Are You Required to Have IMDG Training?

In a recent article, we covered which agencies regulate hazardous materials shipments.  All methods of hazardous materials transportation have specific training requirements, but the one which often catches employers by surprise is IMDG.

If you ship hazardous materials over water, you are required to follow the rules of the International Maritime Dangerous Goods (IMDG) code.  This includes companies who:

• Load shipping containers onsite;
• Hire third parties to load shipping containers onsite; and,
• Send hazardous materials to freight forwarders or third parties to be loaded somewhere else.

Transportation Within the U.S. is Included

Shipping containers are used for overseas transport, but also keep in mind they are used to transport products to the U.S. states Hawaii and Alaska as well as U.S. territories.  For example, a client of ours was responsible for gathering together all the products needed for opening a new Wal-Mart store.  When a new Wal-Mart opened in Alaska and Hawaii, those products needed to be loaded into shipping containers and sent to the new store.  Even though the shipment was within the U.S.,  IMDG regulations were triggered.

Likewise, companies shipping hazardous materials that will be put onto a barge to be sent along the Mississippi River, or any other river where there’s barge traffic, will be subject to IMDG regulations.

Overlooked Examples

Keep in mind that small quantities and specialty parts and accessories can trigger requirements.  For example, we have clients who send vehicles and farm implements via vessel.  These companies often send along boxes of oils and lubricants for operation once the vehicle is unpacked.  This triggers hazardous materials regulations.  Residual fluids left over from testing operations that ensure the vehicle is operating correctly before loading will also trigger hazardous materials regulations.

Who Needs to Be Trained in IMDG?

If IMDG applies to your operations, the following personnel need to have training upon employment or assignment to hazardous materials duties:

Anyone who…

• 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.

 What are the Training Requirements?

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!