(Question on shipping UN3356 Oxygen generator, chemical.)
Q.
We want to ship UN3356 Oxygen generator, chemical which is restricted to CAO carriage but the destination is not served by a CAO aircraft. We are switching to ocean transport but we were told by the shipping company that a Dangerous Goods document is needed. We have several qualified air cargo DG qualification holders under our employment but we do not have anyone with ocean shipment qualifications. Our company authorizes air cargo DG qualification holders to prepare and sign Dangerous Goods Declarations for air carriage but we do not know whether they may prepare and sign ocean DG declarations. Please advise how to solve this problem.  (31 Jan 21)
A.
In referring to the IMDG Code (International Maritime Dangerous Goods Code), it states in 1.3.1 Training of shore-personnel in Chapter 1.3 that shore-personnel must undergo training to “prepare transport documents for dangerous goods”. In the case of air cargo, the DG declaration may be signed by a company official given the authority to place signatures on outgoing documents. The DG declaration must be prepared by a qualified staff, or produced under supervision of the qualified personnel. This is the same with ocean cargo. The DG declaration must be prepared by a qualified staff or produced under supervision of the qualified staff. Such declaration my be signed by the qualified staff or by any officer of the company having authority to sign outgoing documents.

I suggest you to explain the situation to the shipping company or to the stevedorig company and have them prepare the DG document for you.

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