29 Carriage and Transfer of Cargoes (including Dangerous Goods)

 29.1 General Information

29.1.1 The carriage and transfer of cargoes (including dangerous goods) by sea is controlled in order to prevent injury to persons or damage to ships and their cargoes and to prevent pollution of the marine environment under normal operating conditions. Dangerous goods are cargoes classified in the International Maritime Dangerous Goods (IMDG) Code which is given force of law through the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 (SI 1997 No. 2367), as amended and applies to all vessels irrespective of size in UK (navigable) waters. For operation outside the UK refer to 29.1.7. The Merchant Shipping (Carriage of Cargo) Regulations (SI 1999 No 336) also apply to small workboats and the requirements are dealt with in detail in Section 25.3.

The following requirements have been developed, noting the provisions in regulation 22(2) of the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 (SI 1997 No. 2367), as amended. The basic philosophy of these requirements is to apply standards contained in Regulations 54 or 19 of Chapter II-2 of SOLAS to the extent that is practicable and reasonable taking into account the design features and service characteristics of these vessels, as well as the limitation placed on the operation of the vessels, subject to the vessels complying fully with the stowage and segregation requirements of the IMDG Code. The requirements below will only apply to workboats whilst operating in UK waters.

Section 29 is divided into the following sub-sections:

• Governing statutes and limitations, 29.2
• Exceptions and UK relaxations, 29.3
• Construction and certification requirements, 29.4
• Operational Considerations, 29.5
• Emergency Schedules for Fire and spillage provisions, 29.6
• Transfer arrangements of Marine Gas Oil (MGO), UN1202 (GAS OIL or DIESEL FUEL or HEATING OIL, LIGHT) from designated oil fuel tanks, 29.7
• Transfer arrangements from portable tanks (greater than 450 litres) or intermediate bulk containers (IBCs) less than 3000 litres, 29.8
• Transfer arrangements for receptacles containing less than 205 kg or 205 litres of dangerous goods, 29.9
• Dangerous Goods Document of Compliance, 29.10.

29.1.2 Control of dangerous goods is intended to cover all dangerous goods carried as cargo on a vessel. Operators and Masters should be aware that Dangerous Goods includes any specialist equipment which may be classified as dangerous cargoes when carried by crew, passengers or industrial personnel (see section 2). See also 25.9.8.

29.1.3 For the purposes of this Chapter any goods carried on board, such as activity related equipment or materials used in commercial operations, that are not ship's stores (see 29.3.1) are considered to be cargo.

29.1.4 When carrying dangerous goods identified in the IMDG Code, above the quantities and outside the Classes described in 29.3.2, the vessel is required to have a Document of Compliance for the Carriage of Dangerous Goods (DoC DG) issued by the Administration. A Document of Compliance is not required for transfer operations carried out in accordance with section 29.7.

29.1.5 The carriage of Class 1 explosives, with the exception of Class 1.4, compatibility group S, is not permitted. Owners / managing agents wanting to carry DG of Class 1 (other than 1.4S) may be permitted to do so by the MCA’s headquarters, on a case by case basis, and they should note that a qualified military or explosive expert should be present when explosives are being loaded, carried and unloaded or used on-board the vessel. No other dangerous goods will be permitted to be carried when carrying Class 1 explosives.

29.1.6 When the quantities and classes exceed those in 29.3.2, dangerous goods may only be carried at the same time as industrial personnel (i.e. not passengers), on Workboats holding a DoC DG, where such industrial personnel (for example offshore workers, surveyors etc.) are carried on the vessel on the business of the vessel. Procedures in accordance with 25.9.8 should be followed.

29.1.7 For workboats engaged on voyages outside the United Kingdom continental shelf or between two ports, one of which is outside the United Kingdom continental shelf: The carriage of dangerous goods is subject to international regulations (IMDG Code), SOLAS, MARPOL and National Regulations of other Administrations. Where a vessel wishes to carry dangerous goods permitted by the DoC DG issued by the MCA under the provisions of this Chapter it is essential that the owner / managing agent contacts the other Administration to confirm that this standards of safety is acceptable.

Note: Both the DoC DG and the IMDG Code need to be consulted to determine the safety standard required on international voyages.

As Workboats are “Non-convention” size vessels, there is no international standard for the carriage of Dangerous Goods on these vessels. It will be for each Coastal / Port State to decide whether to accept this Document of Compliance for the carriage of Dangerous Goods issued by the Maritime and Coastguard Agency, see 29.1.6 of the Code.

29.2 Governing Statute and Limitations.

29.2.1 Vessels where bulk cargo is loaded into and carried in the vessels hold or tanks are considered to be small tankers or bulk carriers shall not be certified under the provisions of this Code, see also 1.8.5. The only exception is the carriage of Marine Gas Oil (MGO) and UN1202 (GAS OIL or DIESEL FUEL or HEATING OIL, LIGHT), which is addressed under Transfer Arrangements section 29.7 of this Code. Refer also to section 25.3.

29.3 Exceptions and UK relaxations

The carriage of cargoes is the process whereby a vessel is loaded, or intended to be loaded, with any item for delivery to, or collection from, one location and loading/unloading at another location. Cargoes can be divided into:

(i) General cargo – securing and other carriage requirements are Regulated through the Merchant Shipping (Carriage of Cargoes) Regulations 1999 (SI 1999 No. 336). The carriage and transfer of oils^footnote not classified as dangerous goods is addressed in 29.8, Transfer arrangements from portable tanks (greater than 450 litres) or intermediate bulk containers (IBCs).

(ii) Dangerous goods – in addition to the requirements of (i), cargoes which are classified as dangerous goods according to the criteria given in the IMDG Code are regulated through the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 (SI 1997 No. 2367), as amended. Dangerous goods are assigned, and identified by, United Nations (UN) Numbers and Proper Shipping Names according to their hazard classification. Their system of containment systems, e.g. portable tanks, IBCs, drums etc. must comply with the requirements of the IMDG Code.

29.3.1 Ships stores

The IMO definition of ships’ stores (MSC.1/Circ.1216) is as follows:

Ships stores, for the purposes of the carriage of dangerous goods, means materials which are on board a ship for the upkeep, maintenance, safety, operation or navigation of the ship (except for fuel and compressed air used for the ship’s primary propulsion machinery or fixed auxiliary equipment) or for the safety or comfort of the ship’s passengers or crew. Materials intended for use in commercial operations by a ship are not considered as ships’ stores (e.g. materials used for diving, surveying and salvage operations such as IMDG Code classified dangerous goods - for example Class 1 – Explosives and the other eight classes of dangerous goods).

29.3.2 Materials intended for use in commercial operations

For the purpose of this Code, when a net total quantity of not more than 30 kg/litres of the following dangerous goods are carried or used on board, of UN Classes 1.4S, 2.1, 2.2, 3, 6.1, 6.2, 8 and 9, see Information Note for details of Classes, such materials can be considered as ships’ stores and the vessel does not require a Doc DG. However, the vessel is required to meet all other aspects of Chapter 29 including construction, equipment and procedures. These materials can be part of specialist equipment to support the function of the vessel, in order to facilitate the specific tasks for which they are designed. Examples of such materials/specialist equipment would be diving bottles, portable generators/compressors etc. The quantity restrictions referred to in this section do not apply to fuel transfer operations referred to in section 29.7, see 29.1.4.

Further detailed guidance including segregation requirements on the storage and use of such dangerous goods on board workboats described in the above paragraph is given in MGN 497^footnote.

29.4 Construction requirements

This section applies to all small workboats carrying dangerous goods in any quantity.

29.4.1 Scuppers and Drains

29.4.1.1 The scupper and drainage arrangements are to be directed overboard with no connections to internal spaces. (See also 29.7.2).

29.4.2 Electrical Equipment

29.4.2.1 Electrical equipment installed in the area of the vessel where cargo is carried should be of the certified safe type for the cargo being carried, or be capable of being securely isolated during the carriage of packaged dangerous goods.

29.4.3 Structural Fire Protection

29.4.3.1 Bulkheads and decks forming boundaries containing fuel tanks, machinery spaces and accommodation spaces are to be insulated to A-60 standard unless the dangerous goods are stowed three metres or more from such bulkheads, decks and boundaries. Certain classes of dangerous goods could have additional requirements, as described in the IMDG Code, that may prevent it being stowed next to accommodation regardless of A-60 insulation.

29.4.3.2 Where an A-60 insulation is required for an aluminium structure insulation should be an approved ‘A’ Class type tested under Part 3 of the FTP Code and be fitted in accordance with the conditions stated in the approval certificate. Alternatively, the insulation and structure should be type approved for the appropriate structure material for use on High Speed Craft (HSC) as tested and approved to Annex 1 Part 11 of the FTP Code 2010 – Test for fire resisting divisions for HSC (see Standards Appendix 13). Acceptable insulations will have the notation of ‘Fire-resisting divisions 60’. The approval shall state the orientation of the division and whether the division is load bearing or non-load bearing.

29.4.3.3 Where an A-60 insulation is required for a fibre reinforced plastic (FRP) structure reference should be made to the performance standard in MGN 407. An acceptable alternative to this for FRP is an insulation that has been type approved for the appropriate structure material for use on High Speed Craft (HSC) as tested and approved to Annex 1 Part 11 of the FTP Code 2010 – Test for fire resisting divisions for HSC (see Standards Appendix 13). Acceptable insulations will have the notation of ‘Fire-resisting divisions 60”. The approval shall state the orientation of the division and whether the division is load bearing or non-load bearing.

29.4.3.3.1 Refer to section 14.2.3.9 for the use of intumescent materials.

29.4.4 Wheelhouse Visibility

29.4.4.1 For wheelhouse visibility requirements refer to 19.6.

29.4.5 Means of Escape

29.4.5.1 Means of escape whilst carrying dangerous goods should be provided, see section 14.9.6.

29.4.6 Vessel Certification

29.4.6.1 Prior to carrying dangerous goods in quantities in excess of those specified in 29.3.2 or where different UN Classes of dangerous goods other than those specified in 29.3.2 are required to be carried, and subject to the exception in 29.1.4, the vessel should be surveyed and a Document of Compliance for the Carriage of Dangerous Goods issued upon successful completion of the survey. The details of any Document of Compliance on board should be recorded on the Workboat Certificate by the Certifying Authority.

29.4.6.2 Operators are recommended to undertake their own safety assessment before applying for a DoC DG; this assessment procedure should be discussed with the Administration before proceeding. The survey by the Administration to carry dangerous goods will necessarily consider additional requirements for the vessel including the carriage of additional safety equipment, number of persons on board and additional emphasis on structural fire protection, fire suppression, separation between dangerous goods and accommodation, stability, positioning of life saving appliances, assembly stations and emergency exit routes. It may be necessary for the operator to submit a safety case.

29.4.6.3 This survey may only be undertaken by the Administration unless it has been specifically delegated to a Recognised Organisation, and will be valid for a maximum of 5 years. See section 29.10 for further details. Upon successful completion of a survey, a Document of Compliance for the Carriage of Dangerous Goods harmonised with expiry date of the vessels Workboat Certificate will be issued to the vessel indicating the Class of goods that can be carried with a list of equipment fitted. Where the Workboat Code certificate has less than 2 years to run, and prior to 1 January 2020, it will be acceptable to give the Document of Compliance a 5 year validity provided that the Document of Compliance is marked with “DoC DG remains valid subject to the Workboat Code Certificate remaining valid.” For annual inspection requirements see also 29.10.

29.4.6.4 The Administration should be contacted if the vessel wishes to carry both dangerous goods and passengers at the same time, other than in accordance with 29.1.5.

29.5 Operational considerations

29.5.1 Crew Training

29.5.1.1 The crew should undergo training in the carriage of dangerous goods and the IMDG Code, commensurate with their responsibilities, and records kept of the training undertaken. See section 26.8 for details.

29.5.2 Stowage and Segregation requirements

29.5.2.1 Dangerous goods are to be carried on deck only.

29.5.2.2 They shall be secured to the vessels to prevent movement during the voyage.

29.5.2.3 A workboat is suitable for the carriage of dangerous goods as specified in the Doc DG subject to any additional stowage and segregation requirements of the IMDG Code which will take precedence over the table in the DoC DG and shall be followed at all times.

29.5.2.3.1 The IMDG weather deck stowage segregation requirements are included in Table 29.1 for guidance and should be read in conjunction with the IMDG Code as above.

29.5.3 Packaging (including portable tank and IBCs)

29.5.3.1 Dangerous goods shall be packed in accordance with the IMDG Code.

29.5.4 Documentation

29.5.4.1 When carrying dangerous goods, a full manifest of the cargo shall be retained ashore by the Small Commercial Vessel’s owner, or designated person, in case of an incident. The manifest should contain the UN Number, Proper Shipping Name, Packing Group and Quantity for each dangerous good being carried. The designated person ashore should have a list of contact numbers for the emergency services and relevant manufacturers/suppliers of the dangerous goods. The designated person should be employed by the Code vessel’s owner and be aware of the details of the voyage. Prior to accepting back-loaded cargoes, the designated person should establish that their carriage will be in compliance with this Code.

29.6 Emergency Schedules for Fire and Spillage

29.6.1 When dangerous goods are carried, details of the emergency fire fighting equipment and First Aid medical procedures should be provided on board. The IMDG Code and its supplement will give guidance on such items, to ensure that if an emergency occurs, it can be dealt with effectively.

29.6.2 Fire Fighting Equipment

29.6.2.1 There should be an immediate availability of water from the fire main provided by an engine driven fire pump or a separate powered pump. An additional powered fire pump should be provided in the event of the loss of one pump. Also refer to 15.4.1 or 15.5.1. Each pump shall be capable of supplying two hoses and nozzles, required in accordance with the Code, one of the nozzles should be a spray/jet type.

29.6.2.2 At least two portable dry powder extinguishers each rated at least at 34B, in addition to those required by 15.4.2 or 15.5.2, are to be provided and be readily available to the cargo area.

29.6.3 First Aid Kit Requirements

29.6.3.1 The provisions of Annex 4 – “Medicines to be carried on ships carrying dangerous cargoes” to MSN 1768 (M+F)^footnote, should be taken into consideration when carrying dangerous goods.

29.6.3.2 When a vessel is carrying a dangerous substance or substances, in quantities in excess of those defined in column 7 of the Dangerous Goods list of the IMDG Code, as whole or part of the cargo, the Master must ensure the correct antidote to the substance (plus the necessary ancillary equipment e.g. syringes) is carried. The correct antidote can be found in the IMO Medical First Aid Guide for Ships (MFAG), as amended.

29.7 Transfer Arrangements of Marine Gas Oil (MGO), UN1202^footnote, from Designated Oil Fuel Tanks (Oil fuel as defined in Regulation 12A.3.1 of MARPOL Annex I)^footnote

29.7.1 Vessels which are adapted and used for the transfer of MGO from designated^footnote oil fuel tanks to other external facilities (e.g. a wind turbine) should demonstrate that they comply with MARPOL’s requirements as far as practically possible taking into account that pollution of the seas is an offence. The following are the minimum requirements these vessels should follow:

29.7.1.1 The vessel should carry on board an up to date ship specific plan, verified by the Certifying Authority, which includes provisions to deal with oil spill accidents both during the transfer of oil within the workboat and from the workboat to the receiving facilities. IMO Resolution MEPC.54(32)^footnote as amended by Resolution MEPC.86(44) may be used in developing the plan;

29.7.1.2 The vessel should carry suitable clean up equipment, readily available when transferring fuel, with drains and scuppers plugged during that operation to prevent oil entering the water, should a spill take place;

29.7.1.3 The fuel pump should have an emergency shut-down button that is easily accessible from a permanently manned position during fuel transfers;

29.7.1.4 The fuel hose should have a dry break coupling so that NO spillage occurs. The fuel transfer hose should comply with an acceptable standard (see Appendix 13), be bonded and be of a suitable type for the product being transferred, system pressure and height of usage. The hose should be maintained in good condition, and inspected regularly in accordance with the manufacturer’s instructions, or at least annually. Worn or damaged hoses should be replaced;

29.7.1.5 There should be transfer records kept of the fuel transferred providing times, start and finish quantities on board and quantities transferred e.g. by use of a Cargo Records Book (ISBN 978 011 5531576);

29.7.1.6 There should be a full risk assessment carried out for the particular vessel and operation, including but not limited to, the hose not breaking free, pollution, fire safety and training;

29.7.1.7 The cargo pipes, including venting and filling pipes, should comply with section 7.9;

29.7.1.8 Vessels should have procedures covering the loading, discharging and transferring of fuel. The crew should be trained in bunkering and transferring operations which should include safe use of the equipment to minimise fire risks and pollution, appropriate weather windows in which to use the equipment, and use of an up to date Material Safety Data Sheet (MSDS), provided by the fuel supplier which the vessel should carry for the fuel on board;

29.7.1.9 The installation should be examined by the Certifying Authority, including those requirements of 29.4.1 to 29.4.3, 29.5.1 and 29.6, and the vessel’s Workboat Certificate should be endorsed to permit this operation. The endorsement should be reported by the Certifying Authority to the Administration; and

29.7.1.10 For vessels delivering fuel from their own bunker tanks, metering or equivalent arrangements, together with procedures, should be in place to ensure that sufficient fuel remains on board for all normal and emergency operations.

29.7.2 The tank/s should be of suitable design and construction and have protection adequate for the service for which they are intended; construction and fittings should be to an appropriate standard, to the satisfaction of the Certifying Authority. Provision should be made to retain any oil leakage within the confines of the vessels hull to protect persons on board and the marine environment. Tanks should be tested to class standards.

29.7.3 A Stability assessment on the impact of the tanks on the vessels stability should be carried out and the free surface effect considered.

29.7.4 Where a vessel is operating outside of the UK the transfer arrangements carried out according to 29.7 are subject to agreement and any requirements of the Coastal / Port State/s in which the vessel is operating. Section 29.1.7 refers. It will be for each Coastal / Port State to decide whether to accept the Endorsement of the Workboat Code issued by the Certifying Authority.

29.7.5 Action by Certifying Authorities

29.7.5.1 Certifying Authorities are requested to ensure that, where MGO transfers are being undertaken by a coded vessel, the above measures are put in place on the vessel.

29.8 Transfer Arrangements of MGO (UN 1202), other oils (UN 3082) and products posing a risk to the environment (e.g. lubricating oils) in Portable Tanks (greater than 450 litres) or Intermediate Bulk Containers (IBCs) (less than 3000 litres).

29.8.1 When considering proposals for the transport and transfer of MGO, UN1202 and other oils^footnote, UN 3082, and products posing a risk to the environment, in portable tanks or IBCs, the following points should be addressed:

• 1. Portable tanks or IBCs shall meet the constructional requirements of the IMDG Code for the carriage of MGO, UN1202 or oils classified as dangerous goods or products posing a risk to the environment. Portable tanks or IBCs which are intended to be lifted, should comply with the requirements of MSC.1/Circ.860 - GUIDELINES FOR THE APPROVAL OF OFFSHORE CONTAINERS HANDLED IN OPEN SEAS, especially in respect of the lifting arrangements which are subject to additional dynamic forces in the offshore environment, which should be appropriately certificated.

• 2. It should be verified that the intended stowage location is designed for the carriage of cargo and that the loads / point loads are within design limits of the deck. In the absence of such evidence, or the area is not designed for the stowage of cargo, the vessels Certifying Authority should assess that the ships structure can support the weight taking into account the dynamic forces imposed whilst in a seaway and during landing of the tanks units on board.

• 3. Stability – assessment on the impact on vessels stability should be carried out and free surface effect considered.

• 4. “On board” filling of tanks - The filling and transfer arrangements including pipe work, transfer pumps, portable hoses, control of transfer, tank gauging and venting would need to be to the satisfaction of the vessel’s Certifying Authority taking into consideration the following:

  • Flexible Fuel hoses – hoses used for filling tanks shall be approved for such use and suitable stowage provided for both discharge and filling hoses. Refer to 29.7.1.4, see also Appendix 13.
  • Filling arrangements using flexible hose and nozzle / triggers shall be fitted with an automatic shut off function to prevent overfilling / overflow and the tank filling/venting arrangements should be compatible with this functionality. Refer to 29.7.1.4.
  • Tanks in which filling is by other means, should be fitted with continuous level gauging of a type, which if damaged, will not result in leakage.
  • Suitable independent venting arrangements which prevent water ingress may be required depending on the filling arrangements and tank design.
  • Powered pumps used for on board transfer, are to be provided with a remote stop in a suitable location.
  • A Save-all is to be provided around the portable tank and removable connections if filling / refilling is undertaken whist the tank is on board.
  • Tank filling connections etc. which are to be disconnected prior to lifting are to be of a quick release, non drip type.

• 5. The portable tank, IBC and any portable equipment associated with its lifting / securing should be considered as cargo in respect of any limitation applied to the code vessel certification.

  • .1 Satisfactory securing of a portable tank or IBC in its stowage position is to be provided taking into account the forces, directions and accelerations likely to be encountered. Portable lashing equipment if used should be appropriate for the intended purpose. It should be certificated and a procedure for routine verification of its condition be implemented.

  • .2 MGO, UN1202, transfer and lifting procedures to be developed and documented based on the principles of risk assessment which may include checklists. All fuel, and products posing a risk to the environment, transferred to and from the portable tank should be documented in a record book / log book.

  • .3 Emergency response and contingency plans to be developed for spills, fire etc., and

  • .4 For wheelhouse visibility requirements refer to 19.6.

29.8.2 Action by Certifying Authorities

29.8.2.1 Certifying Authorities are requested to ensure that, where these transfers are being undertaken by a coded vessel, the above measures are put in place on the vessel.

29.9 Transfer arrangements for receptacles containing less than 205 kg or 205 litres of dangerous goods

29.9.1 Receptacles should be adequately secured for the expected environment and any lifting to be carried out using appropriate equipment.

29.10 Dangerous Goods Document of Compliance

The following describes the format and criteria for issuing a Document of Compliance for the carriage of Dangerous Goods (DoC DG).

The Certificate should remain valid for a maximum of 5 years and be harmonised with the Workboat Code Certificate or Load Line Exemption Certificate, as appropriate. The conditions on the DoC DG Schedule 2, should be confirmed annually by the Certifying Authority to ensure the vessel remains “Fit for Purpose” and can continue to carry IMDG Code Dangerous Goods in accordance with UK Legislation. This annual inspection should address items such as fire hoses, sprinkler systems and structural arrangements, and subject to the structural and safety systems remain in place and functionally operable (eg 29.4, 29.5 and 29.6 are met) then the DoC DG will remain valid. Where the annual inspections are carried out under MGN 280 this particular DoC DG annual examination shall not be carried out by the owner / managing agent.

Informative Note

UN Hazard Classes

Dangerous Goods are divided into nine United Nations (UN) classes based on the major danger presented by the substance, other risks may be present and these are known as subsidiary risks. The numbering system is not ordered in level of risk.

Owners/managing agents and crew should be aware of the dangerous goods classes. The title of the dangerous good classes is given below – for fuller descriptions the IMDG Code should be consulted.

Class 1 Explosives^footnote(six sub-divisions 1.1, 1.2, 1.3, 1.4, 1.5 and 1.6)

Class 2 Gases

Class 2.1 Flammable gases

Class 2.2 Non-flammable, non-toxic gases Class 2.3 Toxic gases

Class 3 Flammable Liquids

Class 4 Flammable solids; substances liable to spontaneous combustion; substances which, in contact with water emit flammable gases

Class 4.1 Flammable solids

Class 4.2 Substances liable to spontaneous combustion

Class 4.3 Substances which, in contact with water, emit flammable gases Class 5 Oxidising substances and organic peroxides

Class 5.1 Oxidizing substances Class 5.2 Organic peroxides

Class 6 Toxic and infectious substances Class 6.1 Toxic substances

Class 6.2 Infectious substances Class 7 Radioactive material Class 8 Corrosive Substances

Class 9 Miscellaneous dangerous substances and articles

Note :

The term Limited Quantities has a specific meaning within the IMDG Code and refers to the inner receptacle/package and cannot not exceed the size limit set out in Column 7a of the IMDG Code Dangerous Goods List. The term Limited Quantity does not refer to the quantity allowed to be carried on board a ship.

See below for labelling information of the various classes of dangerous goods.

Labels measure 100mm x 100mm

Placards are large labels measuring 250mm x 250mm

Class 1 - Explosive substances or articles

Class 2 - Gases

Class 3 - Flammable liquids

Class 4

Class 5

Class 6

Class 7: Radioactive Material

Table 29.1 IMDG Weatherdeck Stowage Segregation Requirements (see Note 1)

Note1: This Table is included for reference only and should be read in conjunction with the IMDG Code as described in 29.5.2.