Truck and Track Summer 2021

www.truckandtrack.com Summer 2021 Truck and Track 47 DANGEROUS GOODS credit chemistry and the chemical industry with contributing so much to the UK economy.” He points out that the chemical industry requires ‘considerable supply chains’, creating jobs in the process. On top of this, chemistry is crucial in enabling virtually every other industry to operate. While Patrick Walter of The Society of Chemical Industry stated, “ Although it is hard to imagine, if there had never been any chemistry research it is questionable whether some of these industries would exist in the way they do today.” So, when one is confronted with balancing the legislative rules that govern the management of Dangerous Goods in the Supply Chain, one must reflect upon the crucial nature of the Chemical Industry in supporting so many other arms of the British economy. The Chemical Industries Association [CIA] indicated that 180,000 employees work for around 3,000 organisations in the sector, but of those organisations only 160 employs over 250 people. Though these 3,000 organisations help provide UK plc with a remarkable 1.5% of total Gross Domestic Product [GDP]. The trickle-down effect is something we must all welcome in these days of a surreal economy. The Dangerous Goods Supply Chain A Supply Chain is a system of organisations, people, technology, activities, information and resources involved in moving a product or service from suppler [consignor] to customer [consignee]. The physical elements of the supply chain of Raw Material to Finished Product broken down into elements is – ■ RAWMATERIAL SOURCING – transport – stocking – QA – process – QA – stocking – transport ■ FINISHED PRODUCT – QA - production – QA – rework – stocking – transport When working with Dangerous Goods, considerations must be made for – Information, Training, Communication, Documentation, Risk Assessments and Countermeasures, Safety, Security, QA, Environmental, Regulatory Compliance, Insurance, and the most crucial – Common Sense and Logic. Key legislative regulations that traverse the supply chain are as follows: COMAH [Control of Major Accident Hazards] – This came into play after the 1976 Seveso disaster, outside of Milan, giving rise to the European Seveso Directive which in the UK eventually became referred to as COMAH. This legislation controls the storage and movement of Hazardous Goods, defined within agreed aggregated quantities by Kemmler Class, as well as placing limits on ‘named substances’ . There are two levels of COMAH, lower tier and higher tier – dependant upon the quantities and nature of hazardous goods stored on site. Even if the site is registeredunder COMAH, or if belowthe thresholds and protocol outlined in COMAH; the chemical site still needs to address additional regulations, many of which also pertain to non- Chemical sites. These relate to, and are not restricted to – ■ ENVIRONMENTAL – various legislations ■ RISK ASSESEMENTS [including Fire Risk Assessments] ■ MATERIALS HANDLING ■ QUALITY ASSURANCE ■ WASTE DISPOSAL AND RECYCLING ■ ENERGY ■ COSHH – Control of substances hazardous to health ■ REACH–Registration, evaluationandauthorizationof chemicals ■ CLP/GHS – Classification, labelling and packaging, and the global harmonized system of classification and labelling. ■ SECURITY – both on site and in-transit, with particular relevance to what are termed High-Consequence-Dangerous-Goods [HCDG] which also have ADR ramifications ■ SITE PLANNING, EMERGENCY AND CONTINGENCY – liaison with local authority, regulators, and emergency services. ■ TRAINING AND DOCUMENTATION ■ SUPPLIER AND SUBCONTRACTOR APPROVAL ■ HEALTH AND SAFETY AT WORK ACT 1974 ■ DANGEROUS GOODS SAFETY ADVISOR [DGSA] TRADE ASSOCIATIONS – technical guidance and best practice [eg BCGA [British Compressed Gas Association], APN [Association of Pallet Networks], FTA [Freight Transport Association], CBA [Chemical Business Association] etc. When looking at modes of transport to and from the site, these are governed by – Road – ADR Rail – ADR/RID Ship – IMO/IMDG Air – ICAO/IATA/CAA Pipelines – PSR Acronyms above ADR = Accord Dangereuse Routiers [aka Agreement on Dangerous Goods by Road] RID = Regulations concerning the International Transport of Dangerous Goods by Rail IMO = International Maritime Organisation IMDG = International Maritime Dangerous Goods Code ICAO = International civil aviation organisation IATA = International Airline Travellers Association CAA = Civil Aviation Authority PSR = Pipeline Safety Regulations The Key is Assessing Risk and Placing Robust Countermeasures in place thus ensuring a Safe Systems of Work, starting with the ‘Properties’ of the Dangerous Good[s] and then the ‘Process’, be it Production, Quality Assurance, Packaging and Distribution [raw Flammable paint Flammable drums class 3