Date: December 22
In the world of dangerous goods, the end to a tumultuous and challenging 2022 doesn't bring the usual welcome break.
With the new regulations that will come into force on January 1, dangerous goods professionals must study and adapt. The regulations operate on a two-year cycle, so the new road (ADR), rail (RID), maritime (IMDG) and air (ICAO Technical Instructions) regulations will begin to replace the previous editions next month.
For ADR, there is a six-month transition, while for IMDG it is a 12-month transition, but the ICAO/IATA regulations take effect immediately.
New editions provide an opportunity for regulators to fix and modify text that may have caused some confusion or lack of clarity. So there are numerous small changes, such as new definitions, sometimes a reclassification of a product, and perhaps some changes to the maximum amount of dangerous goods that can be put in a package.
Those involved in the food flavoring industry will see the withdrawal of UN 1169, shippers will have to use UN 1197 in the future: the correct shipping name changes to “Extracts, flavoring liquid”.
One of the biggest changes to ADR road regulations means that many more shippers/shippers and freight forwarders will come within the scope of the Dangerous Goods Safety Advisor (DGSA) legislation. There is no additional text in ADR, but a transitional measure included in the 2019 and 2021 editions of the publication has disappeared. Exemptions that have always existed, such as those shippers only engaging with excepted and limited quantities, using certain special provisions, and below loading thresholds continue, but there are many organizations that should consider whether they now need to designate a DGSA.
Becoming a DGSA in the UK involves passing three exams on the same day. There are usually four sessions a year, and a training course to prepare for the exams, while not required, is highly recommended. The other option is to appoint an external consultant to the DGSA, who can provide advice, monitor compliance, and prepare the annual report. Both approaches have their advantages and disadvantages, and organizations have to find the model that works for them, with many looking to both options to provide an internal resource and external input or support.
Lithium Battery Changes
Not a year goes by without changes to the rather long and complex lithium battery regulations. In recent years, there have been a number of incidents in which the finger of accusation has been pointed at lithium batteries, although it is sometimes difficult or impossible to prove final evidence of his involvement. The Felicity Ace sank in February 2022 while en route from Germany to the US after a fire broke out. The car carrier had 3,965 vehicles on board, including 189 Bentleys, 85 Lamborghinis and nearly 2,000 Audis. There was also the case of an undeclared container of lithium batteries that caught fire in the Cosco Pacific while sailing between China and India in January 2020.
One change to the lithium battery brand is that the requirement to insert a phone number to get more information will go away, but senders can use their old brands until December 31, 2026, so they won't have to buy new ones. new for some time.
In addition, the air mode has introduced the requirement that lithium ion (UN 3480) and lithium metal (UN 3090) battery packs shipped under specific thresholds (1B), must now be able to withstand a test of 24 hour stacking.
All of these changes may seem simple, but it is essential that dangerous goods carriers are fully aware of them. Failure to comply will result in stopped shipments, products not reaching their intended destinations, disgruntled customers and, in the event of an incident, potential legal proceedings.
Source: Asociación Peruana de Agentes Marítimos