In Chapter 1.4 of ADR/RID/ADN the safety obligations of the main participants in the carriage of dangerous goods are indicated, following the definitions in Chapter 1.2 for the different participants.
The UNSCETDG should look to this question from two points of view:
1) considering the usefulness of having multimodal agreed definitions of the responsibilities of the participants in the transport of dangerous goods
2) harmonizing the definitions of participants.
On the second point look for instance to the following definitions:
- “Consignor” is defined in the UN Model Regulations, in the IMDG Code, in ADR/RID/ADN (with different wording), but not in the ICAO T.I
- “Shipper” is defined only in IMDG Code, specifying that it has the same meaning of “Consignor”
- in the Multimodal Dangerous Goods Form (as in the UN Model Regulations, IMDG Code and ADR/RID/ADN) reference is made several times to the “Shipper”, apart from the first box where reference is made to “Shipper/Consignor/Sender”
lunedì 5 novembre 2007
HAZARD DATA BASE (2)
In the previous post “HAZARD DATA BASE” in this blog a worldwide data bank was envisaged where all the substances will be gradually included together with their classification; and, looking specifically to people outside Europe, I mentioned the REACH European Regulation 1907/2006, aimed to register chemicals in a central database, and the European draft Regulation to implement GHS.
Taking care of the new development in terms of classification and marking for environmental hazardous substances (see Post “ENVIRONMENTALLY HAZARDOUS SUBSTANCES (2)in this blog), it should be noted that the harmonization in that area should require an agreement with IMO on the list of environmentally hazardous substances (to replace the marine pollutants’one).
The UNSCETDG should then start to consider how to deal with the list of hazardous substances which will be developed according to European legislation (REACH and GHS), the existing list of marine pollutants, and, above all, the fact that, following the implementation of GHS, all the existing lists of hazardous substances (including the List of Dangerous Goods in the UN Model Regulations) should need to be revised to avoid that the same substance is classified in different ways in different sectors, while using the same system of classification (GHS).
The UNSCETDG should not forget that who take the initiative is generally able to better control the outcome !
Taking care of the new development in terms of classification and marking for environmental hazardous substances (see Post “ENVIRONMENTALLY HAZARDOUS SUBSTANCES (2)in this blog), it should be noted that the harmonization in that area should require an agreement with IMO on the list of environmentally hazardous substances (to replace the marine pollutants’one).
The UNSCETDG should then start to consider how to deal with the list of hazardous substances which will be developed according to European legislation (REACH and GHS), the existing list of marine pollutants, and, above all, the fact that, following the implementation of GHS, all the existing lists of hazardous substances (including the List of Dangerous Goods in the UN Model Regulations) should need to be revised to avoid that the same substance is classified in different ways in different sectors, while using the same system of classification (GHS).
The UNSCETDG should not forget that who take the initiative is generally able to better control the outcome !
ENVIRONMENTALLY HAZARDOUS SUBSTANCES (2)
The Joint Meeting ADR/RID/ADN held in September 2007 has adopted the GHS/UN Model Regulations criteria for classification of environmentally hazardous substances and it is expected that the new provisions will be contained in the 2009 edition of ADR, RID and ADN.
With reference to marking, the new provisions require the marking of packages (and containers, tanks, etc.) containing environmentally hazardous substances, also if the substances have been classified as dangerous according to the criteria for other hazards.
At this point one should expect that the UNSCETDG will come back again to this question, adopting a similar position (i.e. to require marking also for substances which have been classified as dangerous according to the criteria for the other hazards). And perhaps could reconsider the idea of having a label instead of a marking for the packages.
Subsequently one should also expect that the IMO DSC will follow such a decision adopting the same provisions (one of the main problems for the DSC was the necessity of having a mandatory marking for marine pollutants also if they have been classified as dangerous according to the criteria for the other hazards). And perhaps at this point the IMO DSC could be able to align marine pollutants (and GESAMP criteria) to the GHS/UN Model Regulations criteria for classification of environmentally hazardous substances.
The revision of all the UN entries (and of the list of marine pollutants in the IMDG Code) according to the new provisions is something that need to be considered. But it could be coped with in the more general framework of the revision of the existing entries according to the GHS harmonized criteria, i.e. revised criteria for toxic substances, etc., also considering a possible development of a more general list of dangerous goods (see, in this blog, the post “HAZARD DATA BASE (2)”). For environmentally hazardous substances, the IMO list of marine pollutants and the EU list could be the starting points.
With reference to marking, the new provisions require the marking of packages (and containers, tanks, etc.) containing environmentally hazardous substances, also if the substances have been classified as dangerous according to the criteria for other hazards.
At this point one should expect that the UNSCETDG will come back again to this question, adopting a similar position (i.e. to require marking also for substances which have been classified as dangerous according to the criteria for the other hazards). And perhaps could reconsider the idea of having a label instead of a marking for the packages.
Subsequently one should also expect that the IMO DSC will follow such a decision adopting the same provisions (one of the main problems for the DSC was the necessity of having a mandatory marking for marine pollutants also if they have been classified as dangerous according to the criteria for the other hazards). And perhaps at this point the IMO DSC could be able to align marine pollutants (and GESAMP criteria) to the GHS/UN Model Regulations criteria for classification of environmentally hazardous substances.
The revision of all the UN entries (and of the list of marine pollutants in the IMDG Code) according to the new provisions is something that need to be considered. But it could be coped with in the more general framework of the revision of the existing entries according to the GHS harmonized criteria, i.e. revised criteria for toxic substances, etc., also considering a possible development of a more general list of dangerous goods (see, in this blog, the post “HAZARD DATA BASE (2)”). For environmentally hazardous substances, the IMO list of marine pollutants and the EU list could be the starting points.
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