IMDG 2012. Change to IMDG Code Amendment 35

What’s changed?

From January 1, 2012 a rule change will become effective that means any vehicles with an internal combustion engine will fall within the scope of the IMDG Code and must be notified to carriers as dangerous goods, UN 3166,Class 9.

Observation from Dangerous Goods List entry for UN 3166:

”Types of articles transported under this entry include internal combustion engines, compression/ignition engines, fuel cell powered engines, motor vehicles, hybrid vehicles, motorcycles and boats.”

How will that affect me?

Effective from January 1, 2012 every vehicle you ship will need to be notified as dangerous goods and you will be required to provide a dangerous goods declaration and document.

Do I need special training to complete Dangerous Goods Notes?

All parties handling dangerous goods should have function specific training, with records maintained accordingly for a period of time established by the competent authority, i.e. Maritime and Coastguard Agency.Please refer to IMDG Code 35-10 Chpt 1.3 Training.

What if I disconnect the engine?

Special Provision 961 describes strict technical measures that can be taken to neutralise the hazard of fuel and batteries and allow the vehicles to be considered non-hazardous.

If you comply fully with these requirements (which include emptying the fuel tank and disconnecting the battery) and provide a written declaration of compliance to support this action, the vehicle may be classed as nonhazardous.

Suggested Declaration:

”We confirm that the vehicle offered for shipment complies with the requirements of IMDG code Special provision 961 and that the fuel tank(s) of the vehicle is empty and installed batteries are protected from short circuit.”

How can I find out details of the “Special Provisions”?

To provide further guidance we have detailed the Special Provisions 312,356, 961 and 962 from the IMDG Code Amendment 35 and the Dangerous Goods List on the following pages.

Who do I ask for more information?

Should you require further clarification, please contact our Dangerous Goods Safety Advisor Ronald Mellor, based in the Export Special Cargo team.

Thank you for your co-operation.

Observation from Dangerous Goods List Entry – UN 3166

“Types of articles transported under this entry include internal combustion engines, compression/ignition engines, fuel cell powered engines, motor vehicles, hybrid vehicles, motorcycles and boats.”

Special Provision 312:

“Vehicles or machinery powered by a fuel cell engine shall be consigned under the entries:

• UN 3166, VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED, or
• UN 3166, VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED, or
• UN 3166, ENGINE, FUEL CELL, FLAMMABLE GAS POWERED, or
• UN 3166, ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED, as appropriate.

These entries include hybrid engine vehicles powered by both a fuel cell and an internal combustion engine and wet batteries, sodium batteries or lithium batteries, transported with the batteries installed.

Other vehicles which contain an internal combustion engine shall be consigned under the entries:

• UN 3166, VEHICLE, FLAMMABLE GAS POWERED, or
• UN 3166, VEHICLE, FLAMMABLE LIQUID POWERED, as appropriate.

These entries include hybrid electric vehicle powered by both an internalcombustion engine and wet batteries, sodium batteries or lithium batteries,transported with the batteries installed.”

Special Provision 356:

“Metal hydride storage systems installed in conveyances or in completed conveyance components or intended to be installed in conveyances shall be approved by the competent authority before acceptance for transport. The transport document shall include an indication that the package was approved by the competent authority or a copy of the competent authority approval shall accompany each consignment.”

Special Provision 962:

Vehicles or equipment powered by internal combustion engines, fuel cells or batteries not meeting the conditions of Special Provision 961 shall be assigned to Class 9 and shall meet the following requirements:

1. Vehicles and equipment shall not show signs of leakage from batteries,fuel cells, compressed gas cylinders or accumulators, or fuel tank(s) when applicable;
2. For flammable liquid powered engines and equipment, the fuel tank(s) containing the flammable liquid shall not be more than one fourth full and in any case the flammable liquid shall not exceed 250 litres;
3. For flammable gas powered vehicles and equipment, the fuel shut-off valve of the fuel tank(s) shall be securely closed;
4. Installed batteries shall be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries shall meet the requirements of the United Nations Manual of Tests & Criteria, part III, subsection 38.3, unless otherwise approved by the competent authority; and
5. Dangerous goods required for the operation of the vehicle or equipment such as fire extinguishers, compressed gas accumulators, airbag inflators, etc., shall be securely mounted in the vehicle or equipment. The marking, labeling and placarding requirements provisions of this Code shall not apply.

Special Provision 961:

Vehicles and equipment are not subject to the provisions of this Code (IMDG Code Amndt. 35) if they are stowed on a roll-on/roll-off ship or in another cargo space designated by the Administration (flag state) as specifically designed and approved for the carriage of vehicles and equipment and there are no signs of leakage from the battery, engine, fuel cell, compressed gas cylinder or accumulator, or fuel tank when applicable.

In addition, vehicles and equipment are not subject to the provisions of this Code if any of the following conditions are met:

1. The fuel tank(s) of the vehicle or equipment powered by a flammable liquid fuel is empty and installed batteries are protected from short circuit;
2. The fuel tank(s) of the vehicle or equipment powered by a flammable gas is emptied of liquefied or compressed gas and the, the positive pressure in the tank does not exceed 2 bar, the fuel shut-off or isolation valve is closed and secured, and installed batteries are protected from short circuit; or
3. The vehicle or equipment is solely powered by a wet or dry storage battery or a sodium battery, and the battery is protected from short circuit.