Thanks to all the visitors of this blog.
But is time for me to retire also from that.
If you still wish to be in contact, please use this address:
tramerper@gmail.com
All my best
sergio benassai
giovedì 29 maggio 2008
giovedì 3 aprile 2008
again on ENVIRONMENTALLY HAZARDOUS SUBSTANCES
Let us consider the case of the intermodal transport of dangerous substances and mixtures (such as wastes).
According to the future new provisions of ADR/RID 2009 it will be necessary to check if they need to be classified as environmentally hazardous substance and, if that is the case, the package need to be marked accordingly, while, according to IMDG Code, it is necessary to check if it is a marine pollutant and to mark accordingly the package (still it is not clear to me why it should be a mark and not a label).
Do we really think that all the European shippers will check every dangerous substance or mixture (which is not clearly mentioned in the European Directives 67/548/EEC and 1999/45/EC as environmentally hazardous one) to verify if indeed it is also an environmentally hazardous one ?
Another question: in the case of a mixture, it is really necessary to apply the quite complex summation method (developed by GHS) to establish if it is acute category I or chronic category I or chronic category II ?
What is the meaning of the 3 categories (and specifically the difference between chronic I and II) from the point of view of transport regulations, taking care that the same requirements apply irrespective of the category (which however is not true for sea transport where marine pollutants and severe marine pollutants are subject to different requirements, for instance concerning Limited Quantities) ?
And again it is not clear to me why chronic effects are relevant from the point of view of the environment, but not from the point of view of health (for instance, carcinogens are not considered dangerous in transport regulations).
A possible suggestion: complete revision of GHS, using for classifying environmentally hazardous substances a simpler approach, similar to what has been developed for acute toxicity, and revising transport regulations perhaps assigning different Packing Groups to different categories (if really necessary).
Another possibility is of course to wait the result of the implementation of the European REACH (and GHS) Regulation, which will allow thousands of substances and mixtures to be classified on the basis of GHS criteria.
According to the future new provisions of ADR/RID 2009 it will be necessary to check if they need to be classified as environmentally hazardous substance and, if that is the case, the package need to be marked accordingly, while, according to IMDG Code, it is necessary to check if it is a marine pollutant and to mark accordingly the package (still it is not clear to me why it should be a mark and not a label).
Do we really think that all the European shippers will check every dangerous substance or mixture (which is not clearly mentioned in the European Directives 67/548/EEC and 1999/45/EC as environmentally hazardous one) to verify if indeed it is also an environmentally hazardous one ?
Another question: in the case of a mixture, it is really necessary to apply the quite complex summation method (developed by GHS) to establish if it is acute category I or chronic category I or chronic category II ?
What is the meaning of the 3 categories (and specifically the difference between chronic I and II) from the point of view of transport regulations, taking care that the same requirements apply irrespective of the category (which however is not true for sea transport where marine pollutants and severe marine pollutants are subject to different requirements, for instance concerning Limited Quantities) ?
And again it is not clear to me why chronic effects are relevant from the point of view of the environment, but not from the point of view of health (for instance, carcinogens are not considered dangerous in transport regulations).
A possible suggestion: complete revision of GHS, using for classifying environmentally hazardous substances a simpler approach, similar to what has been developed for acute toxicity, and revising transport regulations perhaps assigning different Packing Groups to different categories (if really necessary).
Another possibility is of course to wait the result of the implementation of the European REACH (and GHS) Regulation, which will allow thousands of substances and mixtures to be classified on the basis of GHS criteria.
mercoledì 12 marzo 2008
SUMMARY
One year from the start of this blog, it could be useful to summarize what have been said.
And perhaps quoting the HCB report from the TDG Congress in Ottawa is a good way (but I would expect some contribution from you to continue... !)
... Sergio Benassai ... As a general rule, he said, the transport provisions should apply equally to transport by all modes and classification, labelling and packaging should be aligned. Currently, however, there are variations in definitions, terminology, labelling requirements, limited quantity limits, documentation and packing instructions. He regretted that the International Civil Aviation Organisation (ICAO) had missed an opportunity to harmonise its packing instructions with those in the UN model regulations during its recent revision process; some of the differences are not really justified, he said. No proper risk assessment has been undertaken to justify the changes or lack thereof, although he acknowledged there is always an understandable reluctance to introduce changes for the sake of it.
Sergio proposed a way to deal with current disharmony: a World Convention on the transport of dangerous goods. A mandatory instrument with requirements for all modes and all countries would avoid the need for national legislation and could also reduce the need to hold international meetings. It could make more use of references to international standards and the Globally Harmonised System (GHS) of classification and labelling. Discussions about this possibility have shown many countries are not sold on the idea so it is necessary to consider alternatives, Sergio said:
(a) open discussion on a website prior to regulatory meetings, so that lengthy unprepared discussions can be avoided at plenary sessions;
(b) discourage modal bodies from making changes without their being discussed first at UN level;
(c) avoid unnecessary editorial variations from the UN text in the modal rulebooks;
(d) align the modal regulations with the UN paragraph numbering system; and
(e) strengthen coordination at national level so that each country's delegations take the same message to the UN, ICAO, the International Maritime Organisation (IMO) and other rulemaking bodies.
The language of the regulations needs to be clearer, Sergio said. Sharp intakes of breath followed his suggestion that regulators need to accept that English is the global language of trade and that it should be made the official language of all regulations.
Further suggestions from Sergio to foster harmonisation included:
(a) better definition of the responsibilities of the consignor/shipper, loader, carrier, consignee, etc;
(b) closer harmonisation with GHS and the inclusion in the Dangerous Goods List of substances that are carcinogenic, mutagenic or reprotoxic (CMR);
(c) a default system for classifying wastes (something that is being worked on for RID and ADR); and
(d) a single list of dangerous goods using only nos entries and with a UN numbering system similar to that used in the Kemler Code.
This would take a lot of work, though, Sergio said – perhaps it would be simpler to work towards a World Convention after all! ....
Waiting your comments !
And perhaps quoting the HCB report from the TDG Congress in Ottawa is a good way (but I would expect some contribution from you to continue... !)
... Sergio Benassai ... As a general rule, he said, the transport provisions should apply equally to transport by all modes and classification, labelling and packaging should be aligned. Currently, however, there are variations in definitions, terminology, labelling requirements, limited quantity limits, documentation and packing instructions. He regretted that the International Civil Aviation Organisation (ICAO) had missed an opportunity to harmonise its packing instructions with those in the UN model regulations during its recent revision process; some of the differences are not really justified, he said. No proper risk assessment has been undertaken to justify the changes or lack thereof, although he acknowledged there is always an understandable reluctance to introduce changes for the sake of it.
Sergio proposed a way to deal with current disharmony: a World Convention on the transport of dangerous goods. A mandatory instrument with requirements for all modes and all countries would avoid the need for national legislation and could also reduce the need to hold international meetings. It could make more use of references to international standards and the Globally Harmonised System (GHS) of classification and labelling. Discussions about this possibility have shown many countries are not sold on the idea so it is necessary to consider alternatives, Sergio said:
(a) open discussion on a website prior to regulatory meetings, so that lengthy unprepared discussions can be avoided at plenary sessions;
(b) discourage modal bodies from making changes without their being discussed first at UN level;
(c) avoid unnecessary editorial variations from the UN text in the modal rulebooks;
(d) align the modal regulations with the UN paragraph numbering system; and
(e) strengthen coordination at national level so that each country's delegations take the same message to the UN, ICAO, the International Maritime Organisation (IMO) and other rulemaking bodies.
The language of the regulations needs to be clearer, Sergio said. Sharp intakes of breath followed his suggestion that regulators need to accept that English is the global language of trade and that it should be made the official language of all regulations.
Further suggestions from Sergio to foster harmonisation included:
(a) better definition of the responsibilities of the consignor/shipper, loader, carrier, consignee, etc;
(b) closer harmonisation with GHS and the inclusion in the Dangerous Goods List of substances that are carcinogenic, mutagenic or reprotoxic (CMR);
(c) a default system for classifying wastes (something that is being worked on for RID and ADR); and
(d) a single list of dangerous goods using only nos entries and with a UN numbering system similar to that used in the Kemler Code.
This would take a lot of work, though, Sergio said – perhaps it would be simpler to work towards a World Convention after all! ....
Waiting your comments !
lunedì 28 gennaio 2008
GUIDING PRINCIPLES
Further development (and adoption) of guiding principles (see INF 28 at 32^ session of UNSCETDG) should be one of the top priority in future work.
The reason for ?
A comprehensive gathering of guiding principles will encourage the movement towards simplified and clear UN Model Regulations, in the way that the list of dangerous goods could be restricted to general n.o.s. entries (the relevant requirements for such entries being defined on the basis of the guiding principles).
And indeed such an approach has just been followed for self-reactive substances and organic peroxides.
Specific (when really necessary) requirements for specific goods could then be mentioned in an annexed list of dangerous goods where specific, relevant, identified goods (substances, mixtures, articles) should be contained (their classification being in agreement with GHS): a list which, I recall, at European level, the REACH Regualtion will require to develop.
The reason for ?
A comprehensive gathering of guiding principles will encourage the movement towards simplified and clear UN Model Regulations, in the way that the list of dangerous goods could be restricted to general n.o.s. entries (the relevant requirements for such entries being defined on the basis of the guiding principles).
And indeed such an approach has just been followed for self-reactive substances and organic peroxides.
Specific (when really necessary) requirements for specific goods could then be mentioned in an annexed list of dangerous goods where specific, relevant, identified goods (substances, mixtures, articles) should be contained (their classification being in agreement with GHS): a list which, I recall, at European level, the REACH Regualtion will require to develop.
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