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.