SPECIFIC CHANGES THAT WILL HAVE A BEARING ON HOW DANGEROUS GOODS ARE MOVED BY SEA

IN COMMON WITH the other modes, the International Maritime Organisation (IMO) has adopted revisions to the International Maritime Dangerous Goods (IMDG) Code drawn from the 20th revised edition of the UN Model Regulations. These will appear in Amendment 39-18, which will enter into force on 1 January 2020; its provisions may, however, be applied as from 1 January 2019 and it has been the practice of the major shipping lines to encourage observance of the latest revision as soon as possible.

Until 31 December 2019, Amendment 38-16 is still in force and may be used by shippers and carriers, although IMO points out that dangerous goods falling under the provisions of the IMDG Code must comply with one or the other edition – shippers cannot pick and choose provision from both to suit themselves.

MAJOR CHANGES IMO has provided a handy guide to the major changes that appear in Amendment 39-18. While many of them are taken from the UN Model Regulations, there are others that are specific to the maritime mode and shippers more used to the regulations governing transport by other modes should take care.

Among those changes that are common to the other modal rulebooks are: • The use of the word ‘hazard’ rather than

‘risk’ throughout the regulations • A new paragraph 2.0.6 covering the classification of articles containing dangerous goods, nos • The complete overhaul of Chapter 2.8 on the classification of corrosive substances • Revisions to the lists of organic peroxides and self-reactive substances • Updates to the packing instructions in

Chapter 4.2 • Several minor changes throughout part 6 • Restructuring of Section 7.3.7 • Clarification in 3.1.2.2 that only the more applicable proper shipping name may be used when there is more than one name under a UN number. In terms of layout, 5.2.2.2 has been revised to present the specimen labels in a clearer manner.

IMO has also finally brought in provisions for bulk containers, which has involved an extension of Chapter 5.3. It has also adopted the new IMO Type 9 tank for ‘road gas elements vehicles’ – elsewhere termed multiple-element gas containers (MEGCs) – for the transport of compressed gases of Class 2.

As with the other modes, the Dangerous Goods List has been expanded with several new entries: • UN 3535 Toxic solid, flammable, inorganic, nos • UN 3536 Lithium batteries installed in cargo transport unit • UN 3537 to 3548 Articles containing dangerous goods.

STOWAGE AND SEGREGATION One unique aspect of the IMDG Code is its treatment of the stowage and segregation of dangerous goods. Amendment 39-18 introduces

the idea of segregation groups and the accompanying ‘SGG’ codes, which are shown in column (16b) of the Dangerous Goods List. The 18 SGG codes are identified in 3.1.4.4 and Section 7.2.8 has been revised to reflect their arrival. Note that not all substances are assigned a segregation group code.

It is important to differentiation segregation group codes and segregation codes (‘SG’), where there have also been some changes. SG1 has been amended and three new codes, SG76, SG77 and SG78, have been added. IMO has also added a number of substances in the Dangerous Goods List to SG35, SG36 and/or SG49, requiring their stowage separated from acids, alkalis and/or cyanides.

Finally, the Emergency Schedules (EmS) have been updated and revised to reflect new assignments.

The IMDG Code is, sadly, not available in an open-access online version, though IMO does sell one. Further information on this and other material related to the IMDG Code can be found on the IMO website at www.imo.org/en/ Publications/IMDGCode/Pages/Default.aspx.

SOLID CARGOES The IMDG Code is revised on a biennial cycle by the IMO Sub-committee on Carriage of Cargoes and Containers (CCC), which held its fifth session on 10 to 14 September 2018. With the IMDG Code amendment already adopted, it had time to discuss a number of other issues, some of which are also relevant to shippers and carriers of dangerous goods.

For instance, CCC agreed draft amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code, due to be adopted by the Maritime Safety Committee (MSC) in mid-2019 and appear as Amendment 05-19. These include a new individual schedule for bauxite fines as a Group A cargo following a number of ship losses while carrying the material in bulk.

An ongoing issue is the treatment of ammonium-nitrate based fertiliser. CCC agreed to divide the existing schedule into two: MHB Group B (cargoes which possess a chemical hazard which could give rise to a dangerous situation on a ship); and Group C (do not possess chemical hazards). The division will be based on limits for nitrate and chloride content values. Ammonium nitrate content below 20 per cent or chloride content below 2 per cent have been proposed as a criteria for dividing the existing schedule. As in the case of bauxite fines, this change responds to a few ship losses during the carriage of such fertilisers in bulk. The subject will continue on the agenda at CCC’s next meeting in 2019 with the aim of including the revision in the subsequent Amendment 06-21 to the IMSBC Code.

CCC further discussed amending the IMSBC Code definition of Group A (cargoes which may liquefy) to include other phenomena. This follows research by the Global Bauxite Working Group, which found a new phenomenon affecting some bauxite cargoes, known as dynamic separation, that can cause instability of cargo and ship. CCC agreed that the definition should be amended and instructed the E&T Group to work on it, with the intention of adopting the changes into Amendment 06-21.

NEW SHIP FUELS CCC has also been given the task of drawing up specifications for vessels of all types using non-traditional fuels. This work was triggered largely by the increasing use of LNG as a fuel, leading to the agreement of the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), which entered into force on 1 January 2017.

At its September meeting, CCC agreed draft amendments to the IGF Code relating to the protection of the fuel supply for liquefied gas fuel tanks, aimed at preventing explosions. This issue had been referred back to CCC by MSC and the text agreed by CCC will now go back to MSC for adoption.

In a similar area, a correspondence group was established to discuss a proposal to carry out a formal safety assessment study for ships fuelled by low-flashpoint diesel (i.e. diesel fuel with a flashpoint of less than 60°C). The group will report back to CCC’s next session.

Similarly, CCC agreed to develop safety provisions for fuel cells as interim guidelines, to cover installation, fire safety and other relevant matters and instructed the correspondence group on safety of ships using low-flashpoint fuels to develop relevant draft interim guidelines.

CCC is further on with work relating to the use of methanol and ethanol as fuel for ships. Draft interim guidelines were agreed, which include requirements for the arrangement, installation, control and monitoring of machinery, equipment and systems to minimise the risk to the ship, its crew and the environment, taking into account to the nature of the fuels involved. It is hoped that these guidelines can be finalised at the next session. HCB