One of the most common issues we get asked about at ICC The Compliance Center is segregation of dangerous goods. A shipper may have two different chemicals – can they ship them in the same promotion ? Or even in the lapp freight container ? The answer is important because having to discriminate parts of a cargo can increase the cost of transport by a lot .
unfortunately, the solution international relations and security network ’ thyroxine constantly easy to find. unlike regulations will have unlike requirements. For exemplar, Canada ’ s Transportation of Dangerous Goods Regulations ( TDG ) doesn ’ t have any particular guidelines other than a table in section 5.7 that only applies to class 1 Explosives. On the other handwriting, the Hazardous Materials Regulations ( HMR ) in the U.S. system have a detail postpone indicate classes that have to be shipped on classify vehicles, those which may be shipped without restriction, and those which may be shipped on the same vehicle but must be separated to prevent commingling in encase of an accident. But the most complex system for segregation is that for marine shipments under the International Maritime Dangerous Goods ( IMDG ) Code. not following these rules can result in your cargo being stopped at the port if you ’ ve mistakenly combined two substances that the Code has classified as requiring segregation .
Basics of IMDG Segregation
first, why is segregation so significant for marine dispatch. Well, if you ’ ve always seen a ship at sea in a storm, you ’ ll understand how chemicals could mix if they both leak at the faulty time. And marine carriers transport millions of tonnes of dangerous goods per year. so, it ’ randomness crucial to keep chemicals from mixing during the trip.
This has led the International Maritime Organization ( IMO ), which created the IMDG Code, to develop a system that relies on three steps of protection :
- A generic segregation-by-class table found in section 7.2.4 , IMDG Code bulk 1
- Substance-specific guidelines based on codes found in the list of Dangerous Goods , IMDG Code volume 2
- Shipper and carrier cognition of the substances involved
The most crucial thing to remember when planning a marine load is department 7.3.4.1, which states that :
“ Dangerous goods which have to be segregated from each other according to the provisions in chapter 7.2. shall not be transported in the same cargo transport unit… ”
In other words, if you determine that there are any applicable segregation requirements, you can ’ t put the two dangerous goods in the lapp cargo transport unit in concert, nor may you put them in the same package or overpack .
so, let ’ s take a attend at how this works .
Step 1 – Consult the Segregation Table
The rules for segregation by class can be found in IMDG Code Part 7. There are a number of complexities for the crew of the vessel as to where on the ship dangerous goods of differing classes may be loaded – on pack of cards, next to each early in compartments inside the hull, or in discriminate compartments. however, let ’ s concentrate on what the shipper needs to know. Can the classes of dangerous goods go in the same Cargo Transport Unit ( CTU ) or will they have to be placed in separate CTUs so they can be stowed in different areas ? ( Note that of course if goods can ’ thyroxine be placed in the same CTU, you obviously can not package them together. )
The table for segregation by class can be found in section 7.2.4, as follows ;
To determine the segregation for two classes, you would read a rowing for one class ( across ) and for the other class read a column ( down ). Where they intersect, you will either find the letter “ X ” or a count. The numbers ( 1, 2, 3 or 4 ) will tell the people stowing the goods how far apart they must be separated, as follows :
“ 1 ” – “ away from ” ( normally, CTUs at least 3 metres apart )
“ 2 ” – “ separated from ” ( normally, CTUs at least 6 metres apart )
“ 3 ” – “ separated by a complete compartment or hold from ”
“ 4 ” – “ separated longitudinally by an intervening accomplished compartment or oblige from ”
eminence that “ 1 ” indicates the smallest necessitate legal separation, and “ 4 ” the greatest. But for the shipper this doesn ’ t very matter – any number indicates those classes cannot be put in the same CTU .
( technically, department 7.3.4.1 allows you to ship goods that must be stowed “ aside from ” each other, indicated by a “ 1 ” on the board, in the lapp CTU if you can obtain a license from the “ competent authority, ” such as Transport Canada or the U.S. Department of Transportation. however, applying for a permit or equivalency certificate can be a time-consuming operation, and a shipper is not guaranteed success if they apply. )
Let ’ s look at a couple of examples. First, let ’ s see if you could ship a flammable gasoline such as UN1978, PROPANE, in class 2.1 in the same CTU as UN1203, GASOLINE, a flammable fluent .
We find the compatibility in this sheath by reading across for class 2.1 and down for classify 3 :
unfortunately for our design, there is a number ( “ 2 ” ) where the row and column intersect. This means that we can not put these two products into the same CTU for an IMDG cargo .
On the other hand, let ’ s consider a dispatch of a hand sanitizer based on UN1170, ETHANOL ( class 3 ) with UN2555, NITROCELLULOSE WITH WATER ( class 4.1 ). We ’ ll front at class 3 as a row going across, and class 4.1 as a column going down :
In this case, there ’ s an “ ten ” where the row and column intersect. This means that there is no automatic pistol segregation between class 3 and classify 4.1 materials .
But before we start loading our cellulose nitrate and ethyl alcohol into the same freight container, we have another footfall to take. future, we must check these particular substances to see if there is any other compatibility issue between them beyond the generic class compatibility .
Step 2 – Consult Segregation Requirements in the Dangerous Goods List
just because two classes in cosmopolitan preceptor ’ deoxythymidine monophosphate require segregation doesn ’ thymine mean that two particular substances in those classes are in the clear. Our future pace is to go to the Dangerous Goods List in bulk 2 of the IMDG Code, and check column 16b, headed “ Segregation. ”
In this column, we can find two sorts of codes – “ SG ” codes ( Segregation ) and “ SGG ” codes ( Segregation Group ). These will give more guidance regarding segregating specific substances and articles.
Read more: Australia Maritime Strategy
therefore, let ’ s first look up UN1170, ETHANOL :
hera, column 16b is blank. That means UN1170 doesn ’ thymine have any specific extra segregation requirements .
But it ’ s a short unlike when we look up UN2555, NITROCELLULOSE WITH WATER :
here we have two codes in column 16b – SG7 and SG30. To find out what these codes mean, we must go to IMDG Code section 7.2.8, where they explain what these “ segregation codes ” exemplify .
The inaugural code, SG7, means that this merchandise needs to be segregated “ aside from ” class 3 materials. In early words, it ’ south as if there were a “ 1 ” between these specific substances on the generic segregation by classify table. These substances can not be placed in the like CTU, even though the generic postpone indicates there is no particular segregation by classify since the segregation code demands these two specific products be segregated .
The second code doesn ’ deoxythymidine monophosphate affect this particular cargo, but it brings up another complicatedness. Along with the SG codes, there may be “ SGG ” codes. These are “ Segregation Group ” codes, which apply to sealed families of chemicals, regardless of their class. These chemical families will have special extra segregation requirements. The table can be found in part 7.2.5.2 and covers 18 common chemical families that can cause dangerous reactions :
According to our entry for UN2555, the chemical must be segregated from anything placed in the segregation group SGG7, “ heavy metals and their salts. ” This would include compounds of metals with heavy atomic weights, such as mercury ( Hg ), cadmium ( Cd ), arsenic ( As ), chromium ( Cr ), thallium ( Tl ), and lead ( Pb ) .
It ’ s the shipper ’ sulfur responsibility to assign substances to SGG codes ( segregation groups ) as allow. This is described in IMDG Code incision 3.1.4. A issue of coarse chemicals are assigned to their corresponding groups in section 3.1.4.4, but if a chemical is not listed, the shipper must make their own decision. so, for model, if you had a generic shipping name “ TOXIC LIQUID, INORGANIC, N.O.S. ” that contained nitrile compounds, you would assign it to SGG6, Cyanides .
If the ship name international relations and security network ’ t listed in section 3.1.4.4, but the shipper believes the substance belongs in one of these groups, they must indicate the group code on the ship document to allow the vessel crew to stow the means safely. For model, the entrance here might read “ UN 3287, TOXIC LIQUID, INORGANIC, N.O.S. ( potassium nitrile, sodium nitrile ), 6.1, PG II, IMDG Code segregation group 6 ” .
Step 3 – Shipper and Carrier Knowledge
Let ’ s imagine we have two products – say UN1203, GASOLINE, classify 3 and UN1944, MATCHES, SAFETY, classify 4.1. According to the postpone in section 7.2.4, these two classes do not require automatic pistol segregation – that is, there is an “ x ” where the two classes intersect on the postpone. And when we check column 16b, there are no SG or SGG codes at all for both products. Does that mean we ’ rhenium clear to load them together ?
well, not quite. If you or the vessel operator believe that, despite this, there is a risk to the safety of cargo or the vessel itself from shipping the two substances in the like CTU, they should be segregated based on your understand of the hazards. The hazards to consider are listed in incision 7.2.6.1, and include :
- Combustion and/or evolution of considerable heat ;
- development of flammable, toxic or asphyxiant gases
- The geological formation of corrosive substances ; or
- The formation of mentally ill substances .
indeed, if you have enough matches that you fear they might catch fire leading to the ignition of gasoline vapours in the CTU, the two products should be shipped in different CTUs .
Exceptions from Segregation
sometimes you may be fortunate enough to have substances that appear to be antagonistic but actually can be shipped together. section 7.2.6.3 gives three situations where segregation does not need to be applied :
- Between dangerous goods of different classes which comprise the same means but vary only in their urine content. The IMDG Code gives an exercise of solutions of the chemicalsodium sulphide, which might be classed in class 4.2 or class 8 depending on its concentration in water. flush though class 4.2 and course 8 have a “ 1 ” between them on the table in section 7.2.4, they don ’ t need to be segregated, since if they mix they wouldn ’ thyroxine react perilously .
- Between dangerous goods which belong to a group of substances of different classes but for which scientific evidence exists that they do not react perilously when in contact with each other. As a guide, there are three tables, 7.2.6.3.1, 7.2.6.3.2 and 7.2.6.3.3. Products on the same table don ’ thymine have to be segregated even if table 7.2.4 says they should be segregated by class. For model, UN1295, TRICHLOROSILANE, classify 4.3 ( 3, 8 ) and SILICON TETRACHLORIDE, class 8, are both on table 7.2.6.3.2 and do not have to be segregated, evening though course 4.3 and course 8 are listed as contrastive in section 7.2.4. note that these tables are good common examples – if you have valid scientific attest that your two substances can mix without a dangerous reaction, they will not be subjugate to segregation .
- ultimately, there is a board 7.2.6.3.4 that lists certain substances ( by and large organic peroxides ) that may be shipped together if you believe that they can not cause any of the dangerous reactions such as heating system or development of dangerous gases listed in section 7.2.6.1 .
In summation, the small measure exceptions of circumscribed Quantities ( section 3.4.4 ) and exclude Quantities ( section 3.5.8 ) are normally not capable to the segregation requirements, although section 3.4.4.2 mentions some restrictions for limited quantities of explosives course 1 when shipped in combination with fully regulated class 1 substances or articles .
Can It Be Easier?
possibly by now you ’ rhenium wondering why the IMDG Code doesn ’ thymine have an industry-standard simplified code, such as the IATA Dangerous Goods Regulations ( DGR ) produced by the International Air Transport Association to make submission with the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air a little dim-witted for shippers and operators. Turns out that there is such a lead when it comes to determining compatibility, although it ’ randomness possibly not vitamin a well known as the IATA DGR .
The Storck Guide : stowage & Segregation to IMDG Code is produced by the german publish party ecomed Storck GmbH but is available in English. It concentrates on IMDG ’ mho stowage and segregation requirements, with simplified guides that make it quick and bare for vessel carriers to determine segregation requirements and plot where CTUs should be placed on vessels. Of course, this data will besides be useful for shippers planning loads for ocean tape drive .
The Storck Guide is available in hard imitate and besides as a candle. Don ’ deoxythymidine monophosphate forget that it must be updated once every two years, equitable as the IMDG Code is, based on the UN Recommendations on the Transportation of Dangerous Goods .
Conclusion
The segregation requirements of the IMDG Code are complex, and require full access to an update version of the Code. besides, keep in thinker that other regulations may have conflict rules about segregation. If you need aid in determining your segregation requirements, or would like to purchase an update replicate of the IMDG Code or the Storck Guide, contact us here at ICC The Compliance Center at 888-442-9628 ( U.S. ) or 888-977-4834 ( Canada ) and get the advice you need !
Sources:
International Maritime Organization, International Maritime Dangerous Goods Code
Transport Canada, Transportation of Dangerous Goods Regulations
Transport Canada, How to Apply for an Equivalency Certificate ( Permit of Equivalent Level of Safety )
US Department of Transportation, Hazardous Materials Regulations, 49 CFR
PHMSA ( Pipelines and Hazardous Materials Safety Administration ), hazardous Materials Approvals and Permits Overview
Ships Business, Segregation and Stowage Requirements for Dangerous Cargo – IMDG Code Guideline
MSDS Online, Lessons Learned : Improving HazCom and Avoiding the Dangers of ill-sorted Chemicals
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