Car Transporter sea movement changes
Members transporting cars or anything else with an ‘internal combustion engine’ are being advised of the latest requirements under the dangerous goods sea code IMDG. The latest update which occurs every two years (referred to as ‘35-10’) is mandatory from 1st January 2012 and refers to the conditions under which cars and engines (UN3166) fall.
What does that mean? Well for most not very much at all, the vast majority of members who transport this type of cargo will do so using open deck transporters or will be undertaking short sea crossings on Roll on/Roll off ships. If that is the case then there are no more requirements needed under IMDG Special Provision 961 – this is still the case if the transport unit is ‘enclosed’.
The problem really starts where cars and other such cargo is being shipped other than by Ro-Ro - for instance container shipping. In this case it is still possible for goods to be transported under the same SP961 if the vehicle has been emptied of fuel to the point of stalling – this is sensible really as it then means that the potential danger has been mitigated to a great extent.
If fuel is carried in the tank of the vehicle to be transported in a container (CTU) this is still acceptable up to one quarter of a tank although this will then require a dangerous goods note/declaration but will not require the container to be marked with Class 9 placards.
Anything above that limit would be classed as dangerous goods fully in scope of the code and its requirements. It is expected that the UK competent authority (MCA) will produce a guidance document on this in the coming weeks as their interpretation has recently changed.
If you would like further information or have concerns about any of the above, please contact Nick Deal, the Car Transporters Group’s Secretary at: firstname.lastname@example.org