The International Maritime Dangerous Goods
(IMDG) Code
The International Maritime Dangerous Goods (IMDG) Code is the definitive
global regulatory framework for the safe transport of hazardous materials by sea in
packaged form. Developed and maintained by the International Maritime
Organization (IMO), a specialized United Nations agency, the Code's fundamental
purpose is to enhance safety, protect human life and property, and prevent marine
pollution. From its inception as a set of recommendations in 1965, the IMDG
Code evolved into a mandatory international standard on 1 January 2004, under
the International Convention for the Safety of Life at Sea (SOLAS) and the
International Convention for the Prevention of Pollution from Ships (MARPOL).
This report provides a comprehensive examination of the IMDG Code. It traces
the Code’s historical development and outlines its core principles, including the
critical shift to a legally binding framework. It details the Code's tripartite
structure, which consists of two main volumes covering the regulatory provisions
and a practical supplement for emergency response. The report explains the
sophisticated classification system, which categorizes dangerous goods by hazard
type and degree of risk. Furthermore, it details the essential documentation,
operational procedures, and duties required of ship crew throughout the loading,
stowage, and transport processes. Finally, it analyzes the latest amendments,
highlighting the Code's dynamic nature and its continuous adaptation to new
technologies and safety concerns. This document serves as an authoritative guide
for all stakeholders involved in the maritime logistics chain.
1. Foundational Principles and Historical Context of the IMDG Code
1.1 The Genesis of a Global Standard
The genesis of the IMDG Code is rooted in the early 20th century, encouraged by a
recognized need for international uniformity in maritime safety regulations.
Following significant maritime disasters, the International Conferences on Safety
of Life at Sea (SOLAS) in 1929 and 1948 identified the need for a standardized
approach to the sea transport of dangerous goods. These early conferences
recommended further study to develop international regulations on the subject. By
the 1960s, the rapid expansion of chemical manufacturing and the consequent
increase in the sea transport of hazardous materials underscored the urgency for a
uniform set of guidelines.
In response to this growing need, a working group of the Maritime Safety
Committee (MSC) of the IMO began preparing the Code in 1961. The
development was undertaken in close cooperation with the United Nations
Committee of Experts on the Transport of Dangerous Goods, which had already
established a foundational set of recommendations for dangerous goods transport
across all modes, including air, road, and rail. This collaboration was pivotal, as it
ensured that the IMDG Code was aligned with existing multimodal transport
regulations, thereby promoting a cohesive and harmonious global framework. The
IMO officially adopted the IMDG Code in 1965.
1.2 Core Objectives and Principles
CORE OBJECTIVES OF THE IMDG CODE
To ensure the safe carriage of dangerous goods by sea in packaged form by
laying down internationally accepted technical and operational requirements.
To protect human life, including ship’s crew, passengers, shore personnel, and
emergency responders, from hazards associated with dangerous goods.
To ensure the safety of ships and property by preventing fires, explosions, toxic
releases, corrosion, and other accidents caused by dangerous cargoes.
To prevent marine pollution, particularly from substances classified as marine
pollutants, in coordination with the objectives of the MARPOL Convention.
To establish uniform international regulations, eliminating differences between
national rules and ensuring global acceptability of dangerous goods shipments.
To facilitate safe and efficient international trade, allowing the free movement
of dangerous goods without compromising safety or environmental protection.
To define legal responsibilities of shippers, carriers, Masters, officers, and crew
involved in the transport of dangerous goods.
To provide a mandatory regulatory framework under SOLAS Chapter VII,
enabling effective enforcement by Flag States and Port State Control.
CORE PRINCIPLES OF THE IMDG CODE
Hazard Identification and Classification Principle
Dangerous goods must be correctly classified according to their type of hazard
(Classes 1 to 9) and degree of danger (Packing Groups I, II, III), forming the
basis for all safety measures.
Risk-Based Safety Principle
Safety requirements are applied proportionately to the level of risk, ensuring
higher-risk substances are subject to stricter controls.
Approved Packaging Principle
Dangerous goods must be packed in approved, tested, and certified packagings
capable of withstanding the normal conditions of sea transport.
Hazard Communication Principle
Proper marking, labeling, and placarding must be used so that hazards are
clearly and continuously identifiable throughout the voyage.
Stowage and Segregation Principle
Dangerous goods must be correctly stowed and segregated to prevent
incompatible substances from reacting and to minimize escalation in case of
leakage or fire.
Documentation and Traceability Principle
Accurate and complete dangerous goods documentation is essential to ensure
traceability, accountability, and safe planning of cargo operations.
Operational Control and Responsibility Principle
The Master has overall responsibility for the safe acceptance, stowage, and
carriage of dangerous goods, regardless of shipper declarations.
Emergency Preparedness Principle
The Code provides EmS, MFAG, and reporting procedures to ensure effective
response to fires, spillages, and exposure incidents.
Training and Competence Principle
All personnel involved in the transport of dangerous goods must be properly
trained, recognizing human error as a major risk factor.
International Uniformity Principle
The IMDG Code ensures consistent global application, enabling ships to
operate safely across all ports and jurisdictions.
2. The Structure and Components of the IMDG Code
The IMDG Code is structured as a comprehensive, multi-volume document designed
to provide
all necessary information for the safe handling and transport of dangerous goods.
The Code is composed of two volumes and a supplemental publication, each
serving a distinct but interconnected purpose. This tripartite structure was
implemented in a 1996 reformatting effort to improve readability and user-
friendliness, aligning its format with the UN Recommendations on the Transport
of Dangerous Goods.
2.1 Volume 1: The Regulatory Core
Volume 1 contains the core regulatory provisions and detailed instructions for
preparing and transporting dangerous goods. It is composed of Parts 1, 2, and 4
through 7. This volume serves as the primary manual for shippers, packers, and
regulators to understand the foundational rules of the Code.
● Part 1 - General Provisions, Definitions, and Training: This part
establishes the general application of the Code, defines key terminology, and
outlines mandatory training requirements for all personnel involved in the
dangerous goods supply chain, from manufacturers to mariners.
● Part 2 - Classification: This section provides the detailed criteria and
principles for classifying dangerous substances and articles into their
respective hazard classes and divisions. It is the basis for all subsequent
safety procedures.
● Part 4 - Packing and Tank Provisions: This part specifies the technical
requirements for packagings and tanks used to transport dangerous goods,
including new packing instructions.
● Part 5 - Consignment Procedures: This section outlines the crucial steps for
preparing a dangerous goods consignment, including the requirements for
documentation, marking, labeling, and placarding of packages and cargo
transport units.
● Part 6 - Construction and Testing of Packagings, IBCs, Large
Packagings, Portable Tanks, and Road Tank Vehicles: This section
details the standards for the construction and testing of various types of
containers to ensure their durability and safety during transport.
● Part 7 - Provisions Concerning Transport Operations: This critical
section for mariners and operators covers the on-board procedures for safe
transport, including stowage and segregation.
2.2 Volume 2: The Practical Compendium
Volume 2 of the IMDG Code contains the Dangerous Goods List (DGL), which is
found in Part 3 of the Code. This volume is the central reference tool for
identifying specific dangerous goods and the corresponding transport requirements.
The DGL is an index of dangerous substances and articles, organized
numerically by their four-digit UN number. For each substance, the list
provides a two-page spread of information
across 18 columns, detailing essential transport information in a coded format. This
includes the proper shipping name, class or division, subsidiary risks, packing
group, and specific guidance on packing, stowage, and segregation.
Volume 2 also contains provisions for limited quantities and excepted quantities.
These provisions allow for less stringent transport requirements for dangerous
goods shipped in sufficiently small amounts that they do not present the same level
of hazard as larger consignments. The volume is rounded out by an index and
appendices, providing a
comprehensive database for dangerous goods identification.
2.3 The IMDG Code Supplement: The Emergency Toolkit
The IMDG Code Supplement is a separate publication that contains a collection of
critical texts related to the Code. Its primary purpose is to provide guidance for
fires and spillage emergencies on board a ship, enabling the master and crew to
respond without external assistance. This publication provides the crucial "what-
if" information, complementing the regulatory and informational content of the
two main volumes.
The Supplement includes the following key texts:
● The EmS Guide (Emergency Response Procedures for Ships Carrying
Dangerous Goods): This guide provides schedules and detailed procedures
for dealing with fires and spillages involving dangerous goods on board
ships. Its procedures are distinct for
on-deck and under-deck stowage, and it is designed to be integrated into a ship's
Safety Management System and emergency plan.
● The MFAG (Medical First Aid Guide): This guide offers essential first aid
advice for use in accidents involving dangerous goods, ensuring that crew
members are prepared to treat injuries related to exposure to hazardous
materials.
● Reporting Procedures: The Supplement contains descriptions of the
procedures for reporting incidents involving dangerous goods, harmful
substances, and/or marine pollutants to the nearest coastal state.
● The INF Code: This is the International Code for the Safe Carriage of
Packaged Irradiated Nuclear Fuel, Plutonium, and High-Level Radioactive
Wastes on board Ships, a specialized text included for cargoes of Class 7.
The entire structure of the IMDG Code, spanning two volumes and a supplement,
reflects a deliberate design to make complex information accessible to different
stakeholders. Volume 1 provides the foundational rules for those who prepare the
cargo, Volume 2 offers a practical reference list for identifying specific substances,
and the Supplement provides an essential toolkit for emergency response. This
modular approach is designed to be user-friendly and highly effective in a real-
world operational environment.
3. Classification and Hazard Assessment of Dangerous
Goods
3.1 Principles of Classification
For the purposes of the IMDG Code, dangerous goods are substances or articles
that pose a threat to people, property, or the environment during sea transport. The
classification system is the foundation upon which all other regulations in the Code
are built. Its purpose is to distinguish between dangerous and non-dangerous goods
and to identify the primary hazard or hazards a substance presents. This process
determines the safe transport procedures, including how the substance must be
packed, labeled, and stowed on board the vessel.
3.2 The Nine Dangerous Cargo Classes
The IMDG Code classifies dangerous goods into nine main classes, some of which are
further
subdivided to provide a more specific description of the hazard. The numerical
order of the classes and divisions is important for identification, but it does not
correspond to the degree of danger. The nine classes are as follows:
Class Name Primary Hazard and Examples
Subdivisions
1 Explosives Mass explosion TNT,
hazard (1.1), dynamite,
projection hazard fireworks
(1.2), fire hazard
with minor
blast/projection
(1.3), minor
explosion
hazard (1.4), very
insensitive (1.5),
extremely
insensitive (1.6)
2 Gases Flammable (2.1), Propane,
non-flammable oxygen,
and non-toxic chlorine,
(2.2), toxic aerosols
(2.3)
3 Flammable Liquids that can Gasoline,
Liquids easily ignite and acetone,
give off flammable kerosene
vapors.
Subdivisions based
on
flashpoint
4 Flammable Solids Flammable solids Matches,
(4.1), spontaneously phosphorus,
combustible sodium batteries
substances (4.2),
substances that emit
flammable gases
when in contact
with water
(4.3)
5 Oxidizing Oxidizing Hydrogen
Substances & substances (5.1), peroxide,
Organic Peroxides organic peroxides ammonium
(5.2) nitrate
6 Toxic & Toxic substances Cyanide,
Infectious (6.1), infectious arsenic,
Substances substances viruses,
(6.2) bacteria,
clinical waste
7 Radioactive Substances that emit Smoke
Material invisible ionizing detectors,
radiation depleted
uranium
8 Corrosive Substances that Sulfuric acid,
Substances cause irreversible battery fluid
damage to living
tissue or corrode
materials
9 Miscellaneous Substances and Environmentally
Dangerous articles presenting a hazardous
substances,
Class Name Primary Hazard and Examples
Subdivisions
Substances danger not covered lithium batteries,
by other classes dry ice
3.3 The Degree of Danger: Packing Groups
A unique aspect of the IMDG classification system is the use of packing groups to
assess the degree of danger. While the class or division identifies the type of
hazard, the packing group specifies the level of that hazard. This is a crucial
distinction that provides a more granular approach to safety regulation. Substances
from most classes, except for classes 1, 2, 5.2, 6.2, and 7, are assigned to one of
three packing groups.
Packing Group Degree of Danger
Packing Group I High Danger
Packing Group II Medium Danger
Packing Group III Low Danger
The packing group directly influences the required packaging and transport
procedures. For example, a substance in Packing Group I (high danger) will
require more protective packaging than a similar substance in Packing Group III
(low danger). This two-tiered system ensures that safety measures are proportional
to the actual risk posed by the cargo. The packing group for a given substance is
specified in the Dangerous Goods List in Volume 2 of the Code. This approach
allows for optimal safety without implementing overly strict regulations for all
substances within a broad hazard class.
3.4 Key Definitions and Terminology
A precise understanding of the Code's terminology is essential for compliance.
Some key definitions include:
● Dangerous Goods: Defined as substances and articles that pose a threat to
life, health, or the environment due to their properties and condition during
sea transport.
● Hazard: The intrinsic property of a substance or article that can lead to
danger in the transport environment, such as flammability, corrosivity, or
toxicity.
● Marine Pollutant: A substance identified in the Code as having the
potential to be harmful to the marine environment if released. These are
indicated with a special symbol in the Dangerous Goods List.
● Weathering Certificate (BS5609 Certification): A critical requirement for
the labeling of certain dangerous goods, particularly chemicals exported by
ocean freight. British Standard BS5609 certification ensures that the labels
and their adhesive can withstand a three-month saltwater submersion test and
artificial weathering, including exposure to salt spray and sunlight.
The requirement for a weathering certificate is a strong example of how the
Code's provisions go beyond simple instructions to address real-world operational
challenges. Proper hazard communication is meaningless if the label cannot
survive the harsh marine environment. By mandating a specific durability
standard for labels, the Code ensures that critical safety
information remains visible and legible for the duration of the voyage, enabling
crew members and emergency responders to correctly identify the cargo and its
hazards in an incident. This requirement closes a potential safety gap, ensuring that
a procedural check-box is linked to a practical, life-saving purpose.
4. Operational Procedures: Documentation, Packaging, and
Stowage
4.1 Required Documentation
The transport of dangerous goods by sea requires a clear and robust system of
documentation to ensure accountability and to provide critical information to all
stakeholders in the logistics chain. The following documents are mandatory for
compliance with the IMDG Code:
<br>
Document Name Purpose Responsible Party
Dangerous A legal requirement from Consignor/Shipper
Goods the consignor that
identifies the dangerous
Declaration goods and their hazards. It
(DGD) includes the UN number,
proper shipping name,
class, packing group,
quantity, and other key
details. It may incorporate
the Container Packing
Certificate.
Container Packing Certifies that the goods Shipper
Certificate were packed correctly and
are
suitable for transport by
sea.
Dangerous Goods A document prepared by Carrier/Ship
Manifest the carrier that lists all
dangerous goods on board
and their specific stowage
location. It is a critical
operational tool for the
crew.
Dangerous Goods A statutory certificate Flag State Administration
issued by the flag
Document of Compliance administration as evidence state
(DGDoC) that the ship has been
surveyed and found
compliant with the
construction and
equipment requirements of
the SOLAS Convention for
the carriage of dangerous
goods.
A copy of the IMDG All vessels carrying Carrier/Ship
Code dangerous goods must
carry a current copy of the
Code for reference.
This documentation process is not a redundancy but a system of checks and balances
that
ensures a seamless flow of information from the point of origin to the final
destination. The Dangerous Goods Declaration, initiated by the shipper, contains
all of the information needed for the carrier to verify the consignment and for the
crew to create a precise stowage plan. This chain of custody ensures that the
information is correctly transferred and translated into safe physical practice on
the vessel, minimizing the risk of incidents and ensuring legal compliance.
4.2 Packaging and Stowage Principles
The IMDG Code lays down strict criteria for the packaging and stowage of
dangerous goods to ensure they are handled and transported safely. The consignor
is responsible for ensuring that goods are classified and packed in a manner that is
sufficiently sturdy to withstand the normal risks of sea transport, such as handling
and movement.
The principles of stowage and segregation are paramount to the Code's
operational guidelines. Stowage refers to the placement of cargo on board the
ship. All cargo must be stowed and secured to prevent any movement during
transport that could compromise the ship's stability or cause damage. The Master
of the vessel retains overall responsibility for the safe stowage of all cargo, with
the Chief Officer typically delegating supervision.
Segregation involves keeping incompatible dangerous goods apart to prevent
dangerous reactions in the event of a leak, spillage, or accident. The Code provides
detailed segregation tables that specify the minimum required separation between
different hazard classes. This can range from "Away from" (a minimum of 3
meters horizontal separation) to "Separated longitudinally by a complete
compartment" (a minimum of 24 meters separation). The Code also provides
specific guidance on ventilation for volatile substances and requires that
temperature thresholds be considered during stowage planning. The mandatory
separation and stowage rules prevent hazardous interactions and are a core pillar of
the Code's preventative safety philosophy.
5. Duties and Responsibilities of Ship Crew
5.1 Pre-Loading Duties
The duties of a ship's crew in relation to dangerous goods commence well before
the cargo is loaded. Crew members, particularly the Master and Chief Officer,
have the responsibility to ensure that the cargo is fit for transport. This includes
inspecting the cargo transport units for any damage or signs of leakage. Critically,
the crew must verify all required documentation provided by the shipper, such as
the Dangerous Goods Declaration and Container Packing Certificate, to confirm
that the goods have been correctly classified, packaged, and labeled.
Personnel involved in handling these goods must have the necessary training and
hold a valid IMDG certification.
5.2 Loading and Stowage Duties
During the loading process, the crew’s main responsibility is to ensure the safe and
proper placement of all dangerous goods on board the vessel. The Chief Officer is
typically responsible for supervising this process to ensure that the cargo is evenly
distributed to maintain the ship's general stability and that the ship itself is not
imperiled.
Key duties during this phase include:
● Segregation: The crew must strictly adhere to the segregation requirements
of the IMDG Code, ensuring that incompatible goods are kept apart as
specified in the dangerous goods manifest and the Code’s tables.
● Stowage and Securing: All dangerous goods and other cargo must be
securely fixed within the cargo transport units and the ship itself to
prevent any movement that could lead to an accident. Proper planning of
the load, including vertical and horizontal separation, is essential.
● Ventilation: For substances that may emit flammable or toxic vapors, the
crew must ensure that proper ventilation is maintained to prevent the
accumulation of hazardous gases.
5.3 In-Transit Duties
The crew’s responsibilities extend throughout the voyage. The Master and his
officers are tasked with the ongoing monitoring of the cargo to detect any signs of
leakage, spillage, or other incidents. In the event of a fire or spillage, the crew is
expected to take immediate action based on the shipboard emergency plan, which
is guided by the EmS Guide found in the IMDG Code Supplement.
The crew must be prepared to implement specific firefighting procedures
depending on whether the dangerous goods are stowed on or under deck. The
Supplement also provides the MFAG to guide medical first aid for any personnel
involved in an accident. It is the crew’s duty to ensure that all safety procedures,
including the use of appropriate protective clothing and self-contained breathing
apparatus, are followed. International and national requirements also mandate that
the crew contact and report incidents to the nearest coastal state.
5.4 Training and Certification
The IMDG Code mandates that all employees who handle, offer for transport, or
transport dangerous goods internationally must be trained and certified. This is
not an optional measure; it is a legal and operational necessity. Training covers a
wide range of topics, including classification, proper shipping names, packing,
labeling, placarding, documentation, and emergency response. This formal
training ensures that personnel are equipped with the knowledge and skills
necessary to navigate the complexities of the Code and perform their duties
safely, thereby mitigating the risk of incidents caused by human error or
negligence.
6. Latest Amendments to the IMDG Code
6.1 Official Status, Adoption & Applicability
The latest amendment to the International Maritime Dangerous Goods (IMDG)
Code is Amendment 42-24, incorporated in the 2024 Edition of the Code.
42-24 means:
42 → the 42nd amendment to the IMDG Code
24 → the year 2024, in which this amendment was adopted
Therefore, Amendment 42-24 is the 42nd set of changes adopted to
update the IMDG Code in 2024.
Amendment 42-24 was adopted by the IMO Maritime Safety Committee
(MSC) at its 108th session in May 2024, in accordance with the IMDG Code’s
biennial amendment cycle.
Applicability dates:
o Voluntary application: from 1 January 2025
o Mandatory compliance: from 1 January 2026
o From 1 January 2026, Amendment 41-22 ceases to be acceptable for
statutory compliance under SOLAS Chapter VII.
During calendar year 2025 i.e. Transitional Phase, either 41-22 or 42-24 may be
applied, subject to Flag State and Port State acceptance.
6.2. Objective of Amendment 42-24
The primary objective of Amendment 42-24 is to enhance fire prevention,
improve hazard identification, regulate emerging battery technologies, remove
unsafe exemptions, and strengthen documentation traceability in the carriage of
dangerous goods by sea.
6.3. Introduction of New Un Numbers
Amendment 42-24 introduces new UN entries to address modern cargoes and
technologies, notably:
Sodium-ion batteries, including:
o Sodium-ion batteries
o Sodium-ion battery-powered vehicles
o Battery-powered machinery and equipment using sodium-ion technology
Fire-suppressant devices, now formally classified as dangerous goods with
dedicated UN numbers.
These additions reflect the IMO’s recognition that new energy storage systems
present different thermal and chemical hazards compared to lithium-ion
batteries, requiring explicit regulation.
6.4. Major Changes to Carbon & Charcoal Cargoes
Amendment 42-24 makes significant changes to the carriage of carbon-based
cargoes, which have been historically linked to container fires and self-heating
incidents.
Carbon – UN 1361
Special Provision SP925 has been deleted.
As a result:
o Carbon cargoes can no longer claim exemption from IMDG compliance.
o Full compliance with classification, documentation, marking, labeling,
stowage, and segregation is now mandatory.
Activated Carbon – UN 1362
Documentation requirements have been enhanced.
Shippers must now declare:
o Date of production
o Temperature of cargo at the time of packing
This amendment directly addresses the risk of self-heating and delayed ignition
during sea transport.
6.5. Battery-Related Safety Enhancements
Amendment 42-24 further tightens controls on battery cargoes, a leading cause
of container ship fires.
Lithium Battery Modules – UN 3536
Under-deck stowage is now prohibited.
These cargoes are restricted to on-deck stowage only, due to:
o Improved fire detection
o Easier access for firefighting
o Reduced escalation risk
Labeling Changes
The existing “Lithium Battery Class 9 label” has been renamed to:
o “Lithium or Sodium Ion Battery Class 9 Label”
The corresponding battery mark has also been renamed to reflect sodium-ion
inclusion.
6.6. Documentation & Declaration Requirements
Amendment 42-24 strengthens documentation accuracy and traceability.
For certain cargoes, dangerous goods documentation must now include:
o Production or manufacturing date
o Temperature at time of packing
o Confirmation of compliance with updated packing instructions
Incorrect, incomplete, or outdated documentation is treated as non-compliance,
even if the cargo itself is physically safe.
This significantly increases the legal responsibility of shippers and carriers.
6.7. Packaging & Degree of Filling
Amendment 42-24 introduces a formal definition of “degree of filling”.
Revised packing provisions aim to:
o Prevent overfilling of liquid packagings
o Allow for thermal expansion during voyage
o Reduce leakage and package rupture
These provisions ensure uniform interpretation during PSC inspections.
6.8 Stowage & Segregation Revisions
Certain stowage categories and segregation codes have been revised to:
o Increase separation distances
o Prevent incompatible cargo interaction
o Reduce fire escalation potential
Segregation code SG75 has been removed to eliminate ambiguity.
Greater clarity is provided on:
o Vertical segregation
o On-deck versus under-deck stowage
o Ventilation requirements for volatile cargoes
6.9. Impact on Ship Operations & PSC
From 1 January 2026, PSC officers will:
o Enforce Amendment 42-24 strictly
o Treat non-compliance as a detainable deficiency
Ships must ensure:
o IMDG Code on board is updated to 42-24
o DG training reflects latest amendments
o SMS procedures incorporate revised DG controls
The Master remains ultimately responsible for acceptance, stowage, and safe
carriage of dangerous goods.