The regulations
There are many regulations that need to be followed when transporting dangerous goods by sea. The UK government website provides details on many of these regulations.
When transporting by sea, a dangerous goods notification must be completed. Also, when transporting dangerous goods by sea, a DGSA (dangerous goods safety advisor) must be employed. There are, however, some exceptions to this:
- It is only done occasionally (such as breakdown recovery vehicles)
- The dangerous goods are only being received (you’re the consignee)
- The goods are in limited quantities
- The goods are being moved a very short distance by road, such as between buildings on an industrial estate
- Private vehicles are being used
In order to hire a dangerous goods safety advisor, you can contact the Department for Transport email address dangerousgoods@dft.gov.uk.
The United Nations (UN) Classification System
There are 9 classifications according to the United Nations for the transportation of dangerous goods. Explosives, gases (flammable gas, non-flammable, non-toxic, toxic gas), flammable liquid, flammable solids (flammable solid, spontaneously combustible substance, substance which in contact with water emits flammable gas), oxidising substances (oxidising substance, organic peroxide), toxic substances (toxic substance, infectious substance), radioactive material, corrosive substances, and miscellaneous dangerous goods.
The consignor must assign a proper shipping name and UN number to the substance when shipping. Dangerous goods are also subject to limits in quantity, which cannot be exceeded in order to ensure the safe shipment of the goods.
The shipment of hazardous sea freight is governed by the International Maritime Dangerous Goods (IMDG) Code and the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN).
12 steps to ship it safely
Step 1: You should fill in the Safety Data Sheet (SDS). This allows one to determine if the goods being shipping are deemed hazardous. A good may be deemed hazardous if the Secretary of Transportation has determined that the good is capable of posing an unreasonable risk to health, safety and property.
Step 2: If a good is deemed as dangerous or hazardous, then the FA recommends that a needs assessment analysis be carried out, in order to determine which employees at the company will be performing a hazmat function and to identify the level of training needed.
Step 3: Most of the time, training will include security awareness and general awareness. It will also usually involve safety and function-specific training. A hazmat employee, under the 49 CFR, is required to receive training every 3 years.
Step 4: A trained employee must look up the material being shipped in the Hazardous materials Table. This is in order to determine the quantities allowed to be shipped, the labels required and the allowable packaging.
Step 5: The quantities and packaging requirements must be determined. A UN-specification packaging may be required depending on what the packaging group assigned to the material.
Step 6: The package closure instructions must read carefully if an UN-specification packaging is required. All of the materials listed in the instructions must also be obtained. Any variation from the instructions could be classed as a violation of the Hazardous Material Regulations (HMR).
Step 7: The appropriate hazard communication (markings, labels, shipping paper/declaration etc) must be obtained once the proper packaging is received.
Step 8: Mark and label the package.
Step 9: If you are using a combination package, place the material in its inner packaging in accordance with the closure instructions. Then place the inner packaging in its authorized outer packaging and seal the package in accordance with the package closure instructions.
Step 10: Fill out the shipping paper and affix it to the outside of the package in an unobstructed area.
Step 11: The package will be ready to be shipped.
Step 12: The Shipper’s Declaration should be kept on file for 2 years.
If you would like any advice on shipping dangerous goods or to discuss a dangerous goods shipment, please feel free to get in touch.