The Transportation of Dangerous Goods – Where do you start?
See also December 2011 update on the GHS (Global Harmonised System) for the Classification and Labelling of Chemicals/
Dangerous goods are articles and products which can harm a person’s health, produce a safety risk and/or environmentally hazardous to the environment.
The carriage of dangerous goods is governed by a number of regulations. The main three modes of transport, air, sea and road, are covered by –
ADR – European Agreement concerning the international carriage of dangerous goods by road;
IMDG – International Maritime dangerous goods regulations;
IATA -International Air Transport Association regulations.
These regulations are subject to change, the ADR and IMDG changing every two years (current edition 2011). IATA changes every year.
Consideration may also need to be given to “The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009, (example gas cylinders), although these now implement the ADR regulations.
Shippers, whether despatching or receiving have a duty to ensure that consignments comply with the regulations. Coupled with this, in ADR, there is a requirement to ensure that vehicles, including equipment carried, documentation on board, and driver licences comply.
This all sounds quite daunting so shippers should also be aware of exemptions for small consignments and loads. We will talk about these later in this article.
Consideration should be given to IMDG when consignments are crossing water and there is a road journey, before and after this. Here the sea journey is classed as the most hazardous part and the IMDG then takes precedence over ADR for the goods being shipped. The vehicle is still subject to ADR.
The Channel Tunnel’s policy on transporting dangerous goods is based on ADR but it is stricter.
Training of personnel dealing with dangerous goods, whether physical handling or consigning, is essential and the regulations specify that training should take place prior to personnel taking up their responsibilities. There is a requirement to refresh this training every two years.
Having been an Export Shipping Manager in a company which dealt with the despatch of dangerous goods I know it can take quite awhile to despatch these types of products. One area which always concerned me was the lack of knowledge out in the field (sales). The primary job of a sales person is to obtain an order and when achieved job is done, but it is not wise to promise a potential or existing customer a sample or order quickly when dangerous goods are concerned. Why? Despatches by air have to be x-rayed, packages and documentation checked and only then will the consignment go forward for despatch. In all three regulations you then have to consider compatibility, some classes of hazardous goods cannot be shipped together, or at least, be segregated. This all takes time!!
This all sounds daunting! Where do you start?
As a shipper or receiver of dangerous goods you should be in possession of a Material Safety Data Sheet (MSDS). Box 14 on this document will state whether the goods are dangerous, or not, for transport. If not, then you can proceed as a non-hazardous shipment. Box 14 will provide UN Number, Class Number, Packing Group (if required) and Proper Shipping Name, all being essential information for progressing the despatch of the consignment.
Next step will be to package the goods. Check the regulations to see if UN specified packaging is required or, if small quantities can the consignment be classed as “Limited or Excepted Quantities” and then UN packages are not required. UN packages have been leak, drop and stack tested to ensure that they maintain their integrity in difficult circumstances. Always worth looking at the “special provisions” in the regulations as these can contain information which may remove some of the requirements.
The packages will now require labelling and marking. If fully regulated (outside of limited and excepted quantities) they will require the UN number and Proper Shipping Name marking on the package at the very least. Remember this should be undertaken in a manner so that the marking remains on the package, and can be read even if the consignment falls into extreme conditions, such as being immersed in water for a period of time. “Labelling” refers to the Class label(s) and “Handling” label(s) if required.
For ease of handling the packages may then be placed on a pallet and shrink-wrapped. It is important that the above information can be seen.
You must inform the freight forwarder or ferry line that the goods are dangerous for transport. It is worth remembering that air and sea freight consignments will always need a dangerous goods note. Limited and excepted quantities by road do not require completion of this document. Failure to advise the dangerous nature of the goods can lead to all sorts of problems and hefty fines!!!
The picture shows a vessel on fire. This was caused by a dangerous shipment being declared as non-hazardous. No special precautions were put in place and a problem arose. Result vessel sank fortunately without any loss of life.
If a company only despatches small consignments then the exemptions under “Limited and Excepted quantities” should be considered. The principle in both these exemptions are the same. First of all it applies to have much material can be placed in the inner package, and then the maximum allowed in the outer package. Most Packing Group I (high risk) materials fall outside of these exemptions
Secondly, you do not have to use UN certified packages, but common sense must prevail and sturdy outer packages should be used. Excepted quantity packages, although not UN tested, should be internally tested as per the test specifications set out in the regulations. This also relates to limited quantities for air freight.
Thirdly, you only have to label the package with a LQ or EQ label.
For limited quantities inner package limit ranges from 1-6 kilos (or litres). Outer package has to be a maximum of 30 kilos gross weight, or 20 kilos for shrink-wrapped trays.
For excepted quantities inner package limit ranges from 1-30grm/ml and outer from 300-1000grm/ml.
One more area to think about – the vehicle on which the dangerous goods are transported! Shippers have a duty to check that the vehicle is carrying the prescribed equipment and documentation as laid down in ADR. This applies to both despatches and arrivals. There are some exemptions for LQ and EQ. Is the vehicle over its threshold limit for the type of goods on board, which then makes it a fully regulated journey? Does the vehicle need to be orange plated? Are Instructions in Writing required?
All this can be completed in the form of a “Vehicle Check List” but knowledge of ADR is required to ensure it is completed accurately. If VOSA (Department of Transport) stop a vehicle carrying dangerous goods they can check with the companies the vehicle has visited to see if any checks have been carried out!
Companies who store, package, mark, label, consign dangerous goods on a regular basis, outside of limited and excepted quantities, should ensure they have a Dangerous Goods Safety Advisor. This person can either be an employee or an outside consultant.
Having read the article I am sure you will agree that it is essential to have access to the current transport regulations. The liability is yours if anything goes wrong, and ensure your personnel are trained in the areas specific to their responsibilities.