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DANGEROUS goods IN 2023

 On February 16, 2023, we participated in the debate "Dangerous cargo - new rules in 2023." The following took part in the debate:

- Frederic Kowalski - Adecon
- Bartłomei Sporysz - Rohlig Suus
- Anna Pytel - Adecon
- Barłomiej Kowalczyowski - DGM Poland

The debate was organized by the Polish Road Transport Institute. The debate was led by Anna Majowicz - Operations Director.

Debt speakers


Markings of classes of dangerous goods, in accordance with the ADR agreement

Lithium-ion batteries must not be stored in the vicinity of flammable items. In addition, the transport of such cells should have the required test report. In the case of warehouses, the type of stored substances should be determined already at the stage of planning the type and size of facilities in order to adapt the necessary infrastructure to them. When is a warehouse classified as a plant with an increased risk of an industrial accident? What is cross-docking? Detailed guidelines and changes in the regulations on dangerous cargo were presented by experts during the ninth edition of the Workshop for Transport and Logistics Managers - "Dangerous cargo - new rules in 2023".

Contents

Cross-docking an opportunity for faster delivery of dangerous cargo

Cross-docking involves eliminating the storage process during the delivery of goods. The delivered goods are prepared immediately upon receipt at the warehouse in question and directed to further dispatch.

"In the case of cross-docking of dangerous goods, we only have 48 hours to hold such goods without the safeguards normally required. It is also important to remember that if a dangerous good is damaged, it must not be released on the road. It must then be accepted and properly secured, only then can it continue on its way"  warns Frederic Kowalski, Manager Battery Warehouse at Adecon.

"The problem is often a warehouse operating on a cross-docking basis. Packing a container is subject to the IMDG Code, there are segregation tables and 18 segregation groups. These must be observed and the goods must be loaded appropriately in the warehouse. The marking of the container is also the responsibility of the shipper. The packer, shipper and sender all have specific responsibilities" adds Bartek Kowalczykowski, CBTA project specialist at DGM Polska.

Air transport with stringent requirements

In air transport, the "IATA DGR" (International Air Transport Association - Dangerous Goods Regulations) specifies in detail how dangerous goods are to be transported, packaged and packed. The document describes everything down to the smallest detail. In addition, it is regulated by the Dangerous Goods Transport by Air Act.

"There are many restrictions on the transport of dangerous goods by air. Many more than for road transport, for example. Often, goods that are excluded from this category on the road are classified as hazardous in air transport. This is because it is not possible to act in the air in the event of a packaging defect or leak. Only after landing can some kind of neutralisation be undertaken. In general, all the required markings for air transport are accepted in road transport, but the opposite is not the case." points out Anna Pytel, air freight forwarder at Adecon.

According to the new law of 17.08.2022, all air freight forwarders must be trained.

"The Civil Aviation Authority has shifted the responsibility to freight forwarders (Dangerous Goods Declaration DGD). The CAA can issue special permits for the carriage of dangerous goods and has the ability to penalise shippers for unregistered dangerous goods. The shipper in this light is the individual and he will pay the penalty imposed by the authority"   Anna Pytel adds.

Dangerous goods - what does it mean ?

Dangerous goods are divided into 9 main classes according to the ADR agreement [more in the article: Special loads under special supervision]. For example, fireworks are included in class 1 and fertilisers in class 5. An interesting example is coconut pulp, which is in category 4 (materials prone to spontaneous combustion). Li-ion batteries are classified in category 9.

"Category 9 includes miscellaneous materials, defined as multiple hazards or hazards not defined in time. These include goods such as dry ice, fishmeal, polymer balls, but importantly also lithium-ion batteries" points out Bartek Kowalczykowski.

Hazardous goods in a secure warehouse

"A safety data sheet is needed when storing dangerous goods. When building a warehouse for such goods, you should know what and how much you will store. This is important for specific security. Different goods must be separated. Do not store lithium-ion batteries near flammable items. Explosion risk price must be carried out. For example, the largest quantity that will fit in the warehouse is related to the largest battery that is produced. Drain holes are necessary for chemicals. It's also about awareness of the fire hazard. Let them know how many and what types of dangerous goods we have so that they know how to prepare. It is even important to know what are the routes of transporting hazardous materials" enumerates Frederic Kowalski

High-risk industrial accident facility

"It is important to determine the fire risk and inform the fire brigade units. We must monitor warehouse conditions, fire protection and prevention issues, storage options, reactivity, environmental impact, transport information such as UN numbers, all exclusions data and types. Additionally, hazardous material quantities must be controlled. Maximum storage quantities are defined for each warehouse. After exceeding their critical amounts, the warehouse is classified as a high-risk industrial accident facility and is subject to additional, more stringent regulations," emphasized Bartek Kowalczykowski.

Lithium-ion batteries can be a hazard

"I know an example from France where lithium-ion batteries started to catch fire, and there was a tire depot nearby. It turned out that the protections were generally compliant with the requirements, but the communication failed. The fire brigade was not notified in time, and the battery fire was impossible to extinguish. We can take preventive measures. Firefighters' knowledge and informing neighboring warehouses are very crucial." added Frederic Kowalski.

Strategic goods with WSK (Internal control system) requirement

According to the definition of the Internal Control System (ICS): 
"it is a system for maintaining transaction security that does not supervise the quality of products delivered or services provided but is aimed at preventing transactions that violate the law in international trade of goods of strategic importance. Products of dual-use and armament are considered to be goods of strategic importance for state security, as well as for the maintenance of international peace and security," defined the Polish Center for Research and Certification.
The strategic articles include [detailed list in the Annex relating to Art. 3 of Regulation (EC) No 1334/2000]:
0) nuclear materials, installations and devices;
1) materials, chemicals, "micro-organisms" and "toxins";
2) material processing;
3) electronics;
4) computers;
5) telecommunications and "information security";
6) sensors and lasers;
7) navigation and avionics;
8) ship equipment;
9) cosmonautics, aeronautics, propulsion.
"For each category from 0-9, classifications of dual-use goods/strategic goods are applied. Weapons are subject to the Internal Control System and permits from the Ministry of Internal Affairs and Administration for police and military purposes. In the case of the Internal Control System, the legislator imposes an obligation to have separate storage zones. We must label individual shelves or paint them a different color than the rest of the warehouse. This applies to: defensive or offensive weapons, ammunition, explosives, and products covered by the Arms and Ammunition Act" , lists Bartłomiej Sporysz, Rohlig Suus.

Changes to ADR rules

New regulations on the transport of ADR goods came into force this year.

"The most important changes concern lithium-ion batteries. Facilitations have been introduced for the transport of toxic goods. Currently, their quantity estimation may be based on the quantity carrier. Another change concerns machinery and equipment containing dangerous goods, if the content exceeds the LQ level, they must be assigned a UN number. As a result of the amendment, the transitional period regarding dangerous goods representatives has expired. It should also be mentioned that hybrid vehicles are now allowed to transport tanks. This is in line with the increasing importance of hybrids and electric vehicles in ADR road transport. With the increasing lack of explosiveness, electric tractors will gradually carry tanks other than AT",  says Bartłomiej Sporysz.
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