Transport of Dangerous Goods and UN Regulations

Today, the need for security standards and enabling trade is greater than ever. At the same time, addressing the concerns of institutions responsible for regulating legislation regarding the protection of life, the environment and property in connection with the transport of dangerous goods represents a priority no less than the above need. According to the plan adopted at the World Summit on Sustainable Development held in Johannesburg, South Africa in 2002, it was decided that the Globally Harmonized System for Classification and Labelling of Chemicals should be fully operational in countries by 2008. Implementation of the published regulations and recommendations by countries and international organizations, feedback on the legislation in question, and contributions to continued development through proposals and recommendations are expected. UN standards are seen as critical control elements in national, regional and international certification. However, imbalances in UN certifications of packaging can lead to the use of packaging that does not provide the desired performance level, and consequently increases the risk of dramatic accidents that could affect people and the environment. The fundamental principle put forward by the Committee is that competent authorities designated in countries ensure that operations comply with regulations. This responsibility encompasses the monitoring of packaging design, manufacturing, testing and inspection; classification of dangerous goods; preparation and documentation of packaging; and stacking by shipping, warehouse personnel and carriers. However, there is a need to continue developing parameters for monitoring this comprehensive process. In this regard, review of legislation, implementation of changes and additions, and development of regulations remain a critical process. This is a laborious and complex process. The contribution of many experts, organizations, countries and committees is required for the joint publication of relevant regulations and recommendations. A diagram showing the working relationships of the Expert Committee readily illustrates the complexity of the work. It is not easy to fully understand the relationships in the system, but the presence of sectoral organizations related to packaging (ICDM, ICCR, EMPAC/SEFEL, SSCA) is of great importance. Commissions related to UN SC TDG (Sub-Committee of Experts on the Transport of Dangerous Goods) develop UN standards and modular regulations (for example, ADR for road transport). These committees address legislative changes and new regulatory drafts primarily through a series of working and decision meetings. These are: • ECOSOC Sub-Committee of Experts on the Transport of Dangerous Goods (UN SC TDG) – 2 meetings held each year in June and December in Geneva, • Joint meetings of the RID Expert Committee held in Bern in March and in Geneva in September, and the Working Group on the Transport of Dangerous Goods.

All of these complex legislative development efforts are the result of a search for a systematic approach that is comprehensive and comparable across all countries.

This process is also based on a highly dynamic, inclusive and productive environment. We can cite as an example the recent discussion and assessment being conducted on hydrostatic test methods for plastic packaging. Considering that existing test parameters may be insufficient to ensure that hydrostatic tests performed on plastic packaging demonstrate the same performance, a discussion process initiated by German certification body BAM has been opened to the discussion of relevant stakeholders and experts from around the world. According to BAM, the failure to establish a relationship between current internal pressure values and temperature makes the safety information insufficient, and it has argued that imposing a minimum condition of 120°C would be an appropriate solution. This is considered a value that most packaging can provide. Alternatively, the use of a correction factor for this purpose has also been suggested. In the discussions, views emerged that other parameters also have an effect on meeting the expected conditions.   On the other hand, it has also been stated that different resins will exhibit different temperature resistance, and that standards should take into account economic criteria. The American view came as temperature is not a safety issue but a consistency issue. As a result, instead of temperature being established as a safety parameter, it has been advocated that test temperature be included in the test report. While all these views are being discussed by the relevant parties, no conclusion has yet been reached on this matter. Another current example is harmonization regarding classification and labelling of chemicals. New criteria are on the agenda for classification of corrosive materials (Class 8), and the relevant vote will take place in December 2016. The new criteria are based on pH value and surface corrosion properties. As a result of the harmonization of the GHS criteria for corrosive liquids with UN TDG classification, this change is anticipated to lead to a reassessment of the packaging group in transport and changes in classifications. As can be seen from these discussions, the suitability of packaging and tests in the transport of dangerous goods remain an active and developing topic. Rıdvan Eğin / Quality Assurance Coordinator / Sarten Ambalaj A.Ş.

References

1. EIPA Transport and Regulating Committee Meeting Presentation, 10.3.2016, Dusseldorf.

2. Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of Chemicals. UN SCE TDG 48th session on 30.11-9.12.2015.

3. Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of Chemicals. UN SCE TDG 49th session on 27 June-6 July 2016, Geneva, "Proposal for revision of Chapter

2.8 of the Model Regulations: Introduction of alternative methods for classification and packaging group assignment.

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