Dangerous Goods: Ways to Ship it Safely

On August 4, a series of explosions at the port of Beirut, Lebanon, left 200 people dead, injured 5,000 and destroyed large parts of the city. The blasts were traced to 2,750 tons of ammonium nitrate stored unsafely in a warehouse. The UN Recommendations on the Transport of Dangerous Goods classifies ammonium nitrate as an oxidising agent and hence, hazardous. In India, it is listed as an explosive under the Explosives Act, 1884.

This disaster, and others like it, are a grim reminder of the importance of safety in the transport and storage of dangerous goods. This is why the shipping of dangerous cargo is highly specialised and regulation-heavy. In this blog, we dive deep into hazardous cargo and all that goes into transporting it. Read on to find out:

• What constitutes dangerous goods?
• How they are classified
• Rules and regulations of shipping dangerous goods
• Regulators/authorities for each transport mode
• Packaging, labelling, segregation, training requirements
• Documentation requirements
• Responsibilities                         

What are Dangerous Goods?

The Business Dictionary defines dangerous goods as “articles or materials capable of posing significant risk to people, health, property, or environment when transported in quantity”. It also notes that dangerous goods is the “international standard term for goods covered under the UN Recommendations on the Transport of Dangerous Goods”. Dangerous goods are also called hazardous material, hazmat and hazardous cargo.

Dangerous goods can exist in solid, liquid and gaseous form. They can be colourless or coloured, hot or cold, odourless or pungent. They can be corrosive chemicals, explosives, batteries or even daily-use items such as hair spray, perfume, aftershave, liquor and cigarette lighters.

Classes of Dangerous Goods

The UN Committee of Experts on the Transport of Dangerous Goods classifies dangerous goods on the basis of the hazard they pose. Under this system, each substance is assigned a class. There are nine classes in total. Some are split into divisions.

Sometimes, a substance meets the criteria for more than one hazard class. In this case, the class that poses the highest level of hazard is the primary class while the class posing a lower level of hazard is the secondary class. A substance can have more than one secondary class. 

UN Number, Proper Shipping Name and Packing Group‍

Apart from class, dangerous goods are assigned a UN number, a proper shipping name (PSN) and a packing group that serve as identifiers.

• UN Number: This is a four-digit code preceded by the letters UN. A UN number can be assigned to a single substance (acetone, UN 1090) or a group of substances (adhesives, UN 1133; alcohols, UN 1987).
• PSN: This is the name that most accurately describes the goods and is written in upper case. For example, the PSN for lighters or lighter refills is LIGHTERS or LIGHTER REFILLS.
• Packing group: The UN has three packing groups for dangerous goods – I (high danger), II (medium danger) and III (low danger). This identifier helps determine the degree of protective packaging required. Packing groups are indicated by the letters X, Y and Z, where X is for packing groups I, II and III, Y is for packing groups II and III, and Z is only for packing group III. For example, Class 1 dangerous goods (explosives) are assigned packing group II.

Rules and regulations governing the dangerous goods:‍

When it comes to dangerous goods, there are strict rules for each stage of the shipping process – handling, packaging, labelling, marking, stowage, segregation, transport and emergency response. These exist in the form of international agreements, which are closely aligned with the UN recommendations and, while not mandatory, are universally accepted. Additionally, there are national regulations. The rules governing the movement of dangerous goods differ across transport modes.

(A) On the basis of transport modes:

1. Sea – IMDG Code and others 

The International Maritime Dangerous Goods (IMDG) Code is, by its own definition, “the standard guide to all aspects of handling dangerous goods and marine pollutants in sea transport”. Its key objectives are to a) protect human life, b) prevent marine pollution, and c) facilitate free movement of dangerous goods. Developed by the International Maritime Organisation (IMO), it applies to all cargo-carrying ships and is amended every two years. It reportedly covers 3,500 dangerous goods transported in packaged form.

However, there are many more dangerous goods shipped in bulk in solid, liquid and gaseous form. The International Maritime Solid Bulk Cargoes (IMSBC) Code has provisions on the carriage of solid bulk cargo, with the exception of grain. The transport of grain comes under the International Code for the Safe Carriage of Grain in Bulk. Similarly, the International Code of the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) governs bulk carriage of liquified gases. In shipping by sea, oil spills are a real possibility. To minimise the accidental discharge of oil into the sea, MARPOL Annex 1 regulates the construction and operation of oil tankers.

2. Air – DGR and ICAO Technical Instructions 

The International Air Transport Association (IATA) calls the Dangerous Goods Regulations (DGR) “the global reference for shipping dangerous goods by air and the only standard recognised by airlines”. It details shipper/operator responsibilities, transport and storage quantities, and forbidden goods. It also has provision on training, security and incident reporting.

A second set of regulations, the International Civil Aviation Organisation’s (ICAO) Technical Instructions, seeks to ensure airlines carry dangerous goods without the cargo posing a danger to the aircraft or its occupants.

3. Road – Motor Vehicles Rules and Hazardous Substances Rules      

Unlike sea and air transport, which are governed by international rules, many countries, including India, have their own rules for road transport of dangerous goods. In India, these are the Central Motor Vehicles Rules and Hazardous Substances (Classification, Packaging and Labelling) Rules.   

Central Motor Vehicles Rules: Enforced by the Ministry of Road Transport and Highways, these rules cover all aspects of transport by motor vehicles. But some relate strictly to dangerous goods:

• Vehicles carrying dangerous goods must be equipped with a tachograph (which records driving activity such as speed, distance) and spark arrester (a fire safety device) 
• Vehicle must carry legible, conspicuous “emergency information panels” containing the class, UN number and PSN of the cargo
• Vehicle owner must ensure cargo information provided by the shipper is accurate, and must relate this information in writing to the driver
• Driver must keep the written information in the driver’s cabin at all times
• Driver must keep cargo safe by following rules on prevention of fires and explosions
• Driver must take route pre-determined by vehicle owner and shipper 
• Driver must be trained to handle the dangers of moving hazardous cargo

Hazardous Substances Rules: Framed by the Ministry of Environment and Forests, these rules cover classification, packaging, marking, testing, certification, transport and documentation. However, they don’t cover certain dangerous goods, including imported goods, radioactive material, pharmaceutical/cosmetic end products meant for consumer use. Imported goods are exempt as they would most likely conform to the IMDG Code and DGR. Radioactive material is regulated by the Atomic Energy Regulatory Board safety code.

National regulations aside, there is the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR), followed by a bloc of predominantly European countries.

4. Rail – IRCA Red Tariff and Concor Rules  

In India, the booking and delivery of dangerous goods by rail comes under the Indian Railways Conference Association (IRCA) Red Tariff. Some of its provisions include the pasting of caution labels on wagon doors and the use of special lead seals for wagons carrying explosives, gases, inflammable and oxidising substances.

Additionally, the Container Corporation of India (Concor), a public sector unit under the Ministry of Railways, lays down rules regarding the booking of dangerous goods in containers.

Similar to the ADR, the Regulations concerning the International Carriage of Dangerous Goods by Rail (RID) is an international agreement between 45 contracting states from Europe, Asia and North Africa. India is not party to it.

5. Barge – ADN and others

In India, the transport of dangerous goods by barge is regulated by the Inland Waterway Authority of India via regulations such as the National Waterways, Safety of Navigation and Shipping Regulations. For explosives, these regulations enforce procedures laid down in the Explosives Act.         

Internationally, the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN) exists to ensure high levels of security in the carriage of hazardous cargo on inland waterways, promote international trade in dangerous goods and prevent pollution during the movement of such goods. Eighteen countries are parties to the ADN.  

(B) On the basis of different stages of Shipping process

‍1. Packaging

Since dangerous goods are a hazard to human life and property, packaging is of utmost importance. Here are some tips on securing your shipment: 

• Use correct packaging. Packing material for dangerous goods are tested for sustainability and compliance with rules and regulations
• Cargo must be tightly packed, cushioned and secured to prevent damage and leaks
• Any cargo affected by water, moisture and heat must be stuffed in air, wind and watertight containers 
• When combined with regular cargo during shipping, hazardous cargo must be placed within easy access – next to the container doors is best – for fast removal in an emergency

2. Labelling

Labels, markings and placards are a legal requirement for dangerous goods. They are the first indicators of the cargo’s hazardous nature and hold valuable information on how it should be handled. They should be legible, accurately placed and not obscured by old labels and markings. 

• Label: It immediately identifies the cargo and communicates its hazards. A label is attached on the packaging or overpack (“an enclosure used by a single consignor to contain one or more packages and to form one unit for the convenience of handling and stowage during transport”, according to the UN Model Regulations). It must be placed close to the UN number and PSN, and not on a corner where it might fold.  
• Placard: Another standard hazmat identifier, it looks a lot like a label but is larger and more durable. It is placed on containers, cylinders, trucks and other transport vehicles.
• Marking: An additional identifier placed on outer packaging, it is a combination of UN number, PSN, weight, specifications, precautions and emergency response guidelines. It ensures cargo is safely handled. Unlike labels and placards, markings do not have a specific style, colour and size. Some cargo (liquid dangerous goods, radioactive material, poisonous goods) require specialised markings.

3. Documentation

Just as important as packaging and labelling is documentation. Incorrect information can lead to the carrier making wrong handling, segregation and stowage decisions, often with disastrous consequences. Documents for dangerous goods differ across transport modes but most have some basic information in common:

• Hazard class, UN number and PSN
• Name and address of exporter and importer
• Weight and quantity of goods
• Number and type of packaging (cartons, drums, containers)

Additional information that might be required includes identification of:

• Molten/elevated temperature substances
• Temperature-controlled substances
• Radioactive material
• Infectious substances
• Wastes

Some important and common documents used in the shipping of dangerous goods include:            

• Material Safety Data Sheet: Basic information aside, it contains the physical and chemical properties of the goods (melting/boiling points), reactivity, toxicity, effect on human health, first aid and firefighting guidelines, requirements for protective equipment. It is provided by the manufacturer/supplier of the goods to the shipper, who submits it to the carrier.  
• Dangerous Goods (DG) Request: When the shipper approaches the carrier with a  dangerous goods shipment, they submit a DG request or dangerous cargo request.           
• Dangerous Goods (DG) Declaration: Also prepared by the shipper, it is similar to a DG request but more detailed. Carriers accept a dangerous goods shipment on the basis of the DG request and DG declaration, both of which must have matching information. A DG declaration is called a shipper’s declaration in air transport. In multi-modal shipping, a multimodal declaration form can be used to expedite the movement of goods between transport modes.             
• Dangerous Goods Manifest: It is prepared by the ship’s master with the objective of having all relevant cargo-related information in a single document. It is kept on the vessel’s bridge, with a copy in the cargo control room, for easy access. A DG manifest is also a stowage plan because it pinpoints the location of the cargo on the vessel to ensure swift emergency response.         
• Transport Emergency (TREM) Card: A document carried by the driver of a vehicle ferrying hazardous cargo, it contains relevant cargo information and instructions to the driver and emergency responders.
• Container Packing Certificate: When shipping dangerous goods by sea in containers, the loading company must provide a signed and dated certificate to the carrier confirming compliance with the IMDG Code and other relevant rules.

4. Segregation

Moving hazardous cargo also requires knowledge of which dangerous goods can be stored and transported together and which cannot. The IMDG Code defines the process of separating two or more substances that are considered mutually incompatible as segregation. Some common segregation don’ts include:

• Don’t store different types of explosives together
• Don’t store substances that are a fire risk with oxidising agents
• Don’t store a strong concentrated acid with a strong alkali

But by following segregation rules, some classes of dangerous goods can be loaded and transported with another class of dangerous goods. For example, an oxidising agent can be loaded with other oxidisers as well as with non-flammable gases and toxic gases. But it cannot be paired with flammables (solids, liquids and gases) and corrosives.

Importance of training when dealing in dangerous goods

From cargo handlers, packers and equipment operators to transporters and workers in charge of documentation, hazardous cargo poses a risk to innumerable lives. Awareness and training are key to their safety.

• All these people must be properly trained, and not only in their specific functions
• They must be aware of regulations relating to cargo, port, destination country, documentation and reporting
• Training provisions are included in the IATA DGR, IMDG Code, ADR, RID and ADN. Training can be done in-house or via online courses and seminars 
• There are five types of training – general awareness, function-specific, safety, security, and driver training.

Responsibilities of different shipping parties

The safe carriage of dangerous goods requires the full attention of each and every worker in the logistics chain. The biggest responsibilities, however, lie with the shipper and the carrier.‍

Shipper responsibilities

• Assigns correct class, PSN, hazard data to cargo
• Properly packs cargo, secures it in pallets (if needed) and stuffs it in containers
• Ensures that others (packers, container stuffers) comply with rules and regulations 
• Prepares and submits paperwork that is accurate and complete
• Informs carrier of precautionary measures for stowage, especially for cargo that reacts to other cargo if kept together‍

Carrier responsibilities

• Checks that goods are permitted to be carried under the rules 
• Ensures documents, certificates submitted by shipper are in order
• Physically checks labels, placards, markings for accuracy
• Checks packaging for leaks and other damages
• Prepares DG manifest and ensures cargo is stowed as far from the accommodation area as possible
• Ensures all crew members have been instructed on emergency procedures     
• Notifies authorities at the port of offloading
• Reports cargo to appropriate reporting agency, if required

Dangerous goods safety advisor

In Europe, there is a practice among companies involved in the transport of hazardous cargo by road, rail and inland waterways to hire a dangerous goods safety advisor (DGSA). Such companies can be involved in any aspect of the business, such as consignment, carriage, packing, loading and filling. A DGSA monitors compliance with legal requirements, provides health, safety and environmental advice, and prepares reports. The company may appoint one of its own employees (trained) as a DGSA or hire one externally. Under certain rules such as the ADR, the appointment of a DGSA is mandatory in most cases.

Stay safe with Cogoport

For shippers and carriers, transporting dangerous cargo is a huge responsibility. The lives of many are literally in your hands. Working with a logistics company with experience and expertise in hazardous cargo, such as Cogoport, makes the experience a lot easier. Cogoport offers:

• FCL and LCL bookings for hazardous cargo
• FCL dry container bookings for dry dangerous goods
• Trustworthy freight forwarders experienced in handling hazardous cargo