Superseded by MSC.1/Circ.1361
MSC.1/Circ.1265
RECOMMENDATIONS ON THE SAFE USE OF PESTICIDES IN SHIPS APPLICABLE TO THE
FUMIGATION OF CARGO TRANSPORT UNITS
(9
June 2008)
1.
The Maritime Safety Committee, at its sixty-second session (24 to 28 May 1993),
approved the Recommendations on the safe use of pesticides in ships
(MSC/Circ.612), proposed by the Sub-Committee on Containers and Cargoes at its
thirty-second session.
2.
The Maritime Safety Committee, at its eighty-fourth session (7 to 16 May 2008),
approved the Recommendations on the safe use of pesticides in ships applicable
to the fumigation of cargo transport units, which apply to carriage of packaged
dangerous goods in pursuance of the requirements of SOLAS regulation VI/4 and
the relevant parts of the IMDG Code, proposed by the Sub-Committee on Dangerous
Goods, Solid Cargoes and Containers at its twelfth session, as set out in the
annex.
3.
The Committee agreed that the Recommendations should not apply to the carriage
of fresh food produce under controlled atmosphere.
4.
Member Governments are invited to bring the Recommendations to the attention of
competent authorities, mariners, fumigators, fumigant and pesticide
manufacturers and others concerned.
5.
The present circular supersedes MSC/Circ.612, as amended by MSC/Circ.689 and
MSC/Circ.746 with regard to the fumigation of cargo transport units.
Annex.
RECOMMENDATIONS ON THE SAFE USE OF PESTICIDES IN SHIPS APPLICABLE TO THE
FUMIGATION OF CARGO TRANSPORT UNITS
1.1
These recommendations address the hazards to personnel arising from the
operations involved in the carriage of fumigated containers. This guidance is
aimed at everyone involved in the supply chain. Although the contents of the
container may not be subject to the provisions of the International Maritime
Dangerous Goods (IMDG) code, the process of fumigating such a container may
bring it into the scope of the code. If the container comes within the scope of
the code hazard communication provisions are mandatory. Hazard communication
measures required by the IMDG Code include:
.1 warning signs
on containers;
.2 transport
documents describing the fumigation method and, if appropriate, ventilation
date; and
.3 requirements
to declare fumigated containers on ships' manifests.
1.2
It is generally acknowledged, however, that there is widespread non-compliance
with these requirements. Before entering the container all personnel should
assess the risk as to whether it is safe to enter and, if appropriate,
determine the level of fumigant present. The use of gas detection equipment may
be required.
2.1
The presence of insects and rodents on ships is clearly undesirable for various
reasons, and in addition to aesthetic and nuisance aspects, they may damage
equipment and spread disease and infection, contaminate food in galleys and
food stores, and cause damage to cargoes that will result in commercial or
other losses.
2.2
The same highly toxic chemicals are used in containers as on board bulk ships.
However, when a container that contains fumigant chemicals leaves the place at
which it was fumigated, no-one can practically supervise the hazard unless they
are aware of the presence of the fumigant. Any person who later enters the
container can therefore be unknowingly exposed to dangerous levels of highly
toxic chemicals.
2.3.1
Grubs and larvae of insects and other species can infest cargo, as well as
packaging, dunnage, etc., associated with the cargo, at any stage during
harvesting, manufacture, processing, storage, packing or transport. These can
spoil foodstuffs, textiles, leather goods, furniture, art and antiques, affect
electronic equipment, contaminate sterile goods or deface consumer packaging or
labelling, making the goods unfit for sale and therefore valueless.
2.3.2
Insect and mite pests of plant and animal products may be carried into the
containers with goods (introduced infestation); they may move from one kind of
product to another (cross-infestation) and may remain to attack subsequent
cargoes (residual infestation). Their control may be required to comply with
phyto-sanitary requirements to prevent spread of pests and for commercial
reasons to prevent infestation and contamination of, or damage to, cargoes of
human and animal food.
2.4.1
Rodents should be controlled not only because of the damage they may do to
cargo or the ship's equipment, but also, as required by the International
Health Regulations, to prevent the spread of disease. Importers, particularly
those that operate food processing plants, make great efforts to eliminate
infestation in order to prevent the invasion of the importer's local storage or
processing plant from infestation carried in incoming cargo. Consequently, they
regularly fumigate their premises and may insist that goods delivered to their
premises are certified free of infestation by means of fumigation.
3. Shore-side
fumigation operations fumigated containers
3.1 Fumigated containers which
have been ventilated
3.1.1
It is important to ensure that freight containers are properly ventilated by
opening the doors and allowing the gas to escape. This can be a natural
process, or can be accelerated by mechanical means such as blowers or extractors.
The ventilation process can take many hours.
3.1.2
Freight containers or cargo transport units that have been completely
ventilated after fumigation to ensure that no harmful concentration of gas
remains should have the warning signs marked to show that it has been
ventilated and the date of ventilation (in accordance with Special Provision
902 and Column 17 of the Dangerous Goods list for UN3359 Fumigated Unit) is not
subject to the other requirements of the IMDG Code.
3.1.3
Care should be taken even after a container has been declared as ventilated.
Gas can be held in packages of cargo, then desorbed over a long period of time,
even over many days, raising the level of gas inside the container to above the
safe exposure level. Bagged cereals and cartons with large air spaces are
likely to produce this effect. Alternatively, gas and the fumigant sachets or
tablets can become trapped' at the far end of a container by tightly packed
cargo.
3.2 Containers loaded
without ventilation after fumigation (fumigation in transit)
3.2.1
A freight container or cargo transport unit containing cargo under fumigation
should not be allowed on board until sufficient time has elapsed to allow the
attainment of a reasonably uniform gas concentration throughout the cargo.
Because of variations due to types and amounts of fumigants and commodities and
temperature levels, it is recommended that the period to elapse between
fumigant application and loading should be determined locally for each country.
Twenty-four hours is normally adequate for this purpose.
3.2.2
Carriage of fumigated containers which have not been ventilated before loading
must be carried in accordance with the IMDG Code; the text below is reproduced
from the 33rd amendment to the IMDG Code. A container which is carried under
fumigation is classified as Class 9, assigned a UN Number (UN 3359) and a
Proper Shipping Name (Fumigated Unit). The Dangerous Goods List of the IMDG
Code also specifies the following for fumigated units. It assigns two Special Provisions:
In
the Proper Shipping Name, the word "UNIT" means a cargo transport
unit.
A
FUMIGATED UNIT is a closed cargo transport unit containing goods or materials
that either are or have been fumigated within the unit. The fumigant gases used
are either poisonous or asphyxiant. The gases are usually evolved from solid or
liquid preparations distributed within the unit. Fumigated units are subject to
the following provisions:
1. Cargo
transport units shall be fumigated and handled taking into account the
provisions of the IMO publication Recommendations on the Safe Use of Pesticides
in Ships, as amended.
2. Only cargo
transport units that can be closed in such a way that the escape of gas is
reduced to a minimum shall be used for the transport of fumigated cargo.
3. Class 9
placards shall not be affixed to a fumigated unit, except as required for other
class 9 substances or articles packed therein (see 5.3.1.3).
4. Fumigated
units shall be marked with a warning sign affixed to the access door(s)
identifying the type and amount of fumigant used and the date and time of
fumigation (see 5.3.2.5).
5. The transport
document for a fumigated unit shall show the type and amount of fumigant used
and the date and time of fumigation (see 5.4.4.2). In addition, instructions
for disposal for any residual fumigant, including fumigation devices if used,
shall be provided.
6. A closed
cargo transport unit that has been fumigated is not subject to the provisions
of this Code if it has been completely ventilated either by opening the doors
of the unit or by mechanical ventilation after fumigation and if the date of
ventilation is marked on the fumigation warning sign. When the fumigated goods
or materials have been unloaded, the fumigation warning sign(s) shall be
removed (see also 7.4.3).
7. When
fumigated units are stowed under deck, equipment for detecting fumigant gas(es)
shall be carried on the ship with instructions for their use.
8. Fumigants
shall not be applied to the contents of a cargo transport unit once it has been
loaded aboard the ship.
3.2.3
In column 17 (Properties and Observations) of the Dangerous Goods list for UN
3359, the following information is given:
A 'FUMIGATED UNIT' is a closed cargo transport unit containing
goods or materials that either are or have been fumigated within the unit. The
fumigant gases used are either poisonous or asphyxiant. The gases are usually
evolved from solid or liquid preparations distributed within the unit.
Fumigants shall not be applied to the contents of a cargo transport unit once
it has been loaded aboard the ship. A closed cargo transport unit that has been
fumigated is not subject to the provisions of this Code if it has been
completely ventilated either by opening the doors of the unit or by mechanical
ventilation after fumigation and the date of ventilation is marked on the
fumigation warning sign (see also Special Provision 910).
3.2.4 Marking of the Cargo Transport Unit
3.2.4.1
To meet the requirements of the IMDG Code the container has to be marked in
accordance with chapter 5.3 of the IMDG Code, the relevant text is reproduced
below:
Paragraph
5.3.2.5 Fumigated units
.1 The marking
of the proper shipping name (FUMIGATED UNIT) and the UN number (UN 3359) is not
required on fumigated units. However, if a fumigated unit is loaded with
dangerous goods, any mark required by the provisions in 5.3.2.0 to 5.3.2.4
shall be marked on the fumigated unit.
.2 A fumigated
unit shall be marked with the warning sign, as specified in .3, affixed in a
location where it will be easily seen by persons attempting to enter the
interior of the unit. The marking, as required by this paragraph, shall remain
on the unit until the following provisions are met:
.1 the fumigated
unit has been ventilated to remove harmful concentrations of fumigant gas; and
.2 he fumigated
goods or materials have been unloaded.
.3 The
fumigation warning sign shall be rectangular and shall be not less than 300 mm
wide and 250 mm high. The markings shall be in black print on a white
background with lettering not less than 25 mm high. An illustration of this
sign is given below:
Transport
documentation for the fumigated cargo transport unit
3.2.5
To meet the requirements of the IMDG Code the container must be documented in
accordance with chapter 5.4 of the Code the relevant text is reproduced below:
Paragraph
5.4.4.2 Fumigated unit
The transport
document for a fumigated unit shall show the type and amount of fumigant used
and the date and time of fumigation. In addition, instructions for disposal of
any residual fumigant, including fumigation devices, if used, shall be
provided.
There
are a number of chemicals that are used as fumigants such as Phosphine and
Methyl Bromide.
4.1.1
This process requires a long period of time to work completely. This can be
applied with little technical training as it is supplied in sachets, tablets or
pressed plates containing Magnesium Phosphide or Aluminium Phosphide. These
generate Phosphine gas when exposed to the moisture in the air. The gas has a
slight "fishy garlic" smell and breaks down into a powdery grey
residue.
4.1.2
The rate of generation of Phosphine depends on the temperature, the airborne
moisture and the degree the generating material is exposed to the air.
4.1.3
Symptoms of poisoning by inhalation of Phosphine include nausea, vomiting,
headache, feeling weak, fainting, pain in chest, cough, chest tightness and
difficulty breathing. Pulmonary oedema (the presence of excess fluid in the
lungs usually due to heart failure) can follow, usually within 24 hours, but
sometimes this is delayed for some days.
4.2.1
Fumigation with Methyl bromide is a relatively rapid process that can normally
be completed in less than 48 hours. So these containers are not usually
presented for shipment with gas above the toxicity levels (threshold limits)
set by national agencies.
4.2.2
Symptoms of poisoning by inhalation of Methyl Bromide include headaches,
dizziness, and eye irritation; coughing, nausea, abdominal discomfort, and
numbness of feet. Higher exposure will bring about unconsciousness to central
nervous system, convulsions, and loss of vision, balance and hearing.
4.2.3
Methyl Bromide is supplied as a gas. So during application, expertise is
required to carry out the operation.
5.1 Fumigation after loading
on board a ship
5.1.1
No person should be allowed by the master to fumigate the contents of a freight
container, or cargo transport unit once it has been loaded on board a ship.
5.2 Containers loaded
without ventilation after fumigation (fumigation in transit)
5.2.1
If it is intended that freight containers or cargo transport units containing
cargo under fumigation should be taken on board ship without preliminary
ventilation, their shipment must be considered as a Class 9 Hazard under the
IMDG Code and as such the procedures should conform to the provisions as
specified in the entries for FUMIGATED UNIT (UN 3359) of the Code. The
following special precautions, incorporating the IMDG provisions, are
necessary:
.1 A freight
container or cargo transport unit containing cargo under fumigation should not
be allowed on board until sufficient time has elapsed to allow the attainment
of a reasonably uniform gas concentration throughout the cargo. Because of
variations due to types and amounts of fumigants and commodities and
temperature levels, it is recommended that the period to elapse between
fumigant application and loading should be determined locally for each country.
Twenty-four hours is normally adequate for this purpose. Before loading the
container should be checked for leaks and any leakage sealed.
.2 The master
should be informed prior to loading of freight containers and cargo transport
units under fumigation. These should be identified with suitable warning signs,
incorporating the identity of the fumigant and the date and time of fumigation.
Any freight container under fumigation must have the doors substantially
secured before loading onto a ship. Plastic or lightweight metal seals are not
sufficient for this purpose. The securing arrangement must be such as to allow
only authorized entry to the freight container. If container doors are to be
locked, the means of locking should be of such a construction that, in case of
emergency, the doors could be opened without delay. Adequate instructions for
disposal of any residual fumigant material should be provided.
.3 Shipping
documents for freight containers or cargo transport units concerned should show
the date of fumigation and the type and amount of fumigant used.
.4 Stowage on
deck should be at least 6 m away from vent intakes, crew quarters and regularly
occupied spaces.
.5 Stowage under
deck should only be undertaken when unavoidable and then only in a cargo space
equipped with mechanical ventilation sufficient to prevent the build-up of
fumigant concentrations above the toxicity levels (threshold limits) set by
national agencies. The threshold limit for occupational exposure to the
fumigant can be found on the Safety Data Sheet. The ventilation rate of the
mechanical ventilation system should be at least two air changes per hour,
based on the empty cargo space.
.6 Equipment
suitable for detecting the fumigant gas or gases used should be carried on the
ship, with instructions for its use.
.7 Where the
stowage requirements above cannot be met, cargo spaces carrying fumigated
freight containers or cargo transport units should be treated as if under
fumigation and the provisions below should apply.
5.2.2
Before a fumigated container is loaded to a vessel below deck special
precautions are necessary. This includes the following:
.1 At least an
officer and one other are to receive appropriate training and will be
designated as the trained representatives of the master. The master, through
his representative, is responsible for ensuring safe conditions in the occupied
spaces of the vessel.
.2 The trained
representatives should brief the crew before the container is loaded.
5.2.3
The fumigant gas is heavier than air so care should be taken in the holds
particularly when working on the tank tops.
5.2.4
The trained representatives of the master should be provided and be familiar
with:
.1 The
information in the relevant Safety Data Sheet (SDS), if available.
.2 The
instructions on the packaging itself, such as the recommendations of the
fumigant manufacturer concerning methods of detection of the fumigant in air,
its behaviour and hazards properties, symptoms of poisoning, relevant first aid
and special medical treatment and emergency procedures.
5.2.5
The ship should carry:
.1 adequate
gas-detection equipment for the fumigant concerned, together with instructions
for its use;
.2 instructions
on disposal of residual fumigant material;
.3 at least four
sets of adequate respiratory protective