Recently one of our clients had a shipment of their product rejected at a port in Europe. They had been sending it there for years without incident, but this time was different. Inspectors chose to verify their paperwork and they were missing crucial IMDG dangerous goods paperwork. All methods of hazardous materials transportation have specific training requirements, but the one which often catches people by surprise is IMDG.
If you ship hazardous materials by vessel or over water, you are required to follow the rules of the International Maritime Dangerous Goods (IMDG) code. This includes companies who are:
- Loading shipping containers onsite;
- Using third-party companies to load shipping containers for them onsite; and,
- Sending hazardous materials to freight forwarders or third-parties to be loaded somewhere else.
You May Qualify Without Knowing It
Shipping containers are used for overseas transport, but also keep in mind they are used to transport products to U.S. states such as Hawaii and Alaska as well as U.S. territories. For example, a different client of ours was responsible for gathering together all the products needed for opening a new Wal-Mart store, and some of those were hazardous materials. When there were new Wal-Marts to open in Alaska and Hawaii, those products needed to be loaded into shipping containers. As a result, that company became subject to the rules of IMDG.
Keep in mind that even small quantities can trigger requirements. For example, we have clients who send vehicles and farm implements via vessel. Along with the vehicles are boxes of oils and lubricants for operation once they are unpacked. This triggers hazardous materials regulations. Even residual fluids left over in the engines that got there when the factory tested it to make sure it worked triggers hazardous materials regulations.
Just like in DOT regulations for ground shipments and IATA regulations for air shipments, goods loaded into the containers must be packaged in certified packages that have design qualification reports for them. Special IMDG dangerous goods paperwork called a Dangerous Goods Transport Document is also needed to accompany the shipment and all packages and the container need to be labeled and placarded accordingly.
Even if you use a third-party to handle this for you, it’s still your company’s responsibility to make sure they are complying with the rules as you are the shipper and it’s your company who will be dealing with the regulators and with potentially unhappy customers the further the goods are delayed.
If IMDG applies to your operations, the following personnel need to have training upon employment or assignment to hazardous materials duties:
- Classifies and/or identifies the proper shipping names of dangerous goods (hazardous materials);
- Packs dangerous goods;
- Marks, labels or placards dangerous goods;
- Load/unload dangerous goods;
- Prepare transportation documents;
- Offers or accepts dangerous goods for transport;
- Handles, loads or unloads dangerous goods into or from ships;
- Prepares dangerous goods loading/stowage plans;
- Carries dangerous goods in transport;
- Enforces, surveys or inspects dangerous goods for compliance; and is,
- Otherwise involved as determined by a competent authority.
As with other hazardous materials training, students are required to have general awareness, safety, and function-specific training. Refreshers are required every 3 years.
Does this requirement apply to your company? iSi has regularly scheduled IMDG courses and can provide them onsite on your own schedule, at your own convenience. Check here for our course schedule or contact us here for more information and pricing for an onsite class at your facility!