by Steve Schulte, CHMM, CPP, DGSA
The United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCETDG) met in Geneva from June 27 to July 6, 2016. The following is a brief summary of the major amendments to the dangerous goods transportation regulations that will become effective for the Hazardous Materials Transportation Regulations (DOT), International Maritime Dangerous Goods Code (IMDG), International Civil Aviation Organization (ICAO) and the European Road and Rail Dangerous Goods Regulations (ADR/RID) on January 1, 2019.
The major amendments that will become effective are:
- Throughout the dangerous goods regulations the word “risk” will be replaced with the word “Hazard”. For example, "Subsidiary Risk" will change to "Subsidiary Hazard."
- Chapter 2.8 regarding corrosivity and corrosivity criteria, to include packing group criteria, will change to better align with the GHS criteria. It will align in certain areas such as the use of additivity.
- The Dangerous Goods list, specifically column 4, will change from "Subsidiary Risk" to "Subsidiary Hazard" wherever it applies. A new entry to the Dangerous Goods list will also be added for UN3356, Lithium Batteries Installed in Cargo Transport Units.
There are other changes that have been made that the reader may want review in the reference below.
by Lily Hou, Ph.D., CHMM
The New Zealand Environmental Protection Authority (EPA) has published the Decision Document (APP202482) that approves re-classifications of 200 existing chemicals, including chemical substances and products, based on new information that became available between 2012 and 2014. The update includes revisions to chemical names, hazard classifications and controls applied to the chemicals. The approved changes take effect immediately; however, industry has a one-year transition period, until July 21, 2017, to update the SDS and labels of the listed chemicals.
The Chemical Classification Information Database (CCID) provides hazard classifications and supporting data for about 4,800 single chemicals classified in accordance with the New Zealand Hazardous Substances and New Organisms (HSNO) regulations. As of August 2016, the CCID hasn't been updated with the new hazard classifications, yet. The existing classifications in the CCID remain effective until July 21, 2017.
Both the CCID and the Decision Document can be found on New Zealand's EPA website:
The Chemical Classification Information Database (CCID) is available at: http://www.epa.govt.nz/search-databases/Pages/HSNO-CCID.aspx
The Decision Document (APP202482) containing the new classifications can be found at: http://www.epa.govt.nz/publications-resources/bulletin/bulletin/Pages/Changes-made-to-200-approved-chemicals.aspx
Steve Schulte, ChemADVISOR’s Senior Dangerous Goods specialist, recently attended the Dangerous Goods Advisory Council (DGAC) Summer Conference and Board of Directors meeting in Washington, D.C. Mr. Schulte is a member of the DGAC Board. In addition, he serves as the Chairman of the DGAC Packaging Work Group. DGAC holds three conferences annually. The Summer Conference included a regulatory update from PHMSA (Pipeline and Hazardous Materials Safety Administration) of upcoming rulemakings and future Hazardous Materials/Dangerous Goods changes as well as an update on the PHMSA five-year Strategic Framework called PHMSA 2021. The PHMSA goals for the 2021 Strategic Framework are:
- Promote continuous improvement in safety performance.
- Invest in safety innovations and partnerships.
- Build greater public stakeholder trust.
An update regarding the status of papers submitted to the United Nations Committee of Experts on the Transport of Dangerous Goods and the United Nations Committee on Globally Harmonized Classification and Labelling (GHS) was provided and of important note, the long standing goal to harmonize the GHS corrosive criteria with that of Transport of dangerous goods appears to be resolved and only minor editorial issues remain for the November/December 2016 meeting. Other updates included an update from OSHA (Occupational Safety and Health Administration) on HCS2012 and GHS and an update on shipping Lithium Batteries by air and other transport related topics.
by Nathan Kongprachaya
Thailand's National Existing Chemicals Inventory:
The Department of Industrial Works (DIW) has released a preliminary existing chemicals inventory. That inventory, when the appropriate link is working, will be available on DIW’s official website: http://www.diw.go.th/hawk/content.php?mode=eservice.
The DIW has combined the following four sources to make the National Existing Chemicals Inventory:
- Substances present in the DIW database.
- Hazardous substances whose properties match that of those present in Annex 5.6 of the Notification of Department of Industrial Works Re: List of Hazardous Substances (No. 2), and whose production and/or import are notified to the DIW using form Wor Or/ Or Gor 20, beginning from February B.E. 2558 (2015). Substances which are not notified to the DIW before the cut-off date (12/31/2016) will be considered new substances.
- Hazardous substances present in the Notification of the Department of Industrial Works Re: List of Hazardous Substances.
- Chemicals imported between 2014-2016 (obtained from the Customs Department).
The DIW anticipates the completion of the final version of the National Chemicals Inventory in 2017 and plans to update it every 3 years.
Thailand's Proposed Existing and New Chemicals Management Regulations:
Chemicals present in the inventory which meet the below criteria will be prioritized for assessment:
- Chemicals whose production or import volume exceeds 10 metric tons per annum;
- Carcinogenic, mutagenic and repro-toxic (CMR) chemicals - category 1A or 1B;
- Persistent, bio-accumulative and toxic (PBT) chemicals;
- Very persistent and very bio-accumulative (vPvB) chemicals;
- Chemicals of equivalent concern or hazardous;
- Substances under International Conventions
Chemicals determined to be substances of very high concern (SVHC) will require submission of chemical risk assessment reports. Grace periods will be given according to tonnage bands. The DIW proposes 3, 5, and 8 years for chemicals whose production/import volumes exceed 1000 metric tons/year, 100-1000 metric tons/year and 10 but not exceeding 100 metric tons/year, respectively. In addition, the DIW would permit companies to submit joint chemical risk assessment reports. Due to this new requirement, the hazard type of the substances present in the Notification of the Department of Industrial Works Re: List of Hazardous Substances and its amendment may change. Consequently, certain chemicals may be subjected to more stringent production/import requirements. Chemicals not present in the chemicals inventory will be considered new. Non-hazardous chemicals and those which do not meet the aforementioned SVHC criteria are qualified for simplified risk assessment report.
Moreover, the DIW proposes adding new subsections onto the safety data sheets. Examples of such proposals include adding “Specific Uses” under Section 7: Handling and Storage and the inclusion of the full text of R phrases (hazard statements) under Section 16: Other Information.
*Readers should note that these requirements are only proposed and may change in the future when the finalized version of the chemicals inventory is published.*
Department of Industrial Works (DIW), PowerPoint slides outlining regulatory proposals concerning Thailand Chemical Management and Thailand Chemicals Inventory (in Thai): http://php.diw.go.th/haz/wp-content/uploads/2015/03/chem.pdf
Notification of the Department of Industrial Works Re: List of Hazardous Substances (No. 2) B.E. 2558 (in Thai): http://www.ratchakitcha.soc.go.th/DATA/PDF/2558/E/041/12.PDF
Notification of the Department of Industrial Works Re: Notifications of Manufacturers and Importers of Hazardous Substances in Annex 5.6 (in Thai):