Dangerous goods moving by sea to or from the United States are governed by two rulebooks: the IMO's International Maritime Dangerous Goods (IMDG) Code and the U.S. Hazardous Materials Regulations in 49 CFR. U.S. rules allow shipments with a vessel leg to move under the IMDG Code, but several U.S. requirements still apply. This checklist covers the documents a shipper, NVOCC and carrier each need to get right.
IMO describes the IMDG Code as an extension of SOLAS chapter VII and notes that it became mandatory under the SOLAS umbrella from 1 January 2004, with some parts remaining recommendatory. It is amended on a two-year cycle, so documentation templates need checking whenever a new amendment takes effect.
On the U.S. side, 49 CFR 171.22 authorizes shipping hazardous materials in accordance with the IMDG Code, and 171.25 allows IMDG shipments to, from or within the United States by vessel, and by truck or rail, provided all or part of the movement is by vessel. The catch is in the conditions. Under 171.22(g), IMDG shipments must still meet U.S. requirements for emergency response information, training, security plans, incident reporting and PHMSA registration, as applicable.
Under 49 CFR 172.202, the shipping description of a hazardous material on the shipping paper must include:
Section 172.201 adds format rules: when hazardous and non-hazardous materials appear on the same shipping paper, the hazardous entries must be listed first, printed in a contrasting color, or marked with an "X" in an "HM" column. The description must be legible and in English, and it may not contain codes or abbreviations unless the rules authorize them. Under 171.22(f), shipping paper information for imports must also be in English; a bilingual paper is permitted.
Three statements travel with every dangerous goods shipment by sea:
| Document or statement | Who provides it | What the rule says |
|---|---|---|
| Shipper's certification | The shipper (offeror) | 49 CFR 172.204 sets the certification wording; 176.27 says a carrier may not transport hazmat by vessel without it. For import or export shipments not moving by rail, highway or air, the shipper may certify on the bill of lading under IMDG or 49 CFR. |
| Container packing certificate | Whoever packs or loads the container | Under 176.27(c), a signed certificate goes to the vessel operator stating the container is serviceable, holds no incompatible goods, and the packages were inspected, undamaged, properly marked and secured. |
| Emergency response telephone number | The shipper | Under 172.604, a number monitored at all times while the material is in transportation, answered by someone knowledgeable about the material. Numbers that require a call back do not meet the rule. |
For imports, 171.22(f) adds that the shipper, directly or through the forwarding agent at the place of entry, must provide the initial U.S. carrier with the shipper's certification, and a carrier may not accept the hazardous material without it.
Under 49 CFR 176.30, the carrier, its agents or a person they designate must prepare a dangerous cargo manifest, list or stowage plan. It may only list materials regulated by the Hazardous Materials Regulations or the IMDG Code, and must include:
The information must match what the shipper provided on the shipping paper. The person supervising preparation signs and dates it, and the master or a designated licensed deck officer acknowledges it by signature. The carrier must keep a copy for at least one year. The document is kept on or near the bridge, or, when docked in a U.S. port, at a location the master designates with a sign at the bridge pointing to it.
Dangerous goods also show up in Customs filings. For U.S. imports, 19 CFR 4.7a lists the internationally recognized hazardous material code among the data elements the cargo declaration must state when such materials are shipped, so the hazmat data on the house bill feeds the ACE manifest as well. See what ACE AMS filing is for how that filing works.
Retention periods differ by document. Under 172.201(e), each person who provides a shipping paper keeps a copy, or an electronic image, accessible at its principal place of business for two years after the material is accepted by the initial carrier, or three years for hazardous waste. For vessel shipments, the date on the bill of lading may be used in place of the acceptance date. The carrier's DCM copy is kept for at least one year under 176.30(e).
The DCM is where retyping errors hurt most: the information must match the shipper's paperwork, and the master signs off on it. Building it from data already captured at booking keeps the two in agreement.
That is how GDZ-ISIS handles hazardous cargo: bookings can be entered for container, break bulk and hazardous cargo, and the dangerous cargo manifest is built from those entries. If your team still assembles the DCM by hand, schedule a demo to see the alternative.
Yes, for shipments where all or part of the movement is by vessel, under 49 CFR 171.22 and 171.25. U.S. requirements for emergency response information, training, security, incident reporting and registration still apply, as applicable.
Under 49 CFR 172.202: the identification number, proper shipping name, hazard class or division (with subsidiary hazards where required), packing group, and the total quantity with its unit of measure.
The carrier, its agents or a person they designate, under 49 CFR 176.30. The person supervising it signs and dates it, the master or a designated licensed deck officer acknowledges it, and the carrier keeps a copy for at least one year.
Two years after the material is accepted by the initial carrier, or three years for hazardous waste, under 49 CFR 172.201(e). For vessel shipments, the bill of lading date may be used in place of the acceptance date.
Yes, for containers packed with hazardous materials for a manned vessel in ocean or coastwise service. Under 49 CFR 176.27(c), the person who packs or loads the container gives the vessel operator a signed certificate when the shipment is offered.