Dangerous goods in packaged form

According to Notice B from the Danish Maritime Authority, chapter VII, part A, the carriage of dangerous goods in packaged form is required to meet the provisions of the IMDG Code (International Maritime Dangerous Goods Code). This applies irrespective of the size of the ship.

The IMDG Code stipulates requirements for the packaging, marking and stowage of dangerous goods. The goods are divided into nine classes, some of which are divided into sub-groups: 

  • Class 1: Explosive substances and objects (Class 1 is divided into 6 sub-groups).
  • Class 2: Gases, Compressed, liquefied or dissolved under pressure.
  • Class 3:  Flammable liquids.
  • Class 4.1: Flammable solids.
  • Class 4.2: Spontaneously combustible solids.
  • Class 4.3: Substances liberating combustible gases when in contact with water.
  • Class 5.1: Oxidizing agents.
  • Class 5.2: Organic peroxides.
  • Class 6.1: Toxic substances.
  • Class 6.2: Biohazards.
  • Class 7: Radioactive substances.
  • Class 8: Corrosive substances.
  • Class 9: Various dangerous substances and objects, i.e. any other substance which experience proves to be - or which turns out to be - of such a dangerous nature that it should be covered by the provisions of this part.  

The coming version of the IMDG Code (version 38-16), which was adopted by the IMO Maritime Safety Committee at its 96th session as resolution MSC.406(96), will formally enter into force on 1 January 2018. However, it is possible to use the IMDG Code version 38-16 from January 2017; it is available from this link.

For certain types of ro-ro passenger ships, it is possible – as an alternative to the IMDG Code – to use the "Memorandum of understanding on the carriage of dangerous goods by ro-ro ships in the Baltic Sea area" (also referred to as the "Baltic Sea Memorandum"). This makes it possible for these ro-ro passenger ships to transport trucks carrying dangerous goods without having to change the marking and the transport documents for the dangerous goods from the road transport regulations (ADR) to the sea transport regulations (IMDG Code) within the areas given in the Memorandum of Understanding.

On 1 January 2018, a new Baltic Sea Memorandum entered into force, which is available here.

The Baltic Sea MoU has been completely restructured in order to align it with the equivalent provisions of the IMDG Code. The substantial amendments are limited to the following:

  • clarification as regards the carriage of batteries in bulk (UN 2984, UN 2795, UN 2800 and UN 3028)
  • updating of the provisions on stowage of dangerous goods of classes 2-9
  • the competent authorities' contact data.

The ADR regulations divide dangerous goods into the same danger classes as the IMDG Code. The reason that the requirements for the packaging, marking and stowage of dangerous goods in connection with carriage by sea are stricter than those applicable to transport by road is primarily that it is more difficult to fight an accident at sea than ashore. Ashore, accidents are fought by specially trained personnel who normally have unimpeded access to the scene of the accident and who can relatively easily evacuate human beings from a risk area. It is also of importance that, during a sea voyage, the goods may be exposed to considerably larger impacts than in connection with other types of transport.

The construction and certification of ships for the carriage of dangerous goods in general

Notice B from the Danish Maritime Authority, chapter II-2, regulations 10 and 19, contains the requirements for the construction and equipment of ships. Ships with a gross tonnage above 500 built after 1 September 1984 and ships with a gross tonnage below 500 built after 1 June 1985 must be fitted with permanent fire-extinguishing systems in their cargo holds in order to carry dangerous goods in packaged form. Furthermore, there are special requirements for the ships' construction and equipment depending on the individual classes of dangerous goods.

The Administration is required to issue a certificate confirming that the ship's construction and equipment meet the requirements for the carriage of dangerous goods. This is valid for 5 years and annual inspections must be performed, which are endorsed onto the certificate.

A certificate for the carriage of dangerous goods – with the exception of solid dangerous goods in bulk – is not required for the types of cargoes classified as belonging to classes 6.2 and 7. These two classes are not stated on the certificate, either.

Furthermore, a dangerous goods certificate is not required in connection with the carriage of goods in limited quantities.
Ships constructed before 1 September 1984 and 1 June 1985, respectively, need not meet these requirements, but the packaging, marking and stowage of the goods and training of personnel must be in accordance with the requirements of the IMDG Code.

Read more about the approval and emergency preparedness in connection with the carriage of dangerous goods by sea here.


Maritime Regulation and Legal Affairs