The 1,180 GT coaster on a domestic run
The general cargo ship Rivermouth Trader (1,180 GT) is loading at an inland river terminal for a voyage that stays entirely inside one country's territorial waters. The booking covers 60 steel drums of UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. (paint additive), 200 L each, and 22 pallets of UN 1263 PAINT, Class 3, PG II, in 20 L pails. The terminal's dangerous goods clerk tells the master that neither the IMDG Code nor any dangerous goods documentation applies: the voyage is domestic, the ship is under 3,000 GT, and the drums are "just paint additives". The master is also told that the shipper's agent will "sign the papers at the destination". Nothing has been classified beyond the supplier's safety data sheet, which describes the additive as "harmful to aquatic life with long lasting effects" and gives no other environmental data.
1. Does the IMDG Code apply to this loading? Explain the basis for your answer and deal with the additive's environmental wording.
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Yes. The Code is made mandatory through SOLAS chapter VII (regulations 1, 3 and 5) for the carriage of dangerous goods in packaged form, and through MARPOL Annex III for marine pollutants. Neither instrument contains a tonnage threshold, and the Code itself does not distinguish domestic from international voyages - that distinction belongs to the flag Administration, which may grant exemptions under the SOLAS framework. A terminal clerk cannot create one, and a ship cannot assume one exists without a documented exemption.
On the additive: the phrase "harmful to aquatic life with long lasting effects" is a GHS chronic-hazard signal, not a marine pollutant classification. Marine pollutant status is decided against the criteria in the Code's environmental hazard provisions (acute/chronic aquatic toxicity data, or the substance being listed in the Dangerous Goods List). If the criteria are met, the consignment must be classified and documented as MARINE POLLUTANT, carry the marine pollutant mark, and fall under MARPOL Annex III as well as the Code. So both consignments are in scope until the science says otherwise.
2. Who is responsible for classification and documentation here, and what should the master and the carrier's booking staff do before loading?
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The consignor (shipper) owns the classification, packing, marking, labelling, placarding and documentation duties, and must sign the dangerous goods declaration. A declaration signed by an agent "at the destination" is worthless: the document must reach the carrier before loading and travel with the consignment, because the ship and the terminal need the information to stow, segregate, fight a fire and report an incident.
The carrier's booking staff must refuse to accept goods without a complete, signed declaration and the corresponding container/vehicle packing certificate. The master retains the authority - and the duty - to refuse cargo that is not properly declared, since the safety of the ship is his responsibility and SOLAS puts the compliance obligation on the ship and the company, not only on the shipper.
The practical sequence is: booking staff verify the declaration and emergency contact number; the terminal verifies marks and labels against it; the master verifies the stowage plan. Shore staff who perform any of those tasks need documented IMDG training before they do them.