www.truckandtrack.com Winter 2023 Truck and Track 65 DANGEROUS GOODS Over my career within Industrial Chemistry and Logistics, I have often assisted hauliers looking to augment their ambient trucking operations with the carriage of dangerous goods. Since the advent of society having to live with this COVID-19 Virus [as well as others] in our midst, there has been an increase in hauliers having to add ADR-regulated material into their service offering. This article, though not exhaustive, will help logistics operators contemplating adding the carriage of dangerous goods to their operation[s]. In previous Dangerous Goods Columns at Truck and Track, we have featured information related to the regulatory framework that people and organisations must comply with when working the Dangerous Goods Supply chain, including ADR/RID regulations for Road, IATA/CAA for Air and IMO/IMDG for Sea – in terms of carriage. But first a little context ADR is an Agreement concerning the International Carriage of Dangerous Goods by Road published by the United Nations Economic Commission for Europe. It was originally known as the European Agreement concerning the International Carriage of Dangerous Goods by Road but the term ‘European’ was dropped in ADR 2021. This was not Brexit related, simply an acknowledgement that countries outside Europe are signatories to the agreement and the UK is one of those signatories. ADR 2021 states in 1.8.3.1: Each undertaking, the activities of which include the consigning or the carriage of dangerous goods by road, or the related packing, loading, filling, or unloading shall appoint one or more safety advisers for the carriage of dangerous goods, responsible for helping to prevent the risks inherent in such activities with regard to persons, property, and the environment. This encompasses consignors, freight forwarders, warehouse operators and manufacturers producing goods that will be collected from their sites/depots. They must have access to a qualified Dangerous Goods Safety Advisor (DGSA) to ensure that the ADR regulations are adhered to. The requirement for undertakings which are only involved in consigning dangerous goods to appoint a Dangerous Goods Safety Adviser (not originally a requirement for consignors only) was introduced from 1 January 2019 in ADR 2019 but a transitional arrangement was put in place which gave affected parties an extended period until 31 December 2022 at the very latest to comply. We provided more information in the Winter 2022 edition of Truck and Track Magazine > https://www.truckandtrack.com/Magazine/Truck-and-TrackWinter-2022/68/ For a non-ADR logistics operator to consider taking on Dangerous Goods into their service portfolio, it is important to have trained employees and managers who have experience in this highly regulated sector – augmented by a Dangerous Goods Safety Advisor [DGSA] – either a full time member of staff or a contracted consultant. Dangerous Goods are denoted within ADR using Kemmler classification as - Class 1 – Explosive substances or articles Class 2 – Gases Class 3 – Flammable Liquids Class 4.1 – Flammable Solids, Self-Reactive and De-sensitized Explosives Class 4.2 – Substances liable to spontaneously combust Class 4.3 – Substances which in contact with water emit flammable and/or toxic gas Class 5.1 – Oxidizing Substances Class 5.2 – Organic Peroxides Class 6.1 – Toxic Class 6.2 – Biologically Infectious Substances Class 7 – Radioactive Class 8 – Corrosive Class 9 – Miscellaneous dangerous substances and Environmentally Hazardous Foodstuff and ADR In these days of COVID-19 in our midst, supply chains have to manage the carriage of cleaning, hygiene and pest control chemicals essential for the robust operation of food manufacturing, processing and packaging plants. Many of these products fall under ADR regulations. These sites require regular deliveries of janitorial chemicals, fumigation products, anti-oxidants, and rodent pest control chemicals [such as UN 1397 Aluminium Phosphide, Class 4.3 in pellet form to control/prevent rodent infestation]. It should also be noted there are foodstuffs that actually fall within ADR/IMDG rules for carriage, such as potable spirits, concentrated food colourants, flavourings and additives/ preservatives/anti-oxidants – and this also includes animal feed/nutrition. Remember – fishmeal and other selected animal feeds can also fall within the ADR/IMDG framework. Traditional fish meal is either UN 2216 [Class 9 Environmental Hazard], UN 1374 [Class 4.2 Spontaneously Combustible], but Krill had been mistakenly classed [by some] as UN 2216, class 9 when the hazard is actually 4.2 so Krill finally gets its own specific UN number 3497 with packing groups II or III and class 4.2 Spontaneously Combustible to prevent errors in using UN 2216 which only references the environmental hazard. The dilemma - as some chemicals used in the food industry [manufacture/packaging] fall under the carriage of dangerous goods ADR regulations, as well as food manufacturing plants being large users of cleaning and disinfecting chemicals [many under ADR]. When delivering to a food manufacturing plant, the ADR element may not be delivered on the same vehicle as the edible product [destined for food manufacturing], unless strict guidelines are followed. An example is the use of Nitrogen in MAP [Modified Atmosphere Packaging], displacing the Oxygen to reduce Oxidation of the food product, and enhance shelf-life, or Pure High Grain Molasses Spirit [HGMS] in potable alcoholic Upgrading Ambient Logistics for the Dangerous Goods Supply Chain by Ali Karim Ali Karim In this issue, our Dangerous Goods Columnist Ali Karim BSc FRSC provides help for logistics organisations wishing to upgrade/augment their ambient trucking operations to encompass dangerous goods and ensure regulatory compliance with ADR regulations TRUCK & TRAILER SOLUTIONS WELCOME TOALLPORTS GROUP allportsgroup.co.uk
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