UN3166 Engine, Internal Combustion or Vehicles

21st-Dec


UN3166 Engine, Internal Combustion or Vehicles

Notice to customers from Hutchinson Ports UK regarding the shipment of UN3166 Engine, Internal Combustion or Vehicles:

"NOTICE Dated 21.12.2011
UN3166 Engine, Internal Combustion or Vehicles

Following advice from the Maritime and Coastguard Agency and discussions with David Wilson we have been informing and training our employees, and advising any third party companies that have sought our opinion, that cargo moving under UN3166 Engine, Internal Combustion or Vehicles (as described in IMDG code 35-10) should be placarded.

We have today received the following message from the Maritime and Coastguard Agency:

Following numerous questions on the interpretation of the special provisions assigned to UN3166 and conversation with other Competent Authorities.

The UK is encouraging organisations to cease placarding cargo transport units (CTUs) with immediate effect, however in view of the existing differences in interpretation of the placarding requirements, the UK is allowing CTUs to be either placarded or not until 1st April 2012.. After 1st April 2012, CTUs containing UN3166 shall not be placarded with Class 9 placards.

Only fuel tanks have to be empty, fuel lines and the engine itself do not have to be drained to be considered exempt under SP961.  For UN3166 the meaning of the fuel tank is empty, is when the engine is run until it stalls for lack of fuel.

HPH will therefore be instructing gate staff that until the 1st of April 2012 to accept containers with or without class 9 placards but as of April 2012 UN3166 shall not be placarded.  Open CTUs, where the cargo is visible and obviously contains an Internal Combustion Engine, we need to ensure they are declared correctly.

As paragraph 7.5.2.6 states that “Irrelevant markings, labels, placards, orange panels, signs and marine pollutant marks shall be removed or masked before packing a cargo transport unit”, we have discussed with the MCA whether the warning sign required by the USA internal regulations should be allowed or not.  The current situation is that we will allow this irrelevant warning to remain but our gate staff will not be required to check.

It is understood that the whole topic of UN3166, SP961 and SP962 will be discussed at the international DSC meeting in September, after which we will hopefully have a clearer understanding of the international situation, and will advise accordingly."
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