Alex Lynch, senior dangerous goods consultant, Built Environment, explains why it’s important for everyone involved in the transport of dangerous goods via train to stay up-to-date with the Regulations Concerning the International Carriage of Dangerous Goods by Rail (RID).
When it comes to freight, the rail industry does not work in isolation, it is often one part of a broader supply network, relying on other forms of transport, such as shipping, aeroplanes, or road haul, to complete the delivery of a cargo. As a result, the responsibility for carrying products and materials by train safely does not rest with rail operators alone. From the organisation packaging the products, to the freight companies delivering them to the railway, everyone is responsible for ensuring cargo is packaged and handled correctly to minimise safety risks during the train’s journey. This is especially the case when it comes to transporting dangerous goods.
Dangerous goods are substances or articles which, if precautions are not taken, can harm people, property or the environment during transport. Examples include diesel, petrol, caustic soda and toxic chemicals, as well as radioactive materials. Any organisation carrying dangerous goods needs to have a dangerous goods safety adviser (DGSA) on their team to oversee the handling of products to minimise risk.
As rail operators are normally an intermediate link in a longer supply chain, it is not just the DGSAs of rail operators who need to understand the latest legislation on transporting dangerous goods by train. These are outlined in the “Regulation concerning the International Carriage of Dangerous Goods by Rail” (RID), and everyone in the supply chain, whether working on the road, by air or sea, needs to be aware of the upcoming changes.
Getting to grips with RID
RID is issued by the Intergovernmental Organisation for International Carriage by Rail (OTIF), and feeds into EU Directive 2008/68/EC on the inland transport of dangerous goods, offering technical detail on safety procedures to minimise risk.
EU Directive 2008/68/EC – which is in force in the UK – ensures a common definition of the term “dangerous goods” across Europe and provides a universal set of standards to ensure all hazardous materials are safely.
RID applies not just to rail operators, but to everyone involved in the carriage of dangerous goods by train. This includes the organisation packing the materials, the road hauliers or marine freight companies delivering the products to the train, and those loading or unloading them. For that reason, it is important for rail operators to work with their partners up and down the supply chain to make sure they understand the requirements of RID and its implications.
Tracking the changes
RID is updated every two years to take account of innovations in packaging and transportation, changes in the definition of dangerous goods, and also the development of new materials that may pose a safety hazard. On 1 January 2017, the latest revision to the regulations will be introduced, which organisations transporting dangerous goods by rail need to understand in order to remain compliant.
As is often the case when renewing legislation, changes to the core requirements are minimal, but there are some key updates that DGSAs – wherever they are in the supply chain – should be aware of:
- New UN numbers for polymerising substances, engines and machinery
New UN numbers – the unique four-digit codes used to classify materials according to their transportation needs – will be introduced for polymerising substances. These are chemicals that can become highly unstable if appropriate precautions are not taken. For rail transport, polymerising substances will be classed under UN numbers 3531 to 3532, requiring consignors to employ chemical stabilisation techniques to keep the material stable during transport. Engines and machinery containing dangerous goods, such as flammable fuels, will be classed under UN 3528 to 3530, which means organisations will need to take steps to minimise the risk of fire during transport.
- Environmentally hazardous substances in small packages
The rules for transporting small consignments of environmentally hazardous substances – particularly those classed as UN 3077 and 3082 – will be relaxed, meaning packages smaller than five kilos or five litres will no longer have to comply fully with RID marking requirements. These substances pose a small risk to the environment, but are not sufficiently hazardous to be added to any other dangerous goods class.
- “Instructions in Writing” for lithium batteries
A new transport label specifically for consignments of lithium batteries is to be introduced. As a consequence, emergency “Instructions in Writing” – a document that must be included with any dangerous goods cargo, providing guidance for dealing with any safety incident, will also be revised. While used in consumer technology, lithium batteries are classed as dangerous goods because lithium metal can become unstable under extreme changes in temperature, posing a fire risk during transport.
- Uranium hexafluoride
The requirements for transporting uranium hexafluoride – a compound used in uranium enrichment for nuclear power stations – will be amended. The material will now be classed under UN 3507 as toxic with a corrosive subsidiary risk and also under UN 2977 and UN 2978 as radioactive with a toxic and corrosive subsidiary risk.
Staying on track
From 1 January 2017, when RID 2017 comes into force alongside RID 2015, the DGSAs of rail operators and every other organisation involved in transporting dangerous goods by rail will have a six month transition period to update their existing procedures. Organisations should familiarise themselves with the upcoming changes to ensure they continue to be compliant with the regulations after the transition deadline of 1 July 2017.
Organisations should consult experts in dangerous goods, such as independent DGSAs, in order to get the advice they need for the transfer to go as smoothly as possible. This way, everyone in the supply chain can make sure they uphold the highest standards of safety to protect both the environment and public health.
For more information about ESG’s dangerous goods and DGSA services, visit http://www.esg.co.uk/our-services/built-environment/dangerous-goods-safety-advisor/.