UN 1374, UN 3497, FISH MEAL, FISH SCRAP and KRILL MEAL, IMDG Class 4.2 – Substances liable to spontaneous combustion.

UN 1374, UN 3497, FISH MEAL, FISH SCRAP and KRILL MEAL, IMDG Class 4.2 – Substances liable to spontaneous combustion.

The use of fish byproducts for feeding animals is not a new idea.


The use of fish byproducts for feeding animals is not a new idea.

The Travels of Marco Polo mentions a primitive form of fish meal at the beginning of the fourteenth century. The utilization of herring as an industrial raw material actually started as early as about 800 AD in Norway, with a very primitive process of pressing the oil out of herring using wooden boards and stones.

?“The public health, ecological, and social impacts of fish meal—which were a consequence of its cheapness as a feed ingredient—were largely invisible on the other side of the world.”

The unassuming appearance of the dirty yellow powder does not reflect its significant impact. Fish meal, a protein-dense powder made from dried, cooked, and pulverized fish, has played a crucial role in fueling South American oligarchs, creating slums, reshaping ecosystems, and supporting Europe's agricultural industrialization. The global production of meat and eggs was propelled by fish meal, but it also contributed to public health crises, pollution, and unrest. According to medical and environmental historian Floor Haalboom, this humble commodity's dramatic rise and fall?in the mid to late 20th century offers valuable lessons for today, especially as fish meal's popularity is on the rise again.

There are several ways of making fishmeal from raw fish; the simplest way is to let the fish dry out in the sun.
Carts of fresh sardinella line the street on their way to the Marine fish-meal factory
Fish-meal manufacturing takes small fish or offcuts and processes them into a protein-dense powder used to raise animals like pigs, chickens, and other fish.

The Row Fish contains 70% water + 18% solids + 12% fats = 100%

After processing the row fish into fish meal.

The Fishmeal contains 9% water + 85% solids + 6% fats = 100%

The Row Fish

FISH MEAL, FISH SCRAP and KRILL MEAL are IMDG Classified under Class 4.2 – Substances liable to spontaneous combustion.

Due to the oxidation of unsaturated fatty acids, naturally present in the fat, remaining in the fishmeal after production. One of the by-products of oxidation is heat.

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FISH SCRAP, ROW FISH & KRILL USED TO PRODUCE FISH / KRILL MEALS

UN 1374 / Class 4.2: FISH SCRAP, UNSTABILIZED Packing Group III

UN 1374 / Class 4.2: FISH MEAL, UNSTABILIZED Packing Group III

Not anti-oxidant treated. Moisture content: more than 5% but not more than 12% by mass.

Fat content: not more than 12% by mass.

  • Packaging shall be hermetically sealed.

Special Provisions: 29, 300, 907, 928

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UN 1374 / Class 4.2: FISH SCRAP, UNSTABILIZED Packing Group II

UN 1374 / Class 4.2: FISH MEAL, UNSTABILIZED Packing Group II

High hazard. Unrestricted moisture content, Unrestricted fat content in excess of 12%, by mass; unrestricted fat content in excess of 15%, by mass, in the case of anti-oxidant treated fish meal or fish scrap.

  • Packaging shall be hermetically sealed & bags are not allowed for Packing Group II
  • Flexible IBCs shall be sift-proof and water-resistant or shall be fitted with a sift-proof and water-resistant liner.
  • For solid substances in IBCs other than metal or rigid plastics IBCs, the IBCs shall be carried in closed cargo transport units or in freight containers/vehicles, which shall have rigid sides or fences at least to the height of the IBC.

Special Provisions: 300, 928

?Properties and Observations:

  1. Brown to greenish-brown product derived from oily fish.
  2. Strong odour, which may affect other cargo.
  3. Liable to heat and ignite spontaneously.


UN 2216 / Class 9: FISH MEAL, STABILIZED, Anti-oxidant treated. Moisture content greater than 5% but not exceeding 12%, by mass. Fat content not more than 15%

Special Provisions: 29, 117, 300, 308, 907, 928, 973

Properties and Observations:

  1. Brown to greenish-brown product obtained through heating and drying of oily fish.
  2. Strong odour, which may affect other cargo.
  3. Liable to heat spontaneously unless of low-fat content or effectively anti-oxidant treated.


UN 3497 / Class 4.2: KRILL MEAL Packing Group II & III

Packing Group II = Special Provisions:? 300

Packing Group III = Special Provisions: 223, 300

Properties and Observations:

  1. Pink to red meal derived from Krill, which is a shrimp-like marine organism.
  2. Medium odour, which may affect other sensitive cargo.
  3. Liable to self-heating.
  4. Naturally rich in anti-oxidants, which lessen the risk of spontaneous heating.

Fishmeal in freight containers. " IMDG Code "

7.4.1.3 For stowage of FISH MEAL, UNSTABILIZED (UN 1374), FISH MEAL, STABILIZED (UN 2216) and KRILL MEAL(UN 3497) in containers, the provisions of 7.6.2.7.2.2 also apply.

7.6.2.7.2.2 For containers:

  1. After packing, the doors and other openings shall be sealed to prevent the penetration of air into the unit.
  2. Temperature readings in the hold shall be taken once a day early in the morning during the voyage and recorded.
  3. If the temperature of the hold rises excessively above ambient and continues to increase, the possible need to apply copious quantities of water in an emergency and the consequent risk to the stability of the ship shall be considered.
  4. The cargo shall be stowed and?protected from sources of heat.

Tip: A common misconception is that adding antioxidants to fishmeal makes it safe.

This needs to be corrected. Fishmeal without antioxidants can be safe, while fishmeal with antioxidants may not meet class 9 standards and remain in class 4.2.

?Weathering before shipment?of non-anti-oxidant treated fishmeal allows for the?oxidation of unsaturated?fatty acids, naturally present in the fat, remaining in the fishmeal after production. One of the by-products of oxidation is heat, which is to be removed faster than at which it is produced.

This is to prevent the fishmeal from increasing in temperature, which is undesirable. The rate of oxidation increases with temperature, so?a situation may arise where the rate of oxidative heat production is such that it cannot be removed fast enough; eventually, such fishmeal may reach a temperature at which spontaneous combustion will occur.

Related IMDG Special Provisions:?

29: The packages, including bales, are exempt from labelling provided that they are marked with the appropriate class (e.g. “class 4.2”).

117: Only regulated when transported by sea.

300: Fish meal, fish scrap and krill meal shall not be transported if the temperature at the time of loading exceeds 35°C or 5°C above the ambient temperature, whichever is higher.

?308: Stabilization of fish meal shall be achieved to prevent spontaneous combustion by effective application of ethoxyquin, BHT (butylated hydroxytoluene) or tocopherols (also used in a blend with rosemary extract) at the time of production. The said application shall occur within twelve months prior to shipment. Fish scrap or fish meal shall contain at least 50 ppm (mg/kg) of ethoxyquin, 100 ppm (mg/kg) of BHT or 250 ppm (mg/kg) of tocopherol based antioxidant at the time of shipment.

?907: The consignment shall be accompanied by a certificate from a recognized authority stating:

  • moisture content;
  • fat content;
  • details of anti-oxidant treatment for meals older than 6 months (for?UN 2216?only);
  • anti-oxidant concentration at the time of shipment, see special provision 308 (for?UN 2216?only);
  • packing, number of bags and total mass of the consignment;
  • temperature of fishmeal at the time of despatch from the factory;
  • date of production.

No weathering/curing is required prior to loading.

Fishmeal under?UN 1374?shall have been weathered for not less than 28 days before shipment.

When fishmeal is packed into containers, the containers shall be packed in such a way that the free air space has been restricted to the minimum.?

928: The provisions of this Code shall not apply to:

  • fish meal when acidified and wetted with more than 40% water, by mass, irrespective of other factors;
  • Consignments of fish meal which are accompanied by a certificate issued by a recognized competent authority of the country of shipment or other recognized authority stating that the product has no self-heating properties when transported in packaged form; or
  • Fish meal manufactured from “white” fish with a moisture content of not more than 12% and a fat content of not more than 5% by mass.

a certificate issued by a recognized competent authority of the country of shipment or other recognized authority stating that the product has no self-heating properties when transported in packaged form

?937: Packages, with the exception of bales, shall also display the proper shipping name and the UN number of the substance that they contain in accordance with?5.2.1. In any case, the packages, including bales, are exempt from class marking provided that they are loaded in a cargo transport unit and that they contain goods to which only one UN number has been assigned. The cargo transport units in which the packages, including bales, are loaded shall display any relevant labels, placards and marks in accordance with chapter?5.3.

Finally, sharing knowledge about fish meal will require more than just an article; the above article only scratches the surface. More comprehensive information is needed to provide a thorough understanding of the topic. Please don't hesitate to add any additional helpful information to create a valuable reference for everyone's benefit.

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