In this Special Report Desmond Waight explains how some modes require what might be called “supplementary classifications” when transporting dangerous goods, even though the words “supplementary classification” are not used in any of the modal transport of dangerous goods provisions.
In any technical subject it is important to have an understanding of the meaning of any words used. This is equally the case with respect to the transport of dangerous goods. To the writer of this special report, the words “transport of dangerous goods” clearly show that reference is being made to goods (articles and chemicals, be they substances per se or preparations/mixtures) that are subject to control because, during transport, these goods possess characteristics that require that the transport of those goods be subject to legal controls. However, others may refer to them as “hazardous materials”, or “dangerous substances”, or “restricted goods” — terms that can, at least initially, bring up in the writer's mind thoughts of other legislative controls.
Within the transport of dangerous goods world there are other terms used in the regulatory texts that have special meaning, though many are not defined in the section of the regulatory text dealing with definitions (usually Chapter 1.2 of the modal legal texts (see Note below). This is certainly the case with main terms used in relation to the classification of the dangerous goods, namely “primary” and “subsidiary”. However, the term “supplementary classification” is not used by the regulatory texts, but, in the view of the writer, is a useful collective term for some other classifications that are required, or may be required, to be considered under one or more of the modal (ie air, sea, road, rail, or inland waterway) provisions.
A further complication is such supplementary classifications requirements are often rather hidden in the regulatory texts and may not be found in the main part of the regulatory texts dealing with classification. Such classification requirements are normally found in Part 2 of the modal legal texts.
The IATA, so called, Dangerous Goods Regulations are not regulations at all, but terms and conditions of contract that include all the legal provisions of the ICAO Technical Instructions, but rewritten into a field manual that is structured differently to the legal provisions. Thus in IATA the legal provisions may be located in a different part/chapter/section from the legally applicable provisions.
The UN Recommendations and Model Regulations on the transport of dangerous goods (widely known as the “Orange Book”), whose texts are then generally used in the modal provisions, use the word “primary”, in relation to classification issues, in various places.
The word is first used in the section dealing with the precedence of hazard text for where a dangerous good has more than one hazard class or division characteristic.
2.0.3 Precedence of hazard characteristics
126.96.36.199 The table below shall be used to determine the class of a substance, mixture or solution having more than one risk, when it is not named in the Dangerous Goods List in Chapter 3.2. For goods having multiple risks which are not specifically listed by name in the Dangerous Goods List, the most stringent packing group denoted to the respective hazards of the goods takes precedence over other packing groups, irrespective of the precedence of hazard table in this Chapter. The precedence of hazard characteristics of the following have not been dealt with in the Precedence of hazards Table in 188.8.131.52, as these primary characteristics always take precedence.
Then there is nothing relating to classification, although the word is used in other contexts, until in Part 2 in respect of gas classification it notes:
184.108.40.206 Substances of Class 2 are assigned to one of three divisions based on the primary hazard of the gas during transport.
No further mention of the primary hazard, in respect of classification, then occurs until Chapter 3.5, which deals with Excepted Quantity packages, where at 220.127.116.11 it states:
Packages containing excepted quantities of dangerous goods prepared in accordance with this Chapter shall be durably and legibly marked with the mark shown in Figure 3.5.1. The primary hazard class or, when assigned, the division of each of the dangerous goods contained in the package shall be shown in the mark.
Then it takes until Chapter 5 when, in 5.1.4 dealing with mixed packing, it notes:
When two or more dangerous goods are packed within the same outer packaging, the package shall be labelled and marked as required for each substance. Subsidiary risk labels need not be applied if the hazard is already represented by a primary risk label.
The next mention is found in 18.104.22.168.1, which says:
Labels identifying primary and subsidiary risks shall conform to models Nos. 1 to 9 illustrated in 22.214.171.124.2.
Then in 126.96.36.199.3 it states:
the provisions in Chapter 2.0 shall be used to determine the primary risk class of the goods. In addition to the label required for that primary risk class, subsidiary risk labels shall also be applied as specified in the Dangerous Goods List.
Further in Chapter 5.2, and then in Chapter 5.3 (re placarding), and 5.4 additional mentions are made of “primary risk” and, in other places, “primary hazard”. This, unfortunately, shows a lack of consistency in the Orange Book.
But quite clearly determination of the “primary risk” is an essential step in the classification of dangerous goods.
In contrast, the Orange Book introduces the term “subsidiary risk” much earlier and uses it consistently throughout Volumes I and II to refer to the class(es) or division(s) that are considered, under the precedence rules of Part 2, as subsidiary to the primary class or division.
In the Orange Book the word “supplementary” is not used in relation to classification issues at all. Indeed the Orange Book does not have any supplementary classification requirements.
However, when one comes to the surface modal provisions supplementary classification provisions are introduced.
Both the IMDG Code (sea) and the RID/ADR/ADN (rail/road/inland waterway in Europe) modal requirements have a supplementary classification requirement for aquatic environmental effects for goods that are already considered dangerous due to a primary risk in Classes 1 to 8 (see below).
The IMDG Code also has a further supplementary classification requirement for certain goods of all classes, which is related to segregation on board between different types of dangerous goods, including between goods of the same class.
MP/EHS Supplementary classification
For many years the IMDG Code operated a system of supplementary classification to determine whether dangerous goods also had properties that would mean that the goods, if released during carriage, would have the potential to cause significant pollution in the marine environment. It called these Marine Pollutants (MPs). It identified specific substances (with specific entries in the dangerous goods list) that it considered would cause such effects and classified them into two levels of marine environmental hazard, Marine Pollutants and Severe Marine Pollutants.
These were identified in the list of dangerous goods by a “p” and “pp” mark respectively. Certain other listed dangerous goods, usually mixtures, were identified by a “•” mark to indicate that they may or may not be Marine Pollutants, the decision as to whether they were being dependent on the concentration of known Marine Pollutants (sum total 10% or more) or Severe Marine Pollutants (sum total 1% or more). However, there was no guidance on what to do if the mixture contained a mix of both Marine Pollutants and Severe Marine Pollutants at below the threshold level for each type (eg 7% of a Marine Pollutant and 0.5% of a Severe Marine Pollutant). Also a mixture could only ever be a Marine Pollutant and never a Severe Marine Pollutant, even if it contained over 90% of a Severe Marine Pollutant constituent, along with some other constituents.
In Europe, and some other countries, the RID (rail) and ADR (road) provisions over the years also became aware of the problems that certain dangerous goods, not otherwise dangerous, could cause to the environment, and established their own, different, rules for identification of such goods as dangerous goods of Class 9.
For those in the UK, the presence of two differing schemes created additional difficulties, and often queries along the lines of “well if it's a Marine Pollutant for sea, why then is it not environmentally hazardous for ADR/RID?” would arise.
This issue was raised at the Department for Transport (DfT) Working Party on the transport of dangerous goods (WP/TDG), the UK representative forum for those involved with the UN Orange Book and RID/ADR, and where possible changes are discussed.
The UK Expert agreed, and noted that a lead needed to come from the UN Orange Book, with the hope that the modal provisions would pick up and apply the Orange Book decisions.
Given that the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS) was on its way to adoption and rollout, the decision was taken for the UK to propose that the Orange Book should adopt the more hazardous categories of the GHS's Hazardous to the aquatic environment class. These are the categories for which use of the GHS09 pictogram (see box A) is prescribed for supply, namely the Acute category 1 (and not Acute Categories 2 & 3) and Chronic Categories 1 & 2 classifications (but not the Chronic Category 3 or 4).
At that time (ie 2005) the GHS was at its first revised edition stage.
Box A — GHS09 Pictogram
Rather than introduce this as a new class for environmental issues, the Orange Book, having addressed by various classes and divisions both safety and health related issues, the decision was taken to include hazardous to the aquatic environment requirements as classification criteria to be used to assign goods, not otherwise dangerous goods for transport, to Class 9 — Miscellaneous dangerous goods.
However, note the following.
They are called environmentally hazardous substances (EHS); where “substances” is used in the general sense, as it is within much of the Orange Book (and thus the modes), to include both substances per se, and also mixtures (preparations); but generally not articles. The issue of what is and what is not an article is worthy of a Special Report in its own right, and will not be discussed further here.
They are allocated specific UN Numbers and Proper Shipping Names (PSNs):
UN3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., and
UN3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S.
However, these attract Special Provision 274, which requires the PSN to be supplemented by the technical name of the environmentally hazardous constituent.
The Class 9 label (see box B) as generally required for Class 9 Miscellaneous dangerous goods shall for fully regulated goods be supplemented by a mark — being an enlarged and black and white only version of the GHS hazardous to the aquatic environment's pictogram. This mark was slightly modified later to show the fish without fins to align it with the GHS pictogram.
Box B — Orange Book EHS Mark
The UN Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCETDG) takes the view that all goods that were already classified as dangerous for other hazards should be considered as hazardous to the environment.
This decision is recorded in the Orange Book at 188.8.131.52, where it states:
Many of the substances assigned to Classes 1 to 9 are deemed, without additional labelling, as being environmentally hazardous.
It has not, as yet, however been established as a “guiding principle” in the UN's ancillary publication to the Orange Book that is intended to record the rationale behind the Orange Book. The current Guiding Principle can be accessed at www.unece.org.
Hopes that the modes would follow the UN Orange Book lead were dashed when the International Maritime Agency (IMO), while accepting that the UN classification criteria and mark should be adopted, decided not to follow the UN lead in relation to naming of the hazard type, retaining the term Marine Pollutant (MP).
The IMO also decided not to accept the Orange Book view that goods already otherwise classified as dangerous should be considered to be environmentally hazardous and decided to continue to require that the MP status of all goods, otherwise classified as dangerous, should be determined as a supplementary, self-classification.
This requirement for this supplementary (if applicable) classification is quite clearly laid out in IMDG Code Chapter 2.10 where it says:
184.108.40.206 Marine pollutants shall be transported under the appropriate entry according to their properties if they fall within the criteria of any of the classes 1 to 8. If they do not fall within the criteria of any of these classes, they shall be transported under the entry: ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., UN3077 or ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., UN3082, as appropriate, unless there is a specific entry in class 9.
The IMDG Code also requires the following.
When assigned to a generic or not otherwise specified UN Number/PSN that the name of the marine pollutant constituent shall supplement the PSN in the dangerous goods description on the transport document (aka Dangerous Goods Note (DGN)), such as UN1263 PAINTS (Naphtha (petroleum), hydrodesulphurised heavy).
The transport document entry shall state “Marine Pollutant”.
Since that early decision the IMO has updated the classification criteria to reflect changes to the UN GHS criteria, although at a different rate to that of the Orange Book and RID/ADR. However, as from the IMDG Code 2012 Edition, which was optional for use from January 2013 but becomes mandatory from January 2014, the IMDG Code will be in line with RID and ADR and the Orange Book in that the criteria will be based on the GHS hazardous to the aquatic environment criteria as last revised in the GHS 3rd Revised edition.
The only relaxation that the IMO has so far given over the years is that from the 2012 Edition it now explicitly recognises that the words “Marine Pollutant” may be shown in conjunction with the words “Environmentally Hazardous” as used by RID/ADR, see below. However, such a combination statement was arguably not actually prohibited under the previous edition of the Code.
One source of confusion created by the IMDG Code is that while generally making the MP supplementary classification a general self-classification requirement (and thus removing the “•” mark), it did continue to mark those substances that were identified in the earlier code as Marine Pollutants (p) or Severe Marine Pollutants (pp). But instead of using a new mark it decided to mark all these with just the “p” mark.
These substances have to be considered as MPs unless the consignor can show, to the satisfaction of the Competent Authority (CA) of the country of origin of the shipment, that the substance is not a Marine Pollutant. In this case it is expected that the CA would then bring this to the attention of the IMO with a view to removing the mark in future editions of the Code. So far this has not happened.
RID, ADR and ADN (inland waterway in continental Europe) followed the UN Orange Book lead.
They accordingly included GHS Acute 1 or Chronic 1 or 2 classification criteria to determine if a substance (substance, per se, or mixture/preparation, but not article) was to be considered as an Environmentally Hazardous Class 9 “Miscellaneous dangerous good”; and assigned to UN3077 or UN3082 as applicable. They also require the mark as per the Orange Book (see Box B), but call it the Environmentally Hazardous Substance (EHS) mark, rather than the Marine Pollutant (MP) mark — even though they are identical.
While RID/ADR/ADN at first included criteria based on the 1st revised GHS Edition they kept up with the changes, and reflected the GHS 3rd Revision changes from the 2009 edition. However, recognising that this would be different from the IMDG Code, they included a transitional provision:
220.127.116.11 The provisions of 18.104.22.168.10.3 and 22.214.171.124.10.4 concerning the classification of environmentally hazardous substances applicable until 31 December 2010 may be applied until 31 December 2013.
As can be seen, this will no longer apply from January 2014, so that from that date the IMDG Code and RID/ADR/ADN criteria will be aligned.
However, recognising that classification for mixtures strictly to the GHS based provisions has been extremely rarely carried out up to now, RID/ADR/ADN have allowed that classification as an EHS can also be determined using the calculation methods used in the supply of dangerous/hazardous substances and preparations/mixtures.
This is covered in ADR (2013) where its states that:
126.96.36.199.10.5 Substances or mixtures classified as environmentally hazardous substances (aquatic environment) on the basis of Regulation 1272/2008/EC (CLP) (sic).
If data for classification according to the criteria of 188.8.131.52.10.3 and 184.108.40.206.10.4 are not available, a substance or mixture:
shall be classified as an environmentally hazardous substance (aquatic environment) if it has to be assigned category(ies) Aquatic Acute 1, Aquatic Chronic 1 or Aquatic Chronic 2 according to Regulation 1272/2008/EC or, if still relevant according to the said Regulation, risk phrase(s) R50, R50/53 or R51/53 according to the Directives 67/548/EEC [aka Dangerous Substances Directive — DSD] or 1999/45/EC [aka Dangerous Preparations Directive — DPD]
may be regarded as not being an environmentally hazardous substance (aquatic environment) if it does not have to be assigned such a risk phrase or category according to the said Directives or Regulation.
While the IMDG Code does not permit this officially, in practice no objection is likely to be raised over EHS and MP classifications based on the CLP method (by now mandatory for supply of substances, but not until 1 June 2015 for mixtures) or DPD methods.
But, given the IMDG Code position, and the fact that for island nations (and nations with offshore islands — eg the Balearic islands, Corsica, etc.) many journeys also involve a sea crossing, it was felt appropriate for ADR/RID/ADN to align themselves with the IMDG Code position of also requiring a supplementary classification for EHS effects to be carried out for goods that are also classified dangerous for other purposes under RID/ADR/ADN.
However, in RID/ADR/ADN this requirement is not as immediately obvious as it is in the IMDG Code. Indeed, early in RID/ADR/ADN it repeats the Orange Book statement:
220.127.116.11 Substances of classes 1 to 6.2, 8 and 9, other than those assigned to UN Nos. 3077 and 3082, meeting the criteria of 18.104.22.168.10 are additionally to their hazards of classes 1 to 6.2, 8 and 9 considered to be environmentally hazardous substances. Other substances meeting the criteria of no other class, but those of 22.214.171.124.10 are to be assigned to UN Nos. 3077 and 3082 as appropriate.
This suggests that a supplementary classification for EHS for goods which are already classified as dangerous is not required.
Within Chapter 2.2.9 Class 9, “Miscellaneous dangerous goods”, where the EHS criteria are stated there is no hint that the criteria need to be applied to goods already otherwise classified as dangerous.
It is not until one gets to Chapter 5.2 on package labelling and marking that this supplementary classification requirement first really becomes apparent.
126.96.36.199.1 Packages containing environmentally hazardous substances meeting the criteria of 188.8.131.52.10 shall be durably marked with the environmentally hazardous substance mark shown in 184.108.40.206.3 with the exception of single packagings and combination packagings where such single packagings or inner packagings of such combination packagings have:
a quantity of 5 l or less for liquids, or
a net mass of 5 kg or less for solids.
This means that goods, which are dangerous otherwise under RID/ADR/ADN, must, like the IMDG Code, undergo a supplementary classification to determine whether they are EHS substances, or not.
The requirement for marking also applies to tanker and bulk loads and is stated in Chapter 5.3:
5.3.6 Environmentally hazardous substance mark
When a placard is required to be displayed in accordance with the provisions of section 5.3.1, containers, MEGCs, tank-containers, portable tanks and vehicles containing environmentally hazardous substances meeting the criteria of 220.127.116.11.10 shall be marked with the environmentally hazardous substance mark shown in 18.104.22.168.3. The provisions of section 5.3.1 concerning placards shall apply mutatis mutandis to the mark.
Note the following.
Unlike the IMDG Code, RID/ADR/ADN do not require identification of the name of the EHS constituents in a mixture; except, as in the IMDG Code, in the case of the two Class entries of UN3077 and UN3082 (due to the application of Special Provision 274 to these entries).
RID/ADR/ADN like the IMDG Code also requires a supplementary wording on the transport document (when this is required, which unlike the IMDG Code is only for fully regulated dangerous good shipments). The wording required by RID/ADR/ADN is “Environmentally Hazardous”. Consequentially, unlike IMDG Code, it is not required for the two Class 9 entries of UN3077 and UN3082. Under RID/ADR/ADN the combined statement “Marine Pollutant/Environmentally Hazardous” is permitted at all times, and where a combined rail/road/inland waterway and sea carriage is taking place then just “Marine Pollutant” alone is acceptable.
The recommendation of the author is to always use the combined statement, even for UN3077 and UN3082 when consigned solely under RID/ADR/ADN. One cannot then be incorrect.
It is in relation to EHS that complications arise from the use of the word “substance” in transport of dangerous goods to mean both substances per se (in the restrictive sense as defined in GHS and Regulation (EC) No. 1907/2006 (REACH) and in Regulation (EC) No. 1272/2008 (CLP)) and preparations/mixtures. Within Class 9 in the sub-sub-section 22.214.171.124.10 where it sets out the EHS criteria, the word gets used in its restrictive sense; but elsewhere in RID/ADR/ADN the word “substance” is generally used with the wider meaning.
Other supplementary classifications
While the MP/EHS classification provision is the main supplementary provision there are a couple of other supplementary provisions that may be needed.
IMDG Segregation Group
Under the IMDG Code, a system of segregation groups is used, designed so that incompatible materials can be kept apart, such as acids and alkalis, which if both leak can react vigorously (even though they are both Class 8 dangerous goods, whether as a primary or subsidiary risk).
Some 18 different segregation groups are defined (see table below).
Heavy metals and their salts (including their organometallic compounds)
Lead and its compounds
Liquid halogenated hydrocarbons
Mercury and mercury compounds
Nitrites and their mixtures
However, definitions to tie down the application of the groups are not given. For instance, what is an acid? Does it include the very dilute solutions of acids that are so weak as to be not even “irritant” to the skin, but which can corrode a particular metal? What is an alkali? What is a heavy metal? Do powdered metals in mixtures such as paints need to be assigned to group 15? And so forth.
A degree of chemistry knowledge may be required to make this decision.
However, many UN Numbers/PSNs are assigned to a segregation group or groups by the Code. Unfortunately these are not listed in the dangerous goods list, but separately at Section 3.1.4 so one has to go through the allocations of UN numbers to each likely group to determine which group, or groups, are applicable.
Examples include the following.
UN1722 ALLYL CHLOROFORMATE is listed in Segregation Group 1 — Acids.
UN1436 ZINC DUST or ZINC POWDER is listed in Segregation Group 7 — Heavy metals.
UN1620 LEAD CYANIDE is listed not only in Segregation Group 9 — Lead and its compounds, but also in Segregation Group 7 — Heavy metals and their salts; and in Segregation Group 6 — cyanides.
What to do, however, if the UN Number/PSN does not have a segregation group assignment listed?
First, if the dangerous goods assigned to single entries for well-defined substances or articles (eg UN1090 ACETONE or UN1194 ETHYL NITRITE SOLUTION), then it can be assumed that no assignment to one of the 18 groups is applicable; as otherwise the IMO would have assigned it.
If the dangerous good is assigned to a specific entry (eg UN1477 NITRATES, INORGANIC, N.O.S. or UN1987 ALCOHOLS, N.O.S.) or is assigned to a general entry covering a group of substances or articles meeting the criteria of one or more classes or divisions (eg UN1325 FLAMMABLE SOLID, ORGANIC, N.O.S. or UN1993 FLAMMABLE LIQUID, N.O.S.) then the IMDG Code at 126.96.36.199, and repeated at 188.8.131.52, requires that a self-classification decision has to be made over whether the dangerous goods are assignable to one, or more, segregation group(s); or not assignable to any segregation group.
Self-classification assignment to a segregation group requires additional information on the transport document, regardless of whether the goods are consigned as fully regulated or as LQ packages or EQ packages.
However, if the dangerous goods are assigned to a generic entry for well-defined groups of substances or articles (eg UN1133 ADHESIVES, flammable, or UN3470 PAINT, CORROSIVE, FLAMMABLE) there are two schools of thought.
The first view is that, because the IMDG does not include mention of this type of entry in 184.108.40.206, or 220.127.116.11, no assignment is required; nor can it be voluntarily made, according to some.
The second view is that IMDG Code is clearly in error and that such an entry should be self-classified. For example, while a Class 3 flammable adhesive assigned to UN1133 will usually not be assignable to one of the segregation groups, a corrosive and flammable paint assigned to UN3470 with Class 8 as the primary risk, and Class 3 as the subsidiary risk, is most likely to be either a group 1 — acidic or a group 18 — alkaline material. Additionally, it could also be assigned to group 7 — heavy metals, eg due to the presence of significant amounts of zinc in the formulation (as some paints are known to have).
The author of this Special Report strongly believes that the IMDG Code is incorrect, and that such generic entries for well-defined groups should be self-classified for possible assignment to one, or more, of the segregation groups.
Many Safety Data Sheets (SDSs) do not make any mention in Section 14 of the segregation groups to which the dangerous good either has been assigned under the IMDG Code, or which has been derived by self-classification. Including a “not assignable” to any segregation group notation, would be most helpful. Hence when using the data from such SDSs it is necessary to determine whether this supplementary segregation group classification needs to be undertaken, using information elsewhere in the SDS.
RID/ADR/ADN Classification codes
The final kind of supplementary classification that may be needed is the RID/ADR/ADN classification codes.
In Part 2 of RID/ADR/ADN where it describes the classes, RID/ADR/ADN makes mention shortly after the criteria that the class is subdivided. In the case of Class 3:
18.104.22.168.2 The substances and articles of Class 3 are subdivided as follows:
F Flammable liquids, without subsidiary risk and articles containing such substances:
F1 Flammable liquids having a flash-point of or below 60°C
F2 Flammable liquids having a flash-point above 60°C which are carried or handed over for carriage at or above their flash-point (elevated temperature substances)
F3 Articles containing flammable liquids
FT Flammable liquids, toxic:
FT1 Flammable liquids, toxic
FC Flammable liquids, corrosive
FTC Flammable liquids, toxic, corrosive
D Liquid desensitized explosives.
However, it is not until the introduction to the dangerous goods table that RID/ADR/ADN really describes what the classification code is.
Column (3b) “Classification code”
Contains the classification code of the dangerous substance or article.
For dangerous substances or articles of Class 1, the code consists of a division number and compatibility group letter, which are assigned in accordance with the procedures and criteria of 22.214.171.124.4
For dangerous substances or articles of Class 2, the code consists of a number and hazardous property group, which are explained in 126.96.36.199.2 and 188.8.131.52.3
For dangerous substances or articles of Classes 3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 6.2, 8 and 9, the codes are explained in 2.2.x.1.2
Dangerous substances or articles of Class 7 do not have a classification code.
While the classification code system of the Classes is most useful when trying to work out for dangerous goods in the form of mixtures the most appropriate collective entry, ie any entry other than single entry for well-defined substances or articles, it can be needed on other occasions.
Once such case is on a transport document for a Class 1 Explosive or pyrotechnic entry: it is not the Class number (ie “1”) that is needed on the RID/ADR/ADN transport document in third position (after the UN Number and PSN) but the RID/ADR/ADN classification code. This consists of the division number for the explosive followed by the compatibility group letter of the explosive (eg “1.4S”).
The other situation where declaration of the RID/ADR/ADN is needed is where goods are to be shipped via Eurotunnel, as Eurotunnel uses the classification code system to determine its restrictions. For example, Eurotunnel policy restricts gases with a Classification Code of 10 or 20 to 1000 litres maximum per unit package.
Eurotunnel also requires the classification codes to be declared (although it is not a requirement for inclusion on the RID/ADR/ADN transport document). Though the policy document (see link above) only requires that “Declarations have to be made using the 2013 ADR revisions from 1 July 2013”, on its website, it says:
On arrival at our terminals, ADR goods must be declared at the Check-in kiosks.
The process is fast and efficient, so to avoid any unnecessary delays please ensure that your paperwork is legible and always includes the following information:
Gross and net weight
2013 ADR references (class, packing group, classification group)
Net weight per inner package.
This is because while in general the UN Number and PSN and Packing Group (if applicable) quoted on the transport document will often uniquely equate to a specific classification code in the RID/ADR/ADN dangerous goods, this is not always the case. In some cases (eg UN1950) without declaring the classification code as well as the other required data, it is impossible to determine whether the goods are permitted via Eurotunnel or subject to a specific classification-code-related restriction.
Take, for example, UN1950 AEROSOLS, shipped in fully regulated packages. (While most UN1950 aerosols are shipped in LQ packages, this is not always the case.) Those of classification code 5A (ie with just asphyxiant hazard) are permitted through the tunnel without restriction, those of 5F (the normal flammable aerosol) are accepted for carriage, but are restricted to a maximum of 1500kg gross weight per transport unit.
While the UN Orange Book and the modal provisions (IMDG Code and RID/ADR/ADN) do not even mention the concept of “supplementary classification”, it is hopefully now clear to readers that three such supplementary classifications may need to be carried out, in addition to the task of determining the primary risk/hazard and, if applicable, the determination of any subsidiary risk(s).
Last reviewed 5 December 2013