[ID] => 8352
[post_author] => 34
[post_date] => 2017-08-17 10:58:52
[post_date_gmt] => 2017-08-17 09:58:52
[post_content] => The Council on Safe Transportation of Hazardous Articles (COSTHA) chose to concentrate much of its Annual Forum this year on developments in North America. That decision was understandable, as the approach to regulatory activity being taken by the new administration in the US means that industry will have to find a new way to interact with the Department of Transportation (DOT) and its various agencies, while Transport Canada is also working hard to bring its standards up to date and to align as much as possible with the regulations of its major trading partner south of the border. There was plenty to report from the COSTHA meeting, which took place in Scottsdale, Arizona from 30 April to 4 May, as readers will have seen in last month’s issue (HCB
August 2017, page 62).
However, COSTHA is also aware that many of its members operate further afield and there was also plenty to fill the agenda in terms of regulatory developments in emerging markets, as well as updates from the international agencies whose efforts directly impact shippers and carriers to and from North America.
BOOGIE WOOGIE BUGLE BOY
To bring news from Geneva, London and other exotic places, COSTHA had invited Shane Kelley, assistant international standards coordinator at the Pipeline and Hazardous Materials Safety Administration (PHMSA), who brought his trumpet along to help marshal the evening prize-givings. Before that, he reported on the progress made by the UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) during the 2015-16 biennium, which had resulted in the 20th revised edition of the UN Model Regulations. The changes they made will begin to filter down into the modal and national provisions in 2019.
Kelley highlighted some important decisions taken in what had been a very busy two years for the UN experts. High on his list was the adoption of 12 new UN entries for dangerous goods in articles, covering all classes except 1 and 7. These are designed to address articles that contain dangerous goods in amounts exceeding the limited quantity (LQ) thresholds.
The entries come with a new packing instruction and general packing provisions. Packing Group II standards are required, except for ‘robust’ articles, which require strong outer packaging or, in certain circumstances, many be transported unpackaged. The aim of the new entries is to put a stop to the increasing number of UN entries being adopted for specific articles: the system sets out criteria for the classification of articles and also creates a foundation that will reduce the need for special provisions, special permits and approvals and other specific provisions, Kelley explained.
The audience would not have been surprised to hear that the UN experts had also looked at lithium batteries once more and had come up with some further changes. A new entry has been adopted for lithium batteries installed in cargo transport units (CTUs); a summary test document has been agreed; and conditions have been established for the transport of damaged and/or defective lithium batteries.
Some resolution has also been achieved in the search for a way to accommodate both the GHS and TDG approaches to the classification of corrosive substances, with agreement on non-destructive test methods, including additivity and bridging principles.
In addition, the UN experts agreed that the water temperature during the hydraulic testing of plastics packagings must be measured and documented (rather than specifying a water temperature) and packaging and hazard communication provisions were adopted for fuel tanks for motor vehicles. Work on the packaging of Category A infectious waste is ongoing, Kelley said.
His presentation came more up to date with a report on the International Civil Aviation Organisation’s (ICAO) Working Group on training and incident reporting, held in April 2017 and attended by both PHMSA and the Federal Aviation Administration (FAA). The 2017-2018 edition of the ICAO Technical Instructions includes in an Attachment the new provisions for competency-based training that are due to enter into force in 2019, to allow industry time to look at them in detail and raise any issues. There is also guidance material and a competency framework for state employees. The meeting also developed proposed amendments with greater detail on the reporting of incidents by states and the Working Group is continuing to develop guidance for states on this issue.
Over at the International Maritime Organisation (IMO), current work of interest to the COSTHA audience includes the under-deck stowage of explosive articles not carried in closed CTUs; a proposal to adopt provisions similar to US1 for jet perforating guns for transport by offshore supply vessels; the usual update to the marine pollutant list; and new provisions for the carriage of polymeric beads and plastic moulding compounds.
Kelley also mentioned the meeting of the joint experts on RID/ADR/ADN, where the US has a seat at the table and COSTHA has gained observer status. A lot of work has been done to try to alleviate the problems caused by a lack of mutual recognition between US DOT specification gas cylinders and pressure receptacles manufactured and used in Europe. The Compressed Gas Association (CGA) has now requested similar action by PHMSA.
Kelley also gave the audience a preview of the items on the agenda for the UN experts during the 2017-18 biennium, the first meeting of which was due be held in June 2017 (which HCB will report on in a forthcoming issue). To start with, the experts are planning to go back to basics on lithium batteries and develop a comprehensive, hazard-based system for the classification of lithium cells and batteries for transport. The first step will be to look at intrinsic hazards, Kelley said.
Further work will also be carried out on polymerising substances and on the packaging of Category A infectious waste.
The TDG and GHS experts are also working more closely together on a number of issues and the coming biennium will certainly feature work on package-dependent classifications. While the Model Regulations recognise that in many cases the volume and/or packaging method of a material can affect the level of hazard it poses during transport – and this is particularly the case for explosives – the GHS looks only at the intrinsic properties of each material.
Kelley also mentioned that PHMSA is opening up to more public input ahead of the UN sessions, with public meetings held prior to both TDG and GHS sessions to solicit comments on the US position on any working or informal document due to be considered. He then passed the podium to Lindsey Constantino, international transportation specialist at PHMSA, who reported on progress at the US-China Transportation Forum, the eighth annual meeting of which had taken place in 2016 in Los Angeles. This included work on increasing the level of cooperation between US and Chinese authorities on various aspects specific to the transport of hazardous materials, she explained.
Work is now underway to translate the 2016 edition of the Emergency Response Guide (ERG) into Chinese and training on its use will be included on the agenda for the ninth meeting of the Forum, which will take place in the third quarter of 2017. A working group will also be looking at harmonising Chinese domestic regulations with the UN Model Regulations, particularly in the area of LQ.
More information on China was provided by Zhang Qiang from the Ministry of Transport (MOT), ably assisted by DGM’s Terry Guo, who acted as interpreter. Zhang reported that around 1.6bn tonnes of dangerous goods is carried annually in China and that this figure is growing by some 10 per cent a year. Road transport now accounts for 1bn tonnes. He also gave an indication of the size of the sector in China: road transport of dangerous goods involves 10,600 enterprises, 310,000 vehicles and about 1.2m people.
In years gone by, audiences presented with an overview of the way China regulates the transport, handling and supply-and-use of hazardous chemicals have often been overwhelmed by the sheer number of ministries involved in establishing and policing the relevant legislation, regulations and standards. Now, however, that structure is becoming more streamlined and more familiar to those who already use national and international regulations. There are signs that the Chinese authorities are working hard to bring even more harmonisation to their national system.
For instance, a new MOT Order on Hazmat Road Transport Safety Measures intends to cover end-to-end movements; as Constantino had hinted, this is the Order that will permit, for the first time, the use of LQ as well as excepted quantity (EQ) provisions in Chinese regulations. The LQ and EQ provisions themselves will be set down in the GB 28644 standard and are drawn from ADR. They will not cover explosives, items of Division 6.2 and certain high-hazard substances. Zhang mentioned that guidelines are currently in preparation.
Another MOT Order, JT/T 617, which will be implemented “soon”, according to Zhang, represents a consolidated regulation for the transport of dangerous goods by road. In effect it adopts the UN Model Regulations and ADR (except for Parts 6 and 9) as recommended practice but, he said, this may become mandatory later.
Last year MOT published a wide-ranging exemption from the regulations for low-hazard compressed gases under certain circumstances – a maximum cylinder size of 50 litres; no more than 500 kg per transport unit; cylinder warning label on the outer packaging, and so on. Initially this applied specifically to carbon dioxide and responded to a petition from Coca-Cola (“MOT is responsive to industry!” Zhang said), allowing its beverage gas cylinders to be transported in effect as general goods. MOT is now considering extending this exemption to other gases, including nitrogen, helium, neon, argon and, for medical use only, oxygen.
Finally, Zhang mentioned an ongoing project to develop a Safety Information System. The aim of this project is that it will support MOT’s oversight of the transport of dangerous goods. It is currently expected that it will be ready for roll-out in 2020.
THE BOY FROM BRAZIL
All of the above was delivered in one intense afternoon session that demanded a lot of concentration from the after-lunch audience. Yet they had little respite for, after half an hour’s coffee break in the larger-than-ever exhibition hall, they were called back in for two more detailed presentations, the first of which was given by Ezekiel Caetano Ferreira, business manager for Concepta DG Compliance Ltda, who gave an update on Brazil’s dangerous goods regulations.
Brazil is a member of the UN Sub-committee of Experts and is committed to following the UN Model Regulations, Ferreira said; however, the country had fallen behind somewhat and has only just caught up with the 19th revised edition. National Technical Committees are now in place, composed of representative trade associations, to study, improve and support the Brazilian government’s efforts to update or correct the regulations.
All ground shipments of dangerous goods must be accompanied by an Emergency Card, in the Portuguese language, conforming to the Brazilian standard ABNT 7503; there are exemptions for small volume loads, which do not need the Emergency Card, placarding on the vehicle, personal protective equipment, route limitations, driver training, and so on.
Ferreira noted that Brazil’s accident rate has fallen by around 70 per cent over the past ten years. He cited better driver training, better roads (particularly in central and southern parts of the country) and newer trucks (helped by government subsidies) as being the main causes of this impressive improvement. In addition, the Brazilian Association of Chemical Companies has put in place a health, safety, environment and quality (HSEQ) programme that focuses on continuous improvement.
Brazil is currently applying the second revised edition of GHS but, Ferreira said, it intends to update to the sixth revised edition “in the near future”.
CLOCKING UP THE MILES
Picking up the prize for the speaker with furthest to travel, Bashyam Govindarajan, COO of Tirwin Management, arrived from Mumbai with news of developments in India. The country follows the ICAO Technical Instructions for air transport and the International Maritime Dangerous Goods (IMDG) Code for sea transport, he explained, and its domestic rules are based on the UN Model Regulations.
However, there are some specific variations. For instance, in air transport, all carriers need state of operator approval to handle dangerous goods and there are specific approvals required from the government of India for the carriage of radioactive materials and arms and ammunition by air.
There is plenty of oversight of dangerous goods operations in the air sector but, Govind said, safety audits are focused on carriers and terminals. Shippers and forwarders generally only come into the frame after an accident, although this is likely to change in the future. He also noted that most ports in India are not authorised to hold dangerous goods within their area; such goods offloaded from vessels need to be picked up straight away.
The movement of dangerous goods by surface modes is covered by the Hazardous Substances (Classification, Packaging and Labelling) Rules 2011 although, as Govind explained, these relate largely to environmental protection.
Like many emerging markets, India faces a number of challenges when it comes to dangerous goods. There is a lack of knowledge and a greater willingness to accept risks, Govind said. In addition, the cost of compliance is high – a single copy of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) costs five weeks’ average salary, for instance. He stressed that, if any progress is to be made, then the cost of compliance needs to come down and the cost of non-compliant must be put up.
Govind completed his presentation with some ideas about the opportunities that India holds for those in the dangerous goods sphere. The country is shifting its focus towards a production economy and it is now becoming a hub for speciality chemicals, pharmaceuticals, and flavours and fragrances. There is a need for knowledge, which could be delivered through training and public seminars. However, he stressed, these must be cost-effective or else they will fail to find an audience.
OUTSIDE THE HALL
Everything reported in this article happened within the space of one afternoon, and delegates still had the delight of listening to Paul Rankin’s legislative briefing (included in last month’s report) before they could let their hair down over beverages of their choice, kindly sponsored on this occasion by Labelmaster, and a chance to window shop in the exhibition room.
Indeed, these days the formal conference element of COSTHA’s Annual Forum takes up only one and a half days. Outside of that there is another three days of training courses, roundtables, workshops and committee meetings, which inter alia covered regulatory developments in Mexico. Other topics featured during the 2017 event included lithium batteries (of course), air carrier issues, the transport of hazardous waste, issues specific to the automotive sector, and e-commerce.
The breadth of information provided during the five-day shindig is so varied that it is necessary for those with a need for help on issues specific to their operations can find the depth of information only in those break-out sessions, leaving the conference free to range widely over those topics that are of most general interest.
This year it was noticeable that there is a lot going on, both within the regulatory bodies (and their political overlords) in Washington DC and Ottawa, as well as within the industry itself. It will be interesting to see how those developments pan out over the coming year.
Anyone with any interest in the North American hazmat sector would do well to mark their diary for next year’s COSTHA Annual Forum, which will take place at the Bonaventure in Weston, Florida from 22 to 25 April.
Full details can be found at www.costha.com
[post_title] => COSTHA: Playing away
[post_status] => publish
[comment_status] => open
[ping_status] => open
[post_name] => costha-playing-away
[post_modified] => 2017-08-17 10:58:52
[post_modified_gmt] => 2017-08-17 09:58:52
[post_parent] => 0
[guid] => https://www.hcblive.com/?p=8352
[menu_order] => 0
[post_type] => post
[comment_count] => 0
[filter] => raw