Dangerous Goods in Holds on Non-Containerised General Cargo Ships
Without a container's walls acting as a physical barrier, segregating dangerous goods in the hold of a general cargo ship depends entirely on the discipline of the stowage plan.
Operational Explanation
The carriage of non-containerised dangerous goods, directly in the hold of general cargo or break bulk ships, presents segregation challenges distinct from container transport: without the physical shell of a container to delimit cargo units, segregation between incompatible substances depends entirely on the discipline of the stowage plan and on the physical application of the distances/barriers required by the IMDG Code.
The IMDG Code's four segregation categories — "away from", "separated from", "separated by a complete compartment or hold from", and "separated longitudinally by an intervening complete compartment or hold from" — represent increasing separation distances, and must be applied physically within the hold space when the cargo is not containerised, a more complex exercise than simply separating containers.
Regulatory Reference
IMDG Code: segregation table with the four categories of increasing separation, applicable both to containerised cargo and to non-containerised cargo in the hold; for non-containerised cargo, physically applying the segregation distances requires dedicated stowage planning, without the delimiting aid of a container.
Scope of Application
Every general cargo or break bulk ship carrying dangerous goods directly in the hold, non-containerised, with the Master responsible for ensuring the physical application of the required segregation distances.
Procedure / How to Complete It
- Identify, for every non-containerised dangerous substance, the segregation category required relative to the other substances present in the cargo plan.
- Physically plan the hold positioning to comply with the required segregation distances, without the delimiting aid of a container.
- Pay particular attention to the more severe segregation categories (separation by a complete compartment/hold, longitudinal separation), which require structural planning of the cargo plan.
- Check the compatibility of non-containerised stowage also against conventional non-dangerous cargo present in the same hold.
- Document the segregation plan applied, with explicit reference to the IMDG categories used for each pair of incompatible substances.
Practical Example
Example: a general cargo ship carrying drums of an oxidising substance in the hold together with flammable material plans the stowage by applying the "separated by a complete compartment or hold from" segregation category required by the IMDG Code, positioning the two substances in physically separate holds rather than in the same hold with simple distance separation.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Segregation categories applied using the same logic as containerised cargo, without considering the absence of the container's physical shell | Physically insufficient segregation distance in the hold | Plan non-containerised stowage explicitly taking into account the absence of the container's physical barrier |
| Stowage compatibility checked only between dangerous substances, not against the conventional cargo present in the same hold | Incompatibility not detected with non-dangerous but still sensitive cargo (e.g. foodstuffs, heat-sensitive materials) | Always check stowage compatibility also against the conventional cargo present in the same hold |
| The more severe segregation categories (complete compartment, longitudinal separation) not planned structurally in advance | Inability to meet the required segregation with a stowage arrangement already planned | Plan the cargo plan structurally from the outset when more severe segregation categories are required |
PSC Observations
Operational Tips
- Do not apply the same segregation logic used for containers to non-containerised cargo: the absence of the physical barrier requires more careful planning.
- Plan the cargo plan structurally from the outset when more severe segregation categories are required.
- Always check stowage compatibility also against conventional non-dangerous cargo present in the same hold.
Checklist
- IMDG segregation category identified for every pair of non-containerised dangerous substances
- Physical hold positioning planned to meet the required segregation distances
- More severe segregation categories planned structurally in the cargo plan
- Compatibility with conventional non-dangerous cargo in the same hold checked
- Segregation plan documented with explicit reference to the IMDG categories applied