C&G Safety & Environmental Limited

We offer a full range of services to the transport sector, from training staff on all types of LGV licences through to ADR and Dangerous Goods Safety Advisor services.  We understand transport and have many years of experience helping all sizes of business - call us on 01453 800100 to speak to a highly experienced safety consultant.

Dangerous Goods Safety Advisor

Our team of experienced consultants are here to assist you in the following areas:

1. Overview of current legislation by an experienced DGSA consultant
2. The full support of an experienced DGSA Consultancy
3. Safety audit, combined with written or formal presentation summarising current legislation
4. Appointment as DGSA for your company to meet the legal obligations of Dangerous Goods Safety Adviser requirements of the Carriage Regulations (Carriage of Dangerous Goods 2009) and ADR. Reports and legislation updates.
5. Classification, packaging, labelling and documentation (transport document, Tremcard) and training requirements to meet the requirements of The Carriage Regulations CDG 2009, ADR, IMDG etc.
6. Classification, labelling and Safety Data Sheets to comply with CHIP3 and eventually with REACH. Overseas inventory registration, EINECS, TSCA. CAS numbers etc.
7. Handling and storage and waste disposal to meet COSHH and Hazardous Waste regulations
8. Training programmes in Supply (CHIP3 and REACH) and Transport legislation (CDG 2009, ADR, IMDG) and preparation of Work instructions
9. A dedicated DGSA consultant who knows your business

If you need a DGSA consultancy quote please contact us on 01453 800100.

Who needs a DGSA consultancy?

Many industries use chemicals which fall into the 9 UN classes classified as hazardous by the transportation rules.  Both the products and waste they produce may be classified as dangerous goods for transport, if for instance they contain sufficient levels of low flash point solvents, corrosive ingredients, or ingredients that are environmentally hazardous.

If your employees are involved in loading or transporting any dangerous goods in quantities above certain thresholds (package size or load size) you will need to appoint a DGSA consultancy.  We can help you.

DGSA regulations were introduced in 1999 and replaced by The Carriage Regulations 2004; they are now covered by CDG 2009. The regulations currently exclude consignee companies whose only involvement with dangerous goods is that their employees unload them, but consignees who import dangerous goods are considered as consignors if they are the owners of the goods in transit from the docks or airport, and the DGSA regulations would apply.

Duties of your Dangerous Goods Safety Adviser who must hold a vocational training certificate:

• Advise on health, safety and environmental matters in connection with the transport of dangerous goods
• Monitor compliance with the legal requirements governing the safe transport of dangerous goods and maintain procedures in line with regulatory changes
• Prepare accident reports and an annual report for management

If you would benefit from the support of a highly experienced DGSA consultant quote please contact us on 01453 800100.

What are Dangerous Goods?

Goods dangerous for transport are grouped into nine main United Nations hazard classes according to their properties. Some of these classes are further sub-grouped into nine divisions:

• Class 1    Explosive
• Class 2    Gases
• Class 3    Flammable liquids
• Class 4    Other flammables
• Class 5    Oxidising and organic peroxides
• Class 6    Toxic and infectious
• Class 7    Radioactive
• Class 8    Corrosive
• Class 9    Miscellaneous

International Agreements - The UN recommendations

Transportation legislation follows in principle, but not always in detail, the UN Recommendations and Model Regulations (the Orange Book) whose principle of identifying each hazardous substance with a UN Number and specifying for each their principal and subsidiary hazard classes and packing groups has been adopted by all modes of transport, road, rail, air, sea and inland waterways. Although great efforts have been made to harmonize these various modal regulations, there still remain difference between them. The Orange Book contains recommendations for the transport regulators to take into account when framing their regulations, but do not in themselves have any force of law.

The nine classes (some of which are sub-divided into divisions, eg. 6.1 toxic substances) reflect the chief danger each substance presents; there may also be 'subsidiary risks'. Each class or division has a diamond-shaped label with a pictorial representation of the danger. The level of danger is indicated by the Packing Group - PGI is high danger, PGII medium danger and PGIII low danger. The packing groups form the basis of the allocation of Transport Categories (0 – 4 where Transport categories 1, 2 and 3 correspond in general with the UN packing group but note that this is not a universal rule).

Dangerous goods within the UN classes 1 – 9 are mostly chemicals, either individually named substances eg. 'Tetrachloroethylene', or generic descriptions eg. 'Flammable liquid N.O.S.' (Not Otherwise Specified) but also articles eg. 'Matches, safety'. The criteria for classification in the various UN classes are largely harmonised between the transport modes, for example flammable liquids, class 3 are defined (with some exceptions) as those having a flash point not exceeding 60°C and the initial boiling point will determine the appropriate packing group (and hence the Transport Category). These criteria allow the correct classification of goods which are not individually named. There are procedures for correctly classifying materials possessing multiple hazards.

If you need a DGSA consultant quote please contact us on 01453 800100.

UK Transport Legislation – The Carriage Regulations

ADR - Carriage of Dangerous Goods by Road

The British transport regulations (The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009) refer to ADR for classification criteria. Dangerous goods are defined as those which are listed in ADR either as individually named substances or N.O.S entries. All dangerous substances are assigned a UN Number and ADR carries two lists, one ordered by UN Numbers and the other alphabetically. Confusingly, the lists can use different chemical names from the Approved Supply List used by the CHIP regulations. Environmentally Hazardous Substances are not named individually in the indexes but are classified as UN 3082 (Environmentally hazardous substance, liquid, N.O.S.) or UN 3077 (Environmentally hazardous substance, solid, N.O.S.).

Carriage of goods by international journeys by road are carried out under ADR (currently the 2007 edition.

Which rules apply ?

The GB packaging and labelling requirements of The Carriage Regulations 2009 are suspended for international road journeys under ADR and for carriage by road to a port for onward shipment by sea or to an airport for onward shipment by air when the IMDG Code or ICAO Technical Instructions apply respectively. Note that the consignee may carry the responsibilities of a consignor for imported goods where the supplier has no place of business in Great Britain and the consignee has control over the carriage of the goods in Great Britain.

Duties of Consignors and Transport Operators

Duties imposed by the transport regulations can be summarised as follows:

1. Consignor duties: classification, identification, packaging selection, warning marks and labels, preparation of a transport document for the transport operator.
2. Transport Operator duties: selection of vehicle and safety equipment, placarding vehicle, loading/unloading/stowage procedures, emergency instructions, parking and supervision, driver training.

If you need a DGSA consultant quote please contact us on 01453 800100.

Consignor duties

Selection of packagings and labelling - UN specification packaging must be used for dangerous goods which are to be transported but there is an exemption for limited quantity receptacles in combination packages. Marking and labelling of packages is required for packages containing receptacles above this threshold capacity above which the packages must be marked with the UN Number plus the class (primary) danger sign and subsidiary hazard sign if applicable; the signs are 100mm diamond shaped labels conforming to the designs given in the regulations.

Documentation – the consignor must supply a transport document to the operator giving the following information:

• UN number
• Proper Shipping Name (PSN)
• Hazard Class
• Packing Group
• Control temperature and emergency temperature, where appropriate
• The mass/volume of each package and number of packages or in the case of tank/bulk movements, the net mass/volume
• Name and address of Consignor
• Name and address of Consignee
• Consignor's declaration

If you need DGSA consultancy quote please contact us on 01453 800100.

Transport Operator duties

The operator must ensure that the vehicle is suitable for the load and carries the mandated safety equipment and that the driver has a copy of the transport document for each consignment carried and a total load summary plus emergency instructions in writing and the vehicle placarded (orange rectangle for packaged goods).From January 2007 the driver must hold and carry a Driver Vocational Training Certificate whatever the vehicle capacity. There are relaxations from the regulations when goods are packed in receptacles below the Limited Quantity limits and also when the load is less than Exempted Load limits.

Enforcement

Enforcement of legislation on the transport of dangerous goods by road within the UK falls to DfT.

The Department for Transport publishes an explanatory booklet “Working with ADR” (Publication reference 04DFT01) which is available as a download on the DfT website.

Carriage by sea - IMDG code

The 2006 edition of IMDG came into first use on the 1st January 2007 with a 12 month transition period. In UK law, IMDG is mandatory (The Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997).

Some significant difference from the UN recommendations are as follows:

Dangerous Goods List - IMDG adds some additional special provisions to the UN recommendations.

IMDG retains special rules for classifying environmentally hazardous mixtures; it classifies substances into two levels of aquatic pollution hazard and applies different concentration criteria for mixtures, 10% for marine pollutants (P) and 1% for severe marine pollutants (PP).

Special requirements for shipping documentation:

• Subsidiary hazards should be indicated in the Proper Shipping Name
• The number and kind of packages should be shown
• In the case of flammable substances, the flash point should be indicated.
• The words “Marine Pollutant” if applicable with the name of the constituent in the proper shipping name.
• Special requirements for package marking:
• The Proper Shipping Name shall be marked on the package.

If you need DGSA consultancy quote please contact us on 01453 800100.