ChemRegs Newsletter – April 2020
ADR 2021
Due to the current COVID-19 pandemic the UN ECE Working Party on the Transport of Dangerous Goods (WP15), which is the body that decides the amendments to the ADR Agreement, has postponed their May session until November.
The May session was due to review the amendments that had already been agreed in previous sessions for publication in the next edition of the ADR Agreement, ADR 2021. It was also due to consider and agree any new amendments.
It is understood that ADR 2021 will now only include the existing amendments, although these may be subject to further amendment or correction with the agreement of contracting parties and the RID Committee of Experts.
The consolidated list of all the amendments which have been adopted for entry into force on 1 January 2021 can be found in document ECE/TRANS/WP.15/249 on the UN ECE website.
This includes the amendment to special provision 274 when it applies to the technical names needed to supplement UN 3077 and UN 3082, environmentally hazardous substances. UN 3077 and UN 3082 are frequently used for a (relatively small) number of commodity products that appear elsewhere in the Dangerous Goods List e.g. paints, perfumery products etc. It was decided that for such products there is no requirement for a technical name as safety is adequately assured by the generic name identifying the product together with the relevant transport conditions. SP274 will now state:
274 For the purposes of documentation and package marking, the proper shipping name shall be supplemented with the technical name (see 3.1.2.8).
For UN 3077 and UN 3082 only, the technical name may be a name shown in capital letters in column 2 of the Dangerous Goods List, provided that this name does not include “N.O.S.” and that special provision 274 is not assigned. The name which most appropriately describes the substance or mixture shall be used, e.g.:
UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (PAINT)
UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (PERFUMERY PRODUCTS)
ADR 2021 will also have a new UN number for solid medical waste of category A:
UN 3549, MEDICAL WASTE, CATEGORY A, AFFECTING HUMANS, solid or MEDICAL WASTE, CATEGORY A, AFFECTING ANIMALS only, solid.
UN 3549 is not to be used for waste from bio-research or liquid waste but for solid medical waste containing Category A infectious substances generated from the medical treatment of humans or veterinary treatment of animals. It was introduced in a Multilateral Agreement (M317) in March 2019, after discussions following outbreaks such as Ebola, to allow new Category A waste packaging requirements that are practical and safe. This enables hospitals and epidemic-prone areas to respond quickly and safely by advocating the use of the readily available Chapter 6.1 and 6.6 packagings.
The bulk of Category A waste generated at medical facilities consists of disposable personal protective equipment (gloves, masks, face-shields, booties, aprons, coveralls and other pieces of clothing), absorbent materials of all kinds including mats, pads, gauze strips and pads, wipes and the like, bedding material such as bed sheets and liners, disposable towels and wipes, articles of clothing for patients, and medical articles such as swabs and finally the packaging material of most former items that is open in the contaminated zone.
Previously when a consignor has a large volume of such waste to transport they were required to obtain an authorisation from the Department for Transport to use large packages, such as wheeled bins, as these were not authorised for Category A substances in previous versions of ADR.
UN 3549 has 2 new packing instructions, P622 and LP622. These new packing instructions will require the use of a triple packaging system that meets the testing, marking and certification requirements found in Chapters 6.1 or 6.6.
Category A waste is not expected to be shipped in the regular commercial logistic chain. It is expected that the handling and transport of packages of Category A waste for disposal purposes only will be carried out in a dedicated transport unit by a knowledgeable firm that specializes in this type of transport, or by trained personnel under the supervision of the local public health authority.
There are many other amendments including those to electric storage systems (including lithium batteries installed in cargo transport units and defective batteries); waste gas cartridges; harmonisation with the 2018 Edition of IAEA’s Regulations for the Safe Transport of Radioactive Material and listing of dangerous goods.
ADR 2021 is due to be published later this year.
Other News
Derogation from ADR for the carriage of hand sanitisers
Luxembourg has initiated Multilateral Agreement M328 to exempt the distribution of alcoholic hand sanitiser gels and solutions from the provisions of ADR during the current COVID-19 pandemic.
This agreement allows that the collection of sanitisers, hydroalcoholic gels and solutions assigned to one of the following UN numbers:
- UN 1170, Ethanol or Ethanol in solution, Class 3, Packing Group II or III ;
- UN 1219, Isopropyl alcohol, Class 3, Packing Group II;
- UN 1987, Alcohol N.O.S., Class 3, Packing Group II or III;
- UN 1993, Flammable Liquid N.O.S., Class 3, Packing Group II or III;
as well as their delivery to dispensing chemists or other final consignees, may be exempted from any provision of ADR provided that specific conditions are met. These conditions include:
- The gels and solutions referred shall be packed in receptacles not exceeding 5 litres and transported in a total quantity not exceeding 240 litres per transport unit.
- No other dangerous goods within the meaning of ADR shall be loaded in the same transport unit.
- The receptacles or packaging’s used shall be suitable for the substances carried and shall be so selected as to prevent any leakage and to permit safe carriage. Guidance on the choice of receptacles can be found in Articles 4.1.1.1 and 4.1.1.2 of ADR.
- The vehicle carrying the gels and solutions shall be fitted with a fire extinguisher in accordance with the general safety requirements in force in their country of registration.
- A copy of the multilateral agreement, including its annex, shall be kept on board of any transport unit applying it, so that it may be presented upon request.
- Any incident or accident occurring during carriage covered by the multilateral agreement shall be reported within 24 hours, to the competent authority for the transport of Dangerous Goods by Road (ADR) of the respective country.
The agreement is valid until 31 August 2020 and has so far only been signed by Luxembourg, France and Belgium, meaning that it is not valid in the UK until the UK signs it.
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