December 17th 2020
Written by Collette Dunne, Safety Consultant with CMSE Consultancy.
It might be time to do a review of goods coming and going from your site. Is anything classified as a dangerous good?
Do you know, transporting dangerous goods, isn’t just the transport on a truck or in a van, but also includes the role of:
- consignor
- packer
- filler
- loader/unloader and
- consignee.
Furthermore, the people involved in these activities have legal responsibilities.
What are dangerous goods?
As well as national legislation on the carriage of dangerous goods, we also have the ADR. ADR is an agreement between United Nations countries to harmonise transport conditions for dangerous goods, to prevent accidents and reduce risks. It’s updated every two years and specifies how to classify dangerous goods and also the requirements for their transport. Dangerous goods are classified into:
Class 1: Explosive
Class 2.1: Flammable Gas, 2.2. Non Flammable, Non Toxic Gas, 2.3 Toxic Gas.
Class 3: Flammable Liquid
Class 4.1: Flammable Solid, 4.2 Spontaneously Combustible Substance, 4.3 Substance which emits flammable gas in contact with water.
Class 5.1: Oxidising Substance, 5.2 Organic Peroxide.
Class 6.1: Toxic Substance, 6.2 Infectious Substance
Class 7: Radioactive Material
Class 8: Corrosive Substance
Class 9: Miscellaneous Dangerous Substances.
How will I know if our goods are dangerous goods?
There are a number of things you can do initially.
- Read the Safety Data Sheet (SDS) for goods being transported off your site – you should have these readily available. Go to Section 14: Transport Information. If this section is populated, then you are transporting a dangerous good and you are a Consignor. It’s important to have the most recent revision of the safety data sheet as information may change and something that wasn’t classified before, may now be classified and vice versa. Different dangerous goods have different requirements for example, the type of packaging you can use, the maximum weight or volume per package and what other products they can be transported with.
- If you don’t have an SDS for your products, an expert can assess them to determine if they are dangerous goods based on their properties.
- Review materials being delivered to your site. Look at the labels on the outside. Do they have a diamond shaped, coloured pictogram and a number? If yes, they may dangerous goods. If you accept, unload or move them again off-site, then you are involved in the transport of dangerous goods. All vehicles involved in the carriage of dangerous goods should have orange plates displayed.
Common misunderstandings
- Our chemical waste is collected by a registered company so the ADR/Regulations don’t apply to us.
Waste is not exempt. Chemical and other waste can be classified as dangerous goods. If you are delegating some responsibilities to your waste provider, you should have a Contract of Carriage in place. You can delegate some responsibilities but not all.
- We get chemicals delivered through a chemical supplier so they probably look after it.
If you are accepting, unloading or loading then you are involved in their transport. You might even have requirements around the transport of empty containers, depending on what material was last in them.
- We only transport very small quantities so the they don’t apply to us.
Even a single package of dangerous goods might fall under the Regulations but you must check. There are different requirements for limited or excepted quantities with specific conditions.
Why should you learn more?
The cost of a mistake could be huge. Consider what could happen if you don’t follow the ADR, package something incorrectly, load it with a material that it’s incompatible with or if there was a road accident and no-one knew there was a dangerous good on-board. You have a moral, financial and legal responsibility to comply.
So what do I need to do?
- You may be required to appoint a Dangerous Goods Safety Advisor (DGSA). There are a few exceptions to the rule. It’s a good idea to get professional advice to confirm whether you are exempt or not. The function of the DGSA is monitor and advise on compliance and prepare an annual report.
- Confirm who in the organisation is involved in transport activities. These workers may require function specific training.
- Talk to your carriers to confirm that their drivers are competent. Drivers must complete ADR training relevant to the different classifications and the types of packaging (packages, IBCs, drums, tanks). It’s up to you to inform your carrier of what is to be transported.
If you would like a review of your activities or other DGSA support, please contact the CMSE Consultancy Team
Chat to us instantly by clicking the chat box in the bottom right-hand corner of your screen. Alternatively, you can click here to email info@cmse.ie