National and international and rules apply to the transport of dangerous goods by sea. These rules apply to everyone in the transport chain, including senders, loaders, carriers and seaport terminals. The Human Environment and Transport Inspectorate (ILT) oversees compliance with these rules in the Netherlands.
International Maritime Dangerous Goods (IMDG) Code
Transport of dangerous goods by sea, including loading and unloading, must comply with the International Maritime Dangerous Goods (IMDG) Code of the International Maritime Organization (IMO).
The IMDG Code includes:
- General rules for all dangerous goods and substances.
- Specific rules. The Safety Data Sheet (SDS) of each hazardous substance shows the UN number of the substance in section 14. The dangerous goods list in chapter 3.2 of the IMDG Code shows which specific rules apply to each hazardous substance covered by a UN number. Specific rules always take precedence over general rules.
- Rules of exemption. The dangerous goods list indicates in column 7 whether the exemptions in chapter 3.4 of the IMDG Code apply to limited quantities per inner packaging.
Rules for senders
As a sender of dangerous goods, you are required by law to:
- Provide all carriers with:
- All required transport documents such as the Dangerous Goods Declaration (DGD) and Container Package Certificate (CPC) or Vehicle Package Certificate (VPG).
- Accompanying documents such as permits, authorisations, notifications, communications and certificates.
- Ensure safe packaging and clear, highly visible, resistant labels and markings.
Rules for loading dangerous goods
If you are loading dangerous goods, you are required by law to:
- Inspect packages externally for damage and only load intact packages.
- Follow the segregation rules in chapter 7 of the IMDG Code. If the segregation rules indicate that, under certain conditions, an exemption for combined loading in a single transport unit (container or vehicle) is possible, apply for this exemption from the competent authorities. In the Netherlands, this is the ILT. Use the online form Application decision joint loading of dangerous substances or explosives with a seagoing vessel.
- Place dangerous goods as close as possible to the door of the transport unit.
- Ensure that labels and features are and remain highly visible.
- Provide each transport unit containing dangerous goods with a signed CPC or VPC. For tanks, a CPC is not required. Chapter 5.4.2 of the IMDG Code specifies the requirements for the CPC or VPC.
The ILT recommends following the IMO rules for properly securing cargo in containers and trailers. These rules are known as the CTU Code. See examples of correct and incorrect stowage and labelling (in Dutch).
Rules for carriers
Rules apply to seagoing vessels carrying dangerous goods in waters and ports in the Netherlands.
As the carrier, you must make sure that, before transport units with dangerous goods come on board a seagoing vessel, the captain has:
- A list of all dangerous goods loaded in each transport unit.
- The CPC or VPC for each transport unit.
- A stowage plan showing, for each transport unit, the position number indicating its intended location on board.
Stowage and segregation on board
Chapter 7 of the IMDG Code states whether, and under what conditions, transport units carrying dangerous goods must or may:
- Be positioned on upper or lower decks.
- Be kept at certain distances from each other.
- Be maintained at or below a certain temperature.
- Be kept at specified distances from potential sources of ignition.
- Be located near crew accommodation or passenger accommodation.
Specific rules apply to different types of ships. Specific rules always take precedence over general rules.
Required documents on board the vessel
Every ship carrying dangerous goods and marine pollutants must have on board:
- A specific list or manifest based on the documentation and declarations required by the IMDG Code.
- A detailed stowage plan.
- Emergency Response Procedures for Ships Carrying Dangerous Goods (EmS).
Rules for seaport terminals
As a seaport terminal operator, you are responsible for ensuring compliance with the IMDG Code during temporary interruptions to transport.
You must carry out spot checks to ensure:
- Transport units are suitable for the dangerous goods they contain.
- Transport units are correctly labelled and marked.
Land-based personnel of all organisations
If your organisation is involved in the carriage of packaged dangerous goods by sea, you must provide the appropriate IMDG training for your land-based personnel.
Reporting requirement for incidents and accidents
If the transport of dangerous goods creates a risk to public safety, you must report this to the ILT using the online form Melding voorval/ongeval transport gevaarlijke stoffen binnenvaart, zeevaart, spoor en weg (in Dutch).
Oversight by the ILT
The rules for transporting dangerous goods by sea are designed to minimise risks to people and the environment and to limit the consequences of any accidents.
The ILT oversees compliance with the IMDG rules in the Netherlands and Caribbean Netherlands (Bonaire, Sint Eustatius and Saba). In Curaçao, Aruba and Sint Maarten, the ILT supports local inspectors.
The ILT cooperates with Douane (Customs Administration of the Netherlands), municipal port authorities, the Netherlands Police, omgevingsdiensten (environmental services), Rijkswaterstaat (executive agency of the Ministry of Infrastructure and Water Management, in Dutch), the Nederlandse Voedsel- en Warenautoriteit, NWVA (Netherlands Food and Consumer Product Safety Authority), the Autoriteit Nucleaire Veiligheid en Stralingsbescherming, ANVS (Authority for Nuclear Safety and Radiation Protection, ANVS) and the Nederlandse Arbeidsinspectie (Netherlands Labour Authority).