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Dangerous goods and the need for a rigorous inspection regime

At a glance

  • Zurich recently opened a new purpose-built Engineering Technical Centre in Wednesfield, Wolverhampton
  • Anything from an aerosol can to a nuclear flask carrying nuclear waste could be considered as dangerous goods
  • In this article we take a look at the transportation of dangerous goods and the need for a for a rigorous inspection regime

This article counts towards accumulating your annual CII CPD structured learning hours for Emerging Risks.

By reading this article, and correctly answering the three questions underneath, you will have achieved the following learning outcome: Identify key emerging risks and describe their main characteristics.

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Zurich recently opened a new purpose-built Engineering Technical Centre in Wednesfield, Wolverhampton.

The new site brings together Zurich’s engineering consultancy teams into one place. Zurich have over 500 engineering surveyors across the breadth of the United Kingdom (UK), who are able to inspect machinery and equipment of varied specifications and sizes.

As part of their remit, Zurich Engineering Surveyors inspect tank vehicles that transport dangerous goods, and are an appointed UK Department for Transport (DfT) Vehicle Certification Agency (VCA) inspection body, accredited by United Kingdom Accreditation Service (UKAS) as a Type ‘A’ inspection body.

In this article we take a look at the transportation of dangerous goods and the need for a rigorous inspection regime.

What classifies as dangerous goods?

Anything from an aerosol can to a nuclear flask carrying nuclear waste could be considered as dangerous goods.

Alan Clements, Senior Engineer at Zurich, outlines dangerous goods: “Dangerous goods can be classified in a number of ways and not only is it the substance being transported that decides this, but also the quantity being transported.

“For example, a single aerosol can is considered low risk and therefore would not be dangerous goods. However, hundreds of aerosol cans in a large quantity of boxes, in a confined space, would be considered dangerous goods. That’s because, with an increase in the quantity transported, the risk and severity of a potential fire increases. It’s the chain reaction of a potential fire which ultimately determines the risk severity.”

Classifications of dangerous goods

Dangerous goods are assigned to different classes depending on their predominant hazard. The UN classifies dangerous goods in the below classes, and where applicable, divisions:

UN Class 1 Explosives
UN Class 2 Compressed Gases: 2.1 Flammable gas; 2.2 Non-flammable, non-toxic gas
UN Class 3 Flammable liquids
UN Class 4 Flammable solids: 4.1 Flammable solid; 4.2 Spontaneously combustible substance; 4.3 Substance which emits flammable gas in contact with water
UN Class 5 Oxidizers and organic peroxides: 5.1 Oxidising substance; 5.2 Organic Peroxide
UN Class 6 Toxic and infectious substances: 6.1 Toxic substance; 6.2 Infectious substance
UN Class 7 Radioactive material
UN Class 8 Corrosive substances
UN Class 9 Miscellaneous dangerous substances

The different methods of transporting dangerous goods

There are five methods of transporting dangerous goods. It is worth noting that the enforcement for the safe carriage of dangerous goods is undertaken by several authorities (excluding Class 7). The authority responsible will depend on the mode of transport. Additionally, transportation to Northern Ireland or British islands are required to comply to separate Statutory Rules which apply. However, these are included within the UK Carriage of Dangerous Goods regulations.

By road

When transporting dangerous goods by road within the European Union (EU) and other select countries, companies must abide by the European Agreement concerning the International Carriage of Dangerous Goods by road, which is commonly referred to as ADR. Since 2009, ADR has been applied in Great Britain by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (known as CDG2009).

By rail

When transporting dangerous goods by rail within the EU and other select countries, companies must abide by the Regulations concerning the International Carriage of Dangerous Goods by Rail (RID). Since 2009 RID has been applied in Great Britain by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (known as CDG2009).

By air

When transporting dangerous goods by air, companies must abide by the International Air Transport Association (IATA) International Dangerous Goods Regulations.

The International Civil Aviation Organisation (ICAO) prepares international provisions for moving dangerous goods by air. It publishes technical Instructions for the Safe Transport of Dangerous Goods by Air, the ICAO Technical Instructions (TIs).

The International Air Transport Association (IATA) also publishes the IATA Dangerous Goods Regulations (DGR); a manual of rules which IATA member airlines must follow and includes the requirements of the ICAO TIs, plus their own terms and conditions, as applied by IATA. In the UK the Air Navigation (Dangerous Goods) Regulations 2002 also applies.

By sea

When transporting dangerous goods by sea, companies must abide by The International Maritime Dangerous Goods (IMDG) code. In the UK, the Merchant Shipping (Dangerous Goods and Marine Pollutant) Regulations 1997 and the Dangerous Substances in Harbour Areas Regulations (Northern Ireland) 1991 also apply.

By inland waterways

The International Carriage of Dangerous Goods by Inland Navigation (ADN) applies to EU member states. In the UK, due to there being no physical connection to European inland waterways, there is no need to apply ADN domestically.

Alan Clements explains “We’re seeing a shift in the way that dangerous goods are being transported. Rail freight is increasing as it’s cheaper to transport in bulk and better for the environment.

It’s important to note that supply chains are becoming more complex and therefore dangerous goods can, at times, be transported via a number of different methods and therefore consideration for the different regulations and legislation needs to be made.

An example scenario would be where goods arrive via ship in Liverpool, which are then transported by road to Derby and then offloaded onto a train, to be transported via a continuous network of railways all the way to Southern Italy.

The risks will differ at each of stage of the journey and the different regulations and respective authorities will need to be considered.”

How do emergency services know dangerous goods are being transported?

If you are involved in the processing, packing or transporting of dangerous goods, you will need to classify them correctly, so that all organisations in the supply chain, including emergency services, know and understand exactly what the hazard is.

Vehicles must be correctly labelled. An orange-colour plate must be displayed on vehicles and containers carrying dangerous goods. It is designed to help the emergency services deal with incidents involving such vehicles or containers.

The UK orange-coloured plate has more information than the ADR plate. The UK uses an Emergency Action Code also known as Hazchem Code and the ADR panel uses a Hazard Identification Number also known as the Kemler Code. They both contain the UN Substance Identification Number.

Below are examples of how vehicles transporting dangerous goods would be labelled.

A UK petrol tanker would be labelled as such:

  • 3YE (Hazchem code)
  • 1203 (UN substance identification number)
  • Only the highest dangerous substance UN is marked for the complete tank including for compartment tanks
  • Class 3 flammable liquids hazard warning diamond
  • Emergency contact number

A continental petrol tanker which is slightly different, would be labelled as such:

  • 33 (Kemler code)
  • 1203 (UN substance identification number)
  • Marked at each compartment for multi-compartment tanks
  • Class 3 flammable liquids hazard warning diamond at each compartment

Frequency of inspections

To remain legally compliant, tanks must be inspected at regular intervals. They must also be inspected following repair or damage that may impact the safety of the tank. Tanks must be inspected by a UKAS approved inspection body in the UK.

Inspection and testing intervals will depend on the type of tank (fixed tank, tank container or portable tank), the substance being carried and whether it is:

  • an ADR tank
  • an old UK tank
  • a new UK LPG tank
  • an IMDG tank

Alan says “Depending on what type of tanker it is, what it carries and the regulations being applied, will determine how often you need to inspect it.

For example, road tankers (fixed) could have an inspection frequency of every 3 years or 6 years. For gas cylinder type tanks it could have an inspection frequency of every 2 and a half years or every 5 years. It really does vary significantly, with the requirements buried in a 1,300 page document, my advice would be to speak to an expert to find out what your inspection regime should be.”

How Zurich can help

Zurich are a UKAS Type ‘A’ approved body and have many years’ experience inspecting tankers that carry dangerous goods. We have engineering surveyors across the whole of the UK and our engineering technical centre brings together all of our engineering expertise into one place.

Alan concludes: “The transportation of dangerous goods is a highly regulated and compliant industry and there aren’t many companies that can offer the breadth of knowledge and capability that we have at Zurich. There is a real need for experts who know the different regulations and legislation and can correctly inspect tanks and are approved by the relevant bodies.”

For more information on the issues discussed in this article, please get in touch with your local Zurich contact. Alternatively you can contact Alan Clements, Senior Engineer, Zurich UK Engineering or Miles Gardner, Consultancy Services Manager, Zurich UK Engineering.

Image © Getty

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