| Packaged Dangerous Goods
SDS
issues
of the ADR in the UK
With the closer integration into Europe, the UK Government have opted to use the main principles of the European ADR regulations concerning the transport of dangerous goods by road. To bring this into force as from 10th May 2004, the Government introduced the statutory instrument 2004/568 ie., "The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2004" (CDG/UTPE), 68 Regulations and 14 Schedules.
Throughout these regulations, references are made to many of the requirements by section as imposed by the ADR and the closely related RID (European Railway Dangerous Goods regulations). Whereas the ADR regulations cover many aspects such as vehicle and container construction, the regular inspections, driver training, vehicle parking, attendance etc,.
much of this latter legislation is not relevant to the
preparation of safety data sheets by ESL.
Likewise we do not consider, tanker, JBC requirements nor goods in Class l (explosives); Class 7 (radioactive materials); Class 9 (miscellaneous - storage batteries and others); or possibly some of the specialised pressurised equipments in Class 2. ESL's work is generally around chemical preparations and those carried as packaged goods.
For the type of work that ESL undertakes, the following are to be considered in respect of the dangerous goods transport by road ie., -
1) The
CDG/UPTE
2) The Department of Transport Guide "Working with
ADR"
3) The ADR Regulations 2003
4) The Dangerous Goods Emergency Action Code
(EAC) List 2004 - issued in June 2004 by The Stationery Office
(TSO), London.
|
Points of Interest Referring to Section in the CDG/UTPE
Under exemptions listed in Regulation 7, paragraph (4) - relaxation from general ruling for items to be carried in -
(a) Limited quantity - Details are cross referenced to ADR 3.4 --- or
(b) Where items are broken down from original packaging for distribution or formally required under ADR 5.2 and 6.l.3 provided that the item does not exceed 30kg/30 litres per pack of a total of 333kg/333 litres per vehicle or container load.
Note 1 - The above is not to be confused with limited quantity provisions
on item packaging and labelling for supply under the CHIP 3
regulations.
Note 2 - The transport relaxations on limited quantities would also be
applicable to items being carried in private cars and small vans.
|
The point to be made here, is that the ESL SDS provides details for transportation of dangerous goods in any quantity. However, we are often asked by clients to provide labelling information regarding their products. Having knowledge of the product use and pack size, we are then able to show where relaxations could apply and save the client money. There is no general rule for such cases and each would require individual investigation - See also page 25 Reg 18 ADR 4.1
Whereas ESL provides in the SDS classification for
transport the basis for this information is the exterpolation of the CHI classification, physical and toxicity data.
Regulations 15 and 17 relate to the procedures to be used and the application of Table A or ADR 3.2 on dangerous item classification and special provisions. Some specific training will be required in understanding the 20 columns of codes appearing in Table A and which of them relate to actions that concern ESL and its customers.
On going from the above, marking and labelling of items for consignment has to be in accord with Table A of ADR 3.2, but also can involve specific issues under ADR 5.l.l to 5.l.4, 5.2, 5.5.l.l, 5.5.l.3 (this will need some more specific reading).
Schedule 9: This deals with vehicle placarding, marks and plates in the UK. HM Government have opted that we shall not follow the ADR HIN Codes, but retain for the present the EAC markings.
Schedule 11: The new transport regulations give rise to a modification of CHIP 3 Regulation 8. The new part, regulation 8A appears on page 85 of CDG/UTPE. What it does, is to revoke the obsolete CDG/CPL2. It will now require products to display the CHIP labelling information plus that which is also required under national or international rules pertinent to the regulations for the particular mode of transport.
______
|
