Baixe Dangerous Goods Supplement e outras Notas de estudo em PDF para Biologia Marinha, somente na Docsity! 1 PowerPoint training course. This enables training officers and managers who are not experts in the IMDG Code to teach staff their key duties under the Code, and how the guidebooks work. This is to raise awareness of the guidebooks in the workplace and overcome the perception of employees that the IMDG Code is too complex for them to understand. Also in the package is a DVD – Any Fool Can Stuff a Container. This DVD focuses on: ● Choosing a container ● Checking the container ● Making a packing plan ● Packaging cargo ● Packing containers ● Container security ● Receiving containers. Before explaining the guidebooks in detail, it may be of interest to describe the causes of dangerous goods incidents and non-compliance with the IMDG Code, and explain why the Club is taking direct action to improve IMDG Code understanding and compliance. What is the IMDG Code? The IMDG Code is a comprehensive set of globally accepted rules that enables packaged (ie non-bulk) dangerous goods and marine pollutants to be carried safely by sea. Around 10 per cent of all container cargoes contain dangerous goods, so virtually all container ship services fall within the scope of the rules of the Code. DANGEROUS GOODS A LOSS PREVENTION NEWS SUPPLEMENT Introduction The Club, with the support of several Members, has launched Book it right and pack it tight – a set of four guidebooks on the workings of the International Maritime Dangerous Goods (IMDG) Code. They are designed to provide busy operational people, who are not experts in the IMDG Code, with a quick reference and practical everyday guidance to the IMDG Code rules. Uniquely, each of the four guidebooks is dedicated to the requirements of one of the principal parties involved in consigning packaged dangerous goods: ● The shipper ● The shipping line booking agency ● The cargo consolidating companies (managers and supervisors) ● The fork lift operators and cargo handlers – those that actually physically pack the containers. Each of the parties above has key duties under the IMDG Code, and failure to carry out those duties may lead to undeclared dangerous goods being loaded in a ship, an unsafe container load, or unsafe stowage, all of which lead to an unnecessary increase in the risk of carrying dangerous goods by sea. IMDG Code training package The guidebooks come in a boxed set of four. They are part of a complete IMDG Code training package. Each book is supported by its own editable 2 Why is the IMDG Code so complex? The Code has evolved from a set of brief facts and instructions for mariners through more than six decades of committee discussions by experts, to a two-volume document with a supplement, a total of over 800 pages. The rules are now set about with exemptions and exceptions. Industries have successfully lobbied for special rules for particular products, such as paints, alcoholic beverages and aerosols, and rule makers must make allowances to take advantage of benefits from new technologies in products and packaging, as well as more accurate technical information about the behaviour of hazardous substances. As in all things, the rules of the Code must be flexible, or the system becomes commercially restrictive and discredited. So, the Code must draw a balance between being easily understandable for non-technical operational people, and at the same time comprehensive and technical enough to take into account all manner of special considerations. The Code is wide-ranging and there will always be sections that are not applicable to a particular party. It is now so lengthy that some operational personnel are put off from trying to understand it. In fact, the Code is a well-designed document, and ordinary operational people just need guidance to understand its structure and their key duties. That is the purpose of the Book it right and Pack it tight guidebooks. The scope of the Code Many are surprised to learn that the bulk of the Code applies to activities carried out ashore by the shipper, consolidator and packer concerning the preparation and documentation of the load, not to shipboard activities. The Code is complex because it provides rules that apply to activities taking place right at the start of the transport chain and then throughout the carriage by sea. The Code requires the shipper to provide a description of the product and classification of any hazards. It sets limits on the type and size of packaging, specifies warning marks and labels, establishes rules for the types of hazards that can be co-loaded into one container, and devises a documentation system that requires shippers and packers to certify in writing that they have followed the rules of the Code. Only when all of these things have been done does the Code turn its attention to stowage and segregation aboard ship. As examples of this, shipboard stowage does not appear until the last section of the main document, and the emergency instructions for dealing with dangerous goods incidents aboard ship do not appear in the Code proper at all, but in the Supplement to the Code, (sometimes called Volume 3), Daunting for new users The length and density of the text is a psychological barrier to learning for people whose first language is English, or one of the main world languages into which the Code is translated. How much more difficult is this for users reading the Code in a second language? ✔ A typical illustration from the guidebook showing good practice for drum packing. Obstacles to knowledge This problem can be overcome if the employer sponsors IMDG Code training. The training problem is compounded if shippers and packers operate hundreds of miles from the sea and have no natural contact with maritime affairs. The situation is even more difficult if the operation is located in a state or region where business culture is undeveloped, and regulatory compliance is not a priority. The Club recognises the existence of these knowledge gaps, and seeks to address them by making the new IMDG Code guidebooks available through shipping lines to their customers. Causes of dangerous goods incidents Before looking in detail at how the guidebooks work, it may be useful to look at the nature of dangerous goods, and at the main factors that cause dangerous goods incidents. Then the relationship of compliance with the IMDG Code to risk reduction becomes apparent. The hazard and risk factors The IMDG Code requires shippers to identify cargo as dangerous goods if it possesses a known hazard such as flammability, toxicity etc. The IMDG Code rules enable the carriage of dangerous goods to be acceptable under managed risk conditions. For example, the carriage of flammable liquid is never without a fire hazard, but provided the ship is fully aware of the Hanjin Pennsylvania. 5 ● Cargo crushed and collapsed by being overstowed by heavier cargo ● Point-loading damage to cargo by pallets caused by lack of horizontal support between tiers ● Collapse of flimsy and badly made pallets causing stow instability ● Penetration of cargo, particularly drums, from protruding nails in floors, pallets, dunnage and broken pallets ● Direct physical damage to packages caused by fork lift trucks ● Ram-loaded packages split by forcing them into the container by fork lift. 5 The completely unexpected From time to time people do unusual things to containers – tip them from road trailers, shunt them into railway buffers, or drop them from cranes. After such an event, in an ideal world IMDG Code dangerous goods warning placards would compel conscience to overcome carelessness and check the cargo before loading on a ship, but this is not always the case. 6 Human factors – regional and company attitudes IMDG Code rules, like any laws and regulations, only have meaning in proportion to the degree to which people respect and comply with them. We have looked at the physical failures and vice versa. Here are just some important areas: ● Company rules, standards and resources A large multi-national company can apply ready-made templates for operational safety standards that include the IMDG Code, and have compliance officers to plan training and maintain standards. By contrast, managers of small companies often have limited resources, and these are directed towards managing productivity and everyday problems. ● Business ethics There are employers in all societies that encourage employees to regard regulations as ‘red tape’ and barriers to productivity. Operators with this mindset find it easy to push aside the IMDG Code, when it is convenient to do so, by simply not declaring cargo as dangerous goods. Again it is the ship that is bearing the risk, not them. This is primitive business thinking, but often prevails, particularly in small companies. The container packing industry is vulnerable to this attitude. Consider container packing at its most basic. It only requires the rental of a fork lift Container/vehicle packing declaration I hereby declare that the goods described above have been packed/loaded into the container/vehicle identified above in accordance with the applicable provision. Must be completed and signed for all container/vehicle loads by person responsible for packing/loading Name of Company: XYZ Cargo Packing Co. Name/status of declarant: Peter Packer / Supervisor Place and date: Southampton 22.08.2005 Signature of declarant: Peter Packer Packing certificates When dangerous goods are packed into containers for sea, the IMDG Code requires a signed certificate from the packer, confirming that the packages were sound and the load was packed, secured, marked, labelled and placarded all according to the IMDG Code rules. Photo: Containers subjected to handling methods such as this should be opened and inspected for damage before loading to a ship – does it happen? that create problems, but it is people who drive policy, manage companies, operate production plants, create documents and load containers. Why do people fail to comply with the IMDG Code? Individual actions are influenced by organisational procedures and cultures, 6 truck, the construction of a simple container access ramp and use of a piece of land by a roadside to set up business as a container packer. There is not even a requirement for a building. It is an easy entry-level business for a budding entrepreneur with limited funds, and he may not even be aware of the IMDG Code. In newly emerging industrial societies workers may transfer, overnight, from traditional agricultural work to industrial processing involving dangerous chemicals. There will be a time lag before such societies develop the instinctive understanding of industrial and chemical hazards that comes from experience. The IMDG Code has evolved over six decades, but it is a new concept to many companies now manufacturing and packing dangerous goods in newly developing regions. They will need help and training to assimilate the IMDG Code into their industrial cultures. ● Communication In addition to coping with the industrial culture gap, many developing regions are doing business with the world in a second language, usually English. This adds another barrier to perfect understanding. Consider the extract from a safety data sheet below, which is taken from a Far Eastern manufacturer’s website. In the list of hazardous properties it says “Danger of Explosion: Not applicable,” but in the next line under “Fire Hazards” it says, “Material is shock sensitive and potentially explosive.” Lost in translation? The company had a highly technical website advertising sophisticated speciality chemicals but made an error in translation of the sort that can easily be made on a shipping document. ● Individual skills and attitudes It should not be forgotten that individual employees make decisions that affect outcomes, albeit against their organisational background. Many people are trained to perform a narrow set of technical skills repetitively, quickly and semi- automatically to achieve business productivity – for example to create dangerous goods documents on a computer, process a cargo booking, pack a container or book containers through a dock gate. For such individuals it is more difficult to apply the IMDG Code rules than to ignore them. Employees who are disaffected, poorly trained, or poorly supervised will take short cuts and break the rules to get the job done with least effort. That may mean ignoring the IMDG Code. IMDG compliance should mean less incidents We have seen that there are many potential hidden causes of dangerous goods incidents, and many obstacles to the observance of the IMDG Code. While this situation prevails, the risk to ships from hazardous cargo will remain unnecessarily high. However, if all dangerous goods are shipped under the IMDG Code rules, the risks will be considerably lower. If ships know the nature, the hazard and the identity of the cargo, it can be stowed and segregated appropriately, and incidents handled confidently. Dealing with a deck fire involving a known commodity is altogether different from dealing with an unknown commodity burning below deck. Accepting that increasing IMDG Code compliance is at the heart of the solution, how can this be achieved? The Club believes that a significant improvement can be brought about if shippers and container packers in all regions could be provided with practical IMDG Code training aimed specifically at their operational requirements. The result is the Book it right and pack it tight guidebooks and training set. Book it right and pack it tight The Club hopes to make a contribution to boosting global understanding and use of the IMDG Code with the Book it right and pack it tight pack of guidebooks and training material. The quickest way to get into business: 1 Hire a fork lift truck 2 Make a ramp 3 Rent some land by the side of the road 4 You’re in business as a container packer! Lost in translation? Extract from manufacturers Product Safety Data Sheet Flashpoint: Not applicable Flammability: Not applicable Ignition Temperature: Not applicable Danger of Explosion: Not applicable Fire Hazards: Material is shock sensitive and potentially explosive! Illustration from Book it right and pack it tight, of a typical damage scenario. 7 The guidebooks look at the role of the shipper, the shipping line booking agent, the freight consolidator (manager or supervisor), and the fork lift operator and cargo handler who physically loads the container, and identify the key duties of each. The party concerned, instead of having to search through the 800 pages of the Code looking for his instructions, starts by consulting his guidebook. The guidebooks explain in simple terms what duties the IMDG Code requires, with colour illustrations and photographs. Each duty described in the guidebooks includes a reference that takes the reader directly to the text in the Code where the full technical details are found. What the guidebooks contain Guidebook 1 in the series is for shippers. It explains the shipper’s key duties such as: ● Classifying the hazard – the guidebook explains how the UN classification system identifies all the dangerous goods details about a particular hazardous substance ● Documenting the hazard – indicates the details that the IMDG Code requires be notified about dangerous substances, and how the IMDG Code draws them together into a common global format for documentation. The guidebook includes examples of how the shipper must make out a shipper’s declaration for different types of dangerous goods, and how they should be presented on the document, together with an example of a completed dangerous goods document ● Documentation checklist – this book includes a checklist for use by shippers and others to ensure that all the required details have been included on a dangerous goods shipping declaration ● Legal obligation – the guidebook explains the meaning of the legal text that appears on each dangerous goods declaration, and the commitment the shipper is making when he presents dangerous goods for shipment by sea ● Package selection – the guidebook outlines the IMDG Code rules that shippers must follow when selecting packaging that is suitable for dangerous goods, and an illustration of the type of UN code that appears on packages that have been tested and approved for filling with dangerous goods ● Use of different types of packages – the guidebook has colour illustrations of different types of packaging used for dangerous goods including the construction of combination packages made up of inner receptacles contained within outer wrappers ● Marking and labelling – the guidebook explains and illustrates the shipper’s prime duty to apply specific warning marks and labels to each package to give clear and decisive information about the contents of each package. Guidebook 2 covers similar ground from the point of view of shipping line employees. Its purpose is to assist cargo booking staff to check the information provided by shippers at the earliest stage, by asking shippers the right questions, and to help shippers to get the basics right. Guidebook 3 is aimed towards managers and supervisors of cargo consolidation depots where dangerous goods are packed into freight containers. It summarises the shipper’s duties in less detail, and concentrates on the additional factors that come into play when packing dangerous goods into freight containers. Examples of additional key factors for consolidators explained in Guidebook 3 include: ● Segregation of dangerous goods within a container – the guidebook explains how both the hazard and the risk of an incident are escalated if the container packer ignores IMDG Code segregation rules and packs incompatible dangerous goods in the same container. The guidebook then shows how the segregation should be checked either manually or electronically using internet or proprietary computer-aided systems ● Marking and placarding of containers – the guidebook explains the packer’s duties regarding the Illustration of package marks and labels that must be applied by the shipper. CORROSIVE LIQUID ACIDIC, ORGANIC N.O.S. (caprylyl chloride) UN 3265 ETHANOL UN 1170