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Summer 2019 Truck and Track 49
DANGEROUS GOODS
In today’s world, the requirement for documentation, both
paperwork and in digital formats, remains critical when
managing the logistics of dangerous goods from manufacture,
QA, storage and onward transportation. There are hazards
posed by non-hazardous goods and dangerous goods alike.
However,when it comes tohazardousmaterial, documentation
requirements are more acute in terms of the veracity in
managing the risks. This article outlines the main areas of
documentation required when working within the dangerous
goods supply chain. If storing / securing the documents
electronically [or online] such as risk assessments, safety data
sheets etc, then back-up must be factored in to overcome
problems if pc and/or internet connection is compromised.
Acceptable back-up media can be CD, USB, DVD or Hard Copy
– and must be available for inspection by authorised personnel
requesting to see the relevant documents.
ADR 2019, the regulations covering dangerous goods by road and
rail, is applied in all signatory member states. It has a 6-month
transition period so it becomes compulsory on 1st July 2019.
Despite the political situation with regard to the UK’s proposed
withdrawal from the European Union, we have been advised that
Great Britain will follow the ADR regulations within the country.
Any later changes will be advised by the Department for Transport,
London, should they arise.
For those bewildered by the regulations concerning the carriage of
dangerous goods by road, the 4th edition Guide to Exemptions for
the Carriage of Dangerous Goods by Road 2019, is now available
from Labeline. Within this essential book, UN numbers and the
exemptions that apply are listed in an easy reference format which
provides information on how to use the data within the regulatory
framework, thus ensuring your organisation’s compliance to the
law. And, most critically, it provides a concise guide for the busy
transport operator.
The 39th Amendment (2018) of the IMDG Code for Sea can also
be applied now but a one-year transition period means that it
becomes compulsory on 1st January 2020.
For air freight of dangerous goods, please be advised that the
regulations [ICAO Technical Instructions / IATA DGR] came into
effect on 1st January 2019.
The first key document is the risk assessment which examines
the hazards posed in the process, e.g. unloading operations, fire
prevention, security etc, and then management of the associated
risks from the activity. Countermeasures, such as personal
protective equipment and training requirements, need to be
assessed and implemented to manage the risks. When working
with dangerous goods, you must formally document the risks in a
written and periodically reviewed assessment. When it comes to
critical processes, then change control must also be documented.
From this comes what we term the Safe System of Work [SSoW], for
documenting the activities required e.g. unloading a container, or
loading a railcar etc.
If warehousing the product, or if involved in analysis or quality
assurance [in terms of Chemistry], then a safety data sheet is
required to be kept on-hand and accessible to those who may need
to reference it [examples being operators, auditors, regulators and
enforcers], as well as for the use by emergency responders, should
there be an incident with the product.
Anyone involved in themanufacture or logistics of dangerous goods
must have a qualified Dangerous Goods Safety Advisor [DGSA], who
will produce a documented annual report which must be retained
by the organisation, detailing the last twelve month’s activities,
record volumes per Kemmler Class, dangerous occurrences and any
issues raised by the organisation.
Documented training records are essential, such as fork lift
certification, ADR certification for drivers, ADR awareness,
induction, first aid, manual handling and many other areas of
activity. Also, of course, training records, like risk assessments, must
be periodically inspected and updated as per policy, by statute or by
the organisation’s internal protocol.
Insurance is another matter that needs documentation, from
display of the employers’ liability details plus material handling
equipment monitoring by an insurance assessor.
Drivers carrying dangerous goods by road need to be trained
and hold valid ADR certification, as well as carrying the 4-page
document termed ‘Instructions in Writing’, more commonly
referred to as the “Tremcard”.
Commercial vehicles must have documented service and
inspection records but, with dangerous goods and specialised
kit, there are additional documentation requirements, such as
periodic inspections and pressure testing of road-tanks, hoses and
associated equipment including tail-lifts, on-board cranes, rear
mounted fork trucks etc.
Consigning Dangerous Goods
Unlike ambient [non-hazardous goods] when there is a custody
transfer, the ‘Proof of Delivery’ [POD] has to be in dangerous goods
Documentation in the Digital
World for the Carriage of
Dangerous Goods by Ali Karim
In this issue, our Dangerous Goods Columnist, Ali KarimFRSC FCILT, takes a detailed look
at Regulatory Compliance in the digital world for the Carriage of Dangerous Goods.
Ali Karim
John Newsome DGSA
01543 420 121 VEHICLE
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