The Friday-afternoon declaration
At 17:40 on a Friday a booking clerk receives a scanned declaration for a 20 ft container sailing the next morning. It reads: "UN 1263, PAINT, 3, PG III, 24 x 25 L jerricans, net 600 kg, flash point not applicable". In the same container are 40 fibreboard boxes, each marked with the limited quantity mark, containing 4 x 5 L cans of UN 1993, FLAMMABLE LIQUID, N.O.S. (PG III); one of the boxes weighs 34 kg gross. The declaration is signed by the freight forwarder's trainee, carries no emergency telephone number, and the container/vehicle packing certificate is blank. The safety data sheet, which the clerk has in front of her, shows a closed-cup flash point of 12 °C and states that the product is toxic to aquatic life with long lasting effects. The customer says he has shipped this "for years" and no one has ever questioned it.
1. List the defects in the documentation and explain why each one matters.
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- Packing group: a closed-cup flash point of 12 °C with an initial boiling point above 35 °C is PG II, not PG III. The PG drives packaging, tank and stowage requirements; under-declaring it can put the goods in packaging that is not authorised.
- "Flash point not applicable": the flash point must be shown for a flammable liquid. It is the number the ship's firefighting response depends on.
- Marine pollutant: the SDS chronic aquatic wording, once tested against the Code's criteria, will almost certainly make this a marine pollutant. It must be declared as such, marked on the package, and handled under MARPOL Annex III.
- No 24-hour emergency telephone number. The ship and the terminal need a number that answers at 03:00.
- Signature: the declaration must be signed by the consignor, with name and function, not by a forwarder's trainee. The signature is an attestation that the classification and packing are correct.
- Blank container/vehicle packing certificate: the person responsible for packing must certify the container was packed and secured in accordance with the Code.
- The 34 kg limited-quantity box exceeds the 30 kg gross limit for that package.
2. Can the container be loaded as booked? What should the clerk do, and what are the consequences of getting it wrong?
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No. The container should be placed on hold, not loaded, and the booking treated as unready until a corrected declaration and a signed packing certificate are received from the consignor. The clerk should tell the customer specifically what is wrong and what is needed, in writing, and record the time - the sailing cutoff is the consignor's problem to meet, not a reason to accept a defective declaration.
The consequences are not administrative. A PG II flammable liquid declared as PG III may be in packaging approved only for the lower hazard; a marine pollutant shipped undeclared escapes the additional marking and the Annex III obligations; and a ship with no emergency number and a wrong flash point is being asked to plan a fire response on false data. Misdeclaration is one of the main causes of dangerous goods incidents at sea.
If no corrected paperwork arrives before cutoff, the container misses the sailing. That is the correct outcome: the carrier's obligation is to ensure goods are carried in accordance with the Code, and the master can refuse cargo that is not properly described.
3. Explain the limited quantity rules that the 34 kg box breaches, and what reliefs the limited quantity mark does and does not give.
Read the worked answer
Limited quantities are a set of package-level reliefs based on the packing instruction shown for limited quantities in the Dangerous Goods List. For a Class 3 PG III liquid, the inner packaging limit is 5 L and the package as a whole must not exceed 30 kg gross. The box at 34 kg gross fails the outer limit even though each 5 L can is within the inner limit, which is exactly the mistake packers make: they check the can and not the finished package.
The fix is not to re-label it. Split the contents into two boxes of, say, 2 x 5 L each, both under 30 kg gross, and re-apply the mark.
What the limited quantity mark buys: relief from the class hazard label and from certain other package marking requirements, in exchange for the mark itself (minimum 100 mm x 100 mm), the packing instruction limits, and the quantity limits per cargo transport unit. What it does not buy: the goods are still dangerous goods for classification, packing, stowage, segregation and emergency response, and the consignment still has to be visible to the carrier as dangerous goods.