Hazardous goods can be defined as materials or items with hazardous properties which if not properly controlled, may present a potential hazard to human and animal health and safety, the environment and infrastructure..
Hazardous goods must be classified, packaged, marked, labelled and packed as per the regulations set out by the IMDG Code by the International Maritime Organisation and also needs to be handled with utmost care and consideration of its dangerous nature..
Any misdeclaration, miscommunication or incorrect documentation could have severe consequences and could prove disastrous to human lives on shore or on a ship..
The transportation of hazardous goods both locally and internationally is subject to various regulations depending on the origin and destination country.. The entities undertaking the transportation of dangerous goods must strictly adhere to these regulations..
For intermodal transport, these rules and regulations may be related to transport within a political or economic union or trading zone etc..
Most of these regulations may be based on the United Nations Recommendations on Transport of Dangerous Goods (the Orange book)..
However, international rules like the ADR and national rules like the CFR49 may differ from the United Nations Recommendations on the Transport of Dangerous Goods..
Some of these regulations are
- European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR);
- European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN);
- Regulations concerning the International Carriage of Dangerous Goods by Rail (RID); and
- Title 49 of the Code of Federal Regulations of the United States
For international maritime transport, the provisions of the International Maritime Dangerous Goods (IMDG) Code apply.. The IMDG Code outlines detailed provisions on all aspects of the transport of packaged dangerous goods by sea..
We all need to understand that Dangerous Goods or Hazardous Goods have been given this name for a reason..
There are several examples of tragedy including the Tianjin tragedy in 2015 due to misdeclaration, improper packaging, handling and transportation..
As recently as the 25th of June 2017, more than 200 people were killed in Bahawalpur when one of the tankers contracted by Royal Dutch Shell’s local subsidiary crashed and exploded on a main highway in central Punjab Province in Pakistan while carrying some 50,000 liters of fuel from Karachi to Lahore..
In the aftermath of this explosion, newspapers reported as below..
An agency report seen by Reuters and AFP said that Shell never checked if the private tanker it hired complied with safety standards.
The report said that Shell had informed the authority previously that its lorries met technical standards and that it upgraded vehicles it rents, but the tanker involved in the accident had four axles instead of the five recommended to carry such a load.
The report also claimed the tanker’s fitness certificate was “fake” and that Shell Pakistan’s emergency response was “casual.”
Such incidents that have happened and resulted in tragedy goes to show how critical it is for the regulation of transportation of hazardous goods to be adhered to strictly..
Today I am reproducing two posts from the IMDG Code Compliance Centre blog by Shashi Kallada which highlights the importance of the correct labeling of vehicles transporting hazardous goods either as an FCL container or in bulk and what emergency details need to be displayed mandatorily..
Although these posts have been written in an Indian context and cover the regulations in India, this could be an eye-opener for hazardous goods handlers and transporters from other countries, particularly in the aftermath of the tragedies mentioned above..
Below article highlights the critical emergency details that need to be displayed during the transportation of hazardous goods by road..
Other day while going to airport this tanker carrying UN 1824 SODIUM HYDROXIDE SOLUTION, was ahead of my taxi. One doesn’t need to scrutinize much for the correctness of EMERGENCY INFORMATION PANEL as required by India’s Central Motor Vehicle Rules, (CMVR) 1989, almost half of the class 8 placard is not visible.
What are the requirements for EMERGENCY INFORMATION PANEL for vehicles for the transportation of hazardous goods on Roads?
Rule no. 134 of CMVR India, states
(1) Every goods carriage used for transporting any dangerous or hazardous goods shall be legibly and conspicuously marked with an emergency information panel … and shall contain the following information, namely: —
(ii) the correct technical name of the dangerous or hazardous goods in letters not less than 50 millimeters high;
(i) the United Nations class number for the dangerous or hazardous goods in numerals not less than 100 millimeters high;
(iii) the class label of the dangerous or hazardous goods of the size of not less than 250 millimeters square;
iv) the name and telephone number of the emergency services to be contacted in the event of fire or any other accident in letters and numerals that are not less than 50 millimeters high and the name and telephone number of the consignor of the dangerous or hazardous goods or of some other person from whom expert information and advice can be obtained concerning the measures that should be taken in the event of an emergency involving such goods.
Below examples taken from Australian Code for the Transport of Dangerous Goods by Road & Rail, Edition 7.4
Below article speaks about the regulations that govern the transportation of hazardous goods by road in India..
Rules regulating transport of Dangerous Goods by roads within India is promulgated through Hazardous Substances (Classification Packaging and Labelling) Rules, 2011 and The Central Motor Vehicles Rules, 1989.
Hazardous Substances (Classification Packaging and Labelling) Rules, 2011, gives exemption to pharmaceuticaland cosmetic end products available in packages designated for consumer use and to dangerous goods required for the propulsion of the means of transport or the operation of its specialized equipment during transport.
Dangerous goods in packaged form domestically transported must be classified packaged, marked, labelled and the vehicle carrying the goods appropriately marked according to above said rules.
Salient points within The Central Motor Vehicles Rules, 1989 (CMVR, 1989)
Chapter II licensing of drivers of motor vehicles para 9 require drivers to be able to read and write at least one Indian language specified in schedule VIII of the Constitution and English. The driver must successfully pass training from a recognized institute and his licence endorsed by the licencing authority.
As per section 129.2 Chapter V, Construction, Equipment and Maintenance of Motor Vehicles, every goods carriage carrying dangerous goods must be fitted with tachograph, (an instrument to record the lapse of running time of the motor vehicle; time speed maintained, acceleration, deceleration, etc.) conforming to the specification of the Bureau of Indian Standards
Vehicle owner’s responsibility, Section 132.2 Every owner of a goods carriage shall, before undertaking the transportation of dangerous or hazardous goods in his goods carriage, satisfy himself that the information given by the consignor is full and accurate in all respects and correspond to the classification of such goods specified in rule 137.
Information to driver, section 132.3, The owner of a goods carriage shall ensure that the driver of such carriage is given all the relevant information in writing as given in Annexure V of these rules in relation to the dangerous or hazardous goods entrusted to him for transport and satisfy himself that such driver has sufficient understanding of the nature of such goods and the nature of the risks involved in the transport of such goods and is capable of taking appropriate action in case of an emergency.
Route planning, section 132.4, The owner of the goods carriage carrying dangerous or hazardous goods, and the consignor of such goods shall lay down the route for each trip which the driver shall be bound to take unless directed or permitted otherwise by the Police Authorities. They shall also fix a time table for each trip to the destination and back with reference to the route so laid down.
Responsibility of driver, section 133 The driver of a goods carriage transporting dangerous or hazardous goods shall ensure that the information given to him in writing under sub-rule (3) of rule 132 is kept in the driver’s cabin and is available at all time while the dangerous or hazardous goods to which it relates, are being transported. Every driver of a goods carriage transporting any dangerous or hazardous goods shall observe at all times all the directions necessary for preventing fire, explosion or escape of dangerous or hazardous goods carried by him while the goods carriage is in motion, and when it is not being driven he shall ensure that the goods carriage is parked in a place which is safe from fire, explosion and any other risk, and at all times the vehicle remains under the control and supervision of the driver or some other competent person above the age of 18 years.
Emergency information panel: Every goods carriage used for transporting any dangerous or hazardous goods shall be legibly and conspicuously marked with an emergency information panel in each of the three places indicated in the Table below so that the emergency information panel faces to each side of the carriage and to its rear and such panel shall contain the following information, namely:—
(ii) the correct technical name of the dangerous or hazardous goods in letters not less than 50 millimetres high;
(i) the United Nations class number for the dangerous or hazardous goods as given in Column 1, Table 1 appended with rule 137, in numerals not less than 100 milimetres high;
(iii) the class label of the dangerous or hazardous goods of the size of not less than 250 millimetres square;
(iv) the name and telephone number of the emergency services to be contacted in the event of fire or any other accident in letters and numerals that are not less than 50 millimetres high and the name and telephone number of the consignor of the dangerous or hazardous goods or of some other person from whom expert information and advice can be obtained concerning the measures that should be taken in the event of an emergency involving such goods.
The information contained in sub-rule (1) shall also be displayed on the vehicle by means of a sticker relating to the particular dangerous or hazardous goods carried in that particular trip.
Every class label and emergency information panel shall be marked on the goods carriage and shall be kept free and clean from obstructions at all times.
Incident Report: The driver of a goods carriage transporting any dangerous or hazardous goods shall, on the occurrence of an accident involving any dangerous or hazardous goods transported by this carriage, report forthwith to the nearest police station and also inform the owner of the goods carriage or the transporter regarding the accident.
You may download following documents for reference and compliance.
- Hazardous Substances (Classification Packaging And Labelling) Rules, 2011 http://tinyurl.com/pxmdy8p
- The Central Motor Vehicles Rules, 1989 http://tinyurl.com/p2aatuk
Everyone needs to follow the requirements and regulations for the transportation of hazardous cargo in their own countries..
Are the requirements in your country quite different to the above..?? Comment below..
This article was originally published in Shipping and Freight Resource