Bulletin No.: 07/1999

Date (Y-M-D): 1999-05-31

Subject: Hazards Associated with Imported Cargo Transport Units Containing Fumigant Gas

Recent information has indicated that Cargo Transport Units (CTU) unloaded in Canadian ports were under fumigation but not declared as such. This Bulletin draws attention to the fact that CTUs containing cargo under fumigation are regulated under the International Maritime Dangerous Goods Code (IMDG Code) provisions when carried by ship. The master should be informed prior to loading of any CTU with fumigant remaining in it.

Agents, shippers, terminal operators and ship owners are therefore, required to adhere to the provisions of the IMDG Code when shipping CTUs containing cargo under fumigation to Canada.

This Bulletin further draws attention to the following information for anyone preparing entry into CTUs' (containers). It has come to our attention that there have been occurrences of fumigant gas residues remaining at above minimum safe levels, inside containers, during transit and shipment and this may pose a serious hazard to health and safety. Some have been found to contain up to 10 times the maximum safety level (TLV 3 ppm for Methyl bromide).

There have been concerns about possible risk of infestation from insects (such as the Asian Long Horn Beetle) contained in non manufactured wood products, including dunnage and wood used to secure and stow cargo inside the containers. Consequently, there has been an increase in the fumigation of such materials whilst inside the container. Such treatment may be required under Canada's Plant Protection Act and Regulations. Fumigants are used where contact insecticides will not give control. Containers treated with fumigants and aerated in a proper manner should pose little risk. There is the possibility of residues remaining from improper aeration procedures or desorbtion of gas from the treated material and this could, over time, bring fumigant gas levels back up to hazardous levels.

Some containers may also be fumigated but not aerated before shipment and these must be considered as Class 9 Dangerous Goods and be accompanied by proper documentation and placarded with the prescribed warning labels under International Maritime Organization (IMO) IMDG Code requirements as per the attached. Further information can also be obtained from IMO "Recommendations on the Safe Use of Pesticides in Ships, part 3.5."

Anyone wishing to comment on the foregoing, or wishing to forward information of known or suspected fumigation cases, or improperly placarded and documented containers undergoing fumigation is requested to forward such information to the nearest Marine Safety Office or to the address below. It is requested that wide distribution is given to this Bulletin for information purposes.

CLASS 9 - Miscellaneous dangerous substances & articles

CARGO TRANSPORT UNIT UNDER FUMIGATION CONTAINER UNDER FUMIGATION

Fumigation Warning sign
NO CLASS 9 LABEL REQUIRED

UN NO. FormulaProperties
A closed cargo transport unit loaded with cargoes under fumigation. The fumigant gases are either poisonous or asphyxiant. The gases are evolved from solid or liquid preparations distributed within the closed cargo transport unit.

Observations

Reference is made to the IMO/ILO/ECE Guidelines for Packing of Cargo Transport Units (CTUs) and the Recommendations on the Safe Use of Pesticides in Ships. Only a cargo transport unit that can be closed in such a way that the escape of gas is reduced to a minimum should be used for the carriage of fumigated cargo. A closed cargo transport unit containing cargo under fumigation should not be allowed on board until sufficient time has elapsed to allow the attainment of a reasonably uniform gas concentration throughout the cargo. Because of variations due to types and amounts of fumigants and commodities and temperature levels, the period which should elapsed between fumigant application and loading should be determined by the competent authority. determined by the competent authority.

Twenty-four hours is normally adequate for this purpose. The master should be informed prior to loading of a cargo transport unit under fumigation. These should be identified with a warning sign affixed to the access door (s) incorporating the identity of the fumigant used.

Equipment for detecting the fumigant gas or gases should be carried on the ship, with the instruction for its use.

The provisions of this Code should not apply to a closed cargo transport unit which has been ventilated after fumigation to ensure that no harmful concentrations of gas remain. Such a unit should also have the warning sign (s) removed.

Fumigants should not be applied to the contents of a cargo transport unit once it has been loaded aboard a ship.

Stowage
Category B
Clear of living quarters.

Packing, Stowage & Segregation
See also General Introduction and Introduction to this class.

IMDG CODE - PAGE 9025-1 (page 9025 follows)
Amdt. 29-98 (page 9025 follows)
Amdt. 29-98

To add or change your address, contact us at: marinesafety@tc.gc.ca

Owners of commercial vessels, registered and licensed, automatically receive Bulletins.