Security plans for consignees

8 August 2014

I am a DGSA for a company which only receives High Consequence Dangerous Goods (HCDGs), but does not ship them out, and so far, has not prepared a security plan, despite me having advised so.

I have also discussed with another DGSA who has a similar situation, and whose consignee companies feel that the requirement for a security plan does not apply to them, although the DGSA agrees with me that they should.

Do these recipient companies need to have an ADR security plan in place?

Is it an offence to do more?

24 July 2014

If legislation requires that safety measures are necessary in certain specific situations, is it then an offence to apply those measures when to do so would be unnecessary? For instance:

  1. Child Resistant Closure (CRC) on receptacles containing chemicals that are merely “Flammable (R10)” under CHIP/Flammable Liquid Category 3 in CLP

  2. a supply label on an empty receptacle or packaging

  3. an extra CHIP symbol or an additional CLP hazard pictogram on a supply label.

Correctly fined?

10 July 2014

During international transport (by road/rail/sea), our carrier was fined a substantial amount (>£500) by customs for allegedly failing “to show a chemical name after an N.O.S.” on the Dangerous Goods Note (DGN) that we had provided (copy supplied) for the Class 6.1, UN2811 TOXIC SOLID, ORGANIC N.O.S. substance. The Proper Shipping Name (PSN) was followed by the Colour Index (CI) Name of the substance we supplied. The carrier is insisting on passing the fine back to us. Were customs correct in levying this fine?

Classification of oxidising properties for supply and transport

25 June 2014

I have a solid fertiliser mixture that contains the following hazardous components:

  • Ammonium nitrate: CAS No. 6484-52-2 at about 4%

  • Potassium nitrate: CAS No. 7757-79-1 at about 3%.

Both components are classified by the suppliers according to CLP as Ox. Sol. 2 (H272).

All the other components are not classified and the mixture has not been tested for oxidising properties, flammability or any other physical hazard.

Considering the low content of these components, how should the mixture be classified for supply and transport?

Should the mixture be:

  • classed as CLP Ox. Sol. Cat 2/Transport Class 5.1?

  • or, classified for transport as UN2071 of Class 9?

  • or not classified as hazardous for supply/dangerous for transport at all?

Concentration ranges in SDSs

29 May 2014

I have heard that some enforcers in the EU are saying that the classification and labelling shown in section 2 of a safety data sheet (SDS) must be calculated using the highest concentration for the ingredient shown in section 3.2. Are they correct to do this?

Carriage by service engineers

15 May 2014

We currently use transport contractors to move our dangerous goods (mostly corrosives). What would we need to comply with in terms of legislation in order to be able to carry these on our service engineer’s trucks?

CLP compliance date

1 May 2014

When do I have to label preparations according to CLP? Some say before 1 June 2015, some say I don’t have to until 1 June 2017, and some say never. What is the situation please?

DGSA annual reports

17 April 2014

Where can I get official guidance on what the contents of a Dangerous Goods Safety Adviser (DGSA) annual report should include?