The last article ended with the conclusion that the transport of dangerous goods is quite simple, and a few of the issues mentioned above describe it well, but the truth is different.
The transport of dangerous goods in today’s reality can be divided into two groups:
- strict road transport (performed exclusively on the territory of the Poland and cross-border transport)
- transport in the intermodal chain (including crossing the Polish border).
While road transport based on an ADR agreement and acts of Polish law is in fact relatively easy to plan and control, a change in the mode of transport or even crossing one border (even in the „deprived” European Union) may complicate the whole operation. In this article we will focus on this, from the theoretical point of view, much more interesting issue.
Transport of dangerous goods
At the beginning, a situation where dangerous goods are transported by one means of transport through different European countries, where the ADR Agreement, which is theoretically uniform everywhere, unifies the regulations and is the same everywhere. The actual working conditions of any company are unfortunately different – each country has its own regulations constituting an addition to, or sometimes even a counterpoint to, the ADR Agreement, an example of which is France, where the custom of reducing the orange plate on the front bumper of bus cars, should be added in accordance with the ADR Agreement – is prohibited, and the police are very eager to remind unfamiliar drivers with the help of not small fines. Another, but also French, unusual requirement is the need to transport materials and objects of ADR class 1 in double manning.
There are many such requirements, almost every country implements its own (by way of laws, regulations, decrees, etc. ), and the biggest problem is to get to know them properly before starting the journey – it does not infrequently take a lot of time. For the sake of our customers’; time and willingness, we can’t spare it here.Transport of dangerous goods isn’t such a easy issue.
The second option is to combine means of transport for one cargo, for example the transport of a container by car, which then takes the train to the port and then sails across the ocean by ship, or to take a pallet of cargo to the airport and hand it over to the airline. In this situation, in addition to the potential problems generated by local road transport legislation, there are also overlapping sets of rules for the different modes of transport.
In addition to the ADR Agreement („Road”), we also have the IMDG Code („Sea”), RID Regulations („Rail”), ICAO Technical Instructions („Aircraft”) and the ADN Agreement (Inland Waterways”). The basis for all these documents is the so-called orange book, i. e. the basic regulations issued by the United Nations, „the further you go into the forest, the more trees, however”. The most common divergence within the intermodal chain is the change in the status of goods from „off” to „fully”; dangerous along with a change in the mode of transport. For example, empty, uncleaned hazardous material packaging in road transport is, in the vast majority of cases, exempt from the rules, while „at sea”; is treated as if it were still complete and all regulations are required to be complied with – without exception. Therefore, it may occur that the return of such packages by sea requires the container to be fully sealed with IMDG-compliant markings, but the vehicle is „off”; and does not have to meet the requirements of ADR for the time of delivery to the sea/intermodal terminal.
Another situation may be the delivery of dangerous goods to the airport for shipment as air freight – in this case, on the one hand, there is a typical air marking (e. g. a Cargo Aircraft Only sticker), which is not present in road transport, and on the other hand, the quantities of TN which can be transported „on the way”; in the exemption from the regulations have no reference to air freight, i. e. very often after a typically dangerous air freight a „normal” car can arrive legally and everything happens in accordance with the letter of the law.
In our company we make sure that the whole 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 Client’s Accounting can sleep peacefully.