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Dr Colin Hewlett DGSA consultant
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Chemicals
and Transport Limited
New LegislationThe
1996 Carriage of Dangerous Goods Regulations were superseded by new
regulations ‘The Carriage of Dangerous Goods and Use of Transportable Pressure
Equipment Regulations 2004’ which aligns domestic carriage with ADR/RID,
amended in 2005 and consolidated in 2007 (CDG 2007). This major overhaul of
the The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) Regulations 2007 directly refer to the 2007 ADR and RID regulations. Some ADR/RID requirements which
are implemented in the 1.
Paragraph 1.8.5 of RID/ADR introduces reporting requirements for
incidents during the carriage of dangerous goods. Subject to a number of
criteria set out in RID/ADR, reports will need to be submitted to the
competent authority (DfT) where dangerous goods are released or where there
is an imminent loss of product; if personal injury, material or environmental
damage has occurred; or where the authorities are involved. These
requirements are in addition to those under the Reporting of Injuries,
Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) that include
general reporting duties and specific provisions concerning incidents
involving dangerous goods such as a road tanker carrying a
dangerous substance overturns, suffers serious damage, catches fire or the
substance is released or a dangerous substance being conveyed by road is
involved in a fire or released. 2.
Under RID/ADR, any IBC of more than 450 litres capacity will need to
be marked and labelled on two opposite sides. This requirement affects almost
all metal or composite IBCs used for carrying dangerous goods. 3.
Bowsers designed for the carriage of dangerous goods such as liquid
fuels will need to be constructed, tested and inspected to ADR requirements
for tanks or IBCs as appropriate with some derogations introduced by an HSE
authorization valid to 2019 which allows metal and plastic bowsers with a
capacity of up to 3000 litres to be considered as IBCs, providing they meet
the appropriate ADR IBC requirements. 4.
Diesel oil, gas oil or heating oil (UN 1202) - under current domestic
legislation, diesel oil, gas oil or heating oil with a flashpoint up to and
including 60.5 °C are classified as dangerous
for carriage and assigned UN 1202. Under RID/ADR, however, these goods are
classified UN 1202 if the flashpoint is up to and including 100 °C. As a result of aligning 5.
Threshold levels for the carriage of dangerous goods in limited
quantities are given in ADR/RID Table 3.4.6.
6. Exempted load
thresholds are given in ADR/RID 1.1.3.6.3. Derogations from ADR/RID in the
CDG regulations 1.
The provisions disapply the ADR requirement to carry a Transport
Document for small quantities of dangerous goods by road. 2.
The regulations make it mandatory for those transporting dangerous
goods in bulk or in tanks to display orange coloured panels bearing the
appropriate UN number, emergency action code (EAC) and, for carriage in
tanks, an emergency telephone number. These requirements apply to DGSA regulations 1. The Transport of Dangerous Goods (Safety Advisers)
Regulations 1999 S.I. 1999/257 were revoked by the 2004 Carriage Regulations
and the ADR rules now apply; any carrier, filler and loader involved in the
carriage of dangerous goods by road or by rail must comply with the
requirements relating to the appointment and duties of safety advisers of
paragraphs 1.8.3.1 and 1.8.3.3 to 1.8.3.9 of ADR in relation to carriage by
road or of RID in relation to carriage by rail. The requirement of 1.8.3.1 to
include packing and unloading activities are not included in the British
regulations issued as CGD 2007 but this position is under review. 2. DGSAs should note the mandatory additional reporting
requirements in ADR chapter 1.8.5 in relation to incidents involving dangerous
goods (see above) SUPPLY
REGULATIONS EC 304/2003 and amendment EC 1213/2003
Regulation (EC) No 304/2003 Concerning the export and import of dangerous chemicals: dangerous chemicals exported outside the EC are required to be classified and labelled and an SDS supplied to CHIP standards and that the label and SDS is in a language of the country of destination if practicable. The regulations implement and go beyond the requirements of PIC (Prior Informed Consent; Rotterdam Conference 1999). REACH (Registration, Evaluation and Authorisation
of Chemicals): REACH came into law
as a direct-acting EU regulation in June 2007 and comes
fully into effect in June 2007 when the first stage of pre-registration of
chemicals begins (see http://europa.eu.int/comm/enterprise/reach/index.htm). REACH targets are:
GHS The Globally Harmonised System of
Classification and Labelling of Chemicals (GHS) has been the subject of more
than a decade of work; its aim is to provide a framework to bring together
the various national and regional hazard communication systems which control
the supply of hazardous chemicals in
much the same way that the ‘Orange Book’ offers a global framework for the
transport of dangerous goods. The purpose of GHS is to provide a single globally harmonized system
to address classification of chemicals, labels, and safety data sheets.The first
edition of GHS was published in July 2003 as the ‘Purple Book’ and revisions
published bi-annually; these can be downloaded from the unece website http://www.unece.org/trans/danger/publi/ghs/ghs_rev01/01files_e.html.
REACH when fully developed will
adopt much of the recommendations of GHS. WASTE REGULATIONS New
hazardous waste regulations were introduced in 2005 replacing the Special
Waste regulations: The Hazardous Waste ( The
Environment Agency has published Technical Guidance WM2 (June 2003) which can
be downloaded from the EA website: http://www.environment-agency.gov.uk/business/444217/590750/590821/502174/496498/?version=1&lang=_e.
This publication reproduces the European Waste Catalogue. A
useful guidance note, A Guide to the Dangerous Wastes Regulations, can be
downloaded from http://www.environment-agency.gov.uk/commondata/acrobat/what_is_hazwaste_1027611.pdf
Last updated: September 2007 |
