The recent publication of the latest revision to the UN Model regulations has brought about a number of changes to how dangerous goods will be transported and classified, although the full fall out of which will not be felt until the mode specific regulations are published in due course, the first of which being ADR 2019.
These changes include a change in the method by which corrosive substances are classified.
Bridging principles provide guidance for mixtures of corrosive substances that have not been tested but sufficient data exists for the individual ingredients and similar tested mixtures.
These principles include guidance on dilution, batching, concentration of PG I mixtures, interpolation within one packing group and substantially similar mixtures.
A calculation is also introduced to facilitate classification where substances from different packing groups are mixed together.
There are several new entries to the dangerous goods list, including:
- UN 3227 Phosphorothioic acid, O[(cyanophenylmethylene) azanyl] O, O-diethyl ester,
- new entries for peroxides such as Diisobutyryl peroxide, Di-(4-tert-Butylcyclohexyl) Peroxydicarbonate and 1-Phenylethyl Hydroperoxide.
- With the recent changes to the way in which lithium batteries are handled, there are now a further new entry to the dangerous goods list; UN 3526 Lithium Batteries Installed in Cargo Transport Unit.
- There is also a further entry that covers other types of dangerous goods potentially contained within articles; UN 3548 Articles containing Miscellaneous Dangerous Goods N.O.S.
Noteworthy also is now Ammonium Nitrate based fertiliser may be categorised as 1 of 3 different classes of dangerous goods namely Class 1, Class 5.1 or Class 9. This is determined by using the procedure laid out in the Manual of Tests and Criteria, Part III, Section 39.
Another change of note is that from now on, bulk containers will also have to be placarded, rather than labelled as was the case previously.
The Overpack requirements will now apply to lithium batteries marked in accordance with Special Provision 188.
Away from dangerous goods transport but still within the field of marking and labelling etc, GHS now states that GHS pictograms not required for transport must only form part of a complete GHS label (UN Model Regulations 20th Edition 5.1.1 & GHS 7th Edition 22.214.171.124.4).
The full changes are available online at the UNECE Website.
Article by Adam Gallimore, a DGSA at EcoStar Environmental Ltd. EcoStar provide dangerous goods advice, training and consultancy.