Billing Code - PHMSA - Department of Transportation

Adoption of this definition will provide guidance to vessel stowage planners in
determining safe stowage locations for cargo on board vessels.
The term “Protected from sources of heat” as defined by the IMDG Code means
“that packages and cargo transport units must be stowed at least 2.4 m from heated ship
structures, where the surface temperature is liable to exceed 131°F (55°C). Examples of
heated structures are steam pipes, heating coils, top or side walls of heated fuel and cargo
tanks, and bulkheads of machinery spaces. In addition, packages not loaded inside a cargo
transport unit and stowed on deck must be shaded from direct sunlight. The surface of a
cargo transport unit can heat rapidly when in direct sunlight in nearly windless conditions
and the cargo may also become heated. Depending on the nature of the goods in the cargo
transport unit and the planned voyage precautions must be taken to ensure that exposure to
direct sunlight is reduced”. This definition was adopted by the IMO for inclusion in the
next IMDG Code to provide a list of possible sources of heat a cargo transport unit might
encounter during vessel transport. This definition also includes requirements for break
bulk packages stowed on deck that are required to be protected from sources of heat by
means of a stowage provision or a general stowage requirement found in Part 176.
PHMSA received one comment from IVODGA concerning the proposed definition
of “protected from sources of heat.” IVODGA suggested that at the end of the new
definition for “protected from sources of heat” we include that “….containers should not
be stowed in the upper most tier position when this is required, which does not include
tank units that have protective insulation shields” since the new definition seems to bridge
the older shade from radiant heat and other heat related factors onboard vessels. PHMSA
does not see the need to be more specific and restrictive than the internationally accepted
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