BADGP Newsletter No 18 - Jan 2018

British Association of Dangerous Goods
Professionals
Newsletter No. 18, January 2018
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Happy New Year to you all! Doesn’t it seem like such a long time ago now. I am sure that you have
all been extremely busy especially with the new changes to IATA and of course are looking forward
to our AGM in March. If you haven’t signed up to it yet please do – there is till time. I look forward
to seeing you all in March.
Best wishes
Caroline
In this Newsletter
2018 AGM & Annual Industry Seminar............................................................................................ 2

Model Regulations Webinar ............................................................................................................ 3
Review Of Changes To The UN Orange Book ................................................................................ 4
Dangerous Goods in Europe - Activity in EASA Hungary and Problems with Air Transport ........... 10
IMDG Code Amendment 38-16 (IMDG 2016) ............................................................................... 11
Corrigendum December 2017 ....................................................................................................... 11
VCA 33rd Dangerous Goods Seminar............................................................................................ 13
ONR.............................................................................................................................................. 14
Solvents Industry Association (SIA) Launches Latest Safety Film: ‘Safe Loading and
Transportation of Bulk Solvents by Road’...................................................................................... 14
Transport Manager v`s DGSA ....................................................................................................... 15
Impact Of BSSD 2013 On Transport Of Class 7 Dangerous Goods .............................................. 17
Newsletter Contributions ............................................................................................................... 20
BADGP Membership ..................................................................................................................... 20
Contact Details ............................................................................................................................. 20
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Newsletter No 18 -1- January 2018
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2018 AGM & Annual Industry Seminar
Our AGM & Annual Industry Seminar takes place on Thursday 22 nd March 2018 at Sedgebrook
Hall Hotel, Chapel Brampton, Northampton, NN6 8BD.
Registration is now open, and places are filling quickly, so please, if you wish to attend, do
not delay in registering. Click on this link: REGISTER FOR BADGP AGM.
Registration is free of charge for members. Non-members can apply for BADGP membership (only
£70 for 2018) and then attend the event free-of-charge. Attendance includes refreshments and
lunch.
Annual Industry Seminar

As usual, we will conduct the formal business of the Annual General Meeting and then present our
Annual Industry Seminar. We are still finalising the programme, but we have already secured 3
excellent speakers and are in discussions with 2 others to complete the program. Our confirmed
speakers are, Paul Horner of IATA, Phil Lapczuk of DVSA, Keith White, VCA and Bill Atkinson of
OHES.
Exhibition
We are also delighted to host a small exhibition of products and services of interest to our
members. We’d like to thank the following organisations for attending as exhibitors – it is their
sponsorship and support that enables us to run the event, free of charge, to our members (click on
a logo to visit the organisation’s website).
(continued over)
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2018 AGM & Annual Industry Seminar (continued)
If you are interested in sponsoring and exhibiting at the event, we still have some places available.
Please contact: enquiries@badgp.org.
Model Regulations Webinar
BADGP Committee member, Andy Holton, kindly put together a presentation on “Amendments to
the nineteenth revised edition of the Recommendations on the Transport of Dangerous Goods,
Model Regulations (ST/SG/AC.10/1/Rev.19) and Implications for ADR/IMDG/IATA”, which we ran
as a webinar on 19 October 2017. Thank you to all members who signed up and “attended” this
event and to Andy for compiling and presenting it.
Presentation Available On www.badgp.org
Please don’t forget, that the presentation and a full recording of the webinar are available to all
members via the BADGP website. (You must be logged in to access the files, which are located at:
www.badgp.org/presentations-badgp-events).
Feedback
Despite one or two members having some technical issues with the GoToMeeting software that we
use, the feedback from attendees was very good with 100% of respondents saying they would
attend another BADGP webinar.
What Webinar / Events Topics Would You Like To See
Thanks to all of you who provided ideas for future webinars and events. We are always very keen
to understand what topics currently interest you. So, please, do let us know if there is a particular
topic or issue that you would like us to consider for future webinars, seminars, AGM topics, etc.
Please email your ideas to enquiries@badgp.org. We look forward to hearing from you.
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Review Of Changes To The UN Orange Book
Summary of changes kindly compiled from the original text for BADGP members by Dr Andy
Holton for the Model Regulations webinar run in October 2017 and now summarised in this article
by BADGP Committee member, Richard Masters.
Introduction to this article

Amendments to the UN Orange Book 2016, properly called the UN Recommendations on the
Transport of Dangerous Goods Model Regulations revision ST/SG/AC.10/1/Rev.19, has been
finalised by the UN Committee of Experts on the Transport of Dangerous Goods.
Dr Andy Holton has summarised in his webinar the material changes to the 2016 Orange Book that
will be used as the reference when the 2019 ADR, IMDG and ICAO regulations are drafted by the
committees that produce those publications. We thank Dr Holton for his efforts in producing the
webinar, and here for benefit of BADGP members is a convenient summary of those Orange Book
changes in text format.
This article is a summary of Dr Holton’s presentation, which is necessarily an abbreviation of the
original UN document which is detailed and runs to 50 pages of close text. Any reader with an
interest in particular items in this article is recommended to refer to the full original UN Committee
of Experts text that is accessed via this link:
http://www.unece.org/trans/main/dgdb/dgcomm/ac10rep.html
The “Orange” Book
The Orange Book is a basic scheme of provisions on which are based all the national and
international rules for the transport of packaged dangerous goods. (Except bulk dangerous goods
carried by sea that have separate regulations in the International Bulk Chemical Code).
The Orange Book sets out guiding provisions for the following:
1. Classification by type of hazard (Note the actual tests for classifying dangerous goods are
found in a separate publication the UN Recommendations on the Transport of Dangerous
Goods, Manual of Tests & Criteria ST/SG/AC.10/11/Rev.6)
2. List of dangerous goods
3. General packing requirements
4. Marking, labelling & placarding
5. Documentation
6. The format for the Safety Data Sheet for new or amended classification of substances.
Item 1: General changes to clarify the text
It has been considered that the word “risk” is ambiguous, so to improve clarity throughout the text
the word “risk” is replaced by “hazard”, so “potential risk” becomes “potential hazard” and
“subsidiary risk” becomes “subsidiary hazard”.
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The word “carriage” is capable of mis-translation into other languages so it has been replaced by
“transport” throughout the text.
Where the words “dangerous goods” could include a description of articles containing dangerous
goods, the full description “dangerous goods and articles containing dangerous goods” is used.
Where “devices” is used is replaced by “articles”.
Item 2: Inclusion of “polymerizing substances”
To reflect the new awareness and concern regarding the potential hazard of spontaneous
polymerization during transport the description “self-reactive substances” is now expanded to “self-
reactive substances and polymerizing substances”.
Item 3: Damaged and defective lithium batteries
Within the packing and other provisions for lithium batteries, specific reference is made to different
provisions for damaged or defective lithium batteries as these are considered to present serious
potential hazard.
Item 4: Change to definition of animal material
In the definition of “Animal material means animal carcasses or animal body parts” replace “… or
animal foodstuffs” with “Animal material means animal carcasses, animal body parts, foodstuffs or
feedstuffs derived from animals” to avoid confusion with animal foodstuffs that animals eat.
Item 5: Security for explosives (Orange Book 1.4.3.2.1)
A new provision has been added allowing competent authorities to implement, optionally, security
provisions for explosives that are not directly related to transport, including security markings. Any
explosives security marking should be consistent with an internationally harmonised standard such
as EC Directive 2008/43 on a system for the identification and traceability of explosives for civil
use.
Item 6: New Section 2.0.4.3 – carriage of samples of energetic substances
Energetic substances that have reactive and organic molecules in the same molecule that are
controlled by the oxygen balance in the molecules such as: peroxides, ozonides, alkyl nitrates,
fluoramines, olefins etc may be classified as Type C of Class 4.1. New UN Numbers and packing
provisions apply.
Item 7: New section 2.0.5 classification of articles containing dangerous goods
This section will instruct how to classify articles with no UN Number that contain dangerous goods.
The UN Number will depend on the dangerous goods present.
Item 8: Grammatical correction to explosives classification 2.1.1.1(c)
Remove the comma in, “Class 1 comprises:
…
Substances and articles not mentioned under (a) or (b) above which are manufactured with
a view to producing a practical explosive or pyrotechnic effect.”
Item 9: Clarification of Class 1 fireworks flash composition table 2.1.3.5.5
There have been additions to the fireworks flash composition table.
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Item 10: Class 4.1 revised packing method for self-reacting formulations 2.4.2.3.2.3
Self-reacting formulations subject to packing instruction IBC 520 and tank instruction T23 may be
transported in accordance with packing method OP8, and using the same control and emergency
temperatures.
Item 11: Class 4.1 new entry for UN 3227 self-reactive substance 2.4.2.3.2.3
The substance, phosphororthioic acid, O[(cyanophenyl methylene) azanyl] o, o-diethyl ester has
functional groups that could react within the same molecule: oxygen and sulphur, or azanyl (into
nitrogen), or phosphors-sulphur (into phosphate ester) and can be included in UN 3227.
Item 12: Class 4.1 polymerizing substances
Substances meeting the criteria of “polymerizing” that are already classified in classes 1 – 8 must
be assigned to SP386 which has provisions for transport under temperature control for stabilization
purposes.
Item 13: Class 5 classification of ammonium nitrate 2.5.2.1.2
Section 2.5.2.1.2 is expanded to extend the possibility of classifying ammonium nitrate as Class 1,
Class 5.1 or Class 9, packing group II. Solid fertilisers should be tested according to the Manual of
Tests and Criteria section 59.
Item 14: Class 5.2 classification or organic peroxides 2.5.3.2.4
There are new entries for the following substances:
DIISOBUTRYL PEROXIDE
DI-(4-tert-BUTYLCYCLOHEXYL) PEROXYDICARBONATE
1-PHENYLETHYL HYDROPEROXIDE.
Formulations subjected IBC520 are allowed in the following types of packagings:
Combination packagings
Single packagings
Composite packagings
Item 15: Class 6.1 UN 3302 requirement for “stabilization”
UN 3302, 2-DIMETHYLAMINOETHYLACRYLATE is required to be transported as “stabilized” and
as such the DG List Column 2 Proper Shipping Name will include “Stabilized” and Special
Provision 386 will be added to Column 6.
It is possible that entries for other potentially polymerizing substances will be amended in a similar
manner.
Item 16: Class 8 revised classification rules to align with GHS harmonisation - 2.8.4
There is an alternative step-wise assignment method for classifying corrosive mixtures
incorporating:
Flow chart
Bridging principles
Formula (PGꭕ1/GCL) + (PGꭕ2/SCL2) + (…) + PGꭕί/SCLί) > 1
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Item 17: Class 9 new UN Numbers and special provision 2.9.2 and 2.9.4
There are new entries for:
UN 3536, LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNITS
SP 387 is a new special provision for some lithium batteries
UN 3548, ARTICLES CONTAINING MISCELLANEOUS DANGEROUS GOODS N.O.S.
Item 18: Dangerous Goods List 3.1.2.2 – selection of UN Number
3.1.2.2 is amended to include clarification on how to choose the most appropriate UN Number.
Item 19: Dangerous Goods List 3.1.2.6 – inclusion of “temperature controlled”
Where substances are transported under temperature controlled conditions to achieve stabilization
the words “TEMPERATURE CONTROLLED” shall be added to the Proper Shipping Name.
Item 20: Dangerous Goods List 3.2.1 - new UN Numbers
The following new UN Numbers are created:
UN 3535, TOXIC SOLID, FLAMMABLE, INORGANIC, N.O.S.
UN 3537 to UN 3548, ARTICLES CONTAINING DANGEROUS GOODS, N.O.S.
Item 21: Amendments to existing Special Provisions - 3.3.1
There are several amendments to existing Special Provisions:
• SP 188 – Lithium batteries – is amended to include advice on marking overpacks and most
precisely defines “equipment”
• SP 193 – Ammonium nitrate (air & sea only) and SP 307 (all modes) amends the
classification procedure
• SP 251 – Chemical & first aid kits – clarifies quantities eligible for LQ & EQ consignments
• SP 301 – Dangerous goods in machinery – clarification on the enclosure of dangerous
goods within machinery and equipment to prevent reaction during transport
• SP 308 – Fish meal - extends the range of processes by which fish meal may be stabilized
• SP 363 – Engines or machinery powered by fuels classified as dangerous goods –
amendment to an already lengthy text
• SP 376 – Lithium batteries – amendment to provisions for damaged or defective batteries
Item 22: Deletion of some Special Provisions – 3.3.1
The following Special Provisions are deleted:
• SP 186 – Ammonium nitrate
• SP 240 – Battery-powered vehicles
• SP 312 – Vehicles powered by fuel cells
• SP 380 & SP 385 – Vehicles powered by flammable liquid or gas internal combustion
engines, or fuel cells
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Item 23: New Special Provisions – 3.3.1

The following new Special Provisions will be introduced:
• SP 387 - Lithium metal or lithium ion batteries assigned to UN 3090 or UN 3091
• SP 388 – UN 3166 will be applied to vehicles powered by flammable liquid or gas internal
combustion engines, or fuel cells
• SP 389 – Lithium batteries installed in cargo transport units
• SP 391 – the Competent Authority will specify transport conditions for articles containing
dangerous goods of divisions 2.3,4.2, 4.3, 5.1, 5.2 or 6.1 PGI with inhalation toxicity
• SP 392 – Fuel gas in motor vehicles – there will be a relaxation of the provisions of 4.1.4.1
and Chapter 6.2 when transporting motor vehicles for disposal, repair, recycling or
inspection
Item 24: Changes to existing packaging provisions – 4.1.4.1
Changes are made to the following Packaging Provisions:
• P001 – Clarification of the use of plastic drums in composite packages
• P200 & P206 – the terms “liquified gas” and “liquid phase” are clarified
• P520 – new Packing Provisions PP94 & PP95 are added to P520 for samples of UN 3223
or UN 3224 and changes are made to packaging for UN 3109 and UN 3119
• There are minor textural changes to P620, P801, P901, P903, P906, P908, P909 and P910
• LP902 – Changes are made to the specified material of packaging for Safety devices
• LP904 – Damaged lithium batteries – the text is clarified
Item 25: New Packing Provisions - 4.1.4.1
The following new Packing Provisions are added:
• P006 & LP03 are added for articles containing dangerous goods. These apply to most new
UN Numbers between 3537 and 3548
• P911 & LP906 are added for defective / damaged batteries of specified UN Numbers
• LP905 is added for lithium cells / batteries, prototypes and pre-production runs of limited
quantity.
Item 26: Portable tanks – 4.2.5
• T23 – Tank provision T23 is the tank provision for self-reactive substances and organic
peroxides. For certain formulations this amendment links T23 with packing method OP8 in
PP520 allowing greater volume providing the same control and emergency temperatures
can be maintained.
• TP10 – allows transport of lead-lined tanks for up to 3 months after the lining examination
and test is due
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Item 27: Labelling

• GHS pictograms - Clarification is added stating that the GHS pictograms may only be used
as part of a complete GHS label, not as a transport label - 5.1.1
• Provisions for labelling articles containing dangerous goods of UN Numbers 3537 to UN
3548 – 5.2.2.1.13
• New provision allows for label size to be reduced “proportionally” to package size –
5.2.2.2.1.3
• The layout of the specimen labels is revised – 5.2.2.2.2
Example:
2.1 Division 2.1: Flame: black Red 2
or white
Flammable gases (except as (black or
provided for in 5.2.2.2.1.6 d)) white)
Item 28: Placarding – 5.3

The placarding requirements are clarified so that placarding for bulk containers is included.
Item 29: Pressure vessels – 6.2.2
• There are some technical changes to the testing of stainless steel cylinders using ISO
16148:201
• There are new construction standards for pressure drums
• There are new standards for pressure vessel service equipment
• There are revised deadlines for testing UN cylinders
Item 30: Special Provisions for the transport of self-reactive substances, organic peroxides
and other substances stabilized by temperature control – 7.1.5
There is extensive revised text for the transport of substances stabilized by temperature control,
including polymerizing substances, with reference to temperature control methods, stabilization
criteria, Self-Accelerating Decomposition Temperatures (SADT) and Self-Accelerating
Polymerization Temperatures (SAPT), and the ratio to control temperatures and emergency
temperatures.
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Dangerous Goods in Europe - Activity in EASA

Hungary and Problems with Air Transport
BADGP is a member of EASA, the European Association of dangerous goods Safety Advisers
(http://easa-dg.eu). Our Committee members Andy Holton and Trevor Green attend the EASA
meetings and have fed back highlights in previous BADGP Newsletters. In this article Andy Holton
requests feedback from BADGP members on international practices in the control of air cargo.
EASA eases forwards slowly but surely, and a demonstration of this is the effectiveness of
networking. Recently the Dangerous Goods (“DG”) association of Hungary (“BTE”) asked the
EASA members a question about some of the difficulties of the air transport of DGs.
Below is a simplified version of the background and the questions posed in BTE’s original note:
“Some airport operators, or transporters, and airlines have contacted BTE asking for help
concerning some Hungarian audit practices, as well as the legal background of the air
transport of dangerous goods. Recently there have been some cases where the violation of
legislation, the risk of irregularity and the huge fines were disproportionally high.
Due to the problems raised, we contacted the relevant Hungarian authority, who listened to
us and promised to act as a legislator, taking into consideration our reasons, and to initiate
some investigation.
As part of this process, we offered to collect information from the EASA organization that
may help to review and possibly modify national regulatory and control practices.
We hope to do it, as in a similar situation in 2015 we achieved good results in the domestic
modification of penalty regulations of the road, rail and river transport.
In order to have a better picture of international practice in the control of air cargo transport,
we ask for responses to the following questions:
• Which authority checks the air-transport of dangerous goods? (we ask for the name
of the authorizing regulation - or the link to download it)
• Which regulation controls airborne dangerous goods? (name it or provide the link,
please)
• What is the minimum and maximum amount of the fine that can be imposed in such
circumstances?
• Typically, which sort of deficiencies are discovered during official controls?
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• How does the authority typically react to the shortcomings identified?

• In the event of non-compliances or damaged DGs, the operator or transporter
should remove the DGs from the delivery process and notify the relevant authority.
Nevertheless, the authority will also carry out their checks and a fine may be
imposed. Does this happen in practice?
• Are there any national laws where corrective measures during an administrative
procedure can prevent the imposition of fines?
• Are there any available statistics concerning the number of airborne dangerous
goods’ checks and the number of fines imposed (if yes, can we request data?)?”
Out the twenty-odd EASA members, four have replied so far and I would like BADGP to support
EASA in general and Hungary in particular by asking our members for replies and comments to the
above. Please email them to me (aghdgsa@yahoo.com) and Trevor Green
(trevor@wyverncargo.com).
IMDG Code Amendment 38-16 (IMDG 2016)

Corrigendum December 2017
BADGP would like to thank James Douglas, Exis Technologies’ Commercial Director for supplying
this article.
The International Maritime Organization have produced a Corrigendum to Amendment 38-16 of the
IMDG Code. Exis Technologies has produced a summary of the key changes:
• There is a small change to the definition of SADT
• Minor amendments to the PSNs for UN 1333, 1374, 1712, 2216, 2465
• ‘Fishmeal’, ‘ Fishscrap’ now have a space included: Fish meal, Fish scrap
• Deletion of PP40 from UN 1396 (pgIII), 1398 (pgIII), 1402 (pgI), 1403 (pgIII), 1405 (pgIII),
3132 (pgIII), 3208 (pgIII). (This corrects anomaly as PP40 applies to pgII substances only)
• UN 0500 and UN 0501 have their spillage schedule correctly applied, now S-X and S-Y
respectively
• UN 1324 has fire schedule ‘F-G’ replaced by ‘F-A’
• For 1418 (pgII and III) and UN 2870 removes F-G (as per the special case in F-G it applies
only to class 4.3 PGI)
• SW1 added to UN 2383
• PP31 added to UN 2441
• Replace ‘F-E’ with ‘F-A’ for UN 2735 (already F-A for pgII and pgIII)
• Add SP368 to UN 2908
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• The EmS for UN 3513 now has a comma rather than full stop to separate the fire and
spillage schedules (this corrects the obvious typo)
• The properties and observations for UN 3530 no longer refers to fuel cells
• SG72 now refers generally to the segregation exemptions in 7.2.6.3 rather than specifically
to table 7.2.6.3.2. As a result UN 3391 to 3400 now have SG72
• There have been minor changes to a few special provisions: SP207, 225, 369, 384, 907,
928 and 945
• In 3.4.1.2.5, ‘5.1.1.4’ has been replaced by ‘5.1.1.6’ – to reflect new re-numbering in 5.1.1
• There are minor updates to the table in 4.1.1.10
• Minor corrections to P002, P200, P403, P410 and P603
• There are a few generic corrections ‘markings’ to ‘marks’ missed from the A38 update
• 5.2.2.2 – there is a new second sentence on the new class 9 lithium battery mark (you are
not able to put any text such as description of the hazard into the label as you are with most
other labels)
• 5.3.2.0.2 – there was an error in the printed books regarding the size of the PSN mark, this
is now corrected
• There are minor corrections in Part 6 and part 7
• Some of the segregation examples in the annex to chapter 7.2 have been updated and
clarified
• In the Appendix A the entries for Polymerising substances have been moved from generic
entries to specific entries
• There are minor updates to the alphabetical index
Amendment 38-16 of the IMDG Code is mandatory from 1 January 2018. A summary of the
changes from Amendment 37-14 to Amendment 38-16 of the IMDG Code is available here:
http://www.imdgsupport.com/IMDG_2016_Changes.asp
Please note: the changes were current at the time of production. This is a guide only; users must
check with official sources before relying on the information.
Exis Technologies accepts no responsibility for errors or omissions.
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VCA 33rd Dangerous Goods Seminar
Thanks to VCA for sending us this notification.
The 33rd Annual Dangerous Goods seminar will be taking place on the 5th and 6th June 2018,
again at the Daventry Court hotel, Northamptonshire.
This event will provide the ideal opportunity to promote your products and services to members of
the Dangerous Goods community. Now in its 33rd year, this seminar is seen as a ‘must’ for anyone
involved in the manufacture, transport and handling of Dangerous Goods.
While this year’s programme has yet to be confirmed, but as always experts from across the UK
Government will be in attendance including:
• The Department for Transport
• VCA Dangerous Goods Office
• The Driver Vehicle and Standards Agency (DVSA)
• The Health and Safety Executive (HSE)
• The Maritime and Coastguard Agency (MCA)
• The Civil Aviation Authority (CAA)
• The Office of Nuclear Regulation (ONR)
Regulators will be on hand over both days to answer any specific questions from delegates
Invitations with full programme details will be sent out in the next few months.
BADGP hope to be exhibiting again this year.
For more information, please visit: http://www.dft.gov.uk/vca/dangerousgoods/dangerous-goods-
seminar.asp
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ONR
The ONR has posted new information on their

Transport webpages in relation to IRR17 and the
transport of radioactive material. This includes
detail on graded approach requirements for
transport and enforcement responsibilities. More
information is available on the ONR website at:
http://www.onr.org.uk/transport/irr2017.htm.
Solvents Industry Association (SIA) Launches Latest Safety Film: ‘Safe

Loading and Transportation of Bulk Solvents by Road’
Many thanks to Andrew Norman, General Secretary of the SIA for sending us a Press Release, the
text of which we include as this article.
All companies involved in the solvents industry know the importance of

being vigilant when it comes to handling these potentially dangerous
materials.
Even in a sector as safety conscious as the chemical industry, a gentle
reminder from time to time never does any harm, which is why the UK-
based [1] Solvents Industry Association (SIA) has collaborated with the European Solvents
Industry Group (ESIG) to produce the latest in their series of solvent-related safety films.
Entitled ‘Safe Loading and Transportation of Bulk Solvents by Road’, the short film is designed to
support hauliers, drivers and site operators who routinely handle solvents on the move.
This fifth safety film that the organisations have produced encourages best practice in the safe
transportation and bulk transfer of solvents between vehicles and storage vessels
Topics covered in the latest offering include:
• The hazards associated with solvents and solvent-based materials
• Pre-delivery inspection
• Arrival on site and induction
• Adherence to site rules and understanding emergency procedures
• Using the correct Personal Protective Equipment (PPE)
• Safe connection to loading gantries and storage vessels
• Communication between site operators and drivers
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• Safeguards against static discharge and spills

• ADR requirements for vehicles and drivers
The current release is in English but the film will also be available in four further languages;
French, German, Italian and Spanish shortly. The latest film accompanies previous productions
from the SIA and ESIG, which include, ‘Safe Use of Solvents’, ‘Solvents and IBCs’, ‘Solvents and
Static Electricity’ and ‘Solvents and the Safe Use of Gloves’.
All of the above productions are available to view or download via the SIA website at:
www.solvents.org.uk from October 12th 2017.
To order a free USB copy, containing all five films in the series, please contact Andrew Norman,
SIA General Secretary at info@solvents.org.uk.
[1] Established in 1973, the Solvents Industry Association has sought from its inception to support
the UK solvents industry and consumers by promoting the safe and responsible use of solvent
materials. It currently has 26 members, covering all areas of the solvents industry, including
manufacturers, distributors, hauliers, chemical storage companies, packaging manufacturers,
electrostatic control manufacturers, solvent recycling and distillers.
The SIA’s mission is to work to ensure that the UK’s regulatory framework relevant to the
manufacture, storage, distribution and use of solvents is based on sound science and best
practice.
For further information please contact Andrew Norman, SIA General Secretary on
+44 (0)7758 118675 or email directly at info@solvents.org.uk.
Transport Manager v`s DGSA
We are grateful to Phil David, BA, MILT,MIIAI,MSOE,MIRTE,CAE,MIMI, Dangerous Goods Safety

Advisor, Chair of the National Carriage of Dangerous Goods Practitioners Forum, for this article.
Following a roadside check, I return to the office somewhat perplexed, as to why haulage
companies cannot follow the most simple of instructions when it comes to ADR, and its
requirements. Frankly, the standard of some haulage companies is certainly not up to standard
and calls into question, as to who is actually taking control of the road aspect of the operation.
As previously stated, I have sat collating the Carriage of Dangerous Goods annual returns, and it
was no surprise that the number of enforcement checks carried out by the country’s police forces
has fallen, but the pro rata number of Prohibition Notices that has been issued has increased.
Let’s take a step back, and address the fundamental problems that enforcement staff have been
faced with.
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The professional driver, the one that holds a VTC and has taken steps to obtain and qualify for
such a certificate, proves, in the first instance that they are competent. Having received their VTC
through the post, after reaching the standard required, the holder now has the privilege to convey
dangerous goods around the UK, and further afield. Their knowledge and knowhow at this point is
at an all-time high.
So, a few months, perhaps one or two years down the line since they have completed their
training, enforcement agencies are now being faced with a driver who has totally forgotten what
was covered and addressed in their training. I don’t believe for one minute, that any fault can be
attributed to the training providers, as their standards are high. There must be a chain of events
that lead to this end.
The most simplistic daily checks prior to departure from a depot, when the dangerous goods have
been loaded must be carried out, but there is overarching evidence that these are not being done.
So who is control, the Transport Manager at the depot or the Dangerous Goods Safety Advisor
(DGSA)?
To qualify, to become a transport manager, a Certificate of Professional Competence (Manager)
needs to be obtained, and within the learning objectives, the carriage of dangerous goods is
covered. Yes, it can be argued that the DGSA is the specialised person, but what actually are the
transport mangers doing, to ensure that ADR is being complied with?
Companies spend a vast
amount on providing
equipment, training, both
through their requirement
under Health and Safety
Legislation, and the
requirements of ADR, yet in
most encounters, the end
product does not equate to the
amount spent.
In effect, it’s the transport
manager, or a person directly
acting on their behalf that is
waving the checked flag as
the vehicle leaves the depot, and initially, the burden is placed on their shoulders.
So, what is the main problem? The enforcement community always report a problem with
equipment, and this is so easy to comply with. Roadside check after roadside check always
highlights the need to maintain fire extinguishers, PPE and consistency with placards and boards.
However, documentation has also become a problem within recent times.
I will step back, and if there is a complex issue regarding the documentation, then some mitigation
is given to the driver, but this is their respective traffic offices` fundamental test of knowledge and
worth.
A simple walk around would have highlighted the below issue. Yes, it was a bulk carriage, but with
GB tanker boards? OK, the information is there, but is the condition of the board acceptable, when
it this state?
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In the first instance, does this become a transport manager issue or a DGSA issue?
Roadside, this doesn’t become an issue at the time, as a prohibition notice will be issued.
The issue of the prohibition notice is then issued to the company, and in effect reaches the
transport manager. Action is then reminded by the transport manager, and it is very rare that the
DGSA will have an input on rectifying issues.
In an attempt to make DGSA’s more accountable, more and more police forces are asking to see
the previous annual report of the company, as required under ADR 1.8.3.3. This then makes the
DGSA accountable and to a certain degree, ensures that they are carrying out their duties. The
standard of some annual reports are excellent, yet the vast majority of them are inadequate, with
lack of information or structure. Basically, two lines outlining that they have undertaken their duties,
and that’s it. Yes, I can hear the argument that ADR does not give guidance, content or any other
direction as to what the content of the annual report must contain, but surely there is an element of
professionalism and pride associated with a report.
Leading on from this, the amount of DGSA’s are in decline. It is unknown as to whether this is due
to the 5-year cycle, or more and more companies are employing consultant DGSA’s who are
covering numerous undertakings. In any case, the duties must be fulfilled by the DGSA and not in
name only.
Specific duties are placed upon the DGSA, under ADR 1.8.3.3, but are they actually participating in
their given role, or is the burden being shouldered by the transport manager?
The jury is currently out, and may be some time.
Impact Of BSSD 2013 On Transport Of Class 7 Dangerous Goods
Many thanks to Mark Lyons, Director of L2 Business Consulting Limited for this article.
CDG 2009 (as amended) regulates the transport of dangerous goods and enact the use of ADR
(road) and RID (rail) frameworks in the UK, CDG 2009 also has specific sections which deal with
Class 7 dangerous goods (radioactive materials), Regulation 24 and the related Schedule 2, which
set out the regulatory requirements in relation to preparing for and responding to nuclear and
radiological emergencies which occur during the carriage of radioactive material.
The transport of radioactive material is also defined as a practice in the Ionising Radiations
Regulations 2017 (as it was under IRR99), therefore organisations which transport radioactive
materials must also comply with the relevant regulatory requirements for practices under IRR17, in
addition to the requirements of CDG 2009 (as amended).
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Professionals
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This news item is largely written from the perspective of non-nuclear industry duty holders, and
considers the relevant provisions of the BSSD 2013 (EU Basic Safety Standards Directive
(2013/59/EURATOM)) that will be enacted in the UK (discussed in the recent HMG consultation
document published in October 2017) by a planned revision of CDG 2009 in early 2018 and
specifically will include the following:
• Definition of an Emergency – this already exists in CDG 2009 but will be amended to
reflect the requirement of BSSD 2013 (which includes explicit reference to the protection of
property or the environment) and will align current IAEA definition. Overall the final
definition used will align to the updated version of Radiation (Emergency Preparedness and
Public Information) Regulations 2001 (REPPIR). Overall the changed definition is not
expected to have a significant impact upon duty holders.
• Definition of Emergency Worker and prior information and training for emergency
workers – no specific definition of an emergency worker in CDG 2009 or other related UK
law, therefore this will be added into CDG 2009 and that these workers identified in
emergency response plans have their training and information about the risks they are
taking regularly updated. Schedule 2 to CDG 2009 currently requires the Consignor and the
Carrier of radioactive materials to have a written emergency plan, and that the driver, the
Consignor and the Carrier assist with the intervention in the event of a nuclear or
radiological emergency. The changes will require that anyone in an emergency plan with a
role in providing assistance will be included in the definition of an emergency worker.
• Reference levels – these do not currently exist in the UK; therefore, UK HMG intends to
develop new National Reference Levels to address emergency exposure situations. When
the new guidance is developed, duty holder will need to consider it when creating/updating
emergency plans in relation to the transport of radioactive material.
• Emergency response – CDG 2009 already requires the driver or emergency service if the
driver is unable to do so to notify the ONR of the emergency. The Carrier and Consignor
must also initiate the emergency arrangements in respect any radiological emergency and
assist in the intervention. The majority of this area relates to the varying layers of national
response to emergency situations. Overall it is not envisaged that the requirement relating
to emergency response in BSSD 2013 will alter the current arrangements in the UK.
• Provision of information to public likely to be affected – The provision of information to

the public is a current requirement of CDG 2009 where ONR considers the public are likely
to be affected by a radiation emergency. In such circumstances, the Carriers and
Consignees must provide the public with the specified information stipulated. CDG 2009
also requires that the information is updated regularly and that the Carrier and Consignee
liaise with ONR and the local authority in producing and distributing the information. Overall
it is not envisaged that the requirement relating to the provision of information to the public
in BSSD 2013 will alter the current arrangements in the UK.
• Provision of information to public actually affected – this aspect of BSSD address that
if members of the public are actually affected by an emergency they are informed without
delay about the facts of the emergency, the steps to be taken and, as appropriate, the
health protection measures applicable. These requirements are currently covered by
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Professionals
______________________________________________________________________________
REPPIR and hence it is not envisaged that these requirements will substantially alter the
current arrangements in the UK.
• Emergency management system – this requires that the UK develops a suitable

emergency management system as detailed in BSSD 2013 that address emergencies from
within the UK and from outside the UK, including the specific elements to be included in an
emergency response plan. This is currently addressed at a site-specific level by REPPIR,
then additionally by generic emergency planning at local/national levels and for smaller
postulated doses via the Ionising Radiation Regulations. UK HMG has proposed some
changes to current arrangements including proportionate and graded approach to planning
for emergencies. It is likely to be requirements for the carrier and consignor to make a full
assessment of the consequences of the emergency and the effectiveness of the plan in
responding to it. It is envisaged that the plans will be designed to be commensurate with
the results of an assessment of potential emergency exposure situations and ensure they
will result in a reduction of the exposure to individuals.
• Emergency preparedness – this requires that emergency response plans are established
in advance for the various types of emergencies identified by an assessment of potential
emergency exposure situations. UK HMG believes that this is largely in place as it is
covered by REPPIR and IRR9. It is proposed to explicitly make the link between the risk
assessment made under the IRRs to the emergency plan required by Schedule 2 of
CDG09. Existing ONR guidance sets out the immediate notifications to be made, actions to
protect the driver, actions to protect the public, actions to protect the emergency services,
how to prevent the situation from escalating, actions to ensure the radioactive materials
remain secure, and the actions to be taken by the consignor. A new aspect in BSSD 2013
is that emergency response plans produced by operators shall also include provision for the
transition from an emergency exposure situation to an existing exposure situation, which
will be a new requirement in the update to CDG 2009, this will include the requirement to
provide a handover report to be submitted to the relevant authority. BSSD 2013 requires
that emergency response plans must be reviewed, revised and tested at suitable intervals,
existing ONR guidance provides more information on this including the need to include the
requirement to record learning points. It is not envisaged that there will be any substantive
changes to existing arrangements.
• Enforcement – the existing regulatory enforcement powers for HSE and ONR are deemed
compliant to the requirements of BSSD 2013. The information gathered by HSE using the
graded approach, will be used to inform ONR inspection regime.
We will now need to await publication of the revised CDG09 regulations to see what the finalised
requirements will be early in 2018.
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Professionals
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Newsletter Contributions
Many thanks to everyone who has contributed articles for this Newsletter. Our next edition will be
out in about 3 months.
We welcome articles from any interested party. If you would like to submit an article, please do so.
The articles must not be overtly “salesy”, but you can of course mention your company.
Please submit articles by 16th March 2018, together with any photos or graphics, etc. to
enquiries@badgp.org.
BADGP Membership
If you would like to join the BADGP we would be delighted to hear from you.
Membership is on an individual basis and costs £70.00 per year, from 1st January to 31st December
(the membership of anyone that joins after 1st September in any year runs through to 31 st
December of the following year). To apply for membership simply complete the online membership
form which you can find at: www.badgp.org/badgp-membership.
Contact Details
Chairman, Caroline Raine: caroline.raine@gmail.com
Office: enquiries@badgp.org
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© BADGP January 2018

Do please feel free to pass this Newsletter on to any other person who may be interested in
its contents, as long as the Newsletter is passed on in its entirety.
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BADGP Newsletter No 18 - Jan 2018

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British Association of Dangerous Goods

2018 AGM & Annual Industry Seminar............................................................................................ 2

2018 AGM & Annual Industry Seminar

Annual Industry Seminar

2018 AGM & Annual Industry Seminar (continued)

Model Regulations Webinar

Review Of Changes To The UN Orange Book

Introduction to this article

Item 23: New Special Provisions – 3.3.1

Item 27: Labelling

Item 28: Placarding – 5.3

Dangerous Goods in Europe - Activity in EASA

• How does the authority typically react to the shortcomings identified?

IMDG Code Amendment 38-16 (IMDG 2016)

VCA 33rd Dangerous Goods Seminar

Thanks to VCA for sending us this notification.

The ONR has posted new information on their

Solvents Industry Association (SIA) Launches Latest Safety Film: ‘Safe

All companies involved in the solvents industry know the importance of

• Safeguards against static discharge and spills

Transport Manager v`s DGSA

We are grateful to Phil David, BA, MILT,MIIAI,MSOE,MIRTE,CAE,MIMI, Dangerous Goods Safety

Impact Of BSSD 2013 On Transport Of Class 7 Dangerous Goods

• Provision of information to public likely to be affected – The provision of information to

• Emergency management system – this requires that the UK develops a suitable

© BADGP January 2018

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