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Poor knowledge of IMDG Code ...." I think, I know" attitude! presentation by captain Zarir Soli irani director of constellation marine services." This is how I plan to take away 2 precious hours of your lives.".....Capt.Zarir Irani
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Matthew Professional CV experienced Government LiaisonMattGardner52
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Alter Ego: If there is such a unity of interest and ownership between the corporation and its shareholders or members that the separate personalities of the corporation and the individuals no longer exist, courts may treat the corporation as the alter ego of its owners and hold them personally liable.
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2. GOALS
• HANDLING, STOWAGE, AND
SEGREGATION
• SEGREGATION REQUIREMENTS
• IMDG VS. HAZARDOUS MATERIALS
REGULATIONS
• INCIDENT REPORTING (IF
SOMETHING BAD HAPPENS, WHAT
DO YOU DO?)
3. USE OF THE INTERNATIONAL MARITIME
DANGEROUS GOODS CODE (IMDG)
• YOU MAY USE THE INTERNATIONAL
MARITIME DANGEROUS GOODS CODE
WHEN SHIPPING HAZARDOUS MATERIALS
BY VESSEL.
6. KNOWLEDGE CHECK1
171172 173 IMDG 176 ICAO
HMR CFR HAZMAT
THE ______________________CODE MAY BE USED INSTEAD OF THE 49 CFR IF THE
SHIPMENT IS BEING SHIPPED OVERSEAS ON A SHIP.
7. GENERAL OPERATING REQUIREMENTS
YOU MAY NOT TRANSPORT HAZARDOUS MATERIALS BY VESSEL UNLESS THEY ARE
PROPERLY DESCRIBED AND CERTIFIED ON THE SHIPPING PAPER.
8. CONTAINER PACKING CERTIFICATE
• THE FREIGHT CONTAINER OR TRANSPORT
UNIT IS SERVICEABLE FOR THE MATERIALS
LOADED THEREIN, CONTAINS NO
INCOMPATIBLE GOODS, AND IS PROPERLY
MARKED, LABELED OR PLACARDED
• WHEN THE FREIGHT CONTAINER OR
TRANSPORT UNIT CONTAINS PACKAGES,
THESE PACKAGES HAVE BEEN INSPECTED
PRIOR TO LOADING, ARE PROPERLY
MARKED, LABELED OR PLACARDED, ARE
NOT DAMAGED, AND ARE PROPERLY
SECURED.
To transport hazardous materials by vessel, you must obtain a signed certification on the shipping
paper or on a separate document, which states that the packing of the contain has been carried out
in accordance with the CFR or IMDG code.
9. STOWAGE & SEGREGATION
TERMS THAT REFER TO THE LOCATION AND HOW CARGO IS SECURED ARE:
• STOWAGE: WHERE A CARGO MAY BE LOCATED ON THE VESSEL AND HOW IT IS
SECURED
• SEGREGATION: A SEPARATION OF HAZARDOUS CARGO FROM OTHER HAZARDOUS
CARGOES BY DISTANCE OR BARRIERS
10. DANGEROUS CARGO MANIFEST, LIST, OR STOWAGE PLAN
THE CARRIER MUST PREPARE A
DANGEROUS CARGO MANIFEST, LIST,
OR STOWAGE PLAN FOR MATERIALS
SUBJECT TO THE REQUIREMENTS OF
THE CFR OR IMDG:
• NAME OF VESSEL AND OFFICIAL NUMBER
• NATIONALITY OF VESSEL
• SHIPPING NAME
• IDENTIFICATION NUMBER OF EACH
HAZARDOUS MATERIAL ON BOARD
• EMERGENCY RESPONSE TELEPHONE NUMBER
• NUMBER AND DESCRIPTION OF EACH TYPE
OF
• PACKAGE WEIGHT
• CLASSIFICATION OF HAZARDOUS MATERIAL
• STOWAGE LOCATION OF HAZARDOUS
MATERIAL ON BOARD THE VESSEL
12. ACCIDENTS
If an accident involving hazardous materials occurs, the master of the vessel must
request instructions for disposition of the packages from the nearest United
States Coast Guard captain of the port (COTP).
13. DAMAGED PACKAGES
A carrier may not transport by vessel any damaged package containing hazardous
materials that appears to have leaked or may leak.
15. KNOWLEDGE CHECK 2
SEGREGATION CARRIER EMERGENCY DAMAGED BRIDGE
CERTIFICATE UNAUTHORIZED STOWAGE
1. DAMAGED PACKAGES CONTAINING HAZARDOUS MATERIALS MAY BE CONTAINED IN
________________PACKAGING ONLY IN EMERGENCY SITUATIONS.
2. EACH PERSON WHO OFFERS HAZARDOUS MATERIALS FOR TRANSPORTATION MUST
PROVIDE A SIGNED CONTAINER PACKING _________STATING THAT THE PACKING OF
THE CONTAINER COMPLIES WITH THE HMR.
3. PACKAGES THAT ARE ____________OR HAVE LEAKED MAY NOT BE ACCEPTED BY THE
CARRIER FOR TRANSPORTATION BY VESSEL.
4. DAMAGED PACKAGES CONTAINING HAZARDOUS MATERIALS MAY NOT BE OFFERED TO
ANY FORWARD ______________FOR TRANSPORTATION.
5. WHERE HAZARDOUS CARGO IS LOCATED ON THE VESSEL AND HOW IT IS SECURED IS
TERMED______________________
16. STOWAGE LOCATIONS
• Vessel stowage requirements are found in
Column 10 of the Hazardous Materials
Table (HMT). Stowage locations may
include any one of the following, or a
combination of the three:
On deck
Under deck
Under deck away from heat
• Also be aware of codes which may appear
in the Special Provisions column. The “W”
codes, in particular, only apply to
transportation by water.
17. STOWAGE REQUIREMENTS
• The carrier must secure packages of
hazardous materials to prevent movement
in any direction and brace them so that
they are not likely to be pierced or
crushed by a superimposed load.
• Marine pollutants must be properly
stowed.
18. ON DECK STOWAGE OF BULK HAZARDOUS MATERIALS
• The packages must be secured in boxes,
cribs or cradles and strapped
• Packaging susceptible to weather or water
damage must be protected
• No more than 50% of the open deck area
should be used for stowage of hazardous
materials except Class 9 material
• Hazardous materials may not be stowed in
crew and passenger spaces
• No lifesaving and fire-fighting devices or
passageways may be blocked
19. SEGREGATION
Some hazardous materials require
segregation when stowed together on
board a vessel. Segregation is the
maintenance of certain distances
between incompatible hazardous
materials.
If there’s a difference, use
the strictest.
21. SEGREGATION TABLE DEFINITIONS
Detailed definitions for the terms used in the General Segregation Table are found in the CFR
(Code of Federal Regulations).
• 1__ “Away from”
• 2__ “Separated from”
• 3__ “Separated by a complete compartment or hold from”
• 4__ “Separated longitudinally by an intervening complete compartment or hold from”
• X__ The segregation, if any, is shown in the 172.101 table
• *__ See Class 1 Segregation table
22. REQUIREMENTS FOR HAZARDOUS MATERIALS ON
FERRY VESSELS
The person in charge of a transport vehicle containing hazardous materials must provide to
the vessel’s representative a copy of the shipping papers and certification stating that the
hazardous materials were prepared in accordance with the HMR.
23. REQUIREMENTS FOR BARGES
Permits from the Captain of the Port (COTP) may be required for carrying certain hazardous
materials by barge
24. KNOWLEDGE CHECK 3
Heat sources substances center deck portable explosive
shipping papers fixed magazines
A copy of the ___________________ and certification must be provided to the
vessel’s representative for any transport vehicle containing hazardous materials
that is to be carried on board a ferry vessel.
25. Reportable Incidents
Guidelines—issue a telephone report within 12 hours for some incidents, issue a written
reporting within 30 days for any unintentional release or discharge, and any incident
requiring the telephone report.
-NRC
-CDC
• Radioactives/Infectious Substances
• Marine Pollutants
• Other Incidents
26. Reportable Incidents
Marine Pollutants
You must report by phone to the NRC as soon as practical, and not later than 12 hours
after discovery of the event, if you discover a large release of a marine pollutant.
• Solid: must report release greater than 400 kg (882) pounds
• Liquid: must report release greater than 450 L (119 gallons)
27. OTHER INCIDENTS
• DEATH, OR INJURY REQUIRING HOSPITALIZATION
• CHANGE IN FLIGHT PATTERN OR THE ROUTINE OF AN
AIRCRAFT
• SHUTDOWN OF MAJOR FACILITY OR TRANSPORTATION
ARTERY
• EVACUATION OF THE PUBLIC FOR ONE HOUR OR MORE
• RELEASE OF A MARINE POLLUTANT IN THE QUANTITY
IDENTIFIED
• ANY SITUATION THAT, IN YOUR JUDGMENT, REQUIRES
NOTIFICATION, EVEN IF NONE OF THE ABOVE
CONDITIONS ARE MET (FOR EXAMPLE, A CONTINUING
DANGER TO LIVE, ALTHOUGH NO DEATH HAS YET
OCCURRED).
HAZMAT INCIDENTS RESULTING IN ANY OF THE
FOLLOWING ARE REQUIRED TO BE REPORTED AS
SOON AS POSSIBLE TO THE NATIONAL RESPONSE
CENTER:
28. KNOWLEDGE CHECK 4
WHICH ONE OF THE FOLLOWING RESULTS OF A HAZMAT
INCIDENT IS NOT REQUIRED TO BE IMMEDIATELY REPORTED TO
THE NEAREST NATIONAL RESPONSE CENTER?
A. DEATH OR INJURY REQUIRING HOSPITALIZATION
B. DAMAGE TO ANY FACILITY REQUIRING IN-SERVICE REPAIR
C. CHANGE IN FLIGHT PATTERN OR THE ROUTINE OF AN
AIRCRAFT
D. SHUTDOWN OF MAJOR FACILITY OR TRANSPORTATION
ARTERY
29. COMPLETION OF WATER MODULE TRAINING
CONGRATULATIONS!
• Summarize general handling, stowing,
and segregation requirements for
transporting hazardous materials by
vessels
• Define special requirements for transport
vehicles and barges
• Compare the International Maritime
Dangerous Goods Code (IMDG) to the
Hazardous Materials Regulations (HMR)
• Identify the incident reporting
requirements
Editor's Notes
This module covers the requirements for accepting and transporting hazardous materials by most commercial vessels, foreign or domestic, when in navigable waters of the United States. As you all know, very little of our products are shipped by vessel, so I’ve tried to pick out the things that are most relevant to us. While maritime transport of hazardous materials is generally very safe, it takes more time, and some chemicals may degrade in the voyage. It is used for international shipping, and laws in both countries apply. The country where it’s coming from and the country where it’s going to. Sea freight also requires special forms, but is the most cost-effective and environmentally friendly route to ship goods.
We don’t want anything to do with something like this happening! After completing this module on the HAZMAT requirements for water, you should be able to: summarize general operating requirements, as well as general handling, stowage, and segregation requirements for transporting hazardous materials by commercial vessels. Recognize segregation requirements for specific classes of hazardous materials and highlight any exceptions to those requirements. Compare the uses of the International Maritime Dangerous Goods Code for similarities to and differences from the uses of the hazardous materials regulations (HMR). And finally, know the incident reporting requirements in the Code of Federal Regulations.
Instead of looking to the Hazardous Materials Regulations for the rules about carrying hazardous materials as you would normally do, you may use the International Maritime Dangerous Goods Code when carrying hazardous materials by vessel. IMDG Code or International Maritime Dangerous Goods Code is accepted as an international guideline to the safe shipment of hazardous materials by water. The IMDG Code is intended to protect crew members and to prevent marine pollution. The implementation of the Code is mandatory for members of United Nations. This is similar to the way in which you can look to the International Civil Aviation Organization instead of HMR when you’re shipping HAZMAT by air, like we covered last time.
When you do go to the HMR or the IMDG for information, you can find nifty definitions for things you’d never really thought about. Like, for example, I didn’t know what the word “dunnage” meant, but I found it here. And while we’re on the subject of definitions, what exactly is a hazardous material? Hazardous materials are any materials that have the potential to adversely affect public safety.
All hazardous materials must be prepared for transportation in accordance with the HMR before they can be transported by vessel. Certain explosives and chemicals, however, are forbidden and may not be transported by vessel. You know where to find out if something is forbidden or not (Hint: the HMR).
You may not transport hazardous materials by vessel unless they are properly described and certified on the shipping paper.
At the time a package containing hazardous materials is offered for transportation by vessel, the person responsible for packing or loading it must give the vessel operator a signed container packing certificate stating that the container is allowed for the material loaded in it; it contains no incompatible goods; that it is properly marked, labeled, and placarded, and is not damaged. The signed certification may be on the shipping paper or on a separate document stating that the packing of the container has been carried out in accordance with the provisions of the CFR and/or the IMDG code.
The term stowage as used in this lesson refers to where a cargo may be located on the vessel and how it is secured. The term segregation refers to a separation of hazardous cargo from other hazardous cargoes by distance or barriers. Stowage and segregation are critical on a vessel because of the forces and stresses that affect it while it travels on water. Bumpy rides and turbulence can cause cargo to shift that can result in significant damage.
Transporting the HAZMAT material is of course the carrier’s job, but it is the shipper’s responsibility to provide the right information and packaging so that the carrier can do their job. A carrier must prepare a stowage plan for the HAZMAT. A list of the information required for the stowage plan is shown here. Each carrier must retain a copy of the dangerous cargo manifest (or stowage plan) for at least one year.
After stowage is complete, the carrier must inspect each hold or compartment containing hazardous materials, to ensure that stowage has been accomplished properly and that there are no visible signs of damage. The carrier must inspect again after periods of heavy weather, and every 24 hours. That’s good to know that they’re so cautious about their cargo.
If an accident occurs on board a vessel damaging hazardous materials packages, then damaged or unauthorized packagings may not be offered to any forwarding carrier for transportation. The master of the vessel must request instructions for disposal of the packages from the nearest United States Coast Guard Captain of the Port (COTP). The master of the vessel may decide to jettison hazardous materials only to prevent or substantially reduce a hazard to human life or reduce a substantial risk to property. Knowing what might happen to our shipments allows us to be prepared. Personally, I didn’t know that the master of the vessel could throw out hazardous materials into the sea, but they can.
A carrier may not transport by vessel any damaged package containing hazardous materials that appears to have leaked or may leak. Packages may be repaired or restored to the satisfaction of the master of the vessel. A package containing radioactive materials, may not be repaired or restored, not even with duct tape.
A carrier may not knowingly transport by vessel any hazardous material offered under a deceptive name, marking, invoice, or shipping paper. If a shipment is found to be in violation while in transit, the master of the vessel must take whatever measures are necessary to ensure the safety of the vessel, its passengers, and its crew. If the vessel is in port, the carrier may not deliver the shipment to any party, and the master must immediately request instructions for disposal of the material from the nearest Captain of the Port.
Unauthorized
Certificate
Damaged
Carrier
stowage
Column 10 of the HMRT contains specific information relating to authorized vessel stowage locations. You don’t have to remember it’s Column 10, just look around to see where something’s supposed to be stowed. The stowage location can depend on whether it’s a passenger vessel or not. The “W” codes, in particular, only apply to transportation by water. If the prescribed stowage location is shown to be impractical for a vessel, the Captain of the Port may authorize in writing an alternative stowage location or method of segregation as long as it will afford the same level of safety.
Hazardous materials must be stowed in a way that makes inspections easier during the voyage. They must be stowed so that they can be easily removed from a potentially dangerous situation, and in case of fire. If a package contains liquid hazardous materials, it must have orientation markings on it and be stowed with the markings pointing up. Marine pollutants must be properly stowed and secured to minimize the hazards to the marine environment without impairing the safety of the ship and the people on board.
Shown here are guidelines on the stowage of hazardous materials on decks of vessels. The one I think is relevant to us is the weather and water-resistant packaging requirement. Can anyone tell me, do we have to make sure that the packages are water-protected, or do the carriers?
Just like when you load chemicals onto a truck, sometimes, when you stow hazardous materials together, you must segregate them according to the General Segregation Table. You can also find segregation requirements in the Hazardous Materials Table. If you ever come across a difference in requirements, you must use the most restrictive segregation requirements.
Just as a refresher, you use the General Segregation Table by finding one class of material in the vertical column, and then finding another class by horizontal row. The intersection of the vertical column and the horizontal row contains a number or symbol that represents the method of segregation that you must use between the two classes. What the terms mean is listed at the bottom of the table.
Explosives have their own segregation table. So, literally, sometimes you have to go to another segregation table from a segregation table. The symbol “X” can sometimes be the same way, meaning you have to go to a different table, but when you go there, you might find you don’t need to segregate at all. “Away from” means that incompatible hazardous materials may be carried in the same compartment, provided they are horizontally separated by 3 meters (10 feet). “Separated from” means packages must be carried in different compartments. “Separated by a complete compartment or hold from” means packages may be separated between decks as long as one of the decks is resistant to fire and liquid, or so many meters of separation if “on deck”. Personally, it’s all very overwhelming when I think about what the master of the ship has to do to organize all the cargo. Sometimes you need a wall, so many feet of separation, sometimes not only a wall, but have to make sure they’re still far enough apart even with the wall. You have keep some things away from passengers and crew, don’t block lifeboats, and only so many containers can be on deck. I’m sure it’s all computerized and easier than it would seem, but it didn’t used to be.
In the highly unlikely situation that one of our drivers would drive to a ferry to hand off hazardous materials, that driver would have to provide to the vessel a copy of the shipping papers and certification that the hazmat were prepared in accordance with the HMR. In some situations, the truck itself can drive onto the ferry and the whole vehicle can be transported.
The same thing goes for transporting hazardous materials on a barge. It has to be a steel barge, and can’t be a dump scow, which is a barge for disposing of garbage or dredged material. They have hoppers in the bottom that cargo can be dumped through. I’d never heard of a ‘dump scow’ before. It sounds like an excellent insult. You may need a permit from the Captain of the Port to carry certain hazardous materials on a barge.
Answer: Shipping papers
Most of the other many slides in the module had to do with transporting explosives, and some gases and radioactives. So I’m not going to bore you any more to tears than you already are because we don’t carry those things, and secondly, they mostly had to do with how to stow them, and we’re not going to be the ones putting anything on a boat.
Despite all safety efforts, incidents do occur. When hazardous materials are involved in a transportation incident, a report may be required. For certain incidents, you must notify the National Response Center (NRC) as soon as practical, but not later than 12 hours after the incident occurs. For any such incident, you must also follow up with a written Hazardous Materials Incident Report within 30 days of discovering any unintentional release of hazardous materials or unintentional discharge of hazardous waste.
You must report a large release of a marine pollutant, by phone, as soon as possible, to the NRC. This requirement applies to a release of over 400 kilograms of a solid, and to the release of over 450 liters of a liquid.
Hazmat incidents that result in any of the following require notification as soon as possible to the National Response Center or the Center for Disease Control:
• Death or injury requiring hospitalization,
• Change in the operational flight pattern or routine of an aircraft,
• The shutdown of a major facility or transportation artery for more than one hour, an evacuation of the general public that lasts more than one hour,
• Release of a marine pollutant in a reportable quantity
• A situation that, in your judgment, requires notification, even if none of the above conditions are met – for example, a continuing danger to life, although no death has yet occurred.
B
Congratulations! We don’t have to do this for 3 more years! At this point, you should have a general idea of stowage and segregation requirements, know what the IMDG is about and when to use it, and know when to report an incident to the National Response Center. Most of the world’s oxygen comes from the ocean, so much respect to the people on the thousands of ships on the ocean trying to keep accidents from happening.