Day 3 – IMDG Code Amendment 42-24 summary of main changes

Particular thanks to ICHCA member NCB HAZCHECK for their analysis of changes in Amendment 42-24. Today we look at what has changed in the new edition of the IMDG Code. The following content tries to summarise those changes. It gets into the detail and assumes a degree of knowledge of the 950 plus pages of the Code. This is not a full list of all the changes being introduced. Full details and applicable provisions are in the new text of Amendment 42-24.

Summary of Key Changes: Part 1: General Provisions – Definitions Updated definition for recycled plastics material (now mentions IBCs) (1.2). A new definition for “degree of filling” has been added (1.2). Data loggers etc. used in transport are now called “Devices containing dangerous goods” (1.1.1.10) (previously they were “DG in equipment”)

Part 2: Classification UN 3555 has been added to the list of liquid desensitized explosives. One amendment and three new additions to the organic peroxide table. Sodium ion batteries have been added to Class 9, along with new vehicle entries and a new life-saving appliances entry. Updates to paragraph 2.10.2.7 and the introduction of Special Provision SP375 clarify exemptions and permit UN 3077 and UN 3082 to be exempt from IMDG Code requirements if under 5 kg or 5 L, even if not declared marine pollutants. Articles containing dangerous goods 2.0.6.2 amended to also include articles containing ‘cells’ as well as batteries. If they are transported under the small production run exemption these should be documented as “Transport in accordance with SP 301” 2.1.1.3.2 ’Pyrotechnic substance is redefined 2.1.1.3.6 new sub paragraph (6) defines ’explosive or pyrophoric effect’ 2.4.2.2.1.3 ‘powders of metal or metal alloys’ now becomes ‘metal powders’

Part 3: Dangerous Goods List Various amendments have been made to existing entries, special provisions (SPs), stowage codes, properties, and observations, along with the addition of new entries. Notable changes include:

Carbon (UN 1361): Removal of SP925, meaning carbon can no longer be exempted from the IMDG Code. Addition of SP978, which introduces new definitions, weathering, transport, and packaging requirements. Removal of PP12, meaning carbon is no longer permitted in specific bags (5H1, 5L1, and 5M1) in closed CTUs.

Activated Carbon (UN 1362): SP979 clarifies exemptions from the IMDG Code provisions and adds a new documentation requirement under section 5.4.4.2.

Additional changes to UN Number entries: UN 1006, 1013, 1046, and 1066: SP406 increases the limited quantity value to 1000 mL. UN 1835 and UN 3292: PSNs[1] have been amended. UN 1835 and UN 3423: SP409 allows continued use of Amendment 41 for a transition period. This also applies to UN 3560. UN 3423: Reclassified from Class 8 to Class 6.1, sub hazard 8 and now Packing Group I (PGI). It is no longer permitted in LQ, stricter EQ limits apply, and shipment in IBCs requires competent authority approval. UN 1391 and UN 3482: Now permitted in tanks. UN 3129 (PG II & III), UN 3130 (PG II & III), and UN 3148 (PG I, II & III): Stowage category changed to “D” (on deck only, prohibited on passenger ships). SW5 replaced by stowage code “SW31.” UN 3536: Stowage category changed to “D” (no longer permitted under deck or on passenger ships). Several entries have had updates to properties and observations.

New UN numbers/new entries added for: fire suppressant dispersing devices (Class 1.4S UN 0514 and Class 9 UN 3559) disilane (Class 2.1, UN 3553) a pyrophoric gas that spontaneously ignites in air gallium in manufactured articles (Class 8, UN 3554) listed separately because gallium itself is highly corrosive to aluminium and is therefore prohibited on vessels constructed of aluminium trifluoromethyltetrazole-sodium salt in acetone (Class 3,UN 3560) – a desensitised explosive that is highly sensitive to friction in dry state

Batteries Sodium Batteries (Class 9) UN 3551 sodium ion batteries with organic electrolyte UN 3552 sodium ion batteries contained in equipment with organic electrolyte UN 3558 sodium-ion-battery-powered vehicles with Special Provision 404 that UN 3558 powered vehicles are not subject to the IMDG Code if the battery is short circuited and contains no electrical energy

Lithium Ion Batteries UN 3556 lithium-ion-battery-powered vehicles UN 3557 lithium-metal-battery-powered vehicles

UN 3171 used to include several battery powered vehicle types including lithium batteries but can now only be assigned to vehicles powered by wet batteries, metallic sodium batteries and sodium alloy batteries. 2.9.4.7 requires that manufacturers and subsequent distributors of cells or batteries manufactured after 30 June 2003 shall make available the test summary. The term “make available” now defined as “manufacturers and subsequent distributors ensure that the test summary for lithium cells or batteries or equipment with installed lithium cells or batteries is accessible so that the consignor or other persons in the supply chain can confirm compliance.”

Part 3: Special Provision SP28 now applies to liquid desensitized explosives under Class 3. SP388 clarifies the application of UN 3171, including new battery-powered vehicle DGL entries. A new paragraph .8 clarifies that hybrid vehicles on container ships will have the same requirements as SP961.1 on ro-ro decks. SP922, 928, 931, 935, 939, 954, 964, and 979 now reference the new documentation requirements under paragraph 5.4.4.2. SP375 clarifies conditions for UN 3077 and UN 3082 when package size results in non-classification as marine pollutants. SP978 and SP979 replace SP925 for carbon entries, including details on packing group assignments, stowage requirements, and exemptions from the IMDG Code.

Part 4: Packing Instructions Updates Numerous minor changes and formatting improvements have been made. Two new packing instructions have been introduced: P303 applies exclusively to UN 3555. P912 applies to new vehicle entries (UN 3556, 3557, and 3558). A new tank special provision TP42 applies to UN 1391 and UN 3482.

Part 5: Consignment Lithium battery marking now extended to cover the new sodium ion battery entries. For carbon shipments, the transport document must include the date of production, date of packaging, and temperature of the material at the time of packaging. Stowage plans onboard ships must now include both primary and subsidiary hazards. A new paragraph 5.4.4.2 requires a certificate exempting a substance, material, or article from the IMDG Code provisions to be submitted alongside cargo information as required by SOLAS regulation VI/2.

Part 6: Construction and Testing of Packagings et al: The chapters in Part 6 include several updates to referenced standards and minor revisions. Packagings 6.1.3.1: “Packaging marks must be applied to non-removable packaging components.”

Part 7: Transport Operations Stowage code “SW31” has been added, requiring stowage away from potential sources of ignition for certain water-reactive liquids. Carbon is now included in the stowage and handling provisions for Class 4 in section 7.6.2.7.

IMPORTANT NOTES: The IMDG Code is produced by the International Maritime Organization. This is a brief guide to the changes only. Please refer to the IMDG Code proper for a complete list of all changes in this Amendment. A general transitional period runs from January 1, 2025, to December 31, 2025, during which the previous amendment A41-22 remains applicable. For more information and ongoing updates on our work, visit www.ichca.com

[1] Proper shipping name (PSN) standard technical name to describe the hazard properties and composition of dangerous goods. Shipping requires a UN number (usually, 4 digits) and a PSN from Dangerous Goods List that can most accurately describe the dangerous goods.