MEMO: ID9007 Bulk Cargo Previously Fumigated

Bulk cargoes such as seeds, grains, animal feed and wood that have previously been fumigated will fall under the ADN as of 01-01-2027 and will then be subject to specific transport requirements.

With this memo, we would like to inform you of an upcoming change in ADN 2027. The bulk transport of "non-dangerous substances" such as grains, seeds, animal feed and timber in inland waterway vessels will fall under the rules of the ADN if these substances have been fumigated during a preceding voyage.

Use of fumigants

To prevent cargo damage from pests during sea transport, fumigants are applied to these products. Cargo holds are fumigated using pellets that slowly react with moisture in the air. These pellets are usually placed in bags or sleeves inside the hold. The toxic substances used for fumigation are Phosphine, Sulfuryl fluoride or Methyl bromide*. (*Methyl bromide may not be used within the European Union. Outside the EU, this substance is still in use.)

The intention is for these pellets to dissolve completely during the voyage. However, if insufficient moisture is present, the pellets may not dissolve fully or at all. These residues may then release toxic gas at a later stage upon contact with moisture. If this occurs after the cargo has been transferred to an inland waterway vessel, it can create life-threatening situations. A well-known example of such an incident, and a direct reason for tightening the rules, is the incident involving the motor cargo vessel Fox in 2019.

ADN 2027 Rules

The ADN Commission has discussed this matter for several years and concluded that specific rules are required. These will be included in ADN 2027. In summary:

• BULK CARGO, PREVIOUSLY FUMIGATED is classified under substance number 9007. A substance number (ID number) is practically equivalent to a UN number.
  
  
• The transport of ID9007 BULK CARGO, PREVIOUSLY FUMIGATED is prohibited unless the conditions set out in special provision 804 are met. This provision will be included in Chapter 3.3 of the ADN.
  
  

Special Provision 804

Special provision 804 sets out the conditions under which transport is permitted. The ADN does not apply to the transport of this substance, with the exception of what is described in special provision 804.

In addition, the following has been established:

1. Fumigation during transport on board vessels is prohibited.

2. Documents accompanying the transport must contain the following information:
   
   

   • • "Transport in accordance with special provision 804 of the ADN"
     • ID9007 BULK CARGO, PREVIOUSLY FUMIGATED
     • Name and address of the consignor
     • Place of loading and unloading
     • Name and address of the consignee

   This document must be drawn up in the language of the country of dispatch. If that language is not English, French or German, it must also be provided in one of these languages.
   
   

3. The consignor must ensure that all traceable residues of fumigants (such as bags/sleeves) have been removed from the cargo intended for loading onto inland waterway vessels.

   The information must be kept on board in written form during transport and unloading.
   
   

4. The loader must ensure that after loading the bulk cargo, the concentration of fumigants present in the air does not exceed the values as specified:
   
   

   Begassingsmiddel	Waarde
   Fosfine
   - In het laadruim	0,1 ppm
   - Andere plaatsen waar bemanningsleden of andere personen zich bevinden	0,03 ppm
   Sulfaryl fluoride	0,1 ppm
   Methyl bromide*	0,25 ppm

5. The loader must ensure that a measurement has been carried out after loading and that the above-mentioned values are not exceeded. A document stating the measured values and the exact method of measurement must be available on board during transport and unloading.
   
   
6. At all locations where crew members or other persons are present, a warning device (gas detection device) suitable for the fumigant used must be in operation. The device must trigger an alarm at a measured value of at most 0.03 ppm Phosphine, 0.1 ppm Sulfuryl fluoride and 0.25 ppm Methyl bromide. The device must be maintained in accordance with the manufacturer's instructions.
   
   
7. If during the voyage there is reasonable suspicion that fumigant is still being released from the cargo, above the values mentioned under point 4, the competent authority (ILT) must be notified immediately. The vessel must be moored at a suitable location designated by the authority until gas concentrations have dropped below the safe values indicated in the table above.
   
   
8. Only the following persons may be on board during the voyage:
   i) Crew members;
   ii) Persons normally residing on board;
   iii) Persons on board for official reasons.
   
   
9. If an incident occurs during the loading, transport and/or unloading of ID9007 BULK CARGO, PREVIOUSLY FUMIGATED on the territory of an ADN country, the loader, carrier or unloader respectively must ensure that a written report is submitted to the competent authority within one month of the incident.

A reportable incident has occurred when gas concentrations above the values referred to in points 4 and 6 have been measured, persons have been injured, or the authorities have been involved.

The ADN will include a template for the report specifying the required information to be provided.

Summary

The transport of BULK CARGO, PREVIOUSLY FUMIGATED will fall within the scope of the ADN. The substance is classified under substance number ID9007. The transport of such cargo is only permitted when carried out in accordance with special provision 804. With the exception of the rules of that special provision, the ADN does not apply. No additional requirements are therefore imposed on the qualification of vessels or crew members.

The obligation to ensure that no residues of fumigants are present rests with the consignor and the loader. Measurements must be demonstrably carried out and a copy must be available on board. The master must ensure that suitable gas detection devices are present at all locations on board where persons are present, such as the wheelhouse or living quarters, which trigger an alarm when the specified concentrations are exceeded. To make the best choice of a suitable gas detector, we recommend contacting a supplier of such equipment, such as Dräger.

If an incident occurs, it must be reported immediately to the competent authority. A written report of the incident must be submitted to the authorities within one month using a prescribed format.

For questions about this subject, please contact us.

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Disclaimer: Although the greatest possible care has been taken, no rights may be derived from the above text. Only after the official publication of ADN 2027 and the translation by the Dutch government will it be possible to establish with complete certainty what the exact statutory texts will be.