ENVIRONMENTALLY HAZARDOUS SUBSTANCES

The existing provisions in UN Model Regulations, in IMDG Code, in ICAO T.I., in ADR/RID/ADN are not harmonized.
Main problems are related to criteria for classification, subdivision into categories in GHS and into severe and non severe marine pollutants in IMDG Code, requirements for labelling and marking.

Taking also care of the future implementation of GHS in other sectors, a possible solution (for all the modes of transport) could be:
1) to implement GHS criteria (as in UN Model Regulations)
2) to recognize the environmental hazard as a subsidiary risk also for substances which meet the criteria of other classes/divisions
3) to split the existing UN numbers into “severe aquatic pollutants” and “aquatic pollutants”, respectively for category “acute 1 and chronic 1” and category “chronic 2” (in view of future development in GHS concerning terrestrial environment, it seems appropriate to change the proper shipping name)
4) to require the GHS pictogram as the label (not as a mark) for aquatic pollutant (and not the class 9 label), also for substances which meet the criteria of other classes/divisions

In implementing GHS in transport regulations there was a large consensus on the decision that classification of substances will be revised if necessary, according to the GHS criteria, on the basis of case by case proposals. The same principle could be adopted here, but the starting point could also be the provisional adoption of the IMDG Code classification as aquatic (marine) pollutant.

CLASSIFICATION OF WASTES

In the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) no clear reference is made to wastes.
However the UN SubCommittee of Experts on GHS has agreed to cooperate with the Open Ended Working Group of the Basel Convention in order to come out with a proposal for wastes classification on the basis of GHS.

I don’t see any problem in simply stating that wastes have to be classified in accordance with GHS.

First of all I would like to remind that, for transport, wastes are classified according to the criteria for mixtures and then in accordance with GHS.
Moreover, looking to Basel Convention, the list of hazardous characteristics in Annex III (based on transport regulations for Codes H1 to H8) can be easily revised making reference to GHS.

The real problem is that sometime it is very difficult to classify wastes, due to the uncertainties on the real content of hazardous substances and on their concentration and also because (mainly for physical hazards) no clear criteria have been developed for mixtures.

In conclusion:
a) criteria for mixtures (physical hazards) need to be investigated
b) a conservative approach for classifying wastes with unknown content or concentration could be considered (see, for instance, the discussion going on at the Joint Meeting ADR/RID/ADN)

HAZARD DATA BASE

The Globally Harmonized System for Classification and Labelling of Chemical (GHS) has been largely implemented in transport regulations; European Commission published a draft regulation in view of adopting GHS for other sectors; in other countries GHS has been or is going to be implemented.

But... harmonization is not a simple task.

One problem is related to the procedures that are or will be established for classification of hazardous substances.
Indeed the same substance can be classified in different categories (or also in different classes) according to the existing regulations.
Of course, making reference to the harmonized criteria of GHS, a unique, harmonized classification should be envisaged.
However, taking care that classification is often based on the results of tests provided by different industries/laboratories, it is possible that different sources of data entail different classification.

Should not then be a good idea to envisage a worldwide data bank where all the substances will be gradually included together with their classification (and their Safety Data Sheet) ?
Of course, when a different classification is resulting for the same substance, a mechanism of revision should also be envisaged.

Certainly not an easy target.
But (and I’m looking specifically to people outside Europe) take care of the REACH European Regulation 1907/2006, aimed to register chemicals in a central database.
If you don’t move, the worldwide database will be the REACH one.

(Editorial) MULTIMODAL HARMONIZATION of transport regulations

While IMDG Code, and ADR/RID/ADN, are generally in line with UN Model Regulations. both in terms of subdivision in parts, chapters, sections and paragraphs and (more relevant) in terms of text, that is not true for ICAO Technical Instructions (neither for IATA Dangerous Goods Regulations, which are also different from ICAO T.I.).

Unfortunately the ICAO Dangerous Goods Panel (DGP) doesn’t seem going in the direction of increasing harmonization.

Let us consider the proposed revised Packing Instructions, as contained in the Consultative Document.
In recognizing the specific needs of air transport, is it really justifiable not to pursue an editorial harmonization with UN Model Regulations in terms of numbering system, format, etc. ?

A general query: if IAEA is considering a possible alignment of TS-R-1 with UN Model Regulations, why should that be so “impossible” for ICAO DGP ?

Have consignors (or shippers: another modal disharmony) something to say ?

WELCOME

Welcome to this blog.

Here I would like to exchange views in the fields of the transport of dangerous good and of the classification of hazardous substances and mixtures.

With the next post I will propose some topics and some ideas.