On occasion, I will receive a frantic call from a customer whose shipment of dangerous goods has been frustrated for one reason or another. Such is the case this past week, when a forwarder contacted me regarding a shipment that was not declared properly by the shipper. I offered to assist the shipper and forwarder by preparing the dangerous goods (DG) declarations. The consignment consisted of three aerosol cans in a fiberboard which was then overpacked in a larger wooden crate, loaded in an intermodal freight container, bound for Australia via Shanghai, China.
After reviewing the Safety Data Sheet for the product, I was able to quickly determine that the flammable aerosols were permitted to be shipped as limited quantities. I prepared the DG declaration for the shipper to sign and declared the goods as UN1950, AEROSOLS, 2.1, LTD QTY.
I provided a detailed description of the packaging as: 1 WOODEN CRATE (OVERPACK) STC (SAID TO CONTAIN): 1 FIBERBOARD BOX X 3 METAL CANS X 354 ML EA. I indicated the gross weight of the overpack (125.0 kg) and the net weight of the hazardous material (1.1 kg) and the cubic volume.
Well, the shipment was promptly rejected by the steamship line! This immediately created a firestorm of emails between forwarder, shipper, myself and the steamship lines’ customer service representatives—28 in all, to be exact. The quote-unquote “expert” for the steamship line, who touted his 15 years of experience in his email, claimed that the International Maritime Dangerous Goods (IMDG) Code required that the Gross Weight (GW) and Net Weight (NW) be provided on the DGD.
In fact, the IMDG Code does not require the Net Weight (other than net explosive weight for class 1 explosives). The IMDG Code actually states (in Section 184.108.40.206.1):
Total quantity of dangerous goods
Except for empty uncleaned packagings, the total quantity of dangerous goods covered by the description (by volume or mass as appropriate) of each item of dangerous goods bearing a different Proper Shipping Name, UN Number or packing group shall be included. For class 1 dangerous goods, the quantity shall be the net explosive mass. For dangerous goods transported in salvage packagings, an estimate of the quantity of dangerous goods shall be given. The number and kind (e.g. drum, box, etc.) of packages shall also be indicated. UN packaging codes may only be used to supplement the description of the kind of package (e.g., one box [4G]). Abbreviations may be used to specify the unit of measurement for the total quantity.
It was also interesting to note that the IMDG Code further states that:
The number, type and capacity of each inner packaging within the outer packaging of a combination packaging is not required to be indicated.
After quoting what the IMDG Code actually requires, the steamship line changed its position and said that it was, essentially, a business requirement for their partnering line. Now, I don’t have any objection to providing the net weight (NW) in addition to the gross weight (GW). In fact, it is a good idea and is strongly recommended. What I object to is the fact that the steamship line, in this case, was imposing requirements that were not, in fact, requirements and making claims that the documents, as offered, were in violation of the rules.
Wouldn’t it have been easier to have known what the regulatory requirements and business requirements were up front? Often there are misinterpretations of the rules and business policies are often mistaken for regulatory requirements. In my opinion, the carrier should clearly communicate its requirements up front, in much the same manner that carriers have filed and published variations in air regulations. These business requirements or other restrictions should be prominently posted on their websites and other communiqués to existing and potential customers.
Likewise, I am of the opinion that the shipper and freight forwarder should make it a practice to ask if there are any restrictions above and beyond the minimum regulatory requirements. I have often suggested to customers that they host an annual carrier conference whereby they invite their ground, air and vessel carriers in to discuss the types and quantities of dangerous goods that they offer into transportation, and offer or make available packaging and documentation examples so that they can eliminate or significantly reduce the number of frustrated shipments that might occur. It would give both parties an opportunity to discuss some of the potential roadblocks and to jointly resolve these difficulties before they become serious issues.
I also recommend that you have a national account representative for each carrier through which to resolve some of these conflicts that will invariably arise. Often, clients will get two different answers from two different people on two different days. It is frustrating and counter-productive, to say the least!
Sometimes, the “…next best thing to knowing something is knowing where to find it.”
Questions regarding the regulatory requirements can often be found on the U.S. Dept. of Transportation’s (DOT) website (see Spray, June 2013). Finding answers for questions related to the unwritten requirements are more difficult. I would recommend that the shipper start with the carrier’s Dangerous Goods Desk. Have a list of questions available beforehand and ask that the answers be put in writing. You might also participate in dangerous goods trade associations such as the National Aerosol Association (NAA), Western Aerosol Information Bureau (WAIB), the Conference on the Safe Transport of Hazardous Articles (COSTHA) and the Dangerous Goods Advisory Council (DGAC), among others. SPRAY