Shipping Under Special Provision 188

Recently we had one of our loyal customers inquire about shipping lithium-ion batteries by ocean. He said they are not trained under the IMDG Code and needed our help to prepare a shipment of lithium-ion batteries going overseas.  

I asked him to send me the information on the batteries. The batteries had a watt-hour of 2.4.  Based on all the information he provided me, I explained that the batteries he was shipping fall under special provision 188 of the IMDG Code. I guided him on exactly what needs to be done. Because they regularly ship by ground, the requirements for ground transport are the same as ocean transport. I advised him to inform his logistics personnel about the exemption.  

He emailed a couple of days ago for further help. A Freight Forwarder asked our client for a document stating the UN#, shipping name, hazard class, and the special provision number. Although special provision 188 doesn’t mention anything about providing any sort of document, it is now a shipping line (assuming each one may be different) requirement to provide a document with this information. It sounds familiar to what some of the airlines require to ship Section II batteries. The Shipper’s Transport Document for Section II batteries. It would be safe to assume the shipping lines are heading in the same direction.  

To all those shipping lithium batteries under special provision 188 by ocean transport, you may be asked to provide a document stating the above.  

If you need help with your lithium battery shipments or any other dangerous goods shipments, the Regulatory Experts at ICC Compliance Center are always here to help. Contact ICC at 1-888-442-9628 (U.S.) or 1-888-977-4834 (Canada), and ask for one of our Regulatory Experts.

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Racheal Mani

Racheal Mani

Racheal Mani, based out in our Delta, B.C. office, has over 12 years of experience working under different auspices of federal, provincial, and municipal regulatory framework. She specializes in TDG Clear Language, IATA, IMDG, and WHMIS 2015 training. Racheal’s extensive knowledge in the dangerous goods industry is driven from her hands-on experience from packaging of dangerous goods for all modes of transport and her consistent liaison with ICC clients to ensure dangerous goods consignments meet the applicable regulatory requirements prior to transport.

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