The Carriage of Hazardous Substances by Road

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1 Health and Safety Policy UHSP/15/HS/08 Schedule 6.1 Hazardous Substances Policy - Transport The Carriage of Hazardous Substances by Road This document is a schedule from University Hazardous Substances Policy and it should be used in conjunction with the Policy. The arrangements in this Schedule are intended to ensure compliance with the legal requirements for transporting hazardous substances by road. The arrangements apply to all movements of hazardous substances on public roads away from the campus. Separate, arrangements apply for journeys within and in the vicinity of the campus (See Schedule 6.2). Revised October 2011 UHSP/15/HS/08 Schedule 6.1

2 CONTENTS INTRODUCTION 1 Legal Requirements 1 Application 2 POLICY 2 Requirements for the Transport of Hazardous Substances by Road 2 Consignor's Responsibility 2 Vehicle Driver's Responsibility 2 GUIDANCE 3 Limited Quantity Provisions 3 Packaging Requirements for Limited Quantities 3 APPENDIX ADR Dangerous Goods Classes 6 PAGE

3 Hazardous Substances Policy - Transport The Carriage of Hazardous Substances by Road INTRODUCTION Hazardous substances and articles containing hazardous substances are referred to as Dangerous Goods when transported. Carrying goods on public roads involves the risk of traffic accidents. If the goods carried are dangerous, there is also the risk of an incident, such as spillage or release of substances, leading to hazards such as fire, explosion, chemical burn or environmental damage. Dangerous Goods are liquid or solid substances and articles containing them, including wastes, that have been tested and assessed against internationally agreed criteria - a process called classification - and found to be potentially dangerous (hazardous) when carried. Dangerous Goods are assigned to different classes depending on their predominant hazard. Wastes are classified in the same way as other substances. Legal Requirements The transport of Dangerous Goods is highly regulated 1. Highly prescriptive requirements on the carriage of dangerous goods, include labelling, packaging, permitted quantities, documentation, vehicle marking, vehicle equipment, loading, driver training. Their purpose is to protect everyone either directly involved (such as consignors, loaders/unloaders or carriers), or who might become involved (such as members of the emergency services and public). The regulations place duties upon everyone involved in the carriage of dangerous goods. The regulations and ADR requirements are detailed and complex imposing an onerous burden on those involved. The carriage of dangerous goods is best avoided. The regulations refer to Consignors and Carriers. The Consignor is whoever is responsible for requiring goods to be transported. The Carrier is whoever is responsible for the vehicle used for the transport of dangerous goods and it could be the University or a commercial courier. The Consignor's responsibility includes, at a minimum: classifying the goods as required; packaging the goods suitably and safely; marking and labelling the goods correctly; but could involve other duties, depending on the nature and amount of the Dangerous Goods and apply regardless of which Carrier is used. Exemptions However, subject to acceptable packaging and labelling, some goods are exempted from all the other requirements of the regulations and ADR when suitably packaged in small quantities in boxes (Limited Quantity provisions). There are no exemptions for explosives. The carriage of machinery or equipment not specified in ADR and which happen to contain dangerous goods in their internal or operational equipment, is also exempted provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage. There are also partial exemptions for a total load below a specified Limited Load quantity. Guidance on determining Limited Load exemption is outside the scope of this Policy please consult the Health and Safety Unit for help. Classification There is a classification process using internationally agreed criteria to determine whether a substance (solid, liquid or gas) or an article containing a substance is sufficiently hazardous to be regarded as Dangerous Goods. Classification is essential - it is the precursor for everything that follows. Once a substance or article has been properly classified, the Dangerous Goods List in ADR contains the information that allows every other requirement to be ascertained, especially, whether and what Limited Quantity provisions or other exemptions apply. A copy of the Dangerous Goods List can be downloaded from the University Health and Safety website [ Dangerous Goods List ADR2007.pdf] 1 The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007 (SI 2007/1573) (CDG 2007), implement European Directives and the European agreement ( Accord européen relatif au transport international des marchandises dangereuses par route, known as ADR) [ 1

4 Application The following requirements apply to any substances or articles to which the University "Hazardous Substances Policy" applies and which will be conveyed for any purpose on a road vehicle for any journey, by post, other carrier or University vehicle. This includes spare petrol and substances such as LPG, fertilisers, pesticides carried for use by University staff. Separate requirements apply to items hazardous because of the risk of infection or exposure to radiation. NB The Post Office does not normally permit hazardous substances to be posted. The Post Office Customer Service Centre will advise. POLICY Requirements for the Transport of Hazardous Substances by Road Consignor's Responsibility Classification 1 The appropriate entry in the Dangerous Goods List 2 must be located for the substance or article and the following information, needed to classify, package and label the substances correctly, ascertained from the entry: the proper shipping name of the goods; the corresponding UN number; classification code; the label code; the Limited Quantity code; whether carriage is specifically prohibited. 2 Determine the total limited quantity amount permitted from the Limited Quantity code (See Guidance section below). 3 If: there is no appropriate entry in the Dangerous Goods List; or the Limited Quantity code is LQ0; or carriage is specifically prohibited; or it is not possible to keep the amount carried within the total limited quantity amount determined in 2; DO NOT proceed, consult the health and Safety Unit for further help. Packaging and Labelling 4 The inner container must be correctly labelled in accordance with the CHIP/CLP regulations. 5 The package must be labelled as specified in the Guidance section below. 6 Dangerous goods must be packed in good quality packagings and in such a way that they do not escape during handling and carriage and as specified in the Guidance section below. Vehicle Drivers s Responsibility 1 Dangerous goods must be secured to prevent accidents arising from the load shifting. 2 Packages must not be opened during transit. 2 Dangerous Goods List ADR2007.pdf 2

5 GUIDANCE Limited Quantity Provisions The carriage of dangerous goods is exempted from all other provisions of ADR, subject to the quantity restrictions in the table below and the following packaging requirements. There is no exemption for LQ0. Limited Quantity Code Combination Packagings Maximum Net Quantity (Max. gross 30kg) Per inner container Per package 120 ml 1 l LQ1 LQ2 LQ3 500 ml 1 l LQ4 3 l LQ5 5 l Unlimited LQ6 5 l LQ7 5 l LQ8 3 kg LQ9 6 kg LQ ml LQ g LQ12 1 kg LQ13 1 l LQ14 25 ml LQ g LQ ml LQ ml 2 l LQ18 1 kg 4kg LQ19 5 kg LQ22 1 l LQ23 3 kg LQ24 6 kg LQ25 d 1 kg LQ26 d 500 ml 2l LQ27 6 kg LQ28 3 l Packaging Requirements for Limited Quantities Packages may comprise: an inner container, such as a glass bottle, that holds the substance and an outer enclosure that may hold one or more inner containers. A single package, such as a plastic or glass lined steel drum. The packaging and packing provisions of ADR are prescriptive, detailed and complex. For example, UN type approved containers/packagings must be used. However, the packagings for exempted goods need only need to meet the material and construction requirements of ADR and don t need to be type approved. Appropriate re-use of suppliers original packagings that are in good condition would almost certainly meet the requirements. 3

6 General Requirements Packagings: Schedule 6.1 Dangerous goods shall be packed in good quality packagings: strong enough to withstand the shocks and loadings normally encountered during carriage, including handling during loading and unloading; constructed and closed so as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure (resulting from altitude, for example); No dangerous residue shall adhere to the outside of packagings Inner packagings Parts of packagings in direct contact with dangerous goods: shall not be affected or significantly weakened by those dangerous goods; and shall not cause a dangerous effect e.g. catalysing a reaction or reacting with the dangerous goods. Where necessary, they shall be provided with a suitable inner coating or treatment. Packagings containing liquids When filling packagings with liquids, sufficient ullage (empty space) shall be left to ensure that neither leakage nor permanent distortion of the packaging occurs as a result of an expansion of the liquid caused by temperatures likely to occur during transport. Unless specific requirements are prescribed, liquids shall not completely fill a packaging at a temperature of 55 C. Packing Inner packagings: shall be packed in an outer packaging in such a way that, under normal conditions of carriage, they cannot break, be punctured or leak their contents into the outer packaging. inner packagings containing liquids shall be packed with their closures upward and placed within outer packagings consistent with the orientation markings prescribed. Inner packagings that are liable to break or be punctured easily, such as those made of glass, porcelain or stoneware or of certain plastics materials, etc., shall be secured in outer packagings with suitable cushioning material. Any leakage of the contents shall not substantially impair the protective properties of the cushioning material or of the outer packaging. Incompatibles. Dangerous goods shall not be packed together in the same outer packaging or in large packagings, with dangerous or other goods if they react dangerously with each other and cause: (a) combustion or evolution of considerable heat; (b) evolution of flammable, asphyxiant, oxidizing or toxic gases; (c) the formation of corrosive substances; or (d) the formation of unstable substances. Other hazards The closures of packagings containing wetted or diluted substances shall be such that the percentage of liquid (water, solvent or phlegmatizer) does not fall below the prescribed limits during transport. Where pressure may develop in a package by the emission of gas from the contents (as a result of temperature increase or other causes), the packaging may be fitted with a vent provided that the gas emitted will not cause danger on account of its toxicity, its flammability or the quantity released, for example. A venting device shall be fitted if dangerous overpressure may develop due to normal decomposition of substances. The vent shall be so designed that, when the packaging or inner 4

7 packaging is in the attitude in which it is intended to be carried, leakages of liquid and the penetration of foreign substances are prevented under normal conditions of carriage. Liquids may only be filled into inner packagings which have an appropriate resistance to internal pressure that may be developed under normal conditions of carriage. Dangerous goods may be packed together with other articles or substances, provided they will not react dangerously in the event of leakage. The maximum gross mass of a combination packaging shall not exceed 30 kg Mixed goods in Packages Subject to the maximum limits and individual limits, dangerous goods may be packed together with other articles or substances, provided they will not react dangerously in the event of leakage. Specific Requirements Codes LQ1 and LQ2 Compressed and refrigerated gas vessels are considered to be combination packagings. They are exempted provided: they meet the ADR standards for materials and construction; quantities do not exceed the inner container quantities in the table above. Codes LQ3 to LQ19 and LQ22 to LQ28 Substances with these limited quantities codes are exempted from ADR provided: The substance is carried in combination packagings, the following outer packagings being allowed: steel or aluminium drums with removable head; steel or aluminium jerricans with removable head; plywood or fibre drums; plastics drums or jerricans with removable head; boxes of natural wood, plywood, reconstituted wood, fibreboard, plastics, steel or aluminium; and be so designed that they meet the relevant construction requirements of ADR 6.1.4; The maximum net quantities per inner container and per package shown in the table above are not exceeded; Each package is clearly and durably marked with: the UN number (preceded by the letters "UN") of the goods from the Dangerous Goods List; in the case of different goods with different UN numbers within a single package: the UN numbers of the goods; or the letters "LQ" These markings shall be displayed within a diamond-shaped area surrounded by a line that measures at least 100 mm 100 mm. The width of line forming the diamond shall be at least 2 mm; the number shall be at least 6 mm high. Where more than one substance assigned to different UN numbers are included in the package, the diamond shall be large enough to include each relevant UN number. If the size of the package so requires, the dimension may be reduced, provided the markings remain clearly visible. 5

8 APPENDIX ADR Dangerous Goods Classes Dangerous Goods are assigned to different classes depending on their predominant hazard: UN Dangerous Goods Division(s) Classification Class 1 Explosives Explosive 2 Gases 2.1 Flammable gas 2.2 Non-flammable, non-toxic gas 2.3 Toxic gas 3 Flammable liquid Flammable liquid 4 Flammable solids 4.1 Flammable solid 4.2 Spontaneously combustible substance 4.3 Substance which in contact with water emits flammable gas 5 Oxidising substances 5.1 Oxidising substance 5.2 Organic peroxide 6 Toxic substances 6.1 Toxic substance 6.2 Infectious substance 7 Radioactive material Radioactive material 8 Corrosive substances Corrosive substance 9 Miscellaneous dangerous goods Miscellaneous dangerous goods Many substances and generic groups (e.g. paints) have already been classified and the details of their classification can be found in the Dangerous Goods List. Wastes are classified in the same way as other substances. HSU\Library\Documents\Health and Safety Policy\hs15\hs61tran.doc Revised

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