MCA interpretation of the certification and vehicle/container packing certificate requirements of the International Maritime Dangerous Goods (IMDG) Code.
The International Maritime Dangerous Goods (IMDG) Code requires either two signatures on a single transport document, or one signature on each of the Dangerous Goods Transport Document and Container/Vehicle Packing Certificates which shall be attached to each other.
The IMDG Code is brought into UK law through the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 S.I. 2367 (as amended) and the relevant regulatory text is reproduced below.
The dangerous goods transport document prepared by the shipper should in addition carry, or be accompanied by, a certificate or declaration that the consignment offered can be accepted for transport and that the goods are
The form for this declaration is
I hereby declare that the contents of this consignment are fully and accurately described above by the Proper Shipping Name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations.
This requirement is covered by box 22 of the 5.4.5 Multimodal Dangerous Goods Form or box 17 of the SITPRO Dangerous Goods Note or equivalent.
18.104.22.168 When dangerous goods are packed or loaded into any container or vehicle, those responsible for packing the container or vehicle shall provide a container/vehicle packing certificate – specifying the container/vehicle identification number(s) and certifying that the operation has been carried out in accordance with the following conditions
DANGEROUS CO2 (DRY ICE) INSIDE. VENTILATE THOROUGHLY BEFORE ENTERING
22.214.171.124 The information required in the dangerous goods transport document and the container/vehicle packing certificate may be incorporated into a single document. If not, these documents shall be attached one to the other.
If the information is incorporated into a single document, the document shall include a signed declaration such as
It is declared that the packing of the goods into the container/vehicle has been carried out in accordance with the applicable provisions
This requirement is met by a signature and completion of box 20 of the 5.4.5 Multimodal Dangerous Goods Form or box 15 on the SITPRO Dangerous Goods Note or equivalent.
If the consignor loads dangerous goods, which includes
they are then responsible for signing box 20 of the 5.4.5 Multimodal Dangerous Goods Form or box 15 on the SITPRO Dangerous Goods Note or equivalent.
However, if the consignor passes the goods to another organisation for carriage, a process commonly known as groupage, then that secondary organisation (e.g. consolidator, carrier or forwarder) is responsible for the whole process of
In this case it is not the original consignor but the secondary organisation who should then sign box 20 of the 5.4.5 Multimodal Dangerous Goods Forms or box 15 on the SITPRO Dangerous Goods Notes or equivalent, relating to all the dangerous goods in the container/vehicle (or should complete one container/vehicle Packing Certificate for the entire load if that is more convenient).
An operator or master shall not accept for carriage, or take or receive on board a ship any dangerous goods for which a document and certification has not been provided.
In addition any personnel involved in the transport of dangerous goods by sea should have received training commensurate with their responsibilities in transporting dangerous goods by sea.
Environmental Quality Branch
Maritime and Coastguard Agency