Dangerous Goods in Holds on Non-Containerised General Cargo Ships
Segregation on a conventional cargo ship follows exact UN entries, hazards, DGL codes, segregation groups and Table 7.2.4; neither a generic class nor a CTU shell alone determines the required level.
Operational Explanation
Do not derive separated by a complete compartment or hold from mnemonic class families such as oxidizer versus flammable. Identify both goods and apply all entry-specific and mode-specific provisions. A container wall does not automatically equal the structural separation defined by the Code.
Regulatory Reference
IMDG Code (Amendment 42-24, res. MSC.556(108)): 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.
The segregation table has a precise home. It sits in Part 7 of the IMDG Code, which governs provisions concerning transport operations: Chapter 7.1 for stowage and segregation, Chapter 7.2 for segregation requirements between classes, with the four categories of increasing separation. The provisions for packaged cargo below and on deck, and those on cargo transport units, sit in the same Chapter 7.1.
And securing the cargo remains SOLAS. Regulation VII/5 requires dangerous goods in packaged form to be loaded, stowed and secured in accordance with the approved Cargo Securing Manual: the same regulation treated on the dedicated Manual page, and it bites harder for non-containerised cargo, where segregation distances must be achieved physically rather than by container position. Regulation II-2/19 finally makes carriage conditional on the Document of Compliance.
Scope of Application
Packaged dangerous goods on non-containerised/conventional general cargo ships, on deck or below deck, under DGL, packing and ship arrangement. Also check SOLAS II-2/19 Document of Compliance, approved CSM and SMS.
Procedure / How to Complete It
- Identify both goods by exact UN number and proper shipping name.
- Collect primary/subsidiary hazards, packing group and special provisions.
- Apply DGL stowage/segregation entries, segregation groups and Table 7.2.4.
- Apply provisions for conventional cargo ship, on deck/below deck and packaging type.
- Check the plan against SOLAS II-2/19 Document of Compliance, approved CSM, ship arrangement and SMS.
- If the result cannot be determined, do not load by mnemonic rule: obtain competent assessment.
Practical Example
For oxidizer and flammable goods no level is assigned in advance: compare exact UN entries, subsidiary risks, segregation groups and Table 7.2.4, then verify whether ship structure meets the resulting separation.
What Typically Goes Wrong
Using class names alone or presuming the container constitutes the required intervening complete compartment or hold.
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 |
What the PSCO Checks
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.
Preparation checklist
- Exact UN/PSN for both goods
- Primary/subsidiary risks and packing group
- DGL codes and segregation groups
- Table 7.2.4 applied
- On deck/below deck and ship type checked
- DOC/CSM/SMS and ship structure consistent
- No mnemonic rule used as final decision
FAQ
Related Topics
Last substantive revision of this page: 31 August 2026 · page fingerprint b74945aa92c7