DGMS程式需增加或改進的紀錄



YM-LODG Dangerous Goods Q & A

Question 1.

1.1 Is it possible that booking users could apply cargo consolidation of dangerous goods for UN1814 (Class 8) and UN 2790 (Class 8) via IMDG booking system ILIS ( Integrated Line Information System)？

1.2 What is the meaning of approvals ( Including permits, authorizations or agreements ) and

certificates of competent authority？

Answer 1.

1.1 As per IMDG Code provision 7.2.2.3 Segregation in cargo transport units, Dangerous goods which have to be segregated from each other shall not be transported in the same cargo transport unit with the exception of dangerous goods which shall be segregated "away from" each other which may be transported in the same cargo transport unit with the approval of the competent authority. In such cases an equivalent standard of safety shall be maintained. In view of foregoing, we found there are two situations on this provision, First, it is ”Separated from” which is not allowed to be transported in the same container without any exceptions regardless of getting the approval of the competent authority, already. Second, it is “Away from” which may be transported in the same container with the approval of the competent authority. After checking IMDG Code, UN 2790 shall be ”separated from” UN 1814, not ”Away from”. Therefore, we confirmed that it is not acceptable to be loaded into same container.

[pic] [pic]

However, if one of UN 2790 or UN 1814 is transported under“ limited quantities”, they are allowed to be transported in the same container as per IMDG Code provision 3.4.4.

1.2 As per IMDG Code provision 7.9.2.1, approval of competent authority are approvals, including permits, authorizations or agreements, and certificates referred to in chapters 1 to 7.8 of this Code and issued by the competent authority (authorities when the Code requires a multilateral approval) or a body authorized by that competent authority( e. g approvals for alternative packaging in 4.1.3.7, approval for segregation as in 7.2.2.3 or certificates for portable tanks in 6.7.2.18.1) shall be recognized, as appropriate:

1.2.1 By other contracting parties to SOLAS if they comply with the requirements of the

International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended。

1.2.2 And/or by other contracting parties to MARPOL if they comply with the requirements of the International Convention for the Prevention of Pollution from ships,1973, as modified by the Protocol of 1978 relating thereto ( MARPOL 73/78,Annex III ), as amended. Moreover, the competent authorities shall be the ones listed on the list of contact names and addresses of the offices of designated national competent authorities. | |

|Question 2. |

|Is it possible to get any dangerous goods description or note from B/L ( Bill of Lading ) copy, especially for dangerous goods B/L. |

|Answer 2. |

|As everyone knows that if you take a look at the fields of “Description of Packages and Goods ”of dangerous goods B/L ( Bill of Lading ) copy ,|

|and shipper(s) actually surrender carrier(s) the documentation of dangerous declaration and manifest. After reviewing the dangerous goods B/L |

|copy, you will find the description or note of DG commodity、package、cargo weight、IMDG Class、UN NO. .etc. ( Please refer to Fig. 1 ) |

|[pic] |

|Fig. 1 Dangerous goods B/L |

|Question 3. |

|Several kinds of dangerous goods are planned to stuff in the same container, and it is really difficult for carrier(s) to identify how |

|dangerous the goods are in the same transport unit. |

|Should we evaluate danger ranking of dangerous goods in the same transport unit via cargo weight、IMDG Class etc.？ |

|Can we evaluate danger ranking of dangerous goods in the same transport unit from CASP ( Computer Automated Stowage Planning System )？ |

|Answer 3. |

|It is not difficult to improve the function of CASP, especially for each field of container number、cargo weight、cargo IMDG Class, and now we|

|could query and take relevant source into practice through system. But it is really difficult to tell the ranking of all kinds of dangerous |

|goods in the same transport unit. |

|Question 4. |

|The captain & chief officer of MV. YM ANPING firmly believed that dangerous goods of Class 3 shall follow the related regulations for dangerous|

|goods of Class 5.2 while cargo is on its carriage, especially for the problem of “sunlight”; they have no idea whether they should segregate |

|dangerous goods of Class 3 from “sunlight”. Therefore, they are confused if “sunlight” is part of all sources of heat. ( please refer to IMDG |

|Code provision 7.1.12.4：Organic peroxides shall be stowed “away from” all sources of heat. Packages containing organic peroxides shall be |

|protected from direct sunshine and stowed in a cool, well ventilated place. ) |

|Answer 4. |

|Regarding stowage of goods of Class 3, as per IMDG Code provision 7.1.9.3 , The substance of this class shall be kept as cool as reasonably |

|practicable during transit. They “should” be stowed “away from” all possible sources of heat. |

|Moreover, as per IMDG Code provision 7.1.1.15, all sources of heat, where, for certain dangerous goods, protection from sources of heat is |

|required, this shall be taken to include sparks, flames, steam pipes, heating coils, top of side walls of heated fuel and cargo tanks, and |

|bulkheads of machinery spaces (see regulation II-1/2.8 of SOLARS, 1974 (as amend)); alternatively, for the latter, such bulkheads shall be |

|insulated to A-60 standards or equivalent, except that in the case of explosives, in addition to an A-60 bulkhead, "away from" stowage shall be|

|maintained. |

|According to foregoing provision, sunlight is not defined as a source of heat. In addition, in the foreword of IMDG Code, it's been emphasized |

|that the words ''shall'', ''should'' and ''may'', which used in this code, mean that the relevant provisions are ''mandatory'', |

|''recommendatory'' and ''optional'', respectively. If the Chief Officer / Captain of YM ANPING wrongly indicate/ translate the meanings in the |

|IMDG Code, it would be very difficult for DG Center to approve future dangerous goods application. |

|Question 5. |

|We can find ADX Service long term schedule as below following: |

|ADX633W MV. HUA YUN HE |

|ADX634W MV.YM EARTH |

|However Partner announced item a.) ADX 633W to cancel voyage, and the schedule revised as below following: |

|ADX634W MV. HUA YUN HE |

|ADX635W MV.YM EARTH |

|But the previous booking of ADX634W MV. YM EARTH has been approved, then the booking system change vessel automatically from ADX634W MV.YM |

|EARTH to ADX634W MV. HUA YUN HE, and it means system self-approved ADX634W MV. HUA YUN HE, but the booking belongs to previous ADX634W MV. YM |

|EARTH, now we get the problem that MV. HUA YUN HE isn’t YML own vessel, and all YML DG cargo have to get partner’s re-confirmation, but the |

|problem is that IMDG system self-approved YML booking. |

|Answer 5. |

|Pending. |

|Question 6. |

|6.1 What is ISPM 15? |

|6.2 Is it necessary for shippers to declare |

|Fumigation unit? What kind of things |

|shippers should be noted for |

|declaration of fumigation unit? |

|Answer 6. |

|6.1 ISPM 15 is the “International Standards for Phytosanitary Measures Publication No. 15: Guidelines for Regulating Wood Packaging Material in|

|International Trade”.ISPM 15 was developed to address the global spread of timber pests by regulating the movement of timber packing and |

|dunnage for shipping in international trade. ISPM 15 describes phytosanitary measures to reduce the risk of introduction and/or spread of |

|quarantine pests associated with solid timber packing material ( Includes dunnage for shipping ). |

|6.2 As per IMDG Code provision 7.4.3.2, a fumigated unit shall not be allowed on board until a sufficient period has elapsed to attain a |

|reasonable uniform gas concentration throughout the cargo in it. Because of variations due to types and amounts of fumigants and commodities |

|and temperature levels, the period between fumigant application and loading of the fumigated unit on board the ship shall be determined by the |

|competent authority. Twenty-four hours is normally sufficient for this purpose. Unless the doors of a fumigated unit have been opened to allow |

|the fumigant gas and residues to be completely ventilated or the unit has been mechanically ventilated, the shipment shall conform to the |

|provisions of this code concerning UN 3359. |

|According to foregoing provision, If the shippers could provide approvals or certificates from competent authority stating that the fumigant |

|gas and residues are completely ventilated or the unit has been mechanically ventilated, then the cargos can be treated as general cargo to |

|make shipment but contrariwise are treated as Class 9 UN3359. Hence, there are three situations listed as below following: |

|6.2.1. If the wood made packing materials are fumigated inside the container and then it can be treated as shipping dunnage for other |

|containers, we surely can regard it as general cargo because there were no residues of fumigant gas for dunnage itself. ( These kinds of wood |

|made packing materials are fumigated and approved by the competent authorities.) |

|6.2.2. If the shipper(s) could guarantee and have the certificates or approvals from the competent authority stating that there is no |

|fumigant gas in the container after fumigation and complete ventilation, then these cargos could be treated as general cargos to make shipment.|

|(Cargos must be non dangerous goods before fumigation ) |

|Because of time limitation, some shippers fumigate the cargo through ventilated holes right after loading, If the door of a fumigated unit have|

|not been opened to allow the fumigant gas and residues to be completely ventilated or the unit has not been mechanically ventilated after 24 |

|hours, shippers shall declare cargos as Class 9, UN 3359 Fumigation Unit to make shipment in case that people get injured. |

|Question 7. |

|Shall every DG ( dangerous goods ) transport unit(s) stick UN number？ |

|Answer 7. |

|As per IMDG Code provision 5.3.2.1.1.2, packaged dangerous goods loaded in excess of 4,000 kg gross mass, to which only one UN number has been |

|assigned and which are the only dangerous in the cargo transport unit. If transport unit stores 2 and even over 2 kinds of dangerous goods, |

|DG containers shouldn’t stick placard(s) definitely. Moreover, dangerous goods transport unit(s) contain in only limited quantities also be |

|placarded unnecessarily as per IMDG Code 3.4.5.2, but they shall be suitably marked on the exterior of container as "LIMITED QUANTITIES" or |

|''LTD QTY''. |

|Question 8. |

|8.1 Is it necessary to declare one substance with flashing point 89℃ as flammable liquid？ |

|8.2 What are the difference between .UN 1993 and NA 1993？ |

|Answer 8. |

|8.1 The substance with flash point 89℃ is not classified in IMDO Code Class 3 .(≦60.5℃ closed-cup and ≦65.5℃ open cup). |

|Here we list some exception(s) as below following: |

|8.1.1In the temperature of equal or higher than the flash point of transported substance, the substance shall be classified in Class 3 ( For |

|instance, the transport temperature (90℃) is higher than the flashing point 90℃ of the substance ). |

|8.1.2As far as substance within liquid status is concerned, related substance within liquid status have to fix temperature, so as to prevent |

|physical change of substance itself while cargo is on the carriage. If the temperature of said substance is equivalent to or lower than the |

|critical temperature, it will discharge flammable gas probably. If any substance fit aforementioned 2 exceptions, it should be classified as |

|dangerous goods. It is advisable that consignee(s) are required to provide the detail information because sometimes there are no explications |

|about the heating of the substance during transport ting. |

|8.2 After checking related website, DIMETHYL SULFOXIDE should be treated as general cargo. |

| |

| |

| |

| |

|However, there are also some MSDS indicates that DIMETHYL SULFOXIDE should be treated as dangerous goods because it is based on the DOT |

|regulation instead of the IMDG Code. Therefore, its No should be NA 1993 rather than UN1993. |

| |

| |

|According to DOT CFR 49 172.101(e): |

|Those preceded by the letters ''NA'' are associated with proper shipping names not recognized for international transportation, except to and |

|from Canada. Identification numbers in the ''NA9000'' series are associated with proper shipping names not appropriately covered by |

|international hazardous materials (dangerous goods) transportation standards, or not appropriately addressed by international transportation |

|standards for emergency response information purposes, except for transportation between the United States and Canada. |

|According to the forgoing provision, NA. No. can only be used in United States and Canada. Therefore, DIMETHYL SULFOXIDE shall be either |

|declared as NA1993 or non- dangerous goods. |

|Question 9. |

|9.1 Is charcoal appertaining to DG cargo？ |

|9.2 IF charcoal is DG cargo, how about our company’s policy for this kind of commodity？ |

|Answer 9. |

|9.1 As everyone knows, charcoal is made of substance which contains coal. The components of it are usually coal、coconuts. As per IMDG Code |

|special provision 925, some descriptions for charcoal are exempted dangerous goods as below following: |

|9.1.1 If charcoal is made of mineral substance. |

|9.1.2 If mentioned charcoal was passed the test of substance for self-heating. |

|9.1.3 If said charcoal was passed the test of water vapor activation. |

|To sum up above mentioned items, if shipper(s) want to declare their commodity (charcoal) as non-dangerous goods, they have to surrender |

|suitable approvals or certificates as below following: |

|To pass the test of water vapor activation for shipper’s charcoal. |

|Approvals and Certificates of competent ( e.g. Shanghai Chemical Industry Design Institute (SCIDI)、Industrial Technology Research Institute of|

|Taiwan, ROC ( ITRI ), |

| |

|Please note if said commodity can’t be fit in with aforementioned item a.) and b.), shipper(s) shall not refuse to declare their commodities as|

|dangerous goods. |

|Our company met 3 cases about charcoal firing on board since year 2000, the descriptions of 3 event are as below following: |

|Case 1. |

|Time: Aug 17, 2000. |

|Abstract: |

|Captain of MV. Ming Eternity said one of 40 feet dangerous goods container ( Loading port : Colombo, YMLU 4385250, Class 4.2, UN 1361, Charcoal|

|) happens to spontaneous combustion, and it involves the containers on board nearby. After crew deal with, then |

|fire on board be controlled. |

|Cause Analysis: |

|After reviewing investigation of this case, the possible course of said cargo spontaneous combustion is that shipper skips the step of cooling |

|of mentioned charcoal, and it results in high temperature of charcoal, and the weather of Colombo is cloudy and humid at that moment ( It is |

|easy to cause charcoal spontaneous combustion fire while it complied with humidity ), and it caused fire. |

|Prevention Strategy: |

|Our company ever listed all kinds of charcoals as prohibited dangerous goods after the fire accident occurs. |

|But for business concern, our company agreed all kind of charcoal approval restricted to compliance with certain conditions, and the |

|description of restricted conditions are as below following: |

|Shipper(s) have to surrender |

|manufacturing of charcoal, and the statements of the report(s) are as below following: |

|The statements have to describe the procedure of cooling for charcoal clearly. |

|The cooling time of the manufacturing ( charcoal ) before cargo package shall exceed 14 days. |

|Vanning survey report shall |

|include statements as below following: |

|This kind of cargo package shall correspond to IMDG Code. |

|The package shall be in good order ( well sealing up、no crack ). |

|The temperature of cargo shouldn’t be 5℃ higher than the room temperature. |

|4. There are no special smell and smog inside the container during the period of vanning survey. |

|5. To reserve a gap of 30 centimeter between the top of the cargo and the top of the container, to put out a fire inside the container easily.|

|6. The number of container、container type、container number、container seal number。 |

|7. Vanning survey date shall not more than 7 days before on board date. |

|Case 2. |

|Time: Sep 18, 2003. |

|Abstract: |

|Thailand agent books a shipment of ”BBQ Charcoal” via MV. Ym Victory, but the cargo caused fire, |

|then vessel be assigned emergency berthing in Osaka, and the fire accident caused other cargoes damage nearby. 3 days after this event, the |

|same commodity ”BBQ Charcoal” was on board of MV. Kuo Tai, and MV. Kuo Tai also caused fire by this kind of commodity. It also results in other|

|2 container’s cargo damage. |

|Cause Analysis: |

|After reviewing investigation of this event, one reason is shipper didn’t declare the commodity as DG cargo, and it’s not in good order for |

|said cargo package, the other reason is the colleagues of agent didn’t have good awareness of said cargo, and didn’t re-confirm competent |

|authority. |

|Case 3. |

|Time: Apr 06, 2006. |

|Abstract: Tianjin port agent books a charcoal container, shipper declared said commodity is non-dangerous goods and surrendered letter of |

|guarantee, but said container caused fire during carriage, after unloaded |

|mentioned container at port of Port Said, P & I Club picked and sent the sample of commodity to the laboratory. Then they found said commodity |

|is IMDG Class 4.2 dangerous goods with a special property of spontaneous combustion easily. |

|Cause Analysis: |

|After reviewing the investigation report, one reason is that shipper concealed his cargo as general cargo, the other reason is colleagues of |

|agent didn’t re-confirm with competent authority. After finish analyzing aforementioned 3 cases, the case for year 2000 is to sip the normal |

|procedure of commodity ( charcoal ) pre-cooling before shipment. As per the policy of our company for charcoal or active carbon, shipper(s) |

|have the duties to surrender the approvals or certificates of pre-cooling and normal procedure for mentioned cargo as well as the survey report|

|as third party. Therefore, it goes without saying that carrier(s) should avoid this kind of accident hereafter. |

|Aforementioned other 2 cases, both are caused by shipper’s dishonorable declaration of commodity. If parties concerned are responsible for |

|asking shipper(s) to surrender necessary documentation of approvals at the first, person in charge would find out the dishonesty of |

|shipper(s), and will reject the shipment naturally. Therefore, our company get the conclusion that if shipper(s) can provide the certificates |

|or approvals of their commodities as non-dangerous goods, we surely regard their cargo as general cargo. Otherwise, the way to prevent such |

|accident still depends upon the duties of parties concerned; how to manage DG cargo or general cargo with suspect for person in charge. Our |

|company happened to 5 cases of management carelessness since year 2000, therefore, the solution is that parties concerned should go through |

|every commodities with suspect strictly, to ensure the transportation of our company’s dangerous goods more reliable and smooth, such as crew |

|safety、vessel safety、cargo safety. |

|Question 10. |

|10.1 Class 2 is subdivided to Class2.1, Class2.2 and Class 2.3. Why is it that customer could only declare Class 2,UN1950 AEROSOLS as Class 2|

|instead of Class2.1, Class 2.2 or Class2.3 on the DG declaration document? |

|10.2 How is UN 1950 AEROSOLS with Limited quantity (less or equivalent 1000 ml ) segregated when it is declared as Class 2 on DG declaration |

|document? Is it classified in Class2.1 or Class 2.2? |

|Answer 10. |

|10.1 Although UN1950 AEROSOLS is classified in Class 2, according to IMDO Code special provision 63, the division of Class 2 and the |

|subsidiary risks depend on the nature of the contents of the aerosol dispenser. (Please refer to Note 1). Therefore, the Consignee shall |

|provide necessary information about the properties of the contents whether the contents are classified in Class 2.1 or Class 2.2 before loading|

|to carriers for their easy reference to make shipments. With regarding to the documentation of UN 1950 AEROSOLS as Class 2 is regulated by IMDG|

|Code 3.4.6.2 (For aerosols not exceeding 1000 cm3 (UN 1950), no sub-division is assigned and the class to be shown on the dangerous goods |

|transport document is "2".) In other words, when UN 1950 AEROSOLS is transported and its packing capacity follows limited quantity special |

|provision(Please refer to Note 2), it will be written as Class 2 on the documentation of DG declaration. |

|*However, if the packing capacity is over 1000 ml, the UN1950 AEROSOLS has to be classified either Class2.1 or Class 2.2 on the documentation |

|of DG declaration. |

|10.2 According to the Stowage and segregation on the dangerous goods list: for AEROSOLS with a maximum capacity of 1 L: Category A. Segregation|

|as for class 9 but 'Away from' sources of heat and 'Separated from' class 1 except division 1.4.)。 |

|But if the packing capacity is more than 1000 ml, UN 1950 AEROSOLS subsidiary risks is determined by the contents of the aerosol dispenser. |

|Note 1. |

|IMDG special provision 63: the division of Class 2 and the subsidiary risks depend on the nature of the contents of the aerosol dispenser. The |

|following provisions shall apply: |

|Class 2.1 applies if the contents include 85% by mass or more flammable components and the chemical heat of combustion is 30 KJ/g or more. |

|Class 2.2 applies if the contents contain 1% by mass or less flammable components and the heat of combustion is less than 20 KJ/g. |

|Otherwise the product shall be classified as tested by the tests described in the United Nations Manual of Tests and Criteria, Part III, |

|section 31. Extremely flammable and flammable aerosols shall be classified in Class 2.1;non-flammable in Class 2.2. |

|Gases of Class 2.3 shall not be used as a propellant in an aerosol dispenser. |

|Where the contents other than the propellant of aerosol dispensers to be ejected are classified as Class 6.1 packing group II or III or Class 8|

|packing group II or III, the aerosol shall have a subsidiary risk of Class 6.1 or Class 8. |

|Aerosols with contents meeting the criteria for packing group I for toxicity or corrosives shall be prohibited |

|From transport. |

|Except for consignments transported in limited quantities ( Please see chapter 3.4 ), packages containing aerosols shall bear labels for the |

|primary risk and for the subsidiary risk if any. |

|Flammable components are flammable liquids, flammable solids or flammable gases and gases mixtures as defined in Notes 1 to 3 of sub-section |

|31.1.3 of part III of the United Nations Manual of tests and criteria. This designation does not cover pyrophoric, self-heating or |

|water-reactive substances. The chemical heat of combustion shall be determined by one of the following methods: ASTM D 240, ISO/FDIS |

|13943:1999(E/F)86.1 to 86.3 or NFPA 30B. |

|Note 2 |

|IMDG special provision 277: |

|For aerosols or receptacles containing toxic substances, the limited quantity value is 120 ml. For all other aerosols or receptacles, the |

|limited quantity value is 1000 ml. |

|2006/8/17 |

|Question 11. |

|11.1 Is fishmeal belonged to DG cargo? |

|11.2 What are shippers required to be noted when fishmeal is transported? |

|Answer 11. |

|11.1 As per IMDG Code special provision 907: the consignment shall be accompanied by a certificate from a recognized authority stating: |

|--Moisture content; |

|--Fat content; |

|--Details of anti-oxidant treatment for meals older than 6 months(for UN 2216 only); |

|--Anti-oxidant concentration at the time of shipment, which must exceed 100 mg/kg (for UN 2216 only); |

|--Packing, number of bags and total mass of the consignment; |

|--Temperature of fishmeal at the time of dispatch from the factory; |

|--Date of production |

|11.2 No weathering/curing is required prior to loading. Fishmeal under UN 1374 shall have been weathered for not less than 28 days before |

|shipment. When fishmeal is packed into containers, the container(s) shall be packed in such a way that the free air space has been restricted |

|to the minimum. |

|Question 12. |

|Why shipper usually surrender carrier cargo weight of liquid dangerous goods in weight unit |

|instead of volume unit? |

|Answer 12. |

|For example, we assume the cargo weight is 97 kilograms, if the density of cargo is lower than 1, |

|we assume its density 0.97, then we can have this cargo’s volume 100 liters. That proves shipper surrenders carrier cargo weight of liquid |

|dangerous goods in weight unit, the controversial cargo weight in weight unit is underestimated obviously. Though there isn’t any mandatory |

|regulation for weight unit from table IMDG Code P001 and IMDG Code Chapter 5 provision, we can sum up shipper should submit carrier liquid |

|cargo weight in volume unit better than in weight unit practically. |

|13. |

|14. |

|15. |

|16. |

| |

| |

| |

| |

| |

................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download