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Dangerous goods

Dangerous goods and the IMDG Code

An enquiry that reads “5,000 tonnes IMO cargo, Antwerp to Jebel Ali” does not tell you what the cargo is. Dangerous goods are identified by four pieces of information. Until you have all four, nobody can say which ships may carry the parcel, where on board it may go, what it may sit next to, or whether the fixture is possible at all.

The four identifiers, and why all four

Two substances can share a class and behave in completely different ways, so the class alone tells you very little. Two substances with the same UN number, on the other hand, are treated the same at every step of transport, which is the purpose of the number.

The nine classes

ClassWhat it covers
1Explosives, split into divisions, each with its own compatibility groups
2Gases: flammable, non-flammable and non-toxic, and toxic
3Flammable liquids
4Flammable solids, substances that can catch fire by themselves, and substances that give off flammable gas when they touch water
5Oxidising substances and organic peroxides
6Toxic and infectious substances
7Radioactive material
8Corrosive substances
9Other dangerous substances and articles. Lithium batteries are here, and so are many of the cargoes that cause problems today

The Code, and the fact that it moves

The International Maritime Dangerous Goods (IMDG) Code is the IMO's rulebook for dangerous goods carried in packages. SOLAS chapter VII makes it law, and its environmental part links to MARPOL Annex III. That link is why ships use a marine pollutant mark in addition to the hazard labels.

The Code is amended every two years, and each amendment is mandatory. A chartering desk feels the effect directly. A safety data sheet or a declaration that cites an out-of-date amendment does not just contain a small error; it will be refused. Amendment 42-24, in the 2024 edition, became mandatory on 1 January 2026, and every shipment after that date must be declared against it.

Segregation is the part that decides the stowage plan

The central working idea of the Code is segregation: certain goods must be kept apart from certain other goods, and the Code says by how much. The levels are "away from", "separated from", "separated by a complete compartment or hold from", and "separated lengthways by a complete compartment or hold in between". These are defined distances, not loose descriptions, and their effects add up quickly. One parcel of class 5.1 booked late can make half the stowage plan illegal.

The same logic reaches the terminal, because much of the Code deals with packing and marking the cargo unit rather than with the ship. The IMO, ILO and UNECE Code of Practice for Packing of Cargo Transport Units (the CTU Code) covers what happens inside the container. It exists because most of the failures a ship sees were created ashore, by people who never saw the ship.

Bulk dangerous goods are not IMDG

Many people get this wrong. A solid cargo carried loose in the hold with a chemical hazard does not fall under the IMDG Code. It is a Group B cargo under the IMSBC Code, the code for solid bulk cargoes, and follows that cargo's own schedule. Coal that heats itself and uses up oxygen is a Group B cargo, not a class 4.2 package. Liquid chemicals in bulk fall under the IBC Code and MARPOL Annex II, and oil in bulk falls under MARPOL Annex I.

So a hazardous cargo can fall under three different sets of rules, and what decides between them is the packaging, not the substance. The same chemical is IMDG in drums, IBC Code in a chemical tanker and IMSBC in a hold.

Misdeclaration is the real hazard

The accidents that make the news are almost never caused by a correctly declared cargo behaving in an unexpected way. They are caused by cargo declared as something it is not, to avoid a surcharge, a refused booking or the cost of proper packaging, and then stowed on that false basis. A shipper who books calcium hypochlorite as a general chemical has started a fire on a ship whose stowage plan assumed there was nothing to burn.

That is why the paperwork is the most important part, not a formality. The dangerous goods declaration, and for a container the container packing certificate, are how the carrier learns the truth. If they are wrong, every later decision rests on the wrong facts. Afterwards, the charterparty's dangerous goods clause and the shipper's indemnity are all that is left to argue about.

What this means for a fixture

In practice, on a dry cargo or multipurpose desk:

The Code is long, and the desk does not need to know all of it. It needs to know that the four identifiers exist, that everything else starts from them, and that an enquiry without them is not yet an enquiry.

References

Neptune Atlas

A cargo enquiry in Neptune Atlas keeps the description it arrived with instead of being reduced to a commodity code, so a hazardous parcel is not reduced to “chemicals” when it moves from the e-mail into the record. Every paid plan starts with 7 free days. A card is needed to start them, and cancelling before they end costs nothing.

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