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 !
lunedì 5 novembre 2007
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.
giovedì 13 settembre 2007
SMALL STEPS FOR HARMONIZATION
Waiting a World Convention something can (shall) be done to increase harmonization among UN Recommendations and Modal Regulations.
For instance (just to start):
1. Consignor/Shipper
In the Multimodal Dangerous Goods Form reference is made (in boxes 1, 4, 22 and in the Shipper Declaration) to Shipper.
In the Un Recommendations no definition is given in Chapter 1.2 for Shipper, but a definition is provided for Consignor.
The same situation can be found in ADR/RID/ADN, while in IMDG Code both definition of Consignor and Shipper are contained (with the same meaning) and in ICAO T.I. no definition is given for Consignor or Shipper
2. Transport/Carriage
Why ADR/RID/ADN still use the words “Carriage”, “Carry”, etc. instead of “Transport”, etc. as in the UN Recommendations, IMDG Code and ICAO T.I. ?
3. Class/Division
In the UN Recommendations and ICAO T.I. we have Classes (1, 2, …4,…9) and Divisions (… 4.1, 4.2, 4.3 …..).
In IMDG Code and ADR/RID/ADN we have (apart from class 1) only Classes.
In GHS you can find Classes, Categories and SubCategories.
For instance (just to start):
1. Consignor/Shipper
In the Multimodal Dangerous Goods Form reference is made (in boxes 1, 4, 22 and in the Shipper Declaration) to Shipper.
In the Un Recommendations no definition is given in Chapter 1.2 for Shipper, but a definition is provided for Consignor.
The same situation can be found in ADR/RID/ADN, while in IMDG Code both definition of Consignor and Shipper are contained (with the same meaning) and in ICAO T.I. no definition is given for Consignor or Shipper
2. Transport/Carriage
Why ADR/RID/ADN still use the words “Carriage”, “Carry”, etc. instead of “Transport”, etc. as in the UN Recommendations, IMDG Code and ICAO T.I. ?
3. Class/Division
In the UN Recommendations and ICAO T.I. we have Classes (1, 2, …4,…9) and Divisions (… 4.1, 4.2, 4.3 …..).
In IMDG Code and ADR/RID/ADN we have (apart from class 1) only Classes.
In GHS you can find Classes, Categories and SubCategories.
lunedì 23 luglio 2007
UNFORTUNATELY
In this blog I often mentioned the necessity of intermodal harmonization and noted the ICAO resistance to that.
On this point, if you have a look to UN/SCETDG/31/INF.48 (the report of a working group at the 31^ session of the UNSCETDG, July 2007), you can read in the first paragraph, third sentence:
"It was agreed for the discussion to leave LQ by air out of the discussion because the difference are too great."
NO COMMENT
On this point, if you have a look to UN/SCETDG/31/INF.48 (the report of a working group at the 31^ session of the UNSCETDG, July 2007), you can read in the first paragraph, third sentence:
"It was agreed for the discussion to leave LQ by air out of the discussion because the difference are too great."
NO COMMENT
giovedì 21 giugno 2007
GOOD NEWS
ADR
In the last Session (7-11 May 2007) of Working Party 15 (ADR) it was confirmed the decision of simplifying written instructions for drivers of road vehicles, going on the direction of only one written instruction for all classes of dangerous goods.
PING-PONG
ICAO DGP has agreed that the allocation of UN 2000 CELLULOID to table tennis balls was incorrect and that sporting balls when inflated or when containing compressed gases are not subject to the Technical Instructions
HARMONIZATION
The International Council of Chemical Associations has transmitted a sound proposal (ST/SG/AC.10/C.3/2007/3) to UNSCETDG in order to harmonize the provisions for susbstances which, when tested, do not meet the criteria for any class or division because of its chemical/physical properties.
It is then proposed to align UN Recommendations with other regulations (ADR/RID/ADN, US CFR 49) in terms of deleting Special Provision 223 (now assigned to some substances, but not to all the interested ones) and introducing a new paragraph 2.0.1.6 with the relevant statement.
In the last Session (7-11 May 2007) of Working Party 15 (ADR) it was confirmed the decision of simplifying written instructions for drivers of road vehicles, going on the direction of only one written instruction for all classes of dangerous goods.
PING-PONG
ICAO DGP has agreed that the allocation of UN 2000 CELLULOID to table tennis balls was incorrect and that sporting balls when inflated or when containing compressed gases are not subject to the Technical Instructions
HARMONIZATION
The International Council of Chemical Associations has transmitted a sound proposal (ST/SG/AC.10/C.3/2007/3) to UNSCETDG in order to harmonize the provisions for susbstances which, when tested, do not meet the criteria for any class or division because of its chemical/physical properties.
It is then proposed to align UN Recommendations with other regulations (ADR/RID/ADN, US CFR 49) in terms of deleting Special Provision 223 (now assigned to some substances, but not to all the interested ones) and introducing a new paragraph 2.0.1.6 with the relevant statement.
lunedì 21 maggio 2007
HAZARD versus CLASSIFICATION, RISK versus EXEMPTION
It is widely agreed (see also GHS) that classification of dangerous goods is based on hazard, i.e on the intrinsic characteristics of the substance/mixture.
Risk analysis (i.e. definition of events, probability of events, magnitude of negative effects) is not playing (should not play) a role in classification.
But, moving to the development of criteria for specific requirements, such as the choice of specific limits for exemption from the (or some parts of the) regulations, (a sort of) risk analysis could be an useful tool.
Let us look to the existing values for the definition of:
- High Consequence Dangerous Goods in terms of security;
- Limited Quantities;
- Excepted Quantities:
- etc.
Where do the related figures come from ? What is the rationale ?
Should not be possible to develop a reference scenario
for deriving more sound values ?
I'm not thinking in terms of a complex risk analysis, but I'm looking for instance to the Q-system developed by IAEA (see Appendx I in Safety Guide TS-G-1.1, ST-2).
Could something similar be adopted also in the more general framework of the other dangerous goods ?
Risk analysis (i.e. definition of events, probability of events, magnitude of negative effects) is not playing (should not play) a role in classification.
But, moving to the development of criteria for specific requirements, such as the choice of specific limits for exemption from the (or some parts of the) regulations, (a sort of) risk analysis could be an useful tool.
Let us look to the existing values for the definition of:
- High Consequence Dangerous Goods in terms of security;
- Limited Quantities;
- Excepted Quantities:
- etc.
Where do the related figures come from ? What is the rationale ?
Should not be possible to develop a reference scenario
for deriving more sound values ?
I'm not thinking in terms of a complex risk analysis, but I'm looking for instance to the Q-system developed by IAEA (see Appendx I in Safety Guide TS-G-1.1, ST-2).
Could something similar be adopted also in the more general framework of the other dangerous goods ?
venerdì 9 marzo 2007
TOWARDS WORLD CONVENTION
Well aware of the difficulties for achieving the goal of a world convention, I’m thinking what could be possible in the meantime for improving harmonization among different modes of transport.
One step could be a request (from ECOSOC ?) to IMO, ICAO, ECE (for ADR/RID/ADN) in terms of instructing the relevant bodies to clearly justify any (also editorial) departure from UN Model Regulations.
And on this line the UN SubCommittee of Experts on the Transport of Dangerous Goods could agree, at the July 2007 meeting, to invite ICAO DGP, IMO DSC, Joint Meeting ADR/RID/AND, to revise their regulations in terms of adopting the Model Regulations as they are, apart from well justified safety reasons, and, at the same time, bring to the attention of the UNSCETDG, together with such deviations, what is thought to be incorrect or unclear.
One step could be a request (from ECOSOC ?) to IMO, ICAO, ECE (for ADR/RID/ADN) in terms of instructing the relevant bodies to clearly justify any (also editorial) departure from UN Model Regulations.
And on this line the UN SubCommittee of Experts on the Transport of Dangerous Goods could agree, at the July 2007 meeting, to invite ICAO DGP, IMO DSC, Joint Meeting ADR/RID/AND, to revise their regulations in terms of adopting the Model Regulations as they are, apart from well justified safety reasons, and, at the same time, bring to the attention of the UNSCETDG, together with such deviations, what is thought to be incorrect or unclear.
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