dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
Inner quantities on the IMO declaration…do you need to add it?

For many of us who have been preparing international ocean shipments for sometime now we know that the requirements of what needs to be included on the IMO declaration hasn’t changed all that much.   

One of the biggest frustrations is when carriers or agents of carriers reject the IMO declaration because the inner quantity information is not provided on the actual declaration. I know carriers need to enter information in their internal system for acceptance of shipments (DG or not), and perhaps the system requires the breakdown of inner packaging but why is the IMO declaration being rejected? This information can be provided on an alternate document (i.e., packing list).

As per section of the IMDG Code “The number, type and capacity of each inner packaging within the outer packaging of a combination packaging is not required to be indicated.” The Code never asked for it; however, a few editions back, “they” clarified it by adding the above quoted note. And I for one am grateful for it because now when someone comes back stating the declaration is incorrect, I just scan, highlight this section from the Code, and email it to them. I am not trying to be a smart-ass, but for me it’s about educating others. They can read that specific section to avoid future hindrance with others. This goes for me as well. I appreciate it Continue Reading…

20 Years Ago

Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?

Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:

  1. A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
  2. Employees may not perform functions without appropriate training
  3. Training may be provided by the hazmat employer or other public or private sources
  4. A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered

Hazmat employee training must include the following:

  1. General awareness/familiarization training
  2. Function-specific training
  3. Safety training
  4. Security awareness training
  5. In-depth security training

Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.

For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.

Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.

Call 888.442.9628 for more information. Have a problem? We have a solution.

IMDG Addendum

In May, 2012 the Dangerous Goods by Vessel (IMDG, 2010 Edition) was amended prior to the routine two year amendments. United States Department of Transportation (DOT) can add to 49 CFR in few months of this year. These updates fix some typing errors but a few regulations are being changed and these will likely become effective as soon as the DOT rulemaking process is completed. Review the items below to see if your activities are going to change:


Chapter 4.1 List of packing instructions (wording corrections)
Chapter 5.4 Documentation (dangerous goods documentation changed to container/vehicle packing certificate).

Chapter 7.9 Exemptions, in note 1 delete “(e.g. exemptions for limited quantities in 3.4.7)”
CHAPTER 3.1, Segregation Groups
Include in segregation groups 7 & 9, “3483” Motor fuel anti-knock mixture, flammable



Chapter 3.2

For UN 2590, replace “0” with “5 kg” in column (7a)
Duplicate listing; delete first PSN, UN 2687, DESENSITIZED EXPLOSIVE, SOLID, N.O.S.
For UN 2949, insert “T7” in column “13”
For UN3132, packing groups II and III, insert “PP40” in column (9)
For UN 3319, insert “II” in column 5

Chapter 3.3

133 Replace “7.2.8” with “”
181 Replace “7.2.8” with “”


Delete: Aviation Gasoline, see (UN 1863)
4-CHLORO-o-TOLUIDINE HYDROCHLORIDE SOLUTION (UN3450), replace “3450” with “3410”
Fishmeal, UNSTABILIZED (UN 1374), replace “9” with “4.2”
ISOPROPYL ISOCYANATE (UN 2483) replaces “3” with “6.1”
Delete: Trinitrotoluol, wetted, see” (UN 1356). Then insert the following:
TRINITROTUOL, WETTED, class 4.1, Continue Reading…

IMDG Code Errata

An errata and corrigenda has been published by the IMO for the 2008 Edition of the International Maritime Dangerous Goods Code. This errata makes a number of changes to the Code:

  • reference changes
  • minor word changes, i.e. "this data" changes to "these data"
  • deletion of single words
  • punctuation corrections
  • the marine pollutant mark has changed (the fins on the fish are gone)
  • several paragraph rewrites
  • seven column 16 corrections

A copy of this errata and corrigenda can be downloaded from the IMO website at. Wishing everyone a happy and prosperous New Year.