Transport of dangerous goods abroad
1. Introduction
This Policy Statement sets out the means by which departments can ensure they comply with the regulations that apply when transporting dangerous goods abroad. A summary is provided in Appendix 1. "Transporting" is used in the general sense and should be interpreted as including the sending or taking of dangerous goods by any means. Similarly "abroad" should be read as anywhere other than on mainland Britain (so abroad includes all the offshore islands, such as Northern Ireland, Channel Islands, Isle of Wight, Hebrides, etc). Not included within the scope of this Policy Statement are the stringent requirements that apply to the transport of dangerous goods within the UK. Departments are, however, reminded of the need to comply with the relevant legislation when undertaking such consignments.
The transport of dangerous goods abroad usually involves several modes of transport and can cross several international borders. As a result it is necessary to ensure compliance with a number of regulations determined by both mode of transport and geographical location. Whilst the various national and international regulations are very similar, and in some provisions identical, there are some important differences which take account of the risks associated with the different modes. Additional requirements and restrictions are also imposed by certain countries, or certain carriers.
The number of regulations around the world that relate to the transport of dangerous goods are such that it is not feasible here to even list them let alone describe their requirements. The situation is further complicated by the regular updating and changing of the regulations in this area. Because of this, and taking account of other factors included within this Policy Statement, departments are required to either employ a courier company specialising in the transport of dangerous goods or arrange for the necessary training of staff. The first of these two options is likely to be preferential given the training requirements as described below.
In order for dangerous goods to be transported safely the various persons involved in the transport chain must be properly trained and have a detailed understanding of the relevant regulations. At the starting point of the chain is the consignor and it is imperative that this person meets all his responsibilities in order to ensure others further down the chain are able to meet theirs.
The knowledge the consignor requires is substantial and includes the general requirements, applicability and limitations of the regulations; classification, packaging and labelling requirements and the ability to complete all necessary documentation. In some cases regulations require the consignor to have attended an approved training course and hold a certificate confirming successful completion of the associated test. Approval of such training courses and tests is given by the appropriate national authority (in the UK, for example, the national authority for air transport is the Civil Aviation Authority).
2. Definition and classification of dangerous goods
For transport purposes, dangerous goods are, in general, articles or substances that have hazardous properties and pose a risk to health, safety or the environment. The majority of such goods have been allocated a UN number and proper shipping name under an international convention and are listed in various reference documents. The goods listed meet the criteria of one or more of the nine UN hazard classes which relate to the type of hazard.
This Policy Statement covers the transport of all classes of dangerous goods abroad and therefore includes:
hazardous chemicals (solids, gases and liquids)
infectious substances (including various biological materials)
radioactive materials
explosives
other miscellaneous dangerous goods
Further information on classification of dangerous goods is given in Table 1. If departments are unsure whether or not particular goods are regarded as dangerous goods for transport they should seek advice from the Safety Office.
In the case of transport of radioactive materials please consult the University Radiation Protection Officer well in advance of the date of any consignment.
3. Responsibilities of the University and individual staff
Under the various regulations the definition and responsibilities of the "consignor" and/or "shipper" differ. Individuals should be aware that by signing consignment notes, shipper's declaration forms and other similar documents they, as individuals, take on certain duties and responsibilities under the regulations. Under certain regulations it is the signatory as a named individual, not the University, who is the "consignor" or "shipper", the individual is not able to sign "on behalf of" the University.
In implementing this policy the University is taking those steps it considers necessary to ensure, as far as is reasonably practicable, that individuals are aware of those responsibilities and that the University, as the employer and body corporate, meets the various regulatory requirements. Individuals should note that in the event of their disregarding this policy they may be liable to criminal and civil proceedings and the University's insurers may attempt to recover from them any losses and costs associated with their actions.
4. General requirements and prohibitions
Whenever dangerous goods are transported the following general rules and provisions should be noted (these are some of the main points taken from various regulations, it is not possible to include all the regulatory requirements here and the list should not be regarded as exhaustive):
(a) the goods must be classified, packaged and labelled in accordance with the applicable regulations;
(b) at all stages in the transport chain it must be clear that dangerous goods are involved (subject to some exceptions - see f below) and appropriate arrangements made for safe transport. This usually involves completion of documentation, as specified by the applicable regulations, declaring the nature of the goods, which must be given to certain persons in the chain. The clear labelling of the package with the required hazard labels (other than on excepted packages) ensures immediate identification - additional outer packaging must not be used to conceal the fact that dangerous goods are contained within;
(c) dangerous goods must not be carried by passengers on aircraft either as or in checked baggage, carry-on baggage or on their person. They must be in separate packages and carried in the hold;
(d) some dangerous goods are too dangerous to be carried on aircraft under any circumstances and are forbidden, whereas others may be carried on cargo aircraft but not passenger aircraft;
(e) certain regulations limit the amount of particular dangerous goods which can be carried in one package (known as quantity limits);
(f) certain regulations allow the transport of very small quantities of dangerous goods (known as excepted quantities) in such a manner that they may be excepted from the marking (hazard labels etc), loading and, in some cases, documentation requirements;
(g) the documentation for shipments of dangerous goods to, from, or within the United States of America by air requires a 24 hour emergency response telephone number, which must be monitored at all times by a person who is knowledgeable about dangerous goods and can provide the necessary technical emergency response information;
(h) it is a requirement of certain regulations (notably for the transport of dangerous goods by air) that the shipper/consignor is adequately trained and this is demonstrated by them having attended a recognised training course and passed the associated examination.
5. Departmental action
Departments must ensure that, when dangerous goods are transported abroad, all national and international regulations applicable to that particular consignment are complied with. In order to facilitate compliance the preferred method of transport is the use of a courier company specialising in the transport of dangerous goods. Details of such companies should be obtained from the Safety Office.
Alternatively departments may wish to nominate one or more individuals within the department to take responsibility for transport of dangerous goods and arrange for them to receive the necessary training. This option is only likely to be worthwhile if regular consignments are made since re-training and re-certification are required on a regular basis. Cost and benefits should be carefully considered, given that a courier company will probably be required to transport the goods even if departmental personnel undertake some of the associated duties. Departments are advised to consult the Safety Office if they are considering this approach and must not adopt such arrangements without the agreement of the Safety Office. Copies of training certificates must be forwarded to the Safety Office.
This Policy Statement has been written to encompass various regulations and as such a broad approach has been taken. Further alternatives may be available for regular transport abroad of certain types of dangerous goods by certain modes of transport. If the policy results in difficulties for particular consignments, departments should contact the Safety Office for further advice. It may be possible that in certain cases alternative provision can be arranged. However such arrangements must not be made without the agreement of the Safety Office.
Departments must ensure that all persons who may arrange for the transport of dangerous goods abroad, or who may attempt to carry such goods themselves, are aware of this Policy Statement.
THIS STATEMENT FORMS PART OF THE UNIVERSITY SAFETY POLICY. PLEASE AMEND THE INDEX.
March 1999
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