Introduction to the Transport of Packaged Dangerous Goods

86 New Forest Drive, Brockenhurst, Hampshire SO42 7QW Tel: +44(0)15890 622 015 Fax: +44(0)15890 622 232 E-mail: Info@DanGoods.co.uk Web:www.DanGoods.co.uk VAT Registered number: 731 6338 44

DanGoods

Training & Consultancy Limited

Introduction

to the

Transport

of

Packaged

Dangerous Goods -

2015

Copyright (c) Desmond Waight 2014, 2015

However may be passed on as a complete unchanged document, provided without charge, to anyone needing a basic understanding of the requirements relating to the transport of dangerous goods.

DanGoods Training & Consultancy Ltd Pine Lodge

86 New Forest Drive Brockenhurst SO42 7QW tel : +44(0)15890 622 015 fax : +44(0)15890 622 232 mobile: 07880 72 33 30 Intl + 44 7880 72 33 30 e-mail: info@dangoods.co.uk

Registered in England & Wales. No. 3812168

Transport of Packaged Dangerous Goods

Contents

Introduction

International Regulatory Bodies The UN Recommendations ICAO Technical Instructions

IATA Dangerous Goods Regulation IMDG Code

ADR/RID Agreements UK National Rules

Recognition, Danger Classes, and Classification Recognition

Danger Classes Classification

Proper Shipping Name & UN Number Environmental Pollutants Packaging General Outline UN General Conditions UN Package Testing Test Reports Relaxations

Labelling &/or Marking

Containerisation and vehicle loading Placarding &/or marking

Documentation Training Conclusion

INTRODUCTION

Dangerous goods have been regulated in some modes of transport for about 120 years. However the relative importance of the current regulatory bodies is not related to their age, with the most recent entrants perhaps exerting far more influence than some of the more established.

The first international rules covering the transport of dangerous goods (by rail in Europe) date back to 1893.

International air transport, effectively globally, was initially controlled by the terms and conditions of the airline operators which stemmed from 1955; with Governmental control being introduced in early 1980s, as some Governments were unable to

legislate on the basis of rules developed by a trade association.

International road transport in Europe took a long time to develop, and, when it finally did in 1957, it harmonised classification, packaging and labelling issues with the international rail requirements; though developing its own operational requirements relating to vehicles, etc.

Sea freight introduced a general international, effectively global, requirement in 1928, with more detailed requirements following in 1933; though real progress wasn’t made internationally until 1965.

However, through the foresight of the United Nations (UN), its Economic and Social Council recognised in 1953 the need for ‘Recommendations on the Safe Transport of Dangerous Goods’ (RTDG) covering all modes of transport. It set up its ‘Committee of Experts on the Transport of Dangerous Goods’ (UN COE on TDG).

The aim was to provide a base to which all the differing international and national rules can essentially be harmonised, and to leave modal (i.e. air, sea, road, rail, inland waterway, tunnels) issues to the relevant international or regional or national body. The Recommendations were not intended, and do not have, direct effect on

consignors (shippers), consignees, transport operators, etc..

The first Edition of the Recommendations was published in 1957, and they have been revised many times since. A substantial restructuring (reformatting) took place with the 10th Revision, with much reduced Recommendations and a new Annex of Model Regulations. However it wasn’t until the 11th

Revised Edition that the restructured Model Regulations were considered suitable for adoption by the modes, which

occurred in 2001. The most current published version (as at January 2015) is the 18th Revised Edition, which was agreed in December 2012. As at January 2015 the 18th Revised Edition is currently being applied by the various transport modes (air, sea,

road, rail, inland waterway) for the 2013/2014 biennium. In December 2014 the UN SCETDG agreed the changes to create the 19th Revised Edition, which will be formally published in mid-2015. The changes in the 19th Edition will be reflected in the 2017/2018 modal editions. Since 2001 the UN Orange Book Editions can be accessed and downloaded free of charge from the UN ECE website at

http://www.unece.org/trans/danger/publi/unrec/rev13/13nature_e.html

The UN Recommendations and Model Regulations (known in short as “RTDG” or the “Orange Book”, after the background colour of the covers of the two volumes that form the book) are accompanied by a companion ‘Manual of Tests and Criteria’

(MTC), which gives detail of some of the tests to be used to classify dangerous goods. This (as at Janaury 2015) is in its 5th revised Edition, as amended by the separately published “MTC Amendment 1” and “MTC Amendment 2”. Note Amendments to the MTC are not made on any regular time basis. The MTC editions and amendments can be download from the UN ECE website at

http://www.unece.org/trans/danger/publi/manual/manual_e.html

In July 2001 the UN Committee had its remit extended and was renamed the Committee of Experts on the Transport of Dangerous Goods and the Globally Harmonised System of Classification and Labelling. Two sub-committees were formed:

1. Sub-Committee of Experts on the Globally Harmonised System of Classification and Labelling of Chemicals (UN SCEGHS)

This is concerned with the “Globally Harmonised System of Classification and Labelling”, known in short as GHS or the “Purple Book”, from the

background colour of the covers. GHS Notes:

a. In retrospect it would have been more accurate to say “Hazard Communication” rather than just “Labelling”, as the GHS covers Safety Data Sheet (SDS) as well as classification and labelling issues. b. GHS is applicable to supply and transport and other areas of hazard classification (i.e. storage, use and waste)

This Sub-Committee is responsible for maintenance and development of the GHS system of classification. This identifies different classes of hazard, usually sub-divided into categories of danger within a class.

It should be noted that the GHS is intended to cover all areas of application, not just transport and supply, but also storage, use, wastes etc. However each area of application will determine which of the classes, and categories of a

class, should be regulated by their provisions. The UN SCEGHS is

responsible for the updating of the GHS publication. These are available from the UN ECE website at

http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

2. UN Sub-Committee on the Transport of Dangerous Goods (UN SCETDG) This sub-committee is concerned with the transport of dangerous goods. Whilst it will remain responsible for this area classification criteria development has been passed to the GHS group with the SCE-TDG

implementing the decisions and determining which classes and categories will be subject to transport regulation.

The UN SCE-TDG is responsible for the updating of the UN

Recommendations and Model Regulations, and for updating as necessary the MTC.

Modal (i.e. global air, sea, and European road and rail) adoption of the latest UN Orange Book changes is usually two years one month later, so the provisions of the UN 18th Revised Edition, that was agreed in December 2012, were applied by the modes from the 1st January 2015, albeit with some transitional periods for road (to 30.6.2015 in general) and sea (to 31.12.2015) modes, during which the previous provisions could still be used.

Whilst initially there were considerable differences between the modes and the UN Recommendations in the last decade considerable strides towards harmonisation has occurred, with very significant alignments being introduced by the sea, legal air (see later), European road, and European rail modes. However some significant and other differences do still remain.

The modes also have their own unique transport mode operational provisions, e.g. the road mode will cover driver training and vehicle construction issues.

International Regulatory Bodies.

The UN Recommendations

The major global influence on packaged dangerous goods transport is the UN Recommendations and Model Regulations on the Transport of Dangerous Goods. Note: though the RTDG is commonly referred to as the Orange Book as result of the current cover colour it hasn’t always been orange coloured. Other requirements relating to dangerous goods particularly ADR –see later - and the MTC also have orange covers, but these latter publications should not be referred to as the ‘Orange Book’ to avoid confusion with the UN Model Regulations.

The UN Recommendations and Model Regulations have no direct bearing on shippers and transporters, as they are addressed to the international regulatory bodies and to national governments as the recommended basis for the development of their own requirements. However they are very important, as they determine the future changes in the modal provisions to a very great extent.

The Recommendations define the universally recognised 9 danger “Classes”, some of which are divided into “Divisions”, and the criteria for classification. They also provide supplementary classification criteria for determination as to whether a substance/preparation/mixture is an Environmentally Hazardous Substance (EHS). They then give a deliberately short list of descriptions (known as Proper Shipping Names -or PSN for short-) the most appropriate of which must be used for the dangerous goods so classified. These PSNs cover from pure substances, through chemical and product group types to generic hazard type descriptions and allocate to each a four digit number, known as the ‘UN Number’. This number is unique to that dangerous good throughout the world. UN Numbers are never re-allocated.

The Recommendations also contain packaging provisions which are based on the concept of simple design type tests, certification and subsequent package marking; though with exceptions, such as for limited quantities of dangerous goods. The scheme for packaging is often known as UN approved packaging, or Performance Orientated Packaging (POP).

Labelling, marking, placarding, documentation, etc requirements are also laid down. In respect of radioactive materials the UN defers to the requirements of the

radioactive materials. IAEA being another specialised UN group, though the provisions are re-written into the UN Orange Book.

The UN Orange Book also lays down initial training requirements applicable to anyone who will be involved in the transport of dangerous goods, and the need for refresher training to take account of changes in the rules. This training MUST be given before any involvement by the employee with dangerous goods for transport, unless the employee is working under the direct supervision of a person who has been trained. The training must be recorded by the employer and copies made available to the employee on request.

A feature introduced by the UN 13th Edition was the introduction of security

requirements for transported dangerous goods, designed to try and lessen the chance of dangerous goods from being used in terrorist activity. Special measures are laid down for ‘high consequence’ dangerous goods.

The UN recommendations are universally recognised as the basis for modal (air, sea, road, and rail) or national rules to be based upon, and to harmonise to.

ICAO Technical Instructions

The International Air Transport Organisation (ICAO), a UN body, regulates the transport of dangerous goods and articles by air and publishes its ‘Technical Instructions for the Safe Transport of Dangerous Goods by Air’ (TIs) on a biennial basis.

These TIs follow UN Recommendations very fully, adding special requirements applicable to the air mode, such as very severe restrictions on the amounts permitted in packages to be flown on passenger bearing aircraft, a special requirement for receptacles carrying liquid dangerous goods to be able to meet a pressure differential (to deal with the possible de-pressurisation of an aircraft in flight), and additional mandatory training provisions.

The 2015/2016 Edition was applicable from 1.1.2015, basically without any transitional provisions. The TIs are quite well harmonised with the UN Model Regulations, however packaging instructions are not yet aligned to the UN Orange Book scheme, due to the far more restrictive regime that is applied to air.

ICAO also has an additional Part 8 dealing with dangerous goods carried by passengers and crew. NOTE: The air mode is unique in that carriage of good by private persons is only within scope of the air requirements. Under UN and the surface modes such goods are generally excluded from scope.

IATA Dangerous Goods Regulations

Whilst ICAO TIs are the legal text for the carriage of dangerous goods by air, the IATA Dangerous Goods Regulations (DGRs) are often the ones used in practice by shippers and others involved with airfreight.

The IATA DGRs repeat, albeit in different format that is also not aligned to the UN Orange Book’s format, the ICAO TIs requirements, and additionally contains certain conditions of carriage, the principal of these being a special shipper’s declaration format.

The IATA DGRs are published annually (as IATA gets substantial revenue from this).

IMDG Code

The International Maritime Organisation (IMO), another UN agency, publishes a range of requirements. One of which is the International Maritime Dangerous Goods (IMDG) Code, which sets out the sea mode’s requirements for the transport of dangerous goods.

The IMDG Code is largely harmonised with the UN Recommendations.

The IMDG Code’s classification packaging and labelling rules generally follow those of the UN; though the IMDG Code does also contain the unique requirements to classify and label certain substances, and preparations containing over a certain amount of those substances, as Marine Pollutants. Where the goods have no other hazard classification than Marine Pollutant, they are allocated to Class 9. (See below) The Code is currently amended every two years. The current edition, as at January 2015 is the 2012 Edition, which came into force on 1.1.2013, with a transitional period that ended on 31.12.2013. The latest Edition, the 2014 Edition, may be used on a voluntary basis until 31.12.2015; and will become mandatory for use through 2016 and 2017.

NB: The 2008 Edition saw a significant revision to its marine pollutant provisions, with adoption of the UN’s Environmental Hazardous Mark (EHS Mark) for its Marine Pollutant mark in place of the former (a half diamond with an outline ‘shark’ with a cross over).

IMDG Code has a supplement, and in this can be found the Emergency Action Schedules (EmS) codes, covering fire and spillage, and Medical First Aid Guide (MFAG). The EmS codes assigned to dangerous goods are found in the Dangerous

Goods List of the IMDG Code, and are not required to be given on documentation under the Code. The Medical First Aid Guide is based on symptoms and there should be no need to quote this for a particular dangerous good on the dangerous goods documentation.

ADR/RID Agreements

These two agreements cover the international transport of dangerous goods by road and rail respectively.

ADR (Accord européen relatif au transport international des marchandises

dangereuses par route) has been kept aligned to the older RID (Règlement

concernant le transport international ferroviare des marchandises dangereuses) in the areas of classification, packaging, labelling and marking through the medium of joint meetings to develop these aspects of the agreements.

ADR then additionally specifies operational aspects relating to international transport by road, such as provisions relating to transport equipment and their operation. This includes the provision by the carrier to the vehicle crew of ADR standardised emergency instructions in writing ( IiW) which from July 2009 became a standard 4 page instructions covering all classes replacing the former system commonly known as TREMCARDS (which was short for the special series of specific ‘substance’ by ‘substance’ instructions known as TRansport EMergency CARDS, which had been developed by the Conseil Européen des Fédérations de l’Industrie Chimique

(CEFIC)). Note: The format was amended by the 2011 Edition, and again by the 2015 Edition (though extended transitional provisions apply)

RID similarly additionally specifies special matters applicable only to the rail carriage of dangerous goods.

The 2015 Editions came into force on 1.1.2015 with a basic six month transitional provision that ends/ended on 30 June 2015, though some issues have longer transitional provisions.

New Editions come into effect every two years.

From the 2009 Edition ADR/RID also followed the sea lead (and not the UN Orange Book) and for the first time applied the supplementary classification and application of the EHS mark to all goods, inclusive of those in the Classes 1 to 8. This became fully mandatory from 1.1.2011.

ADR agreement covers transport between any two contracting states to ADR of which there are 48 covering the wider Europe and beyond. The United Kingdom is an ADR contracting state.

RID covers basically the same countries but extends further into the Middle East.

National Rules

AIR

National rules for air usually require that those involved follow the ICAO TIs (not the IATA DGRs) in all respects. This is the case in the UK though the Air Navigation (Dangerous Goods) Regulations 2002, as amended.

SEA

The IMDG Code is also usually followed also for national transport of dangerous goods, though there is a special Baltic Agreement that operates for the very short ferry crossings between Denmark, Finland, Germany, Poland and Sweden, and allows some carriage in conformance with ADR/RID.

In the UK the Merchant Shipping (Dangerous Goods and Marine Pollutants)

Regulations 1997, as amended, require compliance with the current Code via issue of a Marine Shipping Notice (MSN) issued by the Maritime and Coastguard Agency (MCA).

ROAD/RAIL

For national road transport most European countries utilise the ADR/RID Agreement, though with some relaxations in the operational areas (but generally not in packaging and labelling).

For those countries in the European Union (known by the acronym EU) Directives and regulations can be made under the European Community (EC) treaty. The 2008/68/EC Inland Transport of Dangerous Goods Directive (ITDGD), as amended, requires that Member States basically adopt the requirements of ADR & RID as national requirements. However there are derogations to these Directives that MS can take advantage of to maintain previous national provisions in their country.

Great Britain in 2009 adopted new regulations, the “Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009” which came into force on 1.7.2009, implementing the ADR/RID Editions. CDG2009 basically makes the requirements of the current ADR/RID Editions (i.e. now the ADR/RID 2015 editions) applicable domestically; albeit with certain derogations permitted and additional provisions (these relate to explosives and the need to use the UK’s Emergency Action Code (EAC) scheme on tankers and bulk carriage of dangerous goods). Small

Directive (new TPED)) were made in September 2011. An even smaller amendment was made in 2013 affecting Schedule 2 to reflect the demise of the Health Protection Agency and take up of its duties by a Secretary of State.

Northern Ireland (NI) makes its own equivalent statutory rules (one set for explosive, with another for all other dangerous goods). However these reflect the GB provisions. The GB and NI regulations are supported by a approved document known as the "Dangerous Goods: Approved Derogations and Transitional Provisions" (ADTP) which gives the applicable special derogations. A revised 2012 edition was published in March 2012. This had only relatively minor changes; except in relation to old tanks used only domestically, where significant changes to the requirements were made (albeit with transitional provisions).

Also supporting the Regulations is the “Emergency Action Code (EAC) List”. A new 2015 edition is expected to be available in February 2015, and to be available free of charge as a pdf download on the National Chemical Emergency Centre (NCEC) website at http://the-ncec.com/. This gives the EAC codes seen at the top of dangerous goods tanker and bulk vehicle orange coloured plates.

RECOGNITION, DANGER CLASSES AND

CLASSIFICATION

Recognition

The first step in the safe transport of dangerous goods is to ensure that all potentially dangerous goods, i.e. both substances and articles, are recognised.

This requires an appreciation of the requirements throughout an organisation, and awareness that some common expressions used to describe goods in commerce may hide their potentially hazardous nature.

Danger Classes

There is now universal acceptance of the nine danger classes, and the further splitting of some of these classes in to divisions or sub-classes.

The UN uses for some classes/divisions a splitting of the dangerous goods into one of three Packing Groups (PG) (shown I, II, or III, not 1, 2, or 3) according to whether the goods are those with the greatest degree of danger for that class (PG I), with the medium danger (PG II) or the minor danger (PG III).

Danger Classes

The nine UN danger Classes and their Divisions are:

Class 1 - Explosives.

Substances which in themselves are capable by chemical reaction of producing gas at such a temperature and pressure and at such speed as to cause damage, and articles containing explosive substances. The class also includes pyrotechnic substances and articles.

Divided into 6 divisions (1.1 to 1.6) and thirteen compatibility groups (A to S, but no ‘I’, ‘M’ or ‘O’). Test methods are prescribed, but anyone suspecting their goods are explosive must usually get the competent authorities to undertake the classification.

Class 2 - Gases.

Divided into three divisions; 2.1 Flammable gases,

2.2 Non-flammable, non toxic gases, and 2.3 Toxic gases.

Classification is largely based on their physical characteristics, though toxicity testing may be required for Division 2.3 goods.

Class 3 - Flammable liquids & liquid desensitised explosives.

Generally determined by the flashpoint (FP) of the material (the lowest temperature at which just sufficient vapour is given off to be ignitable when a flame is introduced into the vapour).

UN classifies goods when the flashpoint is below 60C (by closed cup flashpoint test), but also provides that above 35ºC that the goods must also support combustion (i.e. be able to catch fire and continue to burn) to be classified as Flammable Liquids. The UN also includes in Class 3 goods with flashpoints >60ºC, where those goods are carried at a temperature exceeding their flashpoint.

ADR/RID follows UN, except certain fuels are still considered as Class 3 even if their flashpoint exceeds 60ºC (but does not exceed 100ºC)

The Packing Group is allocated on basis of flashpoint and boiling point (PG I if boils below 35ºC, PG II if boils at 35ºC or above and FP is below 23ºC, and PG III if boils above 35ºC and FP is in range 23 to 60ºC (or 100ºC for diesel etc), or in the case of some viscous materials meeting additional criteria).

Liquid desensitised explosive (whether flammable or not) are also assigned to Class 3.

Class 4 - Other flammables (in short)

Division 4.1- Flammable solids. Solids which under transport conditions are likely to be readily combustible or to contribute to fire through friction. Also self-reactive and related substances that are liable to undergo strongly exothermic reaction and solid desensitised explosives that may explode if not ‘diluted’ properly.

Test methods involve either a fire train test, and in the case of those likely to cause fire through friction by analogy with substances classified by the UN Experts. For self-reactive substances a series of tests and complicated flow chart process is used to evaluate the substance.

Div 4.2 -Substances liable to spontaneous combustion. Substances which under normal transport conditions are liable to spontaneous heating, or to heating in contact with air, and then are liable to catch fire.

Tests for pyrophoric substances consist basically of exposing a controlled amount to the air and observing the results. The speed at which combustion occurs determines

the substance as being of Div 4.2 and the applicable Packing Group. Tests for self-heating substances involves making a cube of the substance of prescribed sizes, keeping in a constant temperature environment, and seeing if the temperature in the sample rises to above 200ºC. PG I is assigned to pyrophoric substances, PG II to self-heating substances which exceed the 200ºC when in a small cube, and PG III when exceeding the 200ºC in the large cube only.

Div 4.3 -Substances which in contact with water emit flammable gases. Test method involves adding water to a measured amount of the substance and checking the rate of issue of flammable gases given off. PG I is ascribed to any substance that gives off gas and immediately ignites or where the rate of evolution of gas exceeds a set amount ( 10 litres per kg of substance in any one minute). PG II or III is ascribed when the evolution rates exceeds limit values.

Class 5 - Oxidising and organic peroxide substances.

Div 5.1. -Oxidising. These are substances which, whilst not necessarily combustible, can assist the combustion of other materials through the provision of oxygen.

Test methods involve mixing the substance with softwood sawdust and observing the rate of burning when ignited.

The classification and PG are obtained by comparing the rate of burning of the substance with sawdust against the rate of burning of the sawdust with certain reference chemicals.

Div 5.2 -Organic Peroxides.

These are substances that are liable to exothermic decomposition, which can be initiated by heat, impurities, friction or impact.

They are recognised by their chemical property, in that they contain a bivalent -O-O- structure.

Packing Groups are not allocated but Organic Peroxides are classified into one of seven types (A to G) though items of Group G are not considered dangerous for transport.

Class 6 - Toxic and infectious substances.

Div 6.1 - Toxic.

These substances are liable to cause death or serious harm to health.

Classification should be done on the basis of known human health effects which have been shown by experience (e.g. methanol), but in the absence of human experience then animals tests should be considered, using exposure through the three routes (oral, dermal and inhalation) in order to determine the LD50, which is the calculated dose necessary to kill half the population of the test animals. Note that it is important to ensure that all three routes of exposure are considered.

Classification and Packing Group assignment is based on the results of the tests, though calculation of the classification of mixtures via the supply system can be used to achieve a transport classification.

Div 6.2 -Infectious substances.

Are those containing viable micro-organisms that are known or reasonably believed to cause disease in man or animals.

Tests and allocation of Packing Groups is not applicable to this Division.

Class 7 - Radioactive Materials.

These are those containing radionuclides where both the activity concentration and the total activity in the consignment exceed specified values. Packing groups are not used, but there is a special system of sub-classification of radioactive substances laid down by the International Atomic Energy Agency in their Regulations covering the transport of radioactive materials.

Class 8 - Corrosive substances.

These are substances that will cause severe damage by chemical action when in contact with living tissue, OR which if leaked in transport will materially damage or destroy other freight or the means of transport.

Tests for tissue effects, if necessary, to determine classification and Packing Group involve leaving the substance on the skin of a tests animal for set periods of time (3 minutes, 1 hour and 4 hours) and then observing whether necrosis ( death of one or more cells) has occurred.

Even if no effect on human tissue is observed the substance should still be considered for its effects on aluminium and steel to see if corrosion exceeding 6.25 mm a year at a temperature of 55ºC. If so the substance is ascribed to PG III. Note: Metal

corrosion can be an issue for chemicals not even irritant to tissues under the supply system (especially low concentrations of acids on steel and low concentrations of alkali on aluminium).

Class 9 - Miscellaneous dangerous substances

These are substances and articles which present a danger during transport but are not covered in other classes.

It includes a wide variety of materials, inclusive of certain asbestos goods and lithium batteries

There is provision for substances not having any other hazard classification to be considered as dangerous goods of Class 9 as result of their environmental hazards. NOTE BENE see however comments under IMDG and ADR earlier as they apply the criteria to require a supplementary* classification as Marine Pollutant (MP) and Environmentally Hazardous Substances (EHS) respectively (whereas UN only considers environmental if the goods are not otherwise dangerous; on the basis that if dangerous then they will per se be environmentally damaging. )

* NB: this is not a Class 9 subsidiary hazard.

Packing Groups, if any, are individually allocated in Class 9

Classification

The process of classification involves the methodical examination of the physico-chemical and toxicological and other properties of the good to be transported (be it substance, preparation, mixture, or article) to see which of the classes or divisions the good meets the definition of.

In the case of the good possessing characteristic properties of more than one Class or Division a scheme of precedence is used to arrive a prime risk, and to determine which of the other classifications should be considered as a subsidiary risk.

Proper Shipping Name & UN Number

After classification the classifier should then determine which ‘Proper Shipping Name’ (PSN) should be ascribed to the goods to be transported, and its accompanying unique worldwide four digit United Nations number.

This PSN may be the chemical name of the substance (e.g. ACETONE UN 1090), or the chemical group name (e.g. CHLOROTOLUENES UN 2238), or may be a type of preparation with certain common characteristics (e.g. ADHESIVES containing

flammable liquid UN 1133), or a generic hazard type description (e.g. FLAMMABLE LIQUIDS N.O.S. UN 1993).

It should be noted that only that part of the entry (in capitals in the UN List, the IMDG Code, ADR and RID but in bold mixed case type in IATA ) is the PSN that needs to be some to be shown on packages and documentation, the rest of the text being supplementary.

For example in ‘UN 1133 ADHESIVES containing flammable liquid’ the PSN is simply ‘ADHESIVES’ or ‘ADHESIVE’; with use of capitals optional.

The abbreviation ‘N.O.S.’ at the end of an entry stands for ‘Not Otherwise Specified’. Most, but not all, of the entries that have this notation must have after the PSN the name of the chemical or chemicals (normally maximum of two need be given) that give(s) rise to the hazard(s),. This is often referred to as the ‘technical name’. The need for this is identified by the listing of Special Provision 274 against that good in the Dangerous Goods List (or by asterisk in the case of IATA). SP 247 is also applied to some goods without the N.O.S. ending to the PSN.

Trade names are NOT acceptable as descriptions for dangerous goods.

In the case of goods without a specific name, mixtures, solutions and preparations it is necessary to allocate the good to the most appropriate PSN and UN number.

In the case of mixtures and solutions this process, which is laid down in the various regulations, may result in the use of the PSN of the dangerous component, in which case the qualifying word ‘Mixture’ or ‘Solution’ is added to the PSN (e.g. ACETONE SOLUTION UN 1090), or in the use of one of the group or generic hazard PSN.

Environmental Pollutants

Marine Pollutants

A special requirement of the IMDG Code is the additional step of deciding whether the good is classed also as a Marine Pollutant (MP).

In the case of substances this used to be a simple case of seeing if the substance is listed and if it has been allocated as either a Severe Marine Pollutant (shown with pp sign in the Index to the IMDG Code), or a Marine Pollutant (shown by p). If the substance is not indicated as a Marine Pollutant then there was no call for the shipper to attempt to self classify.

However from 1.1.2014 the IMDG Code requires the application of the GHS aquatic pollutant criteria as Aquatic Acute Category 1 or Aquatic Chronic Categories 1 or 2 under the GHS Revision 3 criteria; and requires that all goods be considered for this hazard. Additionally substances indicated (by again a p mark) in the IMDG Code index as Marine Pollutants are to be considered as such unless the consignor to demonstrate to the satisfaction of the Competent Authority (CA) that they are not.

Aquatic Pollutants

ADR/RID allocates as Environmentally Hazardous Substances (EHS) those chemicals assigned as Aquatic Acute Category 1 or Aquatic Chronic Categories 1 or 2, also

using the criteria of the GHS 3rd Revised Edition. ADR/RID also allow classification using either the criteria for “N” symbol classification under the EC’s 67/458/EEC Dangerous Substances Directive (DSD) or 1999/45/EC Dangerous Preparations Directive (DPD) as implemented in Great Britain by the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 or as Aquatic Acute Category 1 or Aquatic Chronic Categories 1 or 2 under the Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (in short CLP). If not hazardous per CLP but dangerous per DSD/DPD then

classification is not required.

PACKAGING

General outline

The UN Recommendations cover packaging for all types of dangerous goods except for gas cylinders and packaging for Radioactive Materials. They lay down some general conditions that are reflected in the various modal regulations; and then go on to prescribe a system for simple testing, certification and marking of packages and IBCs.

For example, for a package of Class 3 PG III dangerous goods, inner plastics bottles shall not exceed 30 litres content and, if the outer package is a fibreboard box, that the package shall have a 400 kg maximum gross mass.

The modes have adopted the concept of UN package scheme but each mode specifies the types and sizes of packages that it will accept, and these may differ from the UN scheme

For air the packages sizes allowable are generally quite small for packages to be carried, as cargo, on passenger carrying planes, and only combination packages (inner receptacles in outer packagings) are permitted on such flights.

UN General Conditions

These require that dangerous goods are packed in packages which are in good condition and are properly constructed and closed so as to prevent leakage. They should be capable of withstanding changes in temperature, humidity or pressure. No external contamination should be present. Those parts that come into contact with the dangerous substance should be resistant to it. Packages for liquids should be filled

with sufficient ullage to prevent leakage or distortion due to the expansion of the goods with temperature (max 55ºC). Other specific provisions exist.

NOTE BENE: The UN package tests, see below, do NOT guarantee suitability as required by these general conditions.

UN Package Testing

The basis of the UN package testing scheme is that design type samples (i.e. samples of the complete package that it is intended to be used - e.g. primary receptacles with the specific closure, internal packaging such as dividers, the outer packaging and the package closure defining the ‘package’) are subjected to simple mechanical tests to demonstrate that the design should be able to meet the stresses and strains of normal transport.

All packages are subject to a drop test, with the height of the drop being determined by the Packing Group of the goods for which the package is being designed. (PG I = 1.8 m, PG II = 1.2 m and PG III = 0.8 m), which they must be able to survive without leakage or any damage liable to affect the safety of the package. When dropping plastics they have to be conditioned to minus 18ºC, at which temperature they are more brittle.

All packages (except strangely bags and sacks) are also subject to a stacking test, which involves subjecting three samples to an overload equivalent to the load of a stack of 3 metres of the same packages for a set period (24 hrs). In the case of plastics drums, jerricans and composite plastics packaging the test period is 28 days at an elevated temperature (40ºC).

Single receptacles for liquids (e.g. drums, jerricans, etc.) have additionally to be subjected to further tests. A hydraulic leakage test to show that the receptacle can withstand the maximum pressure that would be developed in the receptacle at 55ºC, with a 50% safety margin, and a leak-proofness (air leakage test at 0.3 bar for PG I and 0.2 bar for PG II and III). The leak-proofness test has to be carried out on all PRODUCTION receptacles, as well as on the design type.

A more extensive series of tests is prescribed for IBCs.

Packages and IBCs that have successfully undergone the tests at an approved test house are awarded a certificate that specifies the UN package or IBC mark that must be shown on production packages that conform to the design type tested. For example a fibreboard box tested with inner receptacles might be marked

Use of a UN marked outer package with inner receptacles for which it is not certified is NOT acceptable to the authorities.

Certificates and Test Reports

Whilst the UN does not require the issue of a certificate for packages that have passed the design type test requirements it is common for this to be done.

More importantly the UN does require the preparation of a test report, and require that a copy of this be made available to the user, and that the user conforms to any

requirements therein.

Thus it is essential that users of any UN marked package (including any re-used package) obtain a copy of the test report and comply with any provisions therein. For example the style and material for closure, any closure torque specified, as well as inserts and void filling provisions.

Relaxations

Limited Quantity packages (LQ)

Since the UN test/certification/marking system takes time and can be expensive, a system of relaxed requirements is specified for limited quantities packages, of certain categories of dangerous goods. The individual modes give different limits to which these Ltd Qty provisions apply.

Note: It is essential to refer to such packages as “Limited Quantity Packaging”, since a system for Limited Quantity Loads (Small Loads) can also be applicable.

Excepted Quantity packages (EQ)

The air mode, which has quite strict, compared to the other modes, requirements has had for some time a system of Excepted Quantity Packaging which essentially allows very small amounts of certain dangerous goods, packaged in triple layer, self tested packages, to be carried by air without many of the requirements that would normally apply. From 2009 a new system derived from the former air system and defined in the UN Orange Book has been introduced into ALL modes (replacing the former air scheme for air). The individual modes still however have some differences. De minimis

In 2013 a new sub-set of EQ packages concept was introduced. This provides that for extremely small amounts (never exceeding 1ml or 1g) of certain dangerous goods provided there is compliance with packaging provisions the packaged goods can then subsequently be treated as if they were not dangerous goods for transport.

Gas receptacles

The requirements for these are only recently harmonised at the UN level, and there was a substantial difference in approach between the USA, UK and Europe.

Accordingly it can be very difficult to import or export gas receptacles between areas, and specialist advice needs to be obtained.

Specials

Special provisions for ‘Superpacks’ (ie packages that have been tested to a higher level using a fragile primary receptacle and which can then be used with any suitable primary receptacle though not recorded as being part of the design type), and salvage packagings (special packagings into which ordinary packages that are damaged or leaking can be placed) exist for use in specialised circumstances. Seek specialist advice.

LABELLING and / or MARKING

The requirements that are acceptable to all modes of international transit (though exceeding the requirements of some) are that there shall be the diamond shaped danger label for the prime classification with the danger class number (or division in the case of Class 5) at the base of the label; together with, if applicable, any required subsidiary hazard label, which MUST show the hazard class number at the base of the diamond.

This is then accompanied by a mark consisting of the Proper Shipping Name and UN Number, requirement for ready legibility being specified and with by 1.1 2014 latest a minimum size for the UN Number and associated letters “UN” being specified. A typical label and mark thus would look as follows:

UN 1760

Corrosive liquid n.o.s (Contains sulphuric acid and hydrochloric acid)

Note: In view of the language issues in Europe ADR/RID does not actually require the PSN on the package, but use of the English PSN will not cause any problems in ADR. The box around the PSN in the above example is not mandated. Labels should be on a contrasting background (or in practice if this is not done then have the outside edge indicated by a dotted line or solid line).

In the case of sea, the Marine Pollutant mark (in effect a half diamond label) used to beshown on the package of any such dangerous good, in addition to any hazard labelling and marking. This is no longer acceptable, but might still be seen on goods in stores.

For environmentally hazardous goods and Marine Pollutants a new supplementary mark (not label) was introduced to all modes from 1.1.2009. This is as follows, printed black on a white or on a contrasting colour background.

NOTES:

 Radioactive labelling and marking has special requirements.

 This way up marking is prescribed where appropriate, including for Limited Quantity packages – see below.

 Special requirements apply to labelling and/or marking of overpackages (goods packed and secured to a pallet are one form of overpackage), see below.

 Sea additionally requires that the mark and the label shall be durable to withstand three months immersion in the sea, should the package be durable for that length of time.

 Air has additional handling labelling, and consignee/consignor name and address requirements.

 ADR/RID follows UN except that it doesn’t in general require the PSN to be marked on packages. This is related to the language issue. HOWEVER the showing of the English PSN will not cause difficulties and is required for any journey over the sea.

 ADR/RID in a few cases specifies special markings for certain substances

Limited Quantity Package marking

The question of labelling and marking of limited quantity packages is only recently harmonised, for the surface modes.

UN

This now requires simply marking with the appropriate of the following marks, with the one with the “Y” indicating compliance with additional requirements for air:

Side length of 100 mm (except where not possible in which case a reduced size is permitted), with 2mm thick line and adequately sized “Y” in black on a white or contrasting background. Note: the edge of the diamond frame is the edge of the mark. Again printed black on white or a contrasting background.

Air

Air in addition to use of the LQ mark (with “Y” indicating that the package meets additional air provisions) still also requires labelling and marking as for ‘fully regulated’.

Sea

This requires the same as the UN.

ADR/RID

These now require* the same as the UN.

* However a previous scheme that required the UN Number(s), or in the case of multiple UN Numbers the letters “LQ” instead, in a diamond frame can be used until the end of June 2015 for road/rail only (but not for sea).

Excepted Quantity Package marking

This UN system entered into force in all modes on 1.1.2009.

This requires marking with the special UN EQ Mark, which is to be reproduced in black or in red on a white or suitable contrasting background colour; in at least 100 x 100 mm. (Note packages must also have at least one side of at least 100 x 100 mm. (Note: this mark should be square)

The “*” indicates where the Class/Division Number shall be shown

The “**” indicates where the name of the consignor or the consignor shall be shown (no address required) unless shown elsewhere on the package.

Overpacks

It is possible to overpack several packages, which individually must meet the

requirements, into a pallet pack or other type of unit load. These are called overpacks. The overpacks must repeat the labelling and marking on the individual packages and be additionally marked with the word “OVERPACK”, with no specification, yet, for how this shall be displayed. If the label(s) and/or mark(s) applicable to all the goods

are clearly visible through the overpackage (e.g. if clear stretched to pallet with packages orientated so that labels and / or marks are visible) then the word

“OVERPACK” is not required. The mark must be at least 12mm high from 1.1.2016 at the latest.

Containerisation and vehicle loading

All modes have some restrictions on the types of dangerous goods that can be loaded into the same vehicle or freight container (e.g. usually nothing else with explosives, and some explosives shall not be loaded with other types of dangerous substances). The most severe restrictions generally are those of the IMDG Code, where use is made of a segregation chart to identify those goods not needing any segregation and which may therefore be loaded together in the same transport unit.

There are requirements laid down on loading and stowage with again the sea mode being generally considered the most severe.

The IMDG Code requires the person who loads the vehicle or freight container (not always the same as the shipper) to ensure the unit was fit to transport dangerous goods, have dangerous goods documents for each consignment (details on

documentation follow), ensure that all goods are externally inspected, ensure that only compatible goods have been loaded, and the whole has been properly packed and secured.

It should be noted that inspections consistently show that compliance with these requirements is very poor.

Placarding and Marking

Once the cargo transport unit (CTU) be it a freight container or a vehicle has been properly packed the unit may then need to be placarded and marked to identify that it contains dangerous goods.

Placards are enlarged class labels, as on the packages, and are usually required under the IMDG Code on all four sides of a container or on each side and end of a vehicle. Where the load consists solely of one UN Number this mark has to be shown in the lower half of the placard or as a separate placard.

For ADR placarding is generally only required for tankers, goods carried in bulk (i.e. without use of packaging or tank) and when packaged goods are in a freight container. Marking under ADR takes the form of a rectangular orange plate placed front and rear of the unit when carrying over the prescribed quantities of regulated packaged

dangerous goods. When tanks and bulk are involved orange plates with additional information are required for road and further markings for sea (seek specialist advise). Placarding and orange plates is not applicable to airfreight, though may be needed on the vehicles bringing or taking the dangerous goods to/from the airport.

Limited Quantity (LQ) and Excepted Quantity (EQ) packages do not require any Class placard under ADR or the IMDG Code, nor any orange plate mark under ADR. For the IMDG Code the CTUs must be marked with an enlarged (250 mm side length) version of the LQ mark, on all four sides of a freight container or one back and both sides of a vehicle.

However for road the enlarged marks is only required where the transport unit exceeds 12 tonnes mass and carries in excess of 8 tonnes of LQ packages.

Documentation

The shipper of the dangerous goods is required to give information to those involved in the carriage. A single prescribed sequence has had to be followed for the core data:-

UN Number, PSN, Class (sub class if any*), Packing Group*

* Note: Subsidiary class(es) and Packing Group shown only if applicable.

For air a special format of shipper’s declaration MUST be used, and very carefully completed.

For sea additional details to be included in the transport documented (aka dangerous goods note (DGN)) are prescribed, for instance if a “Marine Pollutant”*; but, whilst a format is only recommended, the use of a standard style of prescribed dangerous goods notes is the normally the commercial requirement.

ADR/RID also have additional requirements, for instance the need to show the Tunnel Code, where the goods may be travelling on a route that takes them through a ‘controlled’ tunnel. This is shown after the core description above in parenthesis, e.g. UN 1133 ADHESIVES, 3, III, (D/E)”.

* Whilst IMDG Code requires the wording “Marine Pollutant” and ADR requires the indication ““Environmentally Hazardous” if the tank or ‘fully regulated’ package shows the EHS mark (but other than for UN3077 Environmentally hazardous solid,

n.o.s. or UN3082 Environmentally hazardous substance, liquid, n.o.s.) both IMDG and ADR now clearly indicate that the combined statement “Marine

Pollutant/Environmentally Hazardous” may be used to satisfy both modes.

NOTE: it is recommended to show the statement “Marine Pollutant/Environmentally Hazardous “ on the transport document whether for road only or sea only or for a combined journey to ensure compliance with both the rules, including for

UN3077/3082 for a road journey.

Additionally the person who was responsible for loading (or finishing the loading) of the transport unit ready for sea carriage has to provide a Container/Vehicle Packing Certificate certifying that the above actions were taken and then the unit correctly placarded .

N.B. This certification may also on the standard dangerous good note (DGN), but must be signed by the person actually loading the unit, who may not be the shipper who signs the other part of the DGN.

ADR does not require a transport document in the case of EQ packages or LQ packages, but the consignor must advise, in advance in a traceable form, the gross mass of LQ packages being consigned.

ADR also requires the carrier provide to the vehicle crew a single, standard ADR prescribed Instruction in Writing (IiW); which has to be in the language that the crew can read and understand.

Training

The UN requires that all parties who are to be involved in the carriage of dangerous goods shall have before starting work undergone:-

familiarisation or awareness training (in the general principles etc.).

Appropriate self study of this guide would be deemed to be suitable awareness training IF the person has been tested thereon and be shown to know and understand. This should be recorded.

function specific training (e.g. if your job entails documenting potentially dangerous goods then training in documentation requirements shall have been given)

security training. This covers security measures to stop terrorist or other unauthorised access to the dangerous goods and the emergency response measures if that occurs.

IATA has similar requirements, but these tend to be quite strongly enforced, with training from approved certificated 3rd party trainers required in the UK

IMDG has also adopted these requirements for shore-based staff, but has no

certification or approval requirements. From 2009 IMDG requires that records of such training be kept BOTH by the employer AND by the employee.

ADR/RID have adopted the UN provisions and also requires that records of such training be kept BOTH by the employer AND by the employee. There is an

exemption when activity in dangerous goods is ONLY in limited quantity packages. The training of any new employee into the area must be verified before starting work involved with dangerous goods, and refresher training is required to keep abreast of legislation changes (e.g. the November of every even numbered year; to pick up the changes to be implemented from the following January)

All involved must have security of dangerous goods training included in their awareness, function specific and safety training (other than EQ packages and LQ packages, and for road where small load relaxations apply).

Driver Training

ADR require that where dangerous goods are to be loaded, carried, in significant* quantities then the driver of the vehicle must be vocationally trained and certified for the class(es) of goods and the type(s) of carriage (packaged and/or tanks).

* the significant amount depends on the type and degree of danger of the goods being shipped.

Dangerous Goods Safety Advisers

ADR /RID require that where dangerous goods are to be loaded, carried, or unloaded (with some exceptions) in significant quantities then the employer must appoint a vocationally certified Dangerous Goods Safety Adviser (DGSA) prior to any involvement in such carriage.

The DGSA can be an internal employee or a consultant. The DGSA can be certified for all classes, or just certain classes, and for road, and/or rail and/or inland waterway. The certificate is valid for just 5 years. Success at the examination is seen as proof of suitable training.

Conclusion

The safe transport of dangerous goods involves a number of steps, and is dependent on each of these being properly performed.

In this brief summary it is not possible to cover all the details involved, and reference must be made to the current versions of the applicable provisions by persons

competent in their use.

DanGoods Training & Consultancy Ltd is able to provide consultancy and training in this area. Please contact the undersigned for further details.

Desmond

... D C Waight

Director