Vehicles with combustion engines to be shipped as Hazardous cargo

Vehicles with combustion engines to be shipped as Hazardous cargo

It has been advised that as per IMDG Code Amendment 35, effective 1st January 2012, all equipment fitted with an internal combustion engine will fall within the scope of the IMDG Code and must be notified to carriers as dangerous goods, UN 3166, Class 9.. A dangerous goods declaration and document will be required to be submitted to the carrier and/or the master of the ship.. You can download the “generic” format of dangerous goods packing declaration here.. Remember that each shipping line has their own format of packing declaration..

As per UN 3166 items that are included but not restricted to, may be cars, vehicles, plant, boats or any equipment with an internal combustion engine.. These could be equipment that has either a connected battery or a fuel tank containing flammable liquid (petrol or diesel) or flammable gas..

Special Provision 961 describes technical measures that can be taken to neutralise the hazard of fuel and batteries and allow the articles to be consigned as non-hazardous, but that involves isolating the battery and removing the fuel from the tanks which could be quite a task, but can be done if the shipper wishes to ship it as a non-hazardous cargo..

Below is what the Special Provisions 312, 356, 961 and 962 from the IMDG Code Amendment 35 and the Dangerous Goods List say about the new ruling..

Observation from Dangerous Goods List Entry – UN 3166

“Types of articles transported under this entry include internal combustion engines,
compression/ignition engines, fuel cell powered engines, motor vehicles, hybrid
vehicles, motorcycles and boats.”

Special Provision 312:

“Vehicles or machinery powered by a fuel cell engine shall be consigned under the entries:

  • UN 3166, VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED, or
  • UN 3166, VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED, or
  • UN 3166, ENGINE, FUEL CELL, FLAMMABLE GAS POWERED, or
  • UN 3166, ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED, as appropriate.

These entries include hybrid engine vehicles powered by both a fuel cell and an internal combustion engine and wet batteries, sodium batteries or lithium batteries, transported with the batteries installed. Other vehicles which contain an internal combustion engine shall be consigned under the entries:

  • UN 3166, VEHICLE, FLAMMABLE GAS POWERED, or
  • UN 3166, VEHICLE, FLAMMABLE LIQUID POWERED, as appropriate.

These entries include hybrid electric vehicle powered by both an internal combustion engine and wet batteries, sodium batteries or lithium batteries, transported with the batteries installed.”

Special Provision 356:

“Metal hydride storage systems installed in conveyances or in completed conveyance components or intended to be installed in conveyances shall be approved by the competent authority before acceptance for transport. The transport document shall include an indication that the package was approved by the competent authority or a copy of the competent authority approval shall accompany each consignment.”

Special Provision 962:

Vehicles or equipment powered by internal combustion engines, fuel cells or batteries not meeting the conditions of Special Provision 961 shall be assigned to Class 9 and shall meet the following requirements:

  1. Vehicles and equipment shall not show signs of leakage from batteries, fuel cells, compressed gas cylinders or accumulators, or fuel tank(s) when applicable;
  2. For flammable liquid powered engines and equipment, the fuel tank(s) containing the flammable liquid shall not be more than one fourth full and in any case the flammable liquid shall not exceed 250 litres;
  3. For flammable gas powered vehicles and equipment, the fuel shut-off valve of the fuel tank(s) shall be securely closed;
  4. Installed batteries shall be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries shall meet the requirements of the United Nations Manual of Tests & Criteria, part III, subsection 38.3, unless otherwise approved by the competent authority; and
  5. Dangerous goods required for the operation of the vehicle or equipment such as fire extinguishers, compressed gas accumulators, airbag inflators, etc., shall be securely mounted in the vehicle or equipment.

The marking, labelling and placarding requirements provisions of this Code shall not apply.

Special Provision 961:

“Vehicles and equipment are not subject to the provisions of this Code (IMDG Code Amndt. 35) if they are stowed on a roll-on/roll-off ship or in another cargo space designated by the Administration (flag state) as specifically designed and approved for the carriage of vehicles and equipment and there are no signs of leakage from the battery, engine, fuel cell, compressed gas cylinder or accumulator, or fuel tank when applicable.

In addition, vehicles and equipment are not subject to the provisions of this Code if any of the following conditions are met:

  1. The fuel tank(s) of the vehicle or equipment powered by a flammable liquid fuel is empty and installed batteries are protected from short circuit;
  2. The fuel tank(s) of the vehicle or equipment powered by a flammable gas is emptied of liquefied or compressed gas and the, the positive pressure in the tank does not exceed 2 bar, the fuel shut-off or isolation valve is closed and secured, and installed batteries are protected from short circuit; or
  3. The vehicle or equipment is solely powered by a wet or dry storage battery or a sodium battery, and the battery is protected from short circuit.”

Also refer to my previous articles on the details of hazardous cargoes, the process of hazardous cargo acceptance and shipment and Undeclared hazardous cargo and its consequences..

What did you think of the above article..?? Comment below..

15 comments on “Vehicles with combustion engines to be shipped as Hazardous cargo

  1. Paul Davidson says:

    Great article. Thanks for the info, you made it easy to understand. BTW, if anyone needs to fill out a Dangerous Goods Declaration form, I found a blank template form here http://goo.gl/YCVQy3. This site also has some tutorials on how to fill it out and a few related Dangerous Goods Declaration template that you might find useul.

  2. Tom says:

    Under SP962, the statement “The marking, labelling and placarding requirements provisions of this Code shall not apply.” is incomplete, therefore misleading. IAW the Environmental Resource Center, the complete statement should read “Marks, labels, and placards are not required; however, other requirements such as shipping papers and IMDG training are required.”

  3. This was really useful. Gave me EXACTLY the information I was looking for.

  4. Sapoty Brook says:

    I note that SP 961 [3] relates to batteries in equipment as well as in vehicles. The lithium battery cells for my electric bikes are encased in an extruded aluminium outer case with substantial plastic end caps with a key switch and fuses. The terminals are deep inside two holes in the bottom plastic cap. There is also a battery managment system [BMS] circuit board and internal plastic frame supporting the cells and BMS. It is not possible for voltage to appear on the terminals unless the key is inserted in the lock and switched on.

    I think it would be reasonable to say that this is a battery installed in a power supply equipment and it is well protected from short circuit. Therefore this power supply equipment conforms to SP 961 [3] and would not be classed as DG.

    Would you be in agreement with that?

    1. Manaadiar says:

      Hi Sapoty, i would assume considering the safety around the battery this could be considered as Non-Haz.. However, best option would be to see if the manufacturer has any MSDS for these batteries and send that to the shipping line/vessel operator and get their confirmation.. The classification really depends on each shipping line..

  5. Sapoty Brook says:

    My Forwarder in China told us:

    “Ningbo ship company told us that Must provide the ‘Certification for Safe Transport of Chemical Goods’ and ‘ MSDS ‘ if the electric bikes with battery installed.”

    The lithium ion batteries are installed and have a fuse and key switch and strong case to protect from short circuit. So according to the provision below do you agree that the electric bikes do not require the above documentation?

    Special Provision 961:
    3. The vehicle or equipment is solely powered by a wet or dry storage battery or a sodium battery, and the battery is protected from short circuit.”

    1. Manaadiar says:

      Hi Sapoty, according to the Special Provision 961 – you are covered and do not need to declare your bike as a hazardous cargo..

  6. nice post . Thanks for sharing with us .

  7. Natalie Wu says:

    Hi what about engine itself? if shipping by sea, does that make it a UN3166 or meet SP?

  8. farooq525 says:

    Hi Manaadiar , Kindly advise Packing code / Packing group for new UN NO: 3166

  9. manaadiar says:

    Hi Kelvin, in the past, fuel in vehicles was not categorised as DG and various carriers had their own regulations on how vehicles with fuel were shipped.. Now it has become a mandatory regulation set by the IMDG and it has been ruled accordingly..

    1. Ankit says:

      Hey, just wanted to confirm whether a car stowed on a Ro-Ro ship with 1 litre fuel in it will be a DG and will IMDG be applicable to it?

    2. Hi Ankit, if your read the article carefully, you will see that special provisions are made for cars on RORO ships

      Special Provision 961:

      Vehicles and equipment are not subject to the provisions of this Code (IMDG Code Amndt. 35) if they are stowed on a roll-on/roll-off ship or in another cargo space designated by the Administration (flag state) as specifically designed and approved for the carriage of vehicles and equipment and there are no signs of leakage from the battery, engine, fuel cell, compressed gas cylinder or accumulator, or fuel tank when applicable.

    3. Ankit says:

      Hey Hareish, thanx for the reply. Yes i read that but there was a bit confusion as this question has been asked for our competency exams, thanks for clearing my doubt….

(Estimated reading time: 4 minutes)
You may also like :