I had an interesting question from a client last week. He had approached me to ask about helping prepare an IMO declaration to ship a product by ocean transport. Now he isn’t the actual shipper of the goods. He is a freight forwarder whose client is based overseas who is arranging to get the goods from Canada to another part of the world. Advised him that I can’t provide an IMO declaration without verifying that the shipment is packaged and marked/labeled/placarded in accordance with the IMDG Code.  

Based on the SDS he provided, this material is classified as UN3077. It’s quite a large quantity that is being shipped, so I advised him of the available options. UN rated flexible IBCs, a.k.a. supersacks being the cheapest option. I gave him the list of different UN rated supersacks that are acceptable as per the IBC packing instruction in the IMDG Code. He said he’ll forward it to his client to send to the actual shipper.  

A couple of days later he sent me an email with a picture of the material in a supersack. After some emails back and forth, he confirmed there were no UN specification marks on the supersacks. I told him the goods must be transported in UN rated packaging.  

He emailed back the next day stating his client is asking if the current packaged material can be shipped as-is and they will get the UN rated supersacks for next time. It made me smile because the answer was so simple. NO. I explained to him to explain to his clients that it does not work that way. Besides, it’s not just ocean transport that requires UN rated packaging but ground transport too. So technically, that material can’t even leave the site in its current state. I said if they insist on sending it, then I will not be providing any IMO declaration or DG consulting services.  

The good thing is that he understood this. He said he would inform his client that they must get UN rated packaging and no such thing as “next time.” And guess what. They were able to get some locally. Even better, it had the UN#, shipping name, and labels pre-printed on the bags. I will be preparing the IMO declaration once they are ready to ship. It worked out well for everyone involved!

Let us help you make sure your dangerous goods shipment is in compliance with applicable transport regulations. Contact the ICC Regulatory Experts at 1-888-977-4834 (Canada) or 1-888-442-9628 (U.S.).

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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.