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What are Dangerous Goods ?
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Goods dangerous for transport are grouped into nine main United Nations
hazard classes according to their properties. Some of these classes are
further sub-grouped into divisions:
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Class 1 Explosive
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Class 2 Gases
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Class 3 Flammable liquids
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Class 4 Other flammables
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Class 5 Oxidising and
organic peroxides
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Class 6 Toxic and
infectious
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Class 7 Radioactive
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Class 8 Corrosive
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Class 9 Miscellaneous
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Environmentally Hazardous
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International Agreements -The UN
recommendations
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Transportation legislation follows in principle, but not always in
detail, the UN Recommendations and Model Regulations (the Orange Book)
whose principle of identifying each hazardous substance with a UN Number
and specifying for each their principal and subsidiary hazard classes and
packing groups has been adopted by all modes of transport, road, rail, air,
sea and inland waterways. Although great efforts have been made to
harmonize these various modal regulations, there still remains difference
between them. The Orange Book contains recommendations for the transport
regulators to take into account when framing their regulations but do not
in themselves have any force of law. Dangerous goods are classified into
nine danger classes (some of which are sub-divided into divisions, eg. 6.1 toxic substances) dependent on the major kind
of danger that the substance presents; other risks may be present and these
are known as subsidiary risks. Each class or division has a diamond shaped
label with a pictorial representation of the danger. The level of danger is
indicated by the Packing Group, PGI high danger, PGII medium danger and
PGIII low danger. The packing groups form the basis of the allocation of
Transport Categories (0 – 4 where Transport categories 1, 2 and 3
correspond in general with the UN packing group but note that this is not a
universal rule).
Dangerous goods within the UN classes 1 – 9 are mostly chemicals,
either individually named substances eg. 'Tetrachloroethylene', or generic descriptions eg. 'Flammable liquid N.O.S.' (Not Otherwise Specified)
but also articles eg. 'Matches, safety'. The
criteria for classification in the various UN classes are largely
harmonised between the transport modes, for example flammable liquids,
class 3 are defined (with some exceptions) as those having a flash point
not exceeding 60°C and the initial boiling point will determine the
appropriate packing group (and hence the Transport Category). These
criteria allow the correct classification of goods which are not
individually named. There are procedures for correctly classifying
materials possessing multiple hazards.
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UK Transport Legislation – The Carriage
Regulations
ADR - Carriage of Dangerous Goods by Road
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The British transport regulations (The Carriage of Dangerous Goods
and Use of Transportable Pressure Equipment Regulations 2009) refer to ADR
for classification criteria. Dangerous goods are defined as those which are
listed in ADR either as individually named substances or N.O.S entries. All
dangerous substances are assigned a UN Number and ADR carries two lists,
one ordered by UN Numbers and the other alphabetically. Confusingly, the
lists can use different chemical names from the Approved Supply List used
by the CHIP regulations. Environmentally Hazardous Substances are not named
individually in the indexes but are classified as UN 3082 (Environmentally
hazardous substance, liquid, N.O.S.) or UN 3077 (Environmentally hazardous
substance, solid, N.O.S.). The latest editions of the various carriage
regulations have introduced the application of a new Environmentally
Hazardous mark
Carriage of goods by international journeys by road are carried out
under ADR (currently the 2009 edition)
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Which rules apply ?
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The GB packaging and labelling requirements of The Carriage
Regulations 2009 are suspended for international road journeys under ADR
and for carriage by road to a port for onward shipment by sea or to an
airport for onward shipment by air when the IMDG Code or ICAO Technical
Instructions apply respectively. Note that the consignee may carry the
responsibilities of a consignor for imported goods where the supplier has
no place of business in Great Britain
and the consignee has control over the carriage of the goods in Great Britain.
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Duties of Consignors and Transport Operators
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Duties
imposed by the transport regulations can be summarised as follows:
Consignor
duties: classification, identification, packaging selection, warning marks
and labels, preparation of a transport document for the transport operator.
Transport Operator duties: selection of vehicle and safety
equipment, placarding vehicle,
loading/unloading/stowage procedures, emergency instructions, parking and
supervision, driver training.
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Consignor duties
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Selection
of packagings and labelling - UN specification packaging must be used for
dangerous goods which are to be transported but there is an exemption for
limited quantity receptacles in combination packages. Marking and labelling
of packages is required for packages containing inner packagings above this
threshold capacity above which the packages must be marked with the UN
Number plus the class (primary) danger label and subsidiary hazard label if
applicable; the signs are 100mm diamond shaped labels conforming to the
designs given in the regulations.
Documentation
– the consignor must supply a transport document to the operator giving the
following information:
UN number
Proper Shipping Name (PSN)
Hazard Class
Packing Group
Control temperature and emergency temperature, where appropriate
The mass/volume of each package and number of packages or in the
case of tank/bulk movements, the net mass/volume
Name and address of Consignor
Name and address of Consignee
Consignor's declaration
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Transport Operator duties
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The operator must ensure that the vehicle is suitable for the load
and carries the mandated safety equipment and that the driver has a copy of
the transport document for each consignment carried and a total load
summary plus emergency instructions and the vehicle placarded
(orange rectangle for packaged goods). The driver must hold and carry a
Driver Vocational Training Certificate whatever the vehicle capacity. There
are relaxations from the regulations when goods are packed in receptacles
below the Limited Quantity limits and also when the load is less than
Exempted Load limits.
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Enforcement
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Enforcement of legislation on the transport of dangerous goods by
road within the UK
falls to DfT.
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Code of practice and Guidance Note
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The Department for Transport publishes an explanatory booklet
“Working with ADR” (Publication reference 04DFT01) which is available as a
download on the DfT website.
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Carriage by sea - IMDG code
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The 2008 edition of IMDG came into first use
on the 1st January 2009 with a 12 month transition period. In UK
law, IMDG is mandatory (The
Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997).
Some significant difference from the UN
recommendations are as follows:
Dangerous Goods List - IMDG adds some additional special
provisions to the UN recommendations.
Special requirements for shipping documentation:
In the case of flammable substances, the flash point
should be indicated.
The words “Marine Pollutant” if applicable with the name
of the constituent in the proper shipping name.
Special requirements for package marking:
The Proper Shipping Name shall be marked on the package.
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