Many cargo transport units¹¹¹ carrying non-hazardous cargoes and some carrying dangerous goods cargoes are fumigated while in transit by road and sea. Fumigation was traditionally done to eliminate insect and bacteriological infestation in foodstuffs, textiles and packaged goods, but has been extended to sterilisation of timber pallets, packaging and dunnage to comply with national phytosanitary control regulations enacted to prevent the accidental introduction of alien species that attack forests, crops or native indigenous species.

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¹¹¹IMDG Code, 2022 Edition Amendment 41-22, Chapter 5.5 (guidance is also provided in the IMO/I LO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code), Annex 9) 112 IMDG Code, 2022 Edition Amendment 41-22, Chapter 5.5

A fumigated unit is a closed cargo transport unit packed with cargo that is under fumigation. Fumigation is done by introducing solid or liquid materials that produce gases that are highly toxic (commonly Phosphine) or asphyxiant, then sealing the container. The result is a cargo transport unit that is highly dangerous to enter, and potentially dangerous to load below deck in certain types of ship because of the risk of toxic gas escaping from the containers and injuring crew in occupied parts of the ship.

Ships need to be aware of which containers are under fumigation so that appropriate stowage arrangements can be made and precautions taken.

Failure to declare fumigated units to the line is a breach of the IMDG Code and if discovered on the quay can lead to short shipment of containers, delays in port, and prosecution of shippers by enforcement agencies. Shippers who consign fumigated units should carefully observe this section of the guide to ensure that proper procedures are followed.

It is imperative that shippers notify the shipping line of any cargo transport unit to be shipped under fumigation when making the booking.

A fumigated unit (containing toxic or asphyxiant gas for fumigation) is classified as dangerous goods under the IMDG Code as follows:

UN 3359, FUMIGATED CARGO TRANSPORT UNIT, CLASS 9

A fumigated unit is subject to the IMDG Code until it has been ventilated by opening the doors or by mechanical extraction until no harmful concentration of gas remains.

Due to the highly dangerous nature of the fumigant gases used, the IMDG Code specifies conditions for transporting fumigated units.¹¹² These are contained in IMDG 5.5 and in Special Provision 302 and the IMO “Recommendations for the Safe Use of Pesticides in Ships”.

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¹¹² IMDG Code, 2022 Edition Amendment 41-22, Chapter 5.5

Fumigation should be done according to the provisions of IMO publication “Recommendations for the Safe Use of Pesticides in Ships” as amended. Only cargo transport units that can be effectively sealed to prevent escape of gas can be used for fumigation in transit. (Note: closed type cargo transport units can be sealed by applying adhesive tape over air vents and around door seals). Fumigant shall not be applied to a cargo transport unit once it has been loaded aboard a ship.

Fumigated units¹¹³ shall display the following warning mark on the outside of the doors until such time as the cargo transport unit has been ventilated and no dangerous levels of gas remain inside. Then the fumigation warning mark (illustrated) shall be removed. The mark shall indicate:

• Type of fumigant used
• Date of application
• Time of application
• Date of ventilation (if ventilation has been done)

Note: Fumigated units are not required to display Class 9 placards to indicate the fumigation hazard. Placard requirements for other dangerous goods that are carried as cargo in a fumigated unit will be required in the normal way, in addition to the fumigation mark on the doors shown below:

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¹¹³ IMDG Code, 2022 Edition Amendment 41-22, Section 5.5.2.3

The shipper should present the shipping line with a document that indicates the following information*:

• UN 3359
• FUMIGATED CARGO TRANSPORT UNIT
• Class 9
• Type of fumigant used
• Amount of fumigant used
• Date and time of fumigation
• Instructions for disposal of any residual fumigant or fumigation device**

*Note 1: A dangerous goods declaration must be made and presented in the normal way for any dangerous goods in the cargo. This may be totally separate from documents providing information on fumigation.

There is no requirement to present fumigation information on a UN-type dangerous goods declaration, although these are often used and are good for the purpose, as they are readily identifiable as dangerous goods information. A certificate of fumigation from the fumigation company that applied the fumigant is also acceptable.

**Note 2: Disposal of residue: Some fumigant materials are solid plates or tablets that break down to a powdery residue as they release toxic gas over a period of time. When the shipping container is unpacked, these residues should be removed from the container and disposed of with care, as they may be capable of releasing gas on movement or exposure to air.

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¹¹⁴ IMDG Code, 2022 Edition Amendment 41-22, Section 5.5.2.4

Due to the seriousness of the hazards arising from fumigated units, the IMDG Code has instructions for the ship, that are summarised below:

• The master shall be informed prior to loading any fumigated unit
• Fumigated cargo transport units shall be carried on ships in accordance with the IMDG Code provisions for UN 3359 and MSC.1/Circ.1361 Revised recommendations of the safe use of pesticides in ships
• Fumigated units shall not be allowed onboard until sufficient period of time has elapsed to allow a uniform concentration of gas throughout the cargo in it. This period will vary according to the type of fumigant and nature of the cargo
• When fumigated units are stowed under deck, equipment for detecting fumigant gas(es) shall be carried on the ship with instructions for their use

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¹¹⁵ IMDG Code, 2022 Edition Amendment 41-22, Section 5.5.2.5