ADR 2011 Instructions in Writing

Well it may be hard to believe but its 2 years since the Tremcard was banished to the dustbin of history to be replaced by the all-encompassing “Instruction in Writing”.

It may not be popular or informative and many couriers and haulage companies are still asking for  a “proper” Tremcard but they are here to stay so we’ve just got to get used to it.

The good news is that once you have one you don’t have to worry about the next load, the bad news is that they do change from time to time.

That time is now as the new ADR for 2011 came into use at  the beginning of January and, yes you’ve guessed it, they have amended the Instructions in Writing.  It is still a 4-part set but quite a lot of the content has changed so the easiest thing to do is to throw out the old ones and start again with a new set. We are currently in the transition phase which lasts until 30th June 2011 so there is still plenty of time to get organised and order your new set.

If you need any further advice please do not hesiate to get in touch via the contact page on our main website www.hazchemsystems.co.uk or you can e-mail direct from here.

New Transport Regulations – Are You Ready!

Yes its that time of year again, as 2010 comes to a close the new publications which set out the rules for 2011 and 2012 have arrived.

Road Transport – These are controlled by ADR and the new edition (2011) comes into force from 1st January 2011 to cover 2011 and 2012. As usual there is a transition period to give companies time to make the changes but if you use a haulier you may find they don’t give you that time  and will expect new labelling and so on from day 1. So be warned. I’d be interested to hear your experiences on this so please let me know if you get any early or unreasonable demands.

Sea Transport – Regulated by the IMO, the new edition is dated 2010 and also covers the period 2011 and 2012. The publication is known as the IMDG and is a 2 volume tome, some people may also want to have a copy of the IMDG Code Supplement although that is one for the specialist!

Air Freight – Unlike sea and road transport, the Air Freight regulations from IATA change every year and so we go into 2011 with the 52nd Edition dated 2011. There are some fairly major changes again this year and you can download a summary of these from our website here.  Obviously this came out before the latest “Copier Toner Bomb” outrage so it will be interesting to see if there are some hastily produced amendments to tighten things still further. Anybody who buys the current edition from us will receive any forthcoming amendments completely free of charge.

To learn more about the new publications please visit the HazChem Systems publications page where you can also download an order form.

Incidentally I’ve been contacted by a number of people just asking what all these letters mean, so we have put a new glossary page on our website which explains the most common ones therefore if you need any help just click on Glossary. If there is anything else you think should be there or which you don’t understand please send me an enquiry and I’ll help if I can – just contact David.

If you think this article (or any of our previous blogs) could be of interest to your colleagues or friends please consider spreading the word using social media such as Facebook or Digg.

Disclaimer
This is an informal blog about chemical manufacturing and distribution written by HazChem staff. While it is written from a HazChem perspective, contributions should not be taken as formal statements of HazChem policy, unless stated otherwise. Nor does it cover all the issues on which we operate – you can check these out in more detail at our main site.

We welcome and encourage comments, but we reserve the right to remove any that are offensive or irrelevant. We are not responsible for the content of external internet sites. All information contained in this blog is offered on an as-is basis and neither HazChem nor the author accepts any responsibility for any inaccuracies.

GHS the Basics

Signal Words, Hazard Statements, Precautionary Statements, Mixtures and Pictograms, CLP regulations.

Just when you thought you understood everything you needed to know about Hazardous Goods along comes a whole new collection of terms to wrestle with. So what is going on?

GHS stands for Globally Harmonised System of Classification and Labelling of Chemicals and is a further step along the path of ensuring that all countries treat hazardous substances in the same way. This step deals specifically with the classification of chemicals. Many of these criteria will be familiar to those working under the current EU system, although in many cases the actual values used to define the hazard category will differ.

Therefore EU companies will notice a number of additional hazard categories for some criteria that indicate a lower degree of hazard.

The system for classifying mixtures will also change, and this is expected to result in a significant increase in the number of mixtures that are classified as hazardous.

These changes will need to be reflected in Safety data Sheets.

Labelling

The content of labels will change significantly. Under GHS, the rectangular orange symbols familiar to those in the EU will be replaced by a new set of pictograms which will be diamond shaped like the transport symbols, but with the symbols in black on a white background with a red border.

In the EU, Indications of Danger will be replaced with Signal Words, while Risk Phrases and Safety Phrases will be replaced with Hazard Statements and Precautionary Statements.

Implementation of GHS

However where it gets interesting is that although this is an attempt to rationalise rules and regulations in reality these may be implemented on an optional basis. Therefore the likelihood is that some countries will include them in their new regulations while others, will not. Thus there will still be some differences between countries, although the foundation on which the classification is based will be the same.

GHS will be progressively implemented worldwide.

In the EU (and therefore the UK), GHS has been implemented through the CLP Regulation (EC) No 1272/2008. (Guidance on how to comply with the provisions of the new Regulation on Classification, Packaging and Labelling of substances and mixtures)

This is going to create huge problems for many companies but there is help out there. We can help you to put a new software package in place to create your new Safety data sheets and new product labels incorporating the new Pictograms.

Please check out  the Hazchem Website for more information.

So in summary:

Mixtures = Preparations

Signal Words = Indications of Danger

(a) Danger means a signal word indicating the more severe hazard categories
(b) Warning means a signal word indicating the less severe hazard categories

Hazard Statements = Risk Phrases

Safety Phrases = Precautionary Statements

Pictograms = Hazard Symbols

CLP = Carriage, Packaging and Labelling regulations

There – it wasn’t too bad was it?

Don’t forget to come back here soon for a brief introduction to REACH, oh sorry forgot to mention that one.

We’d be welcome to hear your comments on this, so please get in touch.

Thanks to NCEC for the simple explanation of GHS which forms the basis for this Blog.

New Dangerous Goods Notes – Does anybody care?

As you may know SITPRO have now issued a revised version of the ubiquitous 4-Part Dangerous Goods Note to a resounding chorus of  “so what?”

It has made some fairly minor changes to the form although one of the most important changes is to the order of presentation of some of the information. The layout is essentially the same but software packages which complete the form will need to be modified.  Companies who already use the SITPRO DGN can continue to use up their old stocks as long as the information is presented in the correct order. There is no need to throw old stocks away but as new forms are bought in they should move over to the 2009 revised design as soon as possible.

An unnecessary burden?

The problem is that although SITPRO are very strict about the form and how it is completed, many companies do not bother with it at all using their own form or some document provided by their software supplier, so why should this be of any interest?

To quote from SITPRO’s own webpage:

“Dangerous goods transported solely within the United Kingdom are subject to the provisions of ADR /RID or the IMDG Code as appropriate. Thus the carrier is required to ensure that a transport document accompanies the consignment of most dangerous goods and it is the duty of the consignor to ensure that it is made available. Further the consignor and carrier are required to keep a written record of the information contained within the transport document and to retain it for 3 months (for road/rail journeys immediately and for sea journeys from 2012).”

Much of the information which appears on the DGN is mandatory under the three transport modes which apply in the UK so the SITPRO Dangerous Goods Note is simply the best way to ensure that consignors are meeting the regulations. Adopting the SITPRO DGN and the discipline involved in correctly completing it will help companies to meet their legal obligations.

We strongly recommend that everybody uses the SITPRO Dangerous Goods Note, if you want to check out the modified design (or buy some) then please visit the Hazchem Website If you already use them then please get in touch when you need to update.

We’d be welcome to hear your comments on this, so please get in touch.

New IATA Air Freight Regulations for 2010

At HazChem Systems Ltd we like to give people as much notice as possibleabout changes which may affect them so here we go!

Its that time of year again when anybody transporting hazardous goods by Air needs to think about next year.

IATA have now published the 51st Edition of the Dangerous Goods Regulations and if you normally use it, I would strongly recommend that you get yourself a copy as soon as possible.

The changes need to be implemented from 1st January 2010, so to prevent delays to your airfreight goods you need to ensure you have done anything required by then.

If you want to visit our website www.hazchemsystems.co.uk you can find out how to obtain copies of the new publications and you can download a summary of the main changes.

I hope you find this of interest but obviously if you are not involved in Air Freight at all then why not have a look at the website anyway to see what else is happening out there?

New ADR 2009 Tremcards. Just what are the new rules for moving Hazardous Goods by Road?

Most companies involved with transporting hazardous goods know about Tremcards but the publication of the 2009 ADR has thrown everything into confusion with the introduction of a new Emergency Instruction in Writing.
This new document comprises four pages and has to be in a language which the driver of the vehicle can understand. The onus is now on the haulier to provide the document to the driver, and not on the supplier of the goods to provide information about his product.
There are a couple of issues here which are causing great concern.

Firstly, the document is non specific so it does not relate to the actual load being carried.
Secondly, there are no emergency contact numbers anywhere on the document
Thirdly, the stipulation that the only language requirement is for the driver to be able to understand it means that if an incident occured here in the UK with a non English driver for example Lithuanian, there will be no English emergency instructions on the vehicle.

So if we add these three pieces of information together we could have an accident where the driver is injured and unable to assist in any way, with instructions which do not explain how to safely respond given the actual substance involved and which in any case are likely to be unintelligible to anyone finding them and no easily accessible source of emergency information.
This sounds to me like a tragedy waiting to happen.

Like many people who have studied this piece of legislation I cannot understand why the authorities have taken such a backward step where safety is concerned and I would be pleased to hear your comments.Its too late to do anything about it this time around but perhaps there is an opportunity to express our concerns before the ADR is revised again.

In the meantime, while all companies must comply with the new regulations from 1st July 2009, we are strongly encouraging manufacturers to continue to supply the familiar Tremcards in the usual languages alongside the new Instructions in Writing. We believe that more information is certainly better in an era of Responsible Care and feel sure we are not alone in this.

We will try to keep people informed on the changes via our website http://www.hazchemsystems.co.uk/tremcard.html where you can also find out more about how to obtain both the new Instructions in Writing and the CEFIC Tremcards.

If you want to contact me direct please e-mail me here