IMDG Shipping by Vessel: The DG Journal Part 6 of 6, IMDG Limited Quantities by Ocean Process

Welcome to the sixth and final installment of Hazmat University’s DG Journal. Today we will discuss the IMDG shipping by vessel limited quantities (LQ) process, and the 16 steps to bear in mind when preparing these shipments. Read on for a step-by-step process for preparing limited quantity shipments. We advise you use this process, alongside the IMDG Code, to make sure that all of the relevant requirements for classification, identification, marking, labeling, packaging, and documentation are met.

Sea transport is crucial in the shipping of hazardous materials due to the large quantities involved, making compliance with specific regulations and proper training for personnel essential to ensure safety and adherence to guidelines.

But remember, this guidance is NOT meant to replace the regulations. As these regulations are updated often, please be sure to check regulatory references to determine if they affect your shipment before proceeding.

16 Steps for IMDG Shipping by Vessel Process

1. Determine if the substance is CLASSIFIED as a dangerous good in transportation.  Most shippers will use section 14 on the material’s Safety Data Sheet (SDS). If the material is a dangerous good, the proper shipping name and UN number most likely will be found there.  It may also be provided in by the manufacture’s shipping department.
   1. If the information is not listed on an SDS or in the shipping system, the hazard class/division must be determined by comparing the chemical characteristics of the materials with the classification criteria found in IMDG Part 2.
   2. If the information on the chemical characteristics of the material is not available, testing must be performed to determine the hazard class(es).
   3. This section may also provide information about whether the material is a HAZARDOUS SUBSTANCE.  Check 49 CFR 172.101 Appendix A to see if the material or its components are listed.  If the material is being shipped at a quantity equal or above the listed RQ, the material is a hazardous substance and must be identified as such on the package and shipping document.
2. Check the Dangerous Goods List (IMDG 3.2 Columns 1 and 2) for the UN NUMBER and Proper SHIPPING NAME in all caps.  This is the name used to identify the material on the package and the dangerous goods documentation.  If special provision 274 or 318 is listed in Column 6, the technical name must be shown in parenthesis with the proper shipping name.
   1. The Dangerous Goods List in the IMDG Code is sorted by UN Number.  If the UN number is not provided, look up the proper shipping name in the index at the end of Volume 2, then look up the UN number in the Dangerous Goods List.
3. Note the PRIMARY AND SUBSIDIARY HAZARD CLASSES/DIVISIONS (Columns 3 and 4) and PACKING GROUP (Column 5) of the material.  If more than one packing group is listed, check the SDS to determine which packing group to apply.
4. Determine if the material is FORBIDDEN from transported by ocean. (IMDG 1.1.3)
5. Determine if the material is permitted to be transported as a LIMITED QUANTITY. Look at Column 7a.  If a “0” appears in the column, the material must not be shipped as a limited quantity.
6. If the material is not forbidden for transport as a limited quantity, determine the PACKAGE LIMITS in Column 7a for limited quantities.
7. Determine if the material is a MARINE POLLUTANT by checking Column 4 (“P”), IMDG Chapter 2.10, and the List of Marine Pollutants 49 CFR 172.101 Appendix B. If the material is a marine pollutant, it must be identified as such on the package and shipping document.
8. Note the PACKING INSTRUCTION number in Column 8 and special packing provisions in Column 9.
9. Read all SPECIAL PROVISIONS listed in Column 6.  Special provisions are found in IMDG 3.3.
10. Ensure the packaging complies with the general packing provisions and the specific provisions found in the packing instruction (IMDG Chapter 4.1).
11. Prepare the PACKAGING following the packing instruction and the manufacturer’s closure instructions.
12. MARK and LABEL the package as required. (IMDG Chapter 5.2)
13. If preparing an OVERPACK, make sure to:
    1. Check Table 7.2.4 for segregation requirements,
    2. Duplicate all labels and markings on the outside of the overpack,
    3. Mark the outside of the overpack with the OVERPACK marking, and
    4. Add the overpack identification mark if required.
14. Complete the DANGEROUS GOODS DOCUMENTATION. (IMDG Chapter 5.4)
15. Provide appropriate EMERGENCY RESPONSE INFORMATION.  (49 CFR 171.22(g)(1))
16. Offer PLACARDS to trucking company as required by 49 CFR 172 Subpart F and IMDG Chapter 5.3.

Regulatory Exemptions for Shipping Dangerous Goods in Limited Quantities by Vessel – What You Need to Know

When it comes to shipping dangerous goods in limited quantities, the International Maritime Dangerous Goods (IMDG) Code provides certain exemptions to ease the regulatory burden for shippers. These exemptions are designed to reduce the administrative load associated with the shipping process and the overall costs for shippers. It is crucial to comply with the guidelines set by the hazardous materials safety administration to ensure the safety of individuals and the environment.

There are a number of reasons why these exemptions are in place.

Reduced Risk Profile: The primary reason for easing the regulatory standards for limited quantity shipments of dangerous goods is that they pose a lower risk compared to standard shipments. The reduced risk profile allows the IMDG Code to provide regulatory exemptions to these shipments without compromising on safety.

Encouraging Compliance: These exemptions are designed to make it easier for businesses, especially those dealing with small quantities of dangerous goods, to comply with the necessary regulations. Simplifying these requirements can encourage regulatory compliance across the spectrum and incentivize more businesses to adhere to the guidelines, which can lower the risk of dangerous goods accidents to a significant extent. Dangerous goods training is essential for crew members involved in shipping dangerous goods to handle IMDG cargo safely and effectively.

Cost Savings: Complying with the regulatory requirements for standard shipments of dangerous goods can be complex and costly. By exempting limited quantity shipments from some of the more stringent requirements, the IMDG Code aims to simplify and streamline the shipping process and reduce the costs for shippers.

The key regulatory exemptions for shipping dangerous goods in limited quantities by vessel include:

Packaging Requirements

One of the most notable exemptions for limited quantity dangerous goods shipments is regarding the packaging. Typically, dangerous goods must be shipped in packaging that has undergone rigorous performance testing to ensure it can withstand the challenging conditions of ocean transportation.

For limited quantity shipments, this requirement is relaxed and the packages are only required to meet certain select general packaging requirements outlined in Chapter 4 of the IMDG Code. The packaging must be a combination packaging (an inner packaging contained within an outer packaging) and it doesn’t have to undergo the drop and stack test or any other testing that might be required for standard shipment packages.

Labeling and Marking Requirements

For limited quantity shipments, most of the standard marking and labeling requirements are not applicable. The primary labeling requirement is the Limited Quantity label, which must be affixed to the packages. If the material is liquid, orientation arrows must be used, unless otherwise excepted.

Placarding and Cargo Segregation Requirements

Placarding of vehicles and containers is another requirement that does not apply to limited quantity dangerous goods shipments. Moreover, most of the cargo segregation requirements specified in IMDG Code 7.2 are also waived for limited quantity shipments.

It’s critical to note that just like shipping hazardous materials in limited quantities by air, shipping dangerous goods in limited quantities by vessel also requires a shipper’s declaration, which should include the word ‘LIMITED QUANTITY’ or ‘LTD QTY’.

Hazmat University’s Limited Quantities by Vessel Training Course

Hazmat University offers a specialized online training course designed for employees involved in the handling and transport of dangerous goods in limited quantities by vessel. This course can serve as a standalone course for shipping dangerous goods in limited quantities by vessel or as a supplementary component to our other, more extensive online hazmat training courses. IMDG Certification Training is crucial for hazmat employees to ensure compliance with safety regulations, improve efficiency, and reduce risks associated with transporting hazardous materials.

The course is based on the regulatory requirements outlined in the IMDG Code and the training component is compliant with the initial as well as recurrent hazmat training requirements stipulated by 49 CFR Part 172, Subpart H, Section 172.704, as well as the IMDG Code. The International Maritime Organization, a United Nations agency, plays a key role in regulating the transport of hazardous materials by sea, creating safety standards to protect workers, ships, and the marine environment.

Designed by seasoned industry experts, our hazmat online training courses offer in-depth knowledge of the IMDG Code compliance requirements for shipping dangerous goods by vessel. Our 2024 online hazmat training courses have been updated to cover all the latest regulations and amendments, so that you can stay right on top of your regulatory requirements. Safe packaging and proper segregation of incompatible substances are essential when transporting dangerous goods to ensure safety and compliance with international regulations.

Easily accessible and easy to learn, our online hazmat training courses make learning more fun than ever before and allow you to complete your training at your own, comfortable pace. Once you complete your training, you can get a certificate of completion right away. Adhering to the IMDG Code is significant when transporting hazardous materials to prevent dangerous reactions and ensure regulatory compliance.

Originally Posted: December 9, 2021 | Updated: December 27, 2024