IMDG Code requirements for Marshall Flagged vessels

Application of the medical first aid guide in accidents


The Republic of the Marshall Islands  issued Marine Notice regarding the IMDG Code requirements for RMI flagged vessels which clarifies the application of the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods (MFAG) with respect to gas carriers and chemical carriers and articulates the RMI Maritime Administrator’s policy on medical oxygen cylinders.

The IMDG Code is legally treated as a mandatory instrument under Chapter VII of SOLAS. However, certain provisions of the Code remain recommendatory and should be treated as such. Compliance with all relevant requirements of SOLAS, Chapter II-2-Construction-fire protection, fire detection and fire extinction, as amended, is required. The latest version (electronic or hard copy) of the IMDG Code (Volume 1, Volume 2 and the Supplement) shall be carried on board all RMI vessels to which the IMDG Code applies.

Medical Oxygen Cylinders

The MFAG refers to the substances, material and articles covered by the IMDG Code, and the materials covered by Appendix 1 of the International Maritime Solid Bulk Cargoes (IMSBC) Code, for those cargoes identified as being in Group B (cargoes which possess a chemical hazard). Sections 1.7.12 through 1.7.14 of the IMSBC Code provide the full definitions for cargo groups A, B, and C. Note that the IMSBC Code replaced the Code of Safe Practice for Solid Bulk Cargoes (BC Code) on 1 January 2011.

Vessels that fall under Column A or B of the MFAG Appendix 14 – List of Equipment, are required to carry a minimum of 44 liters/200 bar oxygen as follows:

  • one (1) 40 liter/200 bar medical oxygen cylinder located in the vessel’s hospital, assembled for direct use, equipped with one (1) flowmeter unit (two (2) ports) for supplying oxygen for two (2) persons simultaneously; and
  • one (1) complete portable set, ready for use, with a 2 liter/200 bar medical oxygen cylinder and a spare cylinder (also 2 liter/200 bar).

The single 40 liter/200 bar medical oxygen cylinder may be substituted with either two (2) 20 liter/200 bar cylinders or four (4) 10 liter/200 bar cylinders, provided the equipment/flowmeter units are arranged to supply oxygen to two (2) persons simultaneously.

The cylinders are to be hydrostatically tested every five (5) years, or at an interval specified by the manufacturer, whichever occurs sooner. The contents of the cylinders are to be checked and changed as required according to manufacturer’s requirements, or every (3) years, whichever occurs sooner. The entire system is to be inspected annually by a competent person in accordance with manufacturer’s instructions.

It would be acceptable for a vessel which has been issued with a valid Document of Compliance for Dangerous Goods not to carry the medical oxygen cylinders while the vessel does not actually load, carry or discharge any such dangerous goods. Under these circumstances however, the shipboard SMS shall include provisions which ensure that the cylinders/system will be provided onboard before the vessel commences any of the above operations with dangerous goods.

The Administrator interprets MFAG as being applicable to all vessels carrying cargoes which have a UN number. In this respect, it is noted that the introduction to the MFAG states that it should be used in conjunction with the information provided in the IMDG Code, the IMSBC Code, the Emergency Procedures for Ships Carrying Dangerous Goods (EmS), IBC Code and IGC Code.

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