The International Maritime Organization (IMO) has adopted revisions to its maritime safety regulations, specifically within the International Maritime Dangerous Goods (IMDG) Code. These changes are aimed at enhancing the safety protocols for the seaborne transport of ammonium nitrate. The International Cargo Handling Coordination Association (ICHCA) is actively highlighting this development, along with other amendments to the IMDG Code intended to bolster safety in the handling and carriage of dangerous goods. This focus is part of ICHCA’s ongoing awareness campaign throughout 2025, reports ICHCA.
Under Deck Carriage
A recent amendment to the International Maritime Dangerous Goods (IMDG) Code specifically impacts Clause 7.6.2.8.4 concerning the carriage of UN 1942 Ammonium Nitrate and UN 2067 Ammonium Nitrate Based Fertilizer under deck.
The revised clause now explicitly states that under-deck carriage of these substances is only allowed if the hatches, including any tween deck hatches, can be opened readily in an emergency. This is to ensure that effective firefighting measures, including maximum ventilation and boundary cooling, can be implemented.
This amendment follows a White Paper prepared by the International Cargo Handling Coordination Association (ICHCA) on the subject, which was submitted to the International Maritime Organization (IMO) in 2022. The White Paper recommended clarifying the relevant IMDG Clause to address potential risks.
Richard Steele, CEO of ICHCA, strongly urged immediate voluntary adoption of this new regulation, stating, “Although not mandatory until 1st January 2026 it can be applied voluntarily from January 2025. ICHCA is urging all those involved in the maritime transport of ammonium nitrate to abide by the new regulation immediately. The work by our Technical Panel over several months made the case for amending the IMDG Code very clear, backed by a thorough understanding of the properties of these compounds and by detailed guidance on how such risks could be mitigated.”
While the risks associated with poor storage conditions of ammonium nitrate, widely used in fertilizers and explosives, were well-known, the dangers of fire during sea transportation were less recognized. The ICHCA White Paper played a crucial role in highlighting these risks on vessels chartered to ship these compounds through ports globally.
Careful Consideration
Ammonium Nitrate (NH₄NO₃) is described as a white to grey, odorless chemical with a melting point of 169 degrees Celsius and a decomposition temperature of 210 degrees Celsius. Importantly, while it is not flammable on its own, it acts as a strong oxidizer and will significantly accelerate the burning of any combustible materials present.
Brian Devaraj, the lead author of the ICHCA White Paper and a member of their Technical Panel, emphasizes the critical nature of these properties for stowage on vessels, stating, “These properties in particular demand careful consideration of how and where ammonium nitrate is stowed on board vessels. Ammonium nitrate fires can escalate out of control very rapidly. To help prevent consequential loss of life and damage, the new provisions laid out in the IMDG Code, in particular clause 7.6.2.8.4 should be complied with at all times.”
Devaraj further clarifies the importance of the seemingly straightforward clause 7.6.2.8.4: “This seemingly unremarkable clause is in fact crucial to safe shipping of ammonium nitrate. 7.6.2.8.4 states that certain product with specified UN Numbers may be stowed under deck in a clean cargo space capable of being opened in an emergency, including need to open hatches in case of fire to provide maximum ventilation and to apply water. This of course precludes a hold containing ammonium nitrate to be over-stowed with another cargo.”
The primary goal of the recent amendment to this clause is to eliminate any potential misunderstandings by explicitly stating that all vessel hatches, including tween decks and any other compartments, must be openable in the event of an ammonium nitrate fire. Devaraj highlights a particular concern regarding “multi-layered compartments of conventional reefer vessels, wherein compliance to this clause is next to impossible.”
He also notes that several jurisdictions that handle significant quantities of ammonium nitrate have already recognized this risk and implemented specific regulatory requirements, including countries like Australia, South Africa, and Chile. Devaraj concludes that “This newly worded clause in the IMDG will eliminate any ambiguity on its application to all types of ships including bulk, multipurpose tween deckers, conventional reefer vessels etc.”
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Source: International Cargo Handling Coordination Association
