Strict reg­u­la­tions to keep unwanted dan­ger at bay

The Dan­ger­ous Goods Reg­u­la­tion (DGR) en­ables the lo­gis­tics providers to pre­pare and doc­u­ment dan­ger­ous ship­ments. While DGR is con­sid­ered the most up-to-date and user-friendly ref­er­ence in the CARGOTALK in­dus­try, seek in­puts from in­dus­try ex­perts on the

Cargo Talk - - Opinion -

RG Pan­icker DDP Game Changer (West and South 2015) & Man­ag­ing Di­rec­tor, DGM In­dia

The LSP is def­i­nitely not re­spon­si­ble for do­ing the clas­si­fi­ca­tion and iden­ti­fi­ca­tion of the dan­ger­ous goods sub­stance on be­half of the ship­per be­cause he is nei­ther qual­i­fied nor trained to do so, nor is he the man­u­fac­turer who knows what the com­po­si­tion of the sub­stance is. The re­spon­si­bil­ity for clas­si­fi­ca­tion of such sub­stances lies with the ship­per. Un­for­tu­nately, there are no such cer­ti­fied labs in the coun­try that can carry out such a test.

The sec­ond is­sue is the prob­lem of pro­duc­ing and test­ing pack­ages for car­ry­ing dan­ger­ous goods in ac­cor­dance with the UN Model Reg­u­la­tion – test and cri­te­ria. We have only one in­sti­tute for test­ing pack­ages in ac­cor­dance with the pre­scribed code and ap­proved by DGCA and DG Ship­ping. The third bad prac­tice is that DGR doesn’t ap­ply when ship­ping by sea con­tain­ers. The reg­u­la­tion is only in re­la­tion to plac­ard­ing of con­tain­ers if there are dan­ger­ous goods in­side. Even for sea cargo, when shipped in con­tainer un­less in bulk and loose con­di­tion, the dan­ger­ous goods must be packed in UN spec­i­fi­ca­tion and tested, pack­aged, marked and la­belled in ac­cor­dance with the reg­u­la­tion.

Such prac­tices ex­ist be­cause of lack of aware­ness and train­ing in the reg­u­la­tion and hardly any en­force­ment of the reg­u­la­tion by the author­ity. Many LSPs be­lieve the need for train­ing is only to get the DG Reg­u­la­tion train­ing cer­tifi­cate to get IATA or such body’s ac­cred­i­ta­tion as an agent.

Ab­hi­jeet Verma MD & CEO, Ab­hi­jeet Lo­gis­tics

The lo­gis­tics ser­vice provider must en­sure a proper stor­age of goods in the ware­house af­ter un­der­stand­ing the tech­ni­cal know-how from the con­signor. Rel­e­vant doc­u­ments like safety data sheet and test re­port must be kept at the place of stor­age and th­ese doc­u­ments must also ac­com­pany the con­sign­ment un­til it reaches its des­ti­na­tion. The ware­house must be equipped with ap­pli­ances in case of any mishap. How­ever, ap­pro­pri­ate knowl­edge of han­dling dan­ger­ous goods is a must and the staff han­dling th­ese goods must un­dergo proper IATA and IMDG train­ing schools. The lo­gis­tics ser­vice provider must ap­point at least two qual­i­fied staff at the place of stor­age of goods. With re­spect to pack­ag­ing, IATA and IMDG Reg­u­la­tions pro­vide pack­ing in­struc­tions for all dan­ger­ous goods ac­cept­able for car­riage with a wide range of op­tions for in­ner, outer and sin­gle pack­ag­ing. The reg­u­la­tions limit the quan­tity of dan­ger­ous goods per­mit­ted within the pack­ag­ing so as to min­imise the risk. Se­condly, suit­able han­dling should be done to avoid an in­ci­dent oc­cur­ring at any point dur­ing car­riage.

In spite of be­ing eth­i­cal and fol­low­ing ev­ery rule and reg­u­la­tion of dan­ger­ous goods han­dling, stor­age and trans­porta­tion, an LSP can­not guar­an­tee safe trans­porta­tion be­cause ul­ti­mately, one has to rely upon the doc­u­ments and in­for­ma­tion about the prod­ucts by the con­signor.

Lastly, to make trans­porta­tion of dan­ger­ous goods smoother, safer and en­vi­ron­ment friendly, the bad prac­tices fol­lowed must be avoided at any cost. In this re­gard, the car­ri­ers/agents must fo­cus on the bad prac­tices be­ing fol­lowed at pe­ri­odic in­ter­vals and take cor­rec­tive mea­sures. The car­ri­ers/agents need to un­der­stand the prob­lems of the ex­porters of dan­ger­ous goods be it, pric­ing, re­stric­tions, etc., and scale it to the rel­e­vant au­thor­i­ties so that proper ac­tion can be taken, which is good and in favour of all in­volved in the chain.

Vi­pan Jain Chief Op­er­at­ing Of­fi­cer Delhi Cargo Ser­vice Cen­ter

DGR can only be harm­ful when not han­dled prop­erly. Based on the na­ture of cargo and listed com­mod­ity, there is a guide­line for min­i­mum trained staff to han­dle it. It is quite sim­i­lar to driv­ing; you are al­lowed to drive any ve­hi­cle sub­ject to a valid driv­ing li­cence with a re­newal clause as well. There are spec­i­fied train­ings for each one in sup­ply chain from pack­ers, ship­pers, for­warders, ac­cep­tance, load­ing/un­load­ing, stor­age to screen­ing staff etc., and if we all fol­low the de­fined rules, there is hardly any pos­si­bil­ity to make a mis­take.

One of the main chal­lenges are that all the par­tic­i­pants in the sup­ply chain are not fully aware about the prod­uct and its han­dling which leads to er­rors. The aware­ness cam­paigns and even train­ings are not able to re­strict bad prac­tices due to lack of prod­uct knowl­edge. Some­times, the com­bi­na­tion of two dif­fer­ent ma­te­rial can be turned out as dan­ger­ous. A strin­gent reg­u­la­tion has to be in place for any mis­dec­la­ra­tion or ig­no­rance as it is not just fi­nan­cial ir­reg­u­lar­ity, but can be very harm­ful for hu­man lives.

Orig­i­nal pack­ag­ing from cer­ti­fied or ap­proved man­u­fac­turer is very im­por­tant es­pe­cially for air­freight. The abil­ity of pack­ag­ing to con­tain dan­ger­ous goods dur­ing tran­sit is ob­vi­ously crit­i­cal to the safety of the trans­port. Only pack­ages that are cer­ti­fied to have passed UN pack­ag­ing standards tests should be used for dan­ger­ous goods. Though it is not just about hav­ing a 'UN spec­i­fi­ca­tion box' so that the dan­ger­ous goods can be shipped. One can­not sim­ply or­der a 12” x 12” x 10” UN Spec­i­fi­ca­tion fi­bre­board box and drop what you have in­side for trans­port. Dan­ger­ous goods must be pack­aged in per­for­mance ori­ented pack­ag­ing sys­tems spe­cific to the haz­ards pre­sented by the ma­te­rial.

UN cer­ti­fied pack­ag­ing sys­tems must be used the way they were de­signed and tested. Oth­er­wise the cer­ti­fi­ca­tion is no longer valid. It then be­comes noth­ing more than a 'UN spec­i­fi­ca­tion box' – not safe for trans­port and out of com­pli­ance with the reg­u­la­tions. Piyush Ku­mar Singh CEO, In­dus B2B So­lu­tion Some rules that the ship­pers must fol­low to over­come bad prac­tices are –

Pack­ag­ing: While pack­ag­ing dan­ger­ous cargo, ship­pers must en­sure that they fol­low the guide­lines laid down for pack­ag­ing of the spe­cific sub­stance, the ma­te­rial is of good qual­ity, the weight or vol­ume of the pack­age is in ac­cor­dance with the guide­lines (should not be over packed), and that there is no leak­age or open­ings in the pack­ag­ing.

Mark­ing and La­belling: All dan­ger­ous or haz­ardous cargo must be la­belled with the cor­rect de­scrip­tion of the cargo, the clas­si­fi­ca­tion and the listed UN num­ber.

Doc­u­men­ta­tion: Along with pro­vid­ing the in­for­ma­tion of the cargo on all reg­u­lar doc­u­ments of trans­porta­tion, there is a sep­a­rate form called Dan­ger­ous Goods dec­la­ra­tion' or 'Haz Cargo dec­la­ra­tion', that needs to be filled when ship­ping haz­ardous cargo. Ship­pers must fill in this form ac­cu­rately with all re­quired in­for­ma­tion. Sushant Sarin Ex­ec­u­tive Vice Pres­i­dent, Com­mer­cial Line TATA AIG Gen­eral In­sur­ance

With re­spect to road trans­porta­tion, many bad prac­tices are be­ing fol­lowed. First of all, with ref­er­ence to UN class la­bel in­stead of cor­rect fire sym­bol in red, a flower or some vague pic­ture is painted. The in­for­ma­tion given in the EIP does not match with the chem­i­cal be­ing trans­ported. Se­condly, driv­ers keep many TREM cards be­long­ings to chem­i­cals trans­ported ear­lier, in the ve­hi­cle cabin. This, spe­cially leads to con­fu­sion when the driver/cleaner runs away af­ter an ac­ci­dent and emer­gency ac­tion is to be taken.

In In­dia, it is manda­tory for the ve­hi­cles trans­port­ing haz­ardous chem­i­cals to dis­play Emer­gency In­for­ma­tion Panel (EIP) with de­tails and at places as spe­cific un­der Rule 134 of the Cen­tral Mo­tor Ve­hi­cles Rules, 1989. Man­u­fac­tur­ers fol­low strict pro­duc­tion and pack­ag­ing standards but the real threat lies dur­ing trans­porta­tion. Se­lec­tion and use of re­spon­si­ble trans­porters is the first step. Load­ing, stor­age and se­cur­ing of such car­goes is of ut­most im­por­tance dur­ing tran­sit. Se­lec­tion of cor­rect pack­ag­ing and trans­porta­tion medium, strict fol­low-up of haz­ards as­so­ci­ated with the re­spec­tive cargo, cre­at­ing trans­par­ent pa­per trail dur­ing tran­sit and en­sur­ing that cargo re­mains on car­ry­ing ve­hi­cles for min­i­mum pos­si­ble times there by re­duc­ing any ex­ter­nal ac­ci­den­tal pos­si­bil­i­ties and other trans­porta­tion threats.

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