Confirmation of compliance of packaging for dangerous cargoes

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The Russian Maritime Register of Shipping provides the services to confirm the compliance of containers for dangerous goods (including large and special-purpose containers, intermediate bulk containers) with the requirements of the International Maritime Dangerous Goods Code (IMDG) and the provisions of the Model Regulations of the UN Recommendations on the Transport of Dangerous Goods.

According to IMDG, RS is appointed by the national competent inspection authority for approval, acceptance and all subsequent actions related to intermediate bulk containers (IBC) and containers submitted for registration in the Russian Federation.

To start providing the services, the Customer shall apply to the RS with a request to confirm the compliance of containers for dangerous goods.

The Customer shall inform the Register of all production sites where the container is manufactured that is declared for the confirmation of the type compliance.

If the Customer is not a manufacturer of containers for dangerous goods, then, when confirming the compliance of the series-produced containers, the Customer shall be authorized by the manufacturer (which shall be documented) to:

  • submit technical documentation for RS review and approval or to use RS-approved technical documentation

  • organize the relevant surveys including the survey of production within the required scope

  • organize the testing of containers within the required scope. 

The Register uses two procedures for compliance confirmation:

  • confirmation of compliance of series-produced containers

  • confirmation of compliance of container lot 

The procedure for confirmation of compliance of series-produced containers is used when confirming the compliance of containers that are series-produced under the technical supervision by the Register.

The procedure of confirmation of compliance of container lot is used:

  • when confirming the compliance of the container lot that, at the time of confirmation of compliance, was already manufactured without technical supervision by the Register

  • when confirming the compliance of containers manufactured individually under the technical supervision by the Register

  • when confirming the compliance of containers that, according to IMDGC, require that the Register shall certify each piece of containers.

Procedure to confirm compliance of series-produced containers for dangerous cargoes 

Review by the Register of technical documentation for containers.

Survey of the manufacturer of containers for dangerous goods by a Register expert in order to confirm the possibility of series production of containers with consistent quality according to the documentation approved by the Register.

Testing of container samples in a testing laboratory recognized by the Register according to the program approved by the Register. If sampling of containers for testing was carried out without the Register participation, then, before testing, the Register expert shall make sure that the samples submitted for testing are in compliance with the approved documentation.

Recording of survey results by the Register. 

Procedure to confirm compliance of container lot for dangerous goods

For the purposes of confirming the compliance of:

  • the container lot that, at the time of confirmation of compliance, was already manufactured without technical supervision by the Register

  • the container manufactured individually under technical supervision by the Register

  • containers that, according to IMDG, require that the Register shall certify each piece of containers, with the IMDG provisions, the following procedure is establish for the confirmation of compliance. 

1. Review of technical documentation for containers

2. Survey of the submitted container lot by RS expert for confirmation of compliance. At the same time, the Register expert:

  • verifies the compliance of the container with the approved documentation

  • visually inspects to determine the technical condition of the container within the lot and the suitability of the container for intended use

  • participates in sampling of containers for testing A number of samples is determined based on the IMDG requirements, a size of the lot, the uniformity of the technical condition of the containers within the lot. 

3. Testing of container samples in a testing laboratory recognized by RS according to the program approved by RS. If sampling of containers for testing was carried out without the Register participation, then, before testing, the Register expert shall make sure that the samples submitted for testing are in compliance with the approved documentation. 

Requirements for technical documentation

The Register reviews the technical documentation in order to verify the compliance of the design of the container for dangerous goods with the IMDG requirements and to document the design and the technical characteristics of the container.

The containers for dangerous goods shall be manufactured in accordance with the technical documentation approved by the Register.

The technical documentation shall be developed taking into account the IMDG requirements and submitted to the Register for approval.

The technical documentation for containers for dangerous goods shall be submitted to the Register for review and approval (agreement) prior to manufacturing.

Documents shall be made in Russian or English.

Documents are submitted in paper format (originals, duplicates or copies) in two copies; or in electronic form in PDF format (on CD, by e-mail, via FTP-server or in any other way agreed with the Register). For review, it is not allowed submitting a part of the documentation in electronic format and a part of documentation in paper format.

The technical documentation submitted to the Register for review shall be developed in such a way or provided with such additional information so that it can be verified based on it that the relevant IMDG provisions are fulfilled and the design, material and technical characteristics of the container are uniquely determined.

A scope of container documentation to be submitted to the Register for review, whose manufacture will be carried out under the technical supervision by Register, shall allow uniquely identifying the container type, requirements for its manufacture and the compliance of container with the IMDGC requirements: design, dimensions, materials and their thickness, connection methods, manufacture method, marking in accordance with IMDG, requirements for quality control during manufacture, and, if necessary, operating instructions.

In case of already manufactured container lot, a scope of documentation to be submitted to the Register for review shall allow determining the container type and its compliance with the IMDG requirements: design, dimensions, materials and their thickness, connection methods, manufacture method, marking in accordance with IMDGC, and, if necessary, operating instructions.

If the technical documentation submitted confirms the compliance, which is complete or recognized by the Register as sufficient, of the containers for dangerous goods with the RS requirements and the IMDG provisions, such documentation is approved (agreed). Noncomplying documentation is returned for revision and/or rectification.

Approval (agreement) of the technical documentation is confirmed by affixing to it the relevant Register stamps and by compiling a Conclusion Letter. Samples of stamps used by the Register are given in Chapter 8, Part II of the Rules for the Technical Supervision during Construction of Ships and Manufacture of Materials and Products for Ships.

The copies of the documents, to which the Register original stamps are affixed, are the control documents.

In case of negative results of review, the Conclusion Letter states the RS requirements, which shall be met for the approval (agreement) of the documentation. At that, no Register stamps are affixed to the documents.

In case of technical documentation for containers for dangerous goods, the validity period of the Register approval is 4 years.

Regardless of the validity period of the approval (agreement), the technical documentation for containers for dangerous goods is subject to mandatory adjustments related to the need to take into account the mandatory requirements of international conventions and agreements that came into force after approval (agreement) of the documentation. Also, all documentation approved and agreed by the Register is subject to adjustment taking into account the requirements of the RS circular letters if they provide for their mandatory implementation before the expiry date of the documentation approval.

The technical documentation submitted to the Register for re-approval (re-agreement) upon the expiry of the validity period of its previous approval (agreement) shall take into account the IMDG requirements that are applicable at the time when the documentation was submitted.

The approval (agreement) of the technical documentation by the Register becomes void:

  • upon expiration of the approval

  • upon expiration of the documentation validity period (where this validity period is provided)

  • if, without the RS consent, changes were made to the approved (agreed) documentation or production process that affect the matters within the RS competence 

The Register may revoke its approval (agreement) of technical documentation or change the terms of approval (agreement) in the following cases:

  • if the documentation is not timely brought in compliance with the IMDGC regulations, as well as with the requirements of the Register circulars

  • if it turns out that the quality and reliability of containers for dangerous goods are at low level that does not meet the requirements of the Register. 

Changes made to the technical documentation approved (agreed) by the Register and affect the requirements that are regulated by the Register rules or by international conventions shall be approved (agreed) by the Register based on the results of review of reissued changed documents or notices of change. Such changes shall be described in detail or clearly marked in the changed documents, drawings.

All documentation submitted to the Register for review is confidential and may only be transferred to a third party with the written consent of its legal owner or in accordance with the laws of the Russian Federation. 

Requirements for manufacturers of containers for dangerous cargoes

Certification of the manufacturer of containers for the transport of dangerous cargoes is carried out by the Register to confirm the possibility of series production by the firm of containers that are declared for confirmation of compliance according to the approved documentation with the consistent quality level. The quality of series-produced items shall ensure that each piece of containers for dangerous cargoes that is released into circulation complies with the provisions of the relevant chapters of Part VI, IMDG.

The manufacturers of containers for the transport of dangerous goods shall meet the following requirements:

  • The legal status of the firm shall comply with current legislation

  • The firm shall have a manager and a documented organizational chart

  • The personnel of the firm shall have the appropriate education, professional and special training, the required qualifications and experience for the manufacture of containers for transport of dangerous cargoes

  • The firm shall have the required technical equipment for the series production of containers for transport of dangerous goods including appropriate equipment, facilities and areas to store materials, components and finished products

  • The firm shall have valid contracts on rented facilities, site and technical equipment

  • The firm shall provide maintenance of equipment and facilities in accordance with the documentation for their use and maintenance

  • The firm shall have and apply the required metrological support for the quality control of raw materials, materials and finished products, comply with the calibration time intervals for instruments and tools

  • The firm shall have the required valid regulatory and technical documents for the manufacture of containers for transport of dangerous cargoes including documents that contain requirements for the items of technical supervision; technical documentation for containers approved by the Register; process documentation for the manufacture of containers, audits and control. The documentation shall be available for the firm personnel where necessary.

  • The firm shall have an effective quality control system for finished products and maintain the identification of rejected products

  • The firm shall perform audits and monitor the compliance of materials, components and finished products with the approved documentation, as well as monitor the process of manufacture and testing of containers for transport of dangerous cargoes

  • The firm shall take measures to eliminate and prevent non-compliances and claims in the declared area of ​​activity 

Documents issued based on the certification results:

Given the positive results of the confirmation of compliance of containers for dangerous cargoes with the IMDG requirements, the Register shall issue the relevant Certificates, given the negative results, a letter or a Report with comments.

If it is necessary to perform periodical surveys of the containers, the date of the first survey is indicated in the Certificate.

Given the positive results of confirming the compliance of series-produced containers, the Register shall issue a Certificate for container type (CTT). The CTT period of validity is established taking into account the type of container but no more than three years. At the initial confirmation of compliance, the CTT period of validity is established to be no more than two years. 

Given the positive results of the confirmation of compliance of a container lot that was made without technical supervision by the Register, of individually made containers and containers, which, according to IMDG, require that the Register shall certify each piece of containers, the Register issues a Certificate for Container Lot (CT).

The CT validity period is established taking into account the type of container, actual conditions, intended use, and shall not exceed the CTT validity period for a similar type of container. The CT validity period shall not exceed the remaining period of container operation specified by the manufacturer or the period until the next certification.

Certificates for containers are posted on the Register official website at the following addresses: 

Container type certificates: 

Container lot certificates: 

If there is no information on the Certificate on the RS official website, it means that the relevant Certificate is invalid.

Certificates can be revoked:

  • in cases provided for by the General Conditions for Rendering Services by the Register

  • if a design of the container, its properties, etc. have been changed without agreement with the Register

  • if the operational suitability of the container is not provided and the IMDGC requirements are not met. 

The revocation is carried out by removing the information on the Certificate from the Register official website.

  • Container type certificate

  • Certificate 

List of issued certificates for container type:

list of issued certificates for container lot:

Contacts

Dangerous Goods and Packaging Sector

 
 

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