How is the transport of dangerous goods different from the normal transport of goods? – part II

The last article concluded that the transport of dangerous goods is quite simple and a few topics describe it well, but the truth is different.

Transport of dangerous goods in today's reality can be divided into two groups:

  • strictly road transport (performed only on the territory of the Republic of Poland and cross-border transport)
  • transport in the intermodal chain (including beyond the border of the Republic of Poland).

While road transport only, based on the ADR agreement and Polish legal acts, is actually relatively clear and easy to plan and control, a change in the mode of transport, or even crossing one border (even in the "borderless" European Union), complicates the entire operation a lot. In this article, we will focus on this issue which from a theoretical point of view is much more interesting.

Transport of dangerous goods

At the beginning, a situation where dangerous goods are transported by one means of transport through various European countries, where the theoretically uniform ADR Agreement unifies regulations everywhere. The actual working conditions of any company are unfortunately different - each country has its own regulations that are in addition to, or sometimes even counter to the ADR Agreement, an example is France, where the custom of reducing the orange plate placed on the front bumper of bus type cars has been widely adopted, it should be added in accordance with the Agreement ADR , - is prohibited, and the police are very happy to remind unfamiliar drivers with big tickets. Another, also French, unusual requirement is the need to carry double-staffed materials and objects of ADR class 1.

There are many requirements of this type, almost every country introduces its own (through laws, regulations, decrees, etc.), and the biggest problem is getting to know them properly before starting the journey - it often takes a lot of time. For the sake of our clients, we have to devote our time and effort to know them.

The second option is to combine means of transport as part of the transport of one cargo, for example, transporting a container by car, which then gets to the port by train and then sails overseas by ship, or transporting a pallet of goods to the airport and handing it over to the airline. In this situation, in addition to the potential problems generated by local law on road transport, there are also overlapping sets of regulations for various modes of transport.

In addition to ADR Agreements ("road"), we also have the IMDG Code ("sea"), the RID Regulations ("rail"), the ICAO Technical Instructions ("aircraft") and ADN Agreements ("inland waters"). The basis of all these documents is the so-called orange book, i.e. basic regulations issued by the United Nations, "the farther into the forest, however, the more trees". The most common discrepancy within the intermodal chain is the change of goods status from "exempted" to "fully" dangerous with a change in the mode of transport. For example, empty, uncleaned packaging of hazardous materials in road transport is in most cases exempted from the regulations, while "at sea" they are treated as if they were still full and all regulations are required to be observed - without exceptions. Therefore, there may be a situation where the return of such packaging by sea requires full labeling of the container with signs compliant with IMDG, but for the time of delivery to the sea/intermodal terminal, the vehicle is "exempted" and does not have to meet the requirements of ADR.

Another situation may be the delivery of dangerous goods to the airport for shipment as air freight - in this case, on the one hand, you can come across typical aviation markings (e.g. Cargo Aircraft Only sticker), which is not present in road transport, on the other hand, the amount of TN possible to transportation "on the road" on the exemption from the regulations have no reference to air freight, i.e. very often an "ordinary" car can legally arrive for typically dangerous air freight and everything happens in accordance with the letter of the law.

Both, the first and the second situation, require special measures from those involved in transport, in particular from an operator who controls the supply chain. These steps include, for example: checking the goods in terms of all regulations that may be applicable, proper preparation of documentation (including special entries on transport documents) or the selection of appropriate means of transport to minimise the costs of operations. In practice, this means using all available exemptions from the application of the regulations.

In our company, we make sure that the entire operation is carried out, firstly, in accordance with the regulations, and secondly, in the most cost-effective option, so that both the Operations Department and the Customer's Accounting can sleep peacefully.