Regulatory Changes in CDG

11 October 2012

Following Hazchem Network supporting the Freight Transport Association’s CDG Seminar, we were featured in FTA’s FREIGHT Magazine – click here for the article [or right click and ‘save as’]


More information on the seminar and some of the changes are below from our notes -


The FTA CDG 2012 seminar was held in Warrington in September, and very well attended which is little surprise as the topics covered all the major changes in all regulations on the hazardous transport of packaged and bulk in Road [ADR], Rail [ADR / RID], Sea [IMDG] and Air [CAA / IATA] modes of transport. The speakers were respected and experienced industry professionals, and the main conclusions were welcomed by the attendees working in a highly regulated sector, in the midst of tough economic conditions.


New technology has impacted on many products now falling within scope of the CDG regulations. These included new energy generation products, especially the implications on Lithium Batteries now being a very large and growing area. Many devices now contain dangerous goods such as gas-charged self inflating products such as life-rafts, air-bags. In-situ fuel contained in engines with tanks, fuel cells are another area brought into scope of CDG. The regulations reflect this, and the amendments and changes were detailed.


Another area covered was the consequences of what can go wrong, with Ross McLachlan of the Civil Aviation Authority showing that passengers have been caught carrying dangerous goods in their luggage. Ross detailed an incident at a UK airport where a passenger had carried a significant quantity of fireworks in his luggage, and played a video illustrating the pyrotechnic effect of ignition [under controlled circumstances] when they were ignited. Ross also detailed cases where cargo planes were involved in disturbing circumstance when some Lithium Batteries caught light, causing tragic circumstances for the pilots and the planes carrying these goods.


Keith Bradley of the Maritime and Coastguard Agency indicated that there is some truth in the adage ‘worse things happen at sea’, illustrating container fires that have occurred due to ignition of dangerous goods in transit on the ocean.


Terry Laker of The Health and Safety Executive showed latest statistics from VOSA and the Police on the results of road-side inspections of trucks carrying dangerous goods, and yet again the main contraventions remain the confusion on the required fire extinguishers that must be carried by vehicles carrying ADR goods.


There was a positive note from Martin Castle from Department for Transport’s VCA [Vehicle Certification Agency], indicating some of the simplifications / harmonisations for the Domestic and International regulations [this included the tabulation of Fire-Extinguisher requirements for road vehicles, which hopefully will help reduce the ‘confusion’].


Fraser Talbot of The Scottish Qualifications Agency SQA, outlined the changes in driver ADR training certification, which the SQA were conscious that they factored the tough economic conditions in the changes so hauliers involved in CDG, were not overtly encumbered with costs and regulatory red-tape.


Matt Barker of the Vehicle and Operator Services Agency indicated the changes in the Operational Compliance Risk Score system [OCRS].


The key issues that this year’s seminar provided the attendees -


# Road Regulations under ADR for LQ [Limited Quantities] for retail, both in terms of changes in vehicle markings and tunnel code restrictions over load defined thresholds. With increasing products coming under ADR scope, there are new provisions vis-à-vis machinery / equipment that contain hazardous goods, such as gases and fuels.


# Sea Regulations under the IMDG Code clarifying the segregation and stowage requirements, as well as the issues of class 6.2 Clinical Wastes; and the marking of transport containers, especially those dealing with LQ [Limited Quantites].


# For Air under ICAO [International Civil Aviation Organisation] there are updates on the training certification on consigning Hazardous Freight, the packaging / marking under UN codes and the introduction of ‘De-Minimis’ quantities where concessions are being introduced for certain products packaged under these ‘De-Minimis’ provisions.


# The Scottish Qualifications Agency [SQA] detailed the changes in Driver ADR training and qualification protocols


# VOSA and HSE gave real-world feedback on enforcement issues that they have experienced on the road, feeding back to carriers and consignors the common problems that need addressing. VOSA indicated that ADR infringements will score against the haulier in there Operational Compliance Risk Score [OCRS] system.


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