The mandatory effective date for Amendment 30-00 of the International Maritime Dangerous Goods Code (IMDG) is only a few months away, yet there is one issue that has apparently remained unresolved as industry prepares for full implementation.

That issue is how to describe personal care and household-use products when they are offered for international transportation by ocean. These are the hazardous materials that are described in the United States as "consumer commodities."

Let's take the example of an ocean container filled with assorted items destined for the retail hardware store—aerosols, paints, fertilizers, pesticides, and paint strippers. These types of products would be packaged, classified, and described in domestic commerce as "consumer commodities" in hazard class ORM-D.

Under the previous IMDG Amendments, these items could be shipped internationally by sea with the description "Dangerous goods in limited quantities of class (or classes) *, " with the "*" replaced by one or more hazard-class numbers. In the case of our theoretical shipment, the description would read, "Dangerous goods in limited quantities of classes 2, 3, 5.1, 6.1, and 8." In addition, as long as these materials were packaged according to a limited-quantity authorization included in the IMDG Code, met the criteria for the exemption for personal or household-use products, and were packaged and distributed in a form intended or suitable for retail sale, no package markings or labels would be required.

But take a close look at IMDG Chapter 3.4, Section 3.4.6, Subsection 3.4.6.1. This section of the revised IMDG Code continues to authorize the generic description for limited quantities, but it also now requires the U.N. identification number and the packing group to be entered for each substance within such a description.

Therein lies the problem: Employees at most distributors' warehouses are shipping products that were manufactured by others and described on a Material Safety Data Sheet (MSDS) only as "consumer commodity, ORM-D." They are unlikely, therefore, to have any knowledge of the proper shipping description, including the U.N. number or packing group. So where will the distributor find the required information?

It may be time for distributors to ask all manufacturers of such products to provide an MSDS that includes the international dangerous goods shipping description that would apply if the material were not subject to the authorized exceptions. In some cases, manufacturers may need to do laboratory analyses of the products to obtain technical specifications that are needed to develop classification and packing group information.

Armed with the U.N. number and packing group, distributors, carriers, and enforcement authorities could then refer to Column (7) and Chapter 3.4 of the IMDG Code to audit compliance with the limited-quantity authorization.

Alternatively, the shipper still has the authorized option of using the full description, including proper shipping name, hazard class, identification number, packing group, and the words "Limited Quantity" on shipping papers for these types of consumer and household-use products. Many shippers may choose to use the complete description because it will be no more difficult to describe shipments in that manner than to comply with the new rules.