HAZMAT: Handle with care
According to United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations and GOST 19433, depending on the type and properties these goods are divided into nine into classes and subcategories of risk. They can be transported either in protective types of packages, containers, tanks, etc., or without it, in liquid bulk or dry bulk form. If the requirements of the relevant safety rules and norms are not observed, such cargoes may cause explosion, fire, potential harm (death, injury, poisoning, contamination, exposure) to human health and the environment due to their physical, chemical, biological and other properties.
Specifics of regulation
The degree of risk in the transportation of DG is determined depending on the volume and properties of the cargo, the type of vehicle / equipment, the loading / transfer / transportation technologies.
The requirements to ensure the safety of transport and handling of OG in Russia, including on road and rail freight terminals, in river and sea ports, there are more than 13 international agreements, DG codes and standards and about the same number of national regulations.
Whether an emergency situation may occur or not during DG transportation depends on the knowledge and understanding by the participants of the transport market of the requirements of these norms and the ability to perform the rules in practice. Therefore, it is necessary that all participants involved in the transportation of such goods are regularly trained under special programs that take into account the mode of transport and the type of cargo being transported at the current time.
It is difficult to comply with international and national security requirements without special training, including the preparation of necessary transport documents, the list of which is quite extensive. In particular, when working with DG, a shipper should present: an IMO DG declaration; certificates of hazmat class signs at the time of loading, availability of spaces for receiving dangerous goods, watertightness of hatch covers, etc., certificate of loading of the container / vehicle, conformity of packaging, labeling, etc.
Accumulation, analysis and data processing of both positive and negative experience of DG transportation and accidents, the emergence of new technologies, packaging and the cargo itself, contribute to updating of the norms and rules. The basic requirements are formed by international organizations, and then these norms are adopted by national legislation.
In a whole new way
Let us focus on the recent significant changes in the rules and regulations governing the maritime transport of DG by the International Maritime Organization (IMO).
In accordance with the regulations, the authority of the country of port of loading is responsible, independently or by the recognized competent organization, to monitor the observance of security measures for the most dangerous goods transportation. For example, Resolution of IMO MSC 354 (92) imposed a requirement that the Competent Authority of POL should be responsible to control loading procedures for determining the transport characteristics of liquefiable bulk cargo. In Russia, such a competent authority is the Ministry of Transport, and the organization responsible for implementing this requirement is determined by the FAA "Russian Maritime Register of Shipping".
The Register has developed and implemented a system that allows seaport administrations to electronically monitor the implementation of all necessary procedures for determining the transport characteristics of bulk cargo. This system applies to all goods that may exhibit a liquefaction and controls the safety of the carriage of bulk cargo by sea for all consignors, regardless of the port of loading. There are no analogues of this system in the world.
There are still some minor differences as of now between IMO requirements and Russian legislation. So far, many bulk cargoes have not yet come under the control of the authority.. They are not liquid but pose other risks during sea transport (grain, fertilizers, sulfur), and some cargo (DRI, etc.) according to IMO standards should have a certificate on performed security measures issued on behalf of the competent authority.
IMDG Code compliant packages
The International Maritime Dangerous Goods Code (IMDG Code) establishes requirements for packaging dangerous goods. In accordance with the IMDG Code, the Russian Transport Ministry is a competent authority that confirms compliance of the packaging with the IMO requirements. The Ministry of Transport of the Russian Federation charged its subordinate organization the Russian Maritime Register of Shipping (RS) with confirming the compliance of the packaging with the IMDG Code requirements.
In line with its responsibilities RS has posted guidelines on the society official website, which indicates a standard procedure of packaging compliance confirmation. The registry of certified packages is also in the public domain on the RS website. Unfortunately, there is no free access to the database on RS-certified containers and tank containers, which makes it difficult to select containers by bona fide consignors and does not allow verification of the authenticity of the survey documents.
RS also conducts all mandatory procedures and tests prescribed by international codes, including certification of container manufacturers. According to the RS clients, only the container manufacturing company is to undergo inspection and certification, which ensures the product quality and the manufacturer responsibility. This helps block access of fly-by-night firms without the necessary experience and resources offering low quality products to the DG packaging market, which significantly reduces the risk of emergencies while transporting dangerous goods by sea.
Cargo to be tested for safety
An important aspect of ensuring the safe transportation technology is the methods framework for testing cargo samples and classification. The cargo packing types group and its maximum allowable quantity for transportation is handpicked following the sample test results and indicators determining the type and level of primary and additional risks.
However, the testing methods prescribed in Russian standards are far from perfect, complicated, difficult for metrological certification, and sometimes inconsistent with the UN Manual of Tests and Criteria.
In some cases, the tests characterize the cargo as low-risk, for example, the cargo tendency to spontaneous combustion and the intensity of gas escape when interacting with water, but in reality the cargo poses a significant threat to people and the transport.
For example, the metallized pellets and hot briquetted iron exported from Russia, according to the test results can hardly be classified in subclass 9.2 and are permitted to be transported as solid bulk cargo of IMO IMDG Code class. But quite often in sea transportation this cargo behaves as a substance of subclasses 4.2 (self-igniting) and 4.3 (which releases combustible gases when interacting with water), which is confirmed by repeated accidents of catching fires and leads to death of people, destruction of vehicles.
Such inconsistencies require the implementation of measures to harmonize the provisions of national and international regulatory documents that determine, for example, the fire safety of goods transportation across Russia and internationally, as the main component of transport security.
The study of accidents occurred while transporting dangerous goods of Class 4, of specific fire hazard properties of subclasses 4.2 and 4.3, it became evident that the methodology for determining their hazard indicators is rather complicated. This analysis, taking into account the volume of traffic, in turn, points to the need to develop national "Rules (fire safety) for the carriage of bulk cargoes liable to spontaneous combustion", specifying and supplementing the provisions of IMSBC Code, which contains 22 names of such goods.
The Ministry of Transport of the Russian Federation is currently working on updating and harmonization of the control system over safety measures compliance in the DG transportation. The focus on competence, transparency, electronic workflow and the use of both domestic and international positive experiences have been chosen correctly.
The experience of the Register with liquefiable goods and containers for dangerous goods can be taken as a basis for systematizing the safety requirements for water and overland transportation. Having harmonized this system with international requirements, having supplemented the experience of foreign colleagues, Russia can create one of the most advanced control systems over observance of necessary security measures for the transportation of all types of exhaust gases.
Given the surging exports from the country, it is necessary to update and harmonize the norms of national legislation in a shortest possible time and create transparent, competitive conditions for bona fide participants in the DG transportation market. At the same time, it is necessary to create such conditions to protect this activity from incompetent and / or unscrupulous individuals and entities. This is the only way to minimize the threat of emergency accidents and catastrophes with human casualties.
Contributed to IAA PortNews by V.A. Malovechko, PhD in Engineering, A. Sitov. PhD in Economics