Dangerous Goods by Sea – IMDG and the MO41

Regularly we experience situations where parties, other than the shipper, create dangerous goods documentation (MO41) for sea freight on behalf of that shipper.

When creating and signing the dangerous goods declaration, one signs for compliance in all aspects with the applicable code (the IMDG Code for sea freight) and one will be liable for any non-compliance with the IMDG Code.

Often the MO41 is drafted based on provided paperwork and the cargo is not physically inspected. A number of potential issues may be missed and the shipment will travel non-compliant. Common issues include, but may not be limited to:
* Dangerous goods labelling missing
* Dangerous goods labelling incorrect
* Dangerous goods packaging incorrect
* Overpack labelling incorrect or in a lot of instances, non existent
* Pallets/Overpacks not wrapped & strapped sufficiently causing damage and/or incidents
* Container placarding incorrect

Another frequently seen occurrence is where a 3rd party is drafting the MO41 on behalf of a shipper, where the shipper will pack the container themselves on-site. Packing dangerous goods inside a container requires adequate dangerous goods training and certification.

If a shipper has trained & certified staff they would be able to complete and sign an MO41 themselves.

If you are drafting the MO41 for a shipper-packed container, ensure that you:
* Inspect the cargo for correct packaging, packing and labelling
* Oversee and/or inspect the correct packing of the container, ensuring no incompatible dangerous goods are loaded inside the container and the cargo securely loaded for its journey.

If you need any assistance, or would like to know more, please contact us