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This guidance notice is for:
The purpose of this guidance notice is to advise industry of the changes to the International Maritime Dangerous Goods (IMDG) Code marking requirements for dangerous goods that are marine pollutants. The changes come into effect on 1 January 2010.
Old "fish and chips" mark
The IMDG Code requirements for the type of symbol (officially called a ”mark”) applied to dangerous goods that are marine pollutants are changing on 1 January 2010.
The mark will change from the triangle with a crossed-out fish symbol (often called the “fish and chips” mark) to the new environmentally-hazardous symbol (often referred to as the “fish and tree” diamond mark).
New "fish and tree" mark
Any dangerous goods identified as a marine pollutant, in the subsidiary risk column of the dangerous goods list in Part 3 of the IMDG Code, needs to be marked with the marine pollutant symbol if the substance is transported by sea.
Also, any cargo transport unit with these dangerous goods needs to be marked on the outside with the same symbol. The correct sizes of these marks must be used in each case. Please refer to Chapters 5.2 and 5.3 of the 2008 Edition of the IMDG Code for details.
Under Maritime Rules Part 24A “Carriage of Cargoes – Dangerous Goods” manufacturers of dangerous goods packaging are not required to mark the packaging with the marine pollutant mark. That requirement is currently placed on the consolidator or packer of those dangerous goods (Maritime Rules Part 24A.8).
From now on, all pre-marked products being prepared for marine pollutants, should be prepared with the new “fish and tree” diamond marine pollutant mark. Also, it is recommended that any previously prepared stock be additionally marked, re-marked or transported before the requirements come into force. (However, please note the “grace period” described below.)
The shipper of the dangerous goods is responsible for identifying those dangerous goods requiring the marine pollutant mark on the packaging and on the outside of any cargo transport unit or vehicle.
The consolidator or packer is responsible for ensuring the correct marking is carried out. Note that the manufacturer, shipper, consolidator and packer can be the same persons.
Any marine pollutant dangerous goods prepared from now on should show the new “fish and tree” mark. After
1 January 2010 the applied mark is legally required to be the “fish and tree” marine pollutant mark.
Maritime New Zealand’s principal concern is that all dangerous goods are suitably marked. MNZ recognises that a transition period is appropriate.
To provide adequate time to facilitate these changes, MNZ will relax its enforcement policy for the marine pollutant marking requirements until 1 July 2010 for dangerous goods transported only between New Zealand ports. This is to cater for dangerous goods that have been prepared to the 2009 requirements but are likely to be transported in the first 6 months of 2010.
What this means is that MNZ will enforce the requirement for the new “fish and tree” diamond mark by issuing a non-conformance only, until 1 July 2010, but will not prevent the transportation of those goods by sea providing the “fish and chips” mark is correctly applied.
After 1 July 2010, MNZ expects full compliance with the IMDG Code requirements and will enforce accordingly.
All dangerous goods that are marine pollutants being transported internationally by sea must, from 1 January 2010, be prepared with the new “fish and tree” diamond marine pollutant mark.
MNZ recommends that:
For further information please contact our Wellington office:
Phone: 0508 22 55 22 or (04) 473 0111
Fax: (04) 494 8901
Email: enquiries@maritimenz.govt.nz