The words you are searching are inside this book. To get more targeted content, please make full-text search by clicking here.

Dangerous Goods Integrated Learner Guide 2022

Discover the best professional documents and content resources in AnyFlip Document Base.
Search
Published by GMLS | Global Maritime Legal Solutions (Pty) Ltd, 2022-08-10 05:12:40

Dangerous Goods Integrated Learner Guide 2022

Dangerous Goods Integrated Learner Guide 2022

ADVANCED

Loading restrictions in passenger cabin or on flight deck - dangerous goods shall not be carried in an
aircraft cabin occupied by passengers or on the flight deck of an aircraft, except in circumstances
permitted by the provisions of the Technical Instructions.

Removal of contamination

Any hazardous contamination found on an aircraft as a result of leakage or damage to dangerous
goods shall be removed without delay.

An aircraft which has been contaminated by radioactive materials shall immediately be taken out of
service and not returned to service until the radiation level at any accessible surface and the non-
fixed contamination are not more than the values specified in the Technical Instructions.

Separation and segregation

Packages containing dangerous goods which might react dangerously one with another shall not be
stowed on an aircraft next to each other or in a position that would allow interaction between them
in the event of leakage.

Packages of toxic and infectious substances shall be stowed on an aircraft in accordance with the
provisions of the Technical Instructions.

Packages of radioactive materials shall be stowed on an aircraft so that they are separated from
persons, live animals, and undeveloped film, in accordance with the provisions in the Technical
Instructions.

When dangerous goods are loaded in an aircraft, the operator shall protect the dangerous goods
from being damaged and shall secure such goods in the aircraft in such a manner that will prevent
any movement in flight which would change the orientation of the packages. For packages containing
radioactive materials, the securing shall be adequate to ensure that the separation requirements of
8.7.3 are met at all times.

Except as otherwise provided in the Technical Instructions, packages of dangerous goods bearing the
“Cargo aircraft only” label shall be loaded in such a manner that a crew member or other authorized
person can see, handle and, where size and weight permit, separate such packages from other cargo
in flight.

On the following five pages are examples of IATA acceptance checklists for non-radioactive
shipments, radioactive shipments, and dry ice (carbon dioxide, solid).

__________________________________________________________________________________ 101

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

__________________________________________________________________________________ 102

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

__________________________________________________________________________________ 103

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

__________________________________________________________________________________ 104

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

__________________________________________________________________________________ 105

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

__________________________________________________________________________________ 106

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 4 - The Notification to Captain is described and completed according to international codes and
regulations
The commander/captain must be provided with written information about the dangerous goods
loaded on the aircraft.
For this purpose, the data from the Shipper’s Declaration for Dangerous Goods must be copied to
the document known as the NOTOC (Notification to Captain). The NOTOC is sometimes also referred
to as NOTAC - Notification to Aircraft Commander.
The format of a NOTOC may vary, in detail, from airline to airline but they basically cover the same
information. The purpose of the NOTOC is twofold. It is a legal document whereby the person
responsible for loading the aircraft certifies that the regulations have been complied with, and it
serves to inform the pilot in command of what has been loaded, and how and where.
The NOTOC must include:

• the proper shipping name, UN/ID number
• the class/division, subsidiary risks, packing group
• the number of packages and where the goods are located
• for radioactive materials: category and transport index
Producing the NOTAC/NOTOC by computerised means is acceptable, providing all the required
information is shown. Below is an example of a NOTOC.

__________________________________________________________________________________ 107

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 5 - Documentation to be retained is identified and described according to international codes and
regulations

Under the Dangerous Goods (Consignment by Air) (Safety) Regulations Chapter 384 Subsidiary
Legislation, the documents required are Air Waybill and dangerous goods transport document i.e.
Shipper's Declaration for Dangerous Goods unless otherwise specified in the Technical Instructions.

Dangerous Goods consignors i.e. shipper and freight forwarder must keep these documents for at
least 6 months. Chapter 11 of Annex 18 deals with ‘Compliance’ which covers document retention,
as follows:

11.1 Inspection systems Each Contracting State shall establish inspection, surveillance, and
enforcement procedures with a view to achieving compliance with its dangerous goods
regulations. Note - It is envisaged that these procedures would include provisions for the
inspection of both documents and cargo and operators’ practices as well as providing a
method for the investigation of alleged violations (see 11.3).

11.2 Cooperation between States Recommendation - Each Contracting State should participate
in cooperative efforts with other States concerning violations of dangerous goods
regulations, with the aim of eliminating such violations.

Cooperative efforts could include coordination of investigations and enforcement actions;
exchanging information on a regulated party’s compliance history; joint inspections and
other technical liaisons, exchange of technical staff, and joint meetings and conferences.
Appropriate information that could be exchanged include safety alerts, bulletins, or
dangerous goods advisories; proposed and completed regulatory actions; incident reports;
documentary and other evidence developed in the investigation of incidents; proposed
and final enforcement actions; and educational/ outreach materials suitable for public
dissemination.

11.3.1 Each Contracting State shall take such measures as it may deem appropriate to achieve
compliance with its dangerous goods regulations including the prescription of appropriate
penalties for violations.

11.3.2 Recommendation - Each Contracting State should take appropriate action to achieve
compliance with its dangerous goods regulations, including the prescription of appropriate
penalties for violations, when information about a violation is received from another
Contracting State, such as when a consignment of dangerous goods is found not to comply
with the requirements of the Technical Instructions on arrival in a Contracting State and
that State reports the matter to the State of Origin.

__________________________________________________________________________________ 108

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

In the IATA Dangerous Goods Regulations (IATA DGR), documentation and instructions on its
completion for each consignment of dangerous goods are contained in Section 8, and here a
retention period of 3 month is required. The recommended period for retention of documents is six
months minimum.

AC 6 - The documentation to be distributed is explained according to international codes and
regulations

For airfreight, the documents which must accompany the dangerous goods shipment are the air
waybill and the Shippers Declaration for Dangerous Goods. A material data safety sheet (MSDS) may
also accompany the shipment if required.

The Material Safety Data Sheets provides information on:

• Classification e.g. if the chemical is classified as a dangerous good, hazardous substance or
both

• Health effects

• First Aid

• Fire-fighting information

• Storage requirements

• Handling guidelines

• Spill management responses

Material Safety Data Sheets can be obtained from the manufacturer or supplier of the material and
must be current.

The original and the duplicate of the Shippers Declaration for Dangerous Goods must be attached to
the air waybill (stapled to the back of the air waybill). The shipper, operator (carrier/airline), the
captain, and the consignee will all require copies of their relevant documents.

Unless otherwise provided for in the ICAO Technical Instructions (TI), the person who offers
dangerous goods for transport by air must complete, sign, and provide to the operator a dangerous
goods transport document, which shall contain the information required by those Instructions.

The transport document must bear a declaration signed by the person who offers dangerous goods
for transport indicating that the dangerous goods are fully and accurately described by their proper
shipping names (PSN) and that they are classified, packed, marked, labelled, and in proper condition
for transport by air in accordance with the relevant regulations.

__________________________________________________________________________________ 109

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

In addition to the languages which may be required by the State of Origin and pending the
development and adoption of a more suitable form of expression for universal use, English should
be used for the dangerous goods transport document. Note: 'Shipper’s Declaration’ is an IATA term,
however some shippers may call this document 'Dangerous Goods Transport Document' according
to ICAO terminology.

Whichever term is used, the format must always comply with the IATA specification.

Two copies of the declaration must be completed and signed by the shipper. For exceptions regarding
who may sign the dangerous goods declaration refer to Section 8 - Documentation, of the IATA DGR.

The shipper may amend or alter the entries made on the declaration provided any amendments or
alterations are signed by the shipper. Entries in different handwriting or handwriting and typing are
not amendments or alterations.

The Dangerous Goods Acceptance Checklist is completed by the operator.

Consignments may be accepted for carriage if all the questions have been answered “Yes” or “Not
Applicable” as appropriate.

If on completion of the acceptance checklist any question has been answered “No” the consignment
will not be accepted for carriage. It will be returned to the shipper, agent or carrier who presented
it, together with a copy of the acceptance checklist annotated with the reasons for rejection. The
second copy of the checklist should be retained on file.

The original completed checklist is retained on the accepting station file with a copy of the air waybill.

Copies one and two are attached to the documents accompanying the consignment. Copy two is for
retention at the transhipment station, if applicable. Failure to attach the duplicate copies of the
checklist to the accompanying documents may result in delay at transit stations whilst a further
acceptance checklist is prepared.

ADDITIONAL READINGS

• www.icao.int/

• www.iata.org/

Practical workplace exercise

Refer to your workplace files and select an airfreight export or import file of an airfreight dangerous
goods shipment (if you cannot find one then you may use an example off the internet provided you
provided the resource/web address)

__________________________________________________________________________________ 110

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

1. With reference to the file you have selected make a note of all the details of shipment
including the commodity, Proper Shipping Name (PSN), UN number, class of DG, packing
group, packing instructions, packing specifications, weight/size, origin, destination, carrier,
and routing.

2. With reference to the file you have selected explain the importance of why the goods have
been classified as dangerous.

3. With reference to the file you have selected describe the various parties to whom the DG
regulations apply and their roles and responsibilities

4. What are limitations? With reference to the file you have selected identify any limitations
that apply.

5. What are state and operator variations?
6. With reference to the file you have selected make a note of the applicable relevant DG

documentation that applies to this shipment.
7. With reference to the file you have selected make a note of applicable marking and labelling

requirements
Please ensure that you correctly number and label all your practical workplace exercises
(formative assessments). This is over and above the summative and formative assessment and
needs to be uploaded to the LMS before you next class as part of your POE for TETA.

US 242991 – Facilitate the Forwarding and Clearing of Dangerous Goods for
Transportation

• Arranging and evaluating relevant documentation relating to the movement of dangerous goods
for transportation.

• Identifying and classifying dangerous goods.
• Facilitating the transportation of dangerous goods.
• Organising storage for dangerous goods.

__________________________________________________________________________________ 111

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

SO1 – ARRANGING AND EVALUATING RELEVANT DOCUMENTATION RELATING TO THE
MOVEMENT OF DANGEROUS GOODS FOR TRANSPORTATION

Introduction:

Throughout this unit standard there is frequent reference to the South African National Standards
and the South African Bureau of Standards.

Below is a short summary of the applicable standards and
the links to those standards. Each learner is required to
follow these links. You will note that the information is
based on the same international standards as prescribed by
the UN and therefore the other individual regulatory
authorities such as IATA and IMO.

The following SANS codes are applicable to Dangerous Goods:

SANS 10228: Identifies and classifies each of the listed dangerous goods and substances and set out
information including the United Nations Number, the correct shipping name, hazard class assigned
and other information pertinent to the substance.

https://archive.org/details/za.sans.10228.2012/page/n39/mode/2up

SANS 10229: Contains information on acceptable packaging for dangerous goods and substances and
include requirements for the testing of packaging and the correct marking and labelling of packages.

https://archive.org/details/za.sans.10229.1.2010

SANS 10231: This code of practice prescribed the operation rules and procedures for transporting
Dangerous Goods and Hazardous Materials. It also includes the prescribed responsibilities of the
owner/operator of the dangerous goods vehicle. It outlines the information required and who will
have to supply information for the safe conveyance of dangerous goods. The requirements for the
drafting and formulating of an operational agreement are also specified. This code also requires the
owner/operator or vehicle to be registered as dangerous goods carrier. It is also prescribed that the
owner-operator has available adequate insurance cover for civil liability as well as pollution and
environmental rehabilitation cover in the event of an incident.

https://archive.org/details/za.sans.10231.2010

__________________________________________________________________________________ 112

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

SANS 10232-1: 2007: This code includes details of new placarding requirements for vehicles
transporting dangerous goods and the individual or substance exempt quantities and the
compatibility requirements of mixed loads. Part 3 of this code contains information on the
Emergency Response Guides to be used in case of an incident or accident.

AC 1 – The difference between ordinary documentation and documentation relating to the movement
of dangerous goods are explained and described as it relates to South African National Standards and
South African Bureau of Standards code of practice
The general documentation needed for a shipment was covered in US 242986 under SO 4.
Below is a table as an additional reference and guide:

__________________________________________________________________________________ 113

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

Below is an example of the IMO DGD which is specifically for ocean freight and containerised cargo.

reference: https://www.uslegalforms.com/form-library/43439-hk-k-line-dangerous-goods-declaration

__________________________________________________________________________________ 114

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

International Consignment note is used for Rail and road consignments

Reference: https://www.uslegalforms.com/form-library/40163-se-international-consignment-note-internationell-fraktsedel-2004

__________________________________________________________________________________ 115

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

FIATA - The International Federation of Freight Forwarders Associations,
was founded in 1926 in Vienna, Austria and its headquarters are in
Geneva, Switzerland. This organisation is known as “The global voice of
freight forwarders” and has also been referred to as the “Architects of
Transport”.
This is an organisation that represents Freight Forwarders globally
regarding matters such as policies and regulations development in
implementation. FIATA engages with the World Trade Organisation (WTO), United Nations (UN) etc,
to promote trade facilitation and set standards for best practices in the FF community.
One of the many developments of FIATA has been to develop documents that can be used by the
various parties throughout the FF industry.
Please follow the below link for the brochure on all available FIATA documents:
https://fiata.org/fileadmin/user_upload/documents/Diverses/FIATA_Documents_and_Forms.pdf

AC 2 – The primary requirements of a transport document for dangerous goods are explained and
described as South African National Standards and South African Bureau of Standards codes of
practice.
The transport document has been discussed above. The purpose of this document is to provide a
record of the instruction on where and how to ship goods. This document typically travels with the
cargo in hard copy form; however, this is changing and often electronic versions are now acceptable.
The transport document may be negotiable or non-negotiable. With a negotiable BOL the ownership
of the goods is tied to the transport document and may be transferred to another party. The opposite
is applicable to a non-negotiable transport documents such as an air waybill, ownership is not
transferable.
The transport document is an important means of tracking a shipment. The following is a useful
website for tracking of air and sea shipments. https://www.track-trace.com/.
This document is also the contract of carriage and is therefore legally enforceable. The terms of the
contract of carriage are typically on the back of the document.

__________________________________________________________________________________ 116

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

Below is an extract from the MSC contract of carriage with regard to Dangerous goods:

Reference: https://www.msc.com/en/carrier-terms

This document is a proof of receipt that the carrier has received the goods and is also a proof of
delivery that the goods have been collected/drawn at final destination.

For all dangerous goods, the terms of acceptance for the carrier will have to be met. There are tools
to ensure that all regulatory compliances are met, such as the IATA checklist for the acceptance of
dangerous goods.

AC 3 – The duties of the consignee and consignor in the provision of relevant documentation are
explained and described as required by South African National Standard and South African Bureau of
Standards codes of practice

The duties of the various role players throughout the supply chain, with specific reference to the
shipper, has been explained in US 242986 (SO 1, AC 5,6,7). These role players and their duties remain
the same regardless of the mode of transport. Their primary obligation is to ensure that all regulatory
compliances are met with regards to the correct identification and necessary instructions in order to
move dangerous goods safely. The necessary documentation must be provided in accordance with
international standards.

__________________________________________________________________________________ 117

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 4 – The information required on the dangerous goods transport document is explained, described,
and applied as required by South African National Standard and South African Bureau of Standards
codes of practice
The Dangerous goods declaration as a supporting document to the transport document has been
discussed in US 242986 (SO 4, AC 1 & 2).

AC 5 – The information on the documentation is evaluated according to South African National
Standard and South African Bureau of Standards codes of practice as well as organisational polices
to ensure all relevant information is submitted.
The information on the documentation has been discussed in US 242986 (SO 4). The shipper, FF and
Carrier need to ensure that the information provides is correct. This is to avoid a dangerous goods
accident or incident as the result of false or inaccurate information.

SO2 – IDENTIFYING AND CLASSIFYING DANGEROUS GOODS

Please refer to US 242986, class 1, class 2 and the supplied presentations regarding Identification and
Classification.
AC 1 – The information on the Material Safety Data Sheet (MSDS) is evaluated and assessed according
to national legislation.
Although the MSDS (Material Safety Data Sheet) or SDS (Safety Data Sheet)
has been covered in US 242986 (SO 4, AC 6), it is important to understand
that this document has a standard format which has been provided for by
the ISO – International Organisation for Standardization. This organisation
plays a critical role in facilitating international trade by providing standards
that apply globally.
The ISO standard governing the layout of an MSDS is ISO 11014 – Safety data sheet for chemical
products – Contents and order of sections.
Below is an extract from the ISO website. Section 14 – Transport Information is the critical section
for the various role players to consult regarding the movement of dangerous goods. This section will
stipulate the UN number if applicable, as well as the packing group and packing instruction.

__________________________________________________________________________________ 118

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

https://www.iso.org/standard/44690.html
Here is an example of Section 14 from an MSDS for General Purpose Epoxy Resin:

From this example we can clearly see that the UN number is UN 3082, that this is falls under class 9,
packing group III. All this information is verified in the IATA Regulations as per the below extract.

__________________________________________________________________________________ 119

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 2 – The information on available documentation is assessed to establish identification and
classification of substances

Refer to US 242986 (SO 4)

AC 3 – Information supplied by consignee is verified according to relevant MSDS for Identification and
classification.

Refer to US 242986 (SO 4)

AC 4 – Suitable packaging is confirmed according to the classification as per relevant South African
National Standard and South African Bureau of Standards code of practice

Refer to US 242987 SO 2 and 3

SO3 – FACILITATING THE TRANSPORTATION OF DANGEROUS GOODS

AC 1 – Suitable transport is identified according to the relevant classification and documentation

As discussed in this US under SO 2, AC 1; the MSDS will highlight the relevant information regarding
the dangerous nature of the goods. This information will need to be cross checked against the
regulations applicable to the specific mode of transport, in order to see whether it will be allowed or
not, then the regulation will have to be followed to ensure that the goods are packed and marked
appropriately for that mode of transport.

AC 2 – The national legislation and regulations are explained and described as they pertain to the
transport of dangerous goods

Please refer to the introduction of this unit standard (US 242991) regarding the role that the SABS

has in the development in the South African National Standards and how they pertain to the

transport of dangerous goods.

__________________________________________________________________________________ 120

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 3 – General and specific transportation requirements are verified according to South African
National Standards and South African Bureau of Standards codes of practice

Please refer to the introduction of this unit standard (US 242991) regarding the role that the SABS
has in the development in the South African National Standards and how they pertain to the
transport of dangerous goods

SO4 – ORGANISING STORAGE FOR DANGEROUS GOODS

AC 1 – A suitable storage facility is selected according to the classification of dangerous goods.

The three main factors to consider with storage are: compatibility, mixed packing (i.e. packed in the
same receptacle) and mixed loading.

When determining a safe storage area, you should consult the SDS – Safety Data Sheet. If the product
is classified as dangerous then you should consult a dangerous goods compatibility chart which will
provide information on what dangerous goods can be packed together, and what products need to
be segregated.

A risk assessment should be carried out for each storage location or process (i.e. transport process)
for the movement of dangerous goods. This must take into account not only the actual dangerous
goods but also the nature of the other general cargo being stored or transported together with the
dangerous goods.

The risk assessment must address:

• identification of dangerous goods

• mode of transport

• site classification

• potential spillage or leakage

• fires and explosions

• incompatibility and segregation of goods

• machinery used in or around the storage area (e.g. welding equipment produces flame)

• the impact of an incident on the surrounding area (including adjacent buildings for example
where a petrol station may be located)

• the risks associated with occasional work such as repairs and maintenance

__________________________________________________________________________________ 121

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

• the security of the dangerous goods being stored or transported
• provision of safety equipment and personal protective equipment
Workplaces need to identify all dangerous goods and hazardous chemicals in the workplace and label
them and display placards in areas where they are stored or kept.
Workplaces must also ensure safe working practices are established to reduce the risk to employees
as far as possible and in consultation with employees.
When assessing the storage of dangerous goods from a Freight Forwarders perspective, much
thought needs to go into the warehouse location and design. The following a few considerations to
be taken:
• Within the warehouse, materials handling is an important activity. Products must be received,
moved, stored, sorted, and assembled to meet customer order requirements.
• Direct labour and capital investment contribute significantly to total supply chain cost
• May result in product damage and supply chain inefficiency if inappropriately operated and used
• Less handling = less damage!
The layout of the warehouse must also be conducive to the safe storage and handling of dangerous
goods.
Below is an example of a classic U-shaped warehouse. Dangerous goods would not be stored in areas
of high activity such as the staging and dynamic storage areas.
The safer option would be to utilise a section of the static (long term) storage to avoid accidents and
contamination.

__________________________________________________________________________________ 122

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

Further storage requirements and considerations are covered in US 242996 SO 2

AC 2 – Arrangements for booking of cargo and documentation are made by applicable
communication medium (range; phone, e-mail, fax) within the time limits, as is appliable to the
industry.

As per the following image there are many role players throughout the supply chain process.
Naturally as a link between each of these role players there is communication. Communication can
be conducted in many forms and is constantly evolving as a result of technological growth and
changing trends. For example; the means of Whatsapp as a popular means of communication in
business, was not applicable 5 years ago.

There must always be an element of common sense that must be applied regarding communication.
To this end all parties should ensure that any verbal communication be put in writing for safety
reasons. We are dealing with dangerous goods and there is no room for error resulting from
miscommunications and unclear instructions.

__________________________________________________________________________________ 123

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

As common solution between the freight forwarder and their clients is to ensure that there is an SLA
(Service Level Agreement) which is a contract detailing the level of service and each parties
expectations in their working relationship. This agreement is usually reviewed on an annual basis to
take into account any changes or developments that need to be documented.

Furthermore, an FF must use an SLI (Shippers Letter of Instruction) which would detail the exact
requirements for a particular shipment. This document is used to facilitate export transactions and
will guide the FF as to what goods need to move where etc.

For import transactions an FF would use a CI (Clearing Instruction) which would detail any specific
delivery instruction as well any information needed for the import customs clearance.

The primary concern is to ensure that all parties provide clear instructions, in writing, so that there
is no room for error or misunderstandings.

AC 3 – The correct packaging relating to the movement of dangerous goods is verified according to
the relevant classification and documentation

Packaging is covered in detail in US 242987 – SO 2 and 3

US 242997 – Identify and Classify Dangerous Goods for transportation

• Receiving a sample of potential substance.

• Facilitating the analysis and assessment of a sample based on United Nations criteria for
classification and identification.

• Facilitating the development of the Material Safety Data Sheet and transport documentation
relevant to the substance.

• Identifying and allocating packaging requirements according to substance if classified.

__________________________________________________________________________________ 124

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

The person credit with this unit standard is able to identify and classify dangerous goods for
transportation. They are able to analyse and assess a sample for classification and correct
identification in accordance with United Nations criteria. They are also able to complete the safety
data sheet and allocate correct packaging requirements in preparation for safe transportation.
A person credited with this unit standard is capable of:
• Receiving a sample of potential substance.
• Facilitating the analysis and assessment of a sample based on United Nations criteria for

classification and identification.
• Facilitating the development of the Material Safety Data Sheet (MATERIAL SAFETY DATA SHEET)

and transport documentation relevant to the substance.
• Identifying and allocating packaging requirements according to substance if classified.

SO1 RECEIVE SAMPLE OF POTENTIAL SUBSTANCE.

AC 1 – Samples are collected from generator/manufacturer according to standard operational
procedures.
For the purposes of this next section we will assume that samples will be sent via airfreight due to
the typically small nature of a sample.
There is a section in the IATA DGR specifically for samples, please see the following partial extract
from this section:

__________________________________________________________________________________ 125

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

One key consideration is training. The person needing to assign a tentative hazard class, PSN and UN
number must have at least some knowledge of dangerous goods.
A testing authority will make use of the UN Manual of Tests and Criteria to generate an SDS.
As per the UN website:
“The Manual of Tests and Criteria contains criteria, test methods and procedures to be used for
classification of dangerous goods according to the provisions of the "United Nations
Recommendations on the Transport of Dangerous Goods, Model Regulations", as well as of
chemicals presenting physical hazards according to the "Globally Harmonized System of Classification
and Labelling of Chemicals" (GHS). It gives descriptions of the test methods and procedures
considered to be the most useful for providing classifiers with the necessary information to arrive at
a proper classification. It also supplements national or international regulations which are derived
from the Model Regulations or the GHS. “

https://unece.org/about-manual-tests-and-criteria

__________________________________________________________________________________ 126

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

The Manual is divided into five parts as per the following from the UN website:
Part I: Relating to explosives;

Part II: Relating to self-reactive substances, organic peroxides, and polymerizing
substances;

Part III: Relating to aerosols, desensitized explosives (relating to transport only), flammable
liquids, flammable solids, pyrophoric liquids and solids, substances which in contact
with water emit flammable gases, oxidizing liquids and solids, chemically unstable
gases and gas mixtures, substances corrosive to metals, and substances and articles
of transport Class 9 (ammonium nitrate fertilizers, lithium metal and lithium ion
batteries) and solid ammonium nitrate based fertilizers;

Part IV: Test methods concerning transport equipment; and

Part V: Classification procedures, test methods and criteria relating to sectors other than
transport.

The sample will be sent for the appropriate testing in order to determine the chemical characteristics.
This information will be used to generate the MSDS/SDS.

AC 2 – The formulation for new product (recipe of sample) is obtained to facilitate the classification
of the substance according to criteria listed in South African National Standards code of practice.

Please refer to AC 1 and the UN manual of tests and criteria.

SO 2 – FACILITATE THE ANALYSIS AND ASSESSMENT OF A SAMPLE BASED ON UNITED
NATIONS CRITERIA FOR CLASSIFICATION AND IDENTIFICATION.

AC 1 – The analysis criteria are identified, described, and applied according to South African National
Standards code of practice.

Classification and Identification has been covered in US 242986 SO 3.

Each class of dangerous goods will have specific test criteria that must be covered in order to
determine if that substance or product falls into that class, and to what degree of danger it poses.

__________________________________________________________________________________ 127

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

This technical aspect of the tests is covered in the UN Manual of Tests and criteria. Below is a
summary of the test requirements for the various class and what the tests are measuring.

__________________________________________________________________________________ 128

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 2 – The test requirement contents are identified, explained, and described according to South
African National Standards code of practice.
Please refer to the table above for test requirements
AC 3 – The analysis of the sample is facilitated based on the classification criteria.
Please refer to SO 1 AC 1 regarding sample analysis

SPECIFIC OUTCOME 3 - FACILITATE THE DEVELOPMENT OF THE MATERIAL SAFETY
DATA SHEET (MSDS) AND TRANSPORT DOCUMENTATION RELEVANT TO THE
SUBSTANCE.

AC 1 – The requirements of OHS Act in the development of the Material Safety Data Sheet is explained
and described.

The South African Occupational Health and Safety Act number 85 of 1993 is to provide for the health
and safety of people at work. By taking another look at the definition of dangerous goods, we can
see that this directly relates to the OHS Act because of the possible risk to people.

Definition: Dangerous goods are substances or articles which when transported, handled, or stored,
pose a risk to health, safety, property, or the environment.

Here is a link to the OHS Act of 1993 for your perusal.

https://www.gov.za/sites/default/files/gcis_document/201409/act85of1993.pdf

Specifically relevant to this unit standard is the following link which refers to the latest version the
regulations from the OHS Act: Hazardous Chemical Agents 2021.

https://www.gov.za/sites/default/files/gcis_document/202103/44348rg11263gon280.pdf

__________________________________________________________________________________ 129

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

There is specific reference to the MSDS and also the UN Recommendations as discussed in earlier
unit standards. Both of these topics have been covered, and the OHS Act ensures that the national
legislation to ensure the safety or people in the workplace, meets International standards. The OHS
Act also covers measures to take should there be exposure to hazardous chemical agents, as well as
how to control such exposure. Personal Protective equipment is of primary consideration and any
employer should ensure that their staff have the correct training and PPE to ensure that all risk is
kept to a minimum.

PPE requirements will be determined based on the type of hazard that dangerous goods articles or
substances pos. Below are a few examples of such PPE:

- Eye and Face Protection; safety glasses, visors.

- Hand protection; gloves

- Body protection; aprons, hazmat suits, hard hats, safety shoes

- Respiratory protection; face masks, visors, respirators

- Hearing protection; ear plugs

AC 2 – All the relevant information on the Material Safety Data Sheet is verified according to the OHS
Act.

The OHS Act is in accordance with international regulations and the MSDS follows a format as
provided by the International Organization for Standardization as discussed in US 242991 SO 2

AC 3 – All relevant transportation documentation relevant to the substance is identified, explained,
described, and completed according to relevant codes of practice.

Refer to US 242991 – SO 4

SPECIFIC OUTCOME 4 - IDENTIFY AND ALLOCATE PACKAGING REQUIREMENTS
ACCORDING TO SUBSTANCE IF CLASSIFIED.

AC 1 - The packaging requirements relating to medical waste are identified, explained, and allocated
according to South African National Standards code of practice.

We can refer to the National Environmental Management: Waste Act, 2008 (Act No 59 of 2008)

__________________________________________________________________________________ 130

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

The following national standards are referenced in the ACT:
SANS 10248 – Management of Healthcare waste.
SANS 452 – Non-reusable and Reusable Sharps Containers.
Now sharps are the following waste articles as extracted from the Act:

The regulation of packaging for medical waste is critical to ensure that organisations control the
potential hazards from chemicals and also to prevent the spread of infectious diseases. These
organisations must have policies and procedures in place to ensure the safety of their workers and
the public.

All necessary staff must have the appropriate training for the safe handling of hazardous waste. This
will include knowing how to read and interpret the details on the MSDS (Material Safety Data Sheet)

Please see the below extract from the SANS 10248.

6 Identification, classification, segregation, collection, and minimization of healthcare waste

6.1 Identification

6.1.1 The management of healthcare risk waste shall start with the correct identification of the
waste, followed by classification, segregation, collection, and minimization. The generators of
waste shall be responsible for the identification and segregation of the waste.

6.1.2 Healthcare waste is grouped into healthcare risk waste and healthcare general waste and
categorized as follows:

a) healthcare risk waste categories: infectious waste, anatomical (pathological) waste,
sharps, chemical and pharmaceutical waste, heavy metals, pressurized containers, and
radioactive waste; and

__________________________________________________________________________________ 131

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

b) healthcare general waste categories: packaging material, kitchen waste (domestic waste),
office waste and building demolition waste, waste from patients (e.g. fruit juice bottles
and magazines), non-clinical glass, non-infectious non-anatomical waste (e.g. paper
tissues), disposable curtains, extracted teeth, nail clippings, hair and decontaminated
waste, and garden and park waste.

6.1.3 For traceability and treatment purposes the waste shall be identified in accordance with 6.1.2
and shall be correctly labelled.
Classification remains the same as identified earlier in this learner guide. Reference is made to the
international standards as set out by the UN. Therefore, the healthcare risk waste shall also be
classified in accordance with the hazards and risks involved.
Below is the flow chart from SANS 10248 regarding the appropriate healthcare risk waste flow.
It is important to take note of the various types and colours of waste containers/packaging,
depending on the identification of the waste.

__________________________________________________________________________________ 132

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

Source https://archive.org/details/za.sans.10248.1.2008/page/n57/mode/2up?view=theatre

Packaging specifications:
• The packaging must be clearly marked with an F
• A colour coding system is used for easy identification for the different categories.
• All international packaging and label requirements must be adhered to as discussed earlier in
the learner guide

__________________________________________________________________________________ 133

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 2 - The packaging methods are explained and described as it relates to the South African National
Standards codes of practice.

Please refer to US 242986 SO 3

__________________________________________________________________________________ 134

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

AC 3 - Certificate of package is received according to South African National Standards code of
practice.
There must be an appropriate paper trail to ensure compliance to all processes and procedures.
There must always be a documented handover at each point where the goods change hands. And
this handover must be scheduled in advance. The documentation required must include the
following information:

• Nature and quantity of the goods
• Signatures of the responsible officers
• Time and date
Below is a blank example of a collection note for waste material:

__________________________________________________________________________________ 135

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

US 242996 – Handle dangerous goods during warehousing and storage

• Identifying and classifying dangerous goods in accordance with documentation, packaging, and
labelling.

• Handling and storing classified goods and substances.
• Preparing the dangerous goods for transportation.
• Taking appropriate actions in the event of accidents in the handling of dangerous goods.

Introduction

The person credited with this unit standard is able to handle dangerous goods during warehousing
and storage. They are able to classify goods in preparation for storage and prepare these goods for
safe transportation. Learners are also able to handle incidents in the event of them happening in
accordance with required safety procedures and guidelines.

A person credited with this unit standard is capable of:

• Identifying and classifying dangerous goods in accordance with documentation, packaging,
and labelling.

• Handling and storing classified goods and substances.

• Preparing the dangerous goods for transportation.

• Taking appropriate actions in the event of accidents in the handling of dangerous goods.

SO1 IDENTIFY AND CLASSIFY DANGEROUS GOODS IN ACCORDANCE WITH
DOCUMENTATION, PACKAGING AND LABELLING

AC 1 – The type of dangerous goods is identified and determined in relation to labelling and
documentation

This has been covered in US 242986, however below is a summary.

The United Nations Economic and Social Council (ECOSOC) has a Sub-Committee of Experts on the
Transport of Dangerous Goods and on the Globally Harmonized System of Classification and
Labelling, responsible for the UN Model Regulations (published as the “Orange Book). They cover the
transport of dangerous goods by all modes of transport except by bulk tanker.

__________________________________________________________________________________ 136

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

These are neither obligatory nor legally binding on individual countries but have gained a wide degree
of international acceptance: they form the basis of several international agreements and many
national laws.

These address the classification of dangerous goods, their listing, packing requirements (including
standards for construction, testing, and approval of all kinds of packaging, containers, and tanks),
marking, labelling, loading, documentation, stowage, segregation, emergency response, training,
supervision, construction, and approval of means of transport.

The UN Recommendations do not cover the manufacture, the use of, or the disposal of dangerous
goods. Dangerous goods are identified by diamond shaped hazard warning labels. Dangerous goods
could be substances in solid form, liquid form or gas or they could be articles. They are often subject
to chemical regulations.

Dangerous goods include materials (substances and articles) that are toxic, poisonous, radioactive,
explosive, flammable, corrosive, oxidizing, asphyxiating, biohazardous (a biological agent or
condition that is a hazard to humans or the environment), pathogenic (means capable of causing
disease), or allergenic (induces allergies, such as pollen). Also included are physical conditions such
as compressed gases and liquids or hot materials, including all goods containing such materials or
chemicals, or may have other characteristics that render them hazardous in specific circumstances.

Dangerous Good may only be shipped with prior approval from an international or national sea
carrier, rail carrier, road carrier or air carrier and only prior to pre-booking a shipment. Such
shipments are also subject to possible surcharges on the freight. It is the shipper's responsibilities to
identify, to declare and to provide the necessary and correct shipping documents for shipping
dangerous goods. Any person or company involved in the movement of dangerous goods is
responsible for complying with the dangerous goods regulations.

Delays and freight costs due to improper identification, classification and/or incorrect or missing
documentation of dangerous goods will be the responsibility of the shipper. Shipments of dangerous
goods may require more transit time than regular shipments.

Dangerous goods are usually classified with reference to the immediate hazard they pose rather than
the long-term health effects.

Dangerous goods are grouped into nine classes, which may be subdivided into divisions and/or
packing groups.

The most common dangerous goods are assigned a UN number, a four-digit code which identifies it

internationally: less common substances are transported under generic codes such as "UN1993:

flammable liquid, not otherwise specified", or “UN1954: flammable compressed gas, N.O.S.” The

abbreviation N.O.S. is used to indicate “not otherwise specified.”

__________________________________________________________________________________ 137

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

The main international legal instruments, harmonized on the basis of the UN Model Regulations (the
“Orange Book”), are:

• The International Maritime Dangerous Goods (IMDG) Code published by the International
Maritime Organisation (IMO).

• The Technical Instructions for the Safe Transport of Dangerous Goods by Air published by the
International Civil Aviation Authority (ICAO). The Dangerous Goods Regulations published by
IATA are modelled on the ICAO technical instructions.

• The European Agreement concerning the International Carriage of Dangerous Goods by Road
(ADR) published by The United Nations Economic Commission for Europe (UNECE).

• the European Agreement concerning the International Carriage of Dangerous Goods by
Inland Waterways (ADN)

• The International Agreement for the Carriage of Dangerous Goods by Rail (RID) published by
The Inter-Governmental Organisation for International Carriage by Rail (OTIF).

• The Hazardous Materials Regulations (Title 49 CFR Parts 100-185) published by The Office of
Hazardous Materials Safety, US DOT.

Some classes have been sub-divided in order to adequately describe the nature of the properties of
the individual goods. There is a label for each class/division to convey the nature of the hazard. These
labels must appear on the outside of the package when it is offered for transport and must remain
on the package while it is in transit. You can also see such labels and warnings on most package types
such as aerosol cans, bottles of bleach, containers of thinners, tins of paint etc that you purchase in
the supermarket. Also look to see if a Hazard Class is written on the container – quite often it will
have something like “Class 5.1” or “Corrosive”.

Dangerous goods are divided into classes based on the specific chemical characteristics producing
the risk.

Mitigating (mitigate = allay, alleviate, ease, lighten, mollify) the risks associated with hazardous
materials may require the application of safety precautions during their transport, use, storage, and
disposal.

Please see US 242986 for details on the 9 classes of Dangerous Goods.

The hazard presented by each class is identified by an internationally accepted hazard warning label
(diamond shape label). This appears on the outer packaging of the dangerous goods when they are
being transported as a warning to all those working within the transport chain or coming into contact
with them.

__________________________________________________________________________________ 138

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

There may be instances when a hazardous material will have a primary hazard plus one (or more)
secondary hazards. For example, the primary hazard for methyl vinyl ketone (UN1251) is 6.1, it is
poisonous. However, it is also flammable and corrosive. In cases like this, there are definite rules
regarding how to label such a shipment, but we do not go further into such detail here and it is
sufficient that you simply are aware of such possibilities.

AC 2 – The dangerous goods are classified in accordance with South African National Standards codes
(10228) of practice and international codes

The SABS has been discussed in US 242991 (SO 1), however below is more information.

The South African Bureau of Standards (SABS) develops national standards for the transport industry
and co-ordinates South Africa’s input to the development of international standards by the
International Organization for Standardization (ISO) and other international standards bodies of
relevance to the South African transportation sector such as the UN ECE (United Nations Economic
Commission for Europe).

The SABS is a statutory body that was established in terms of the Standards Act, 1945 (Act No. 24 of
1945) and continues to operate in terms of the latest edition of the Standards Act, 2008 (Act No. 29
of 2008) as the national institution for the promotion and maintenance of standardization and quality
in connection with commodities and the rendering of services.

The SABS publish national standards which it prepares through a consensus process in technical
committees, provides information on national standards of all countries as well as international
standards. The SABS tests and certifies products and services to standards. The SABS develops
technical regulations (compulsory specifications) based on national standards, monitors and
enforces compliance with such technical regulations.

With a view to maximising its service delivery to the industries it serves, the SABS has aligned its
activities with seven different industry sectors, each housing the whole range of SABS services
pertinent to a particular industry. This change ensures easy access to products, faster reaction and
turn-around times, and the creation of centres of knowledge excellence that will be easily available
to clients.

The seven industry sectors are:

❖ Chemicals

❖ Electro technical

❖ Food and Health

__________________________________________________________________________________ 139

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

❖ Mechanical and Materials

❖ Mining and Minerals

❖ Services

❖ Transportation

The SABS Standards Division acts as a facilitator in the development and maintenance of South
African national standards and other normative documents, provides secretarial and technical
writing facilities and services for the committee responsible for these tasks and acts as a publishing
house.

The development of South African national standards and other normative documents is funded by
the State. The affairs of the SABS are controlled by the Board of the SABS, whose members are
appointed by the Minister of Trade and Industry. The Board determines the direction and objectives
of the SABS.

Amongst this vast array of services and products offered by the SABS, we are here only interested in
the Transportation sector and specifically the transport of dangerous goods and the role of the SABS,
and the following standards:

❖ SANS 10228 for definition of hazardous substances

❖ SANS 10229 for packaging requirements and

❖ SANS 10232 for road transport of dangerous goods

The main aims and benefits of standardization can be summarized as follows:

▪ to improve the quality (fitness for purpose) of goods and services;

▪ to maintain and improve the quality of life of society, by paying attention to such
matters as safety, health, and protection of the environment, and by providing a basis
for legislation needed for the protection of the public;

▪ to utilize resources more efficiently through better (i.e. standardized) communication;
through simplification of manufacturing, product identification and purchasing by
means of variety control; and through cost savings as a result of economies of scale,
reductions in wastage, etc.;

▪ to provide a framework within which to facilitate and encourage trade among willing
partners, contracts based on standards, to eliminate trade barriers, and to promote
service excellence and fair and efficient trade at all levels; and

__________________________________________________________________________________ 140

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

▪ to promote efforts to facilitate the correct application of standards through, for
example, training.

Standards are set so that confusion and danger on the roads can be minimised as all road users and
transport companies conform to the same standards.

Transportation of Dangerous Goods and Substances by Road is covered by The National Road Traffic
Act 93 of 1996, Chapter VIII of the Regulations: Transportation of Dangerous Goods and Substances
by Road.

SO2 - HANDLE AND STORE CLASSIFIED GOODS AND SUBSTANCES

AC 1 – Options and possibilities for the segregation/demarcation in the safe handling and storage of
dangerous goods are identified and described in accordance with laid down safety standards,
pollution, and environmental requirements

Many of the substances listed in Classes 1 to 9 are deemed, without additional labelling, as being
environmentally hazardous. The three main factors to consider with storage are compatibility,
mixed packing (i.e. packed in the same receptacle) and mixed loading.

Dangerous goods present a potential threat not only when they are isolated but also – and often
even more so – when they are near other dangerous goods. Dangerous goods could harm or damage
other general cargo and there is therefore a need to segregate certain dangerous goods and also
keep dangerous goods away from general cargo. Dangerous goods that are not correctly handled or
properly stored have the potential to cause corrosion, fire, explosion, radioactivity, asphyxiation,
toxicity, or environmental harm.

If shippers are not trained to classify dangerous goods and if cargo is not marked, labelled, and
documented correctly and if staff are not trained to recognise dangerous goods then accidents will
happen. There may be occasions where it is not obvious that cargo should not be stored together.
For example, a large consignment of unmarked toxic substances stored near foodstuffs or
magnetised material stored in close proximity to sensitive electronic equipment poses a severe risk
which at a glance may not be obvious. Example will be given below on the labels for magnetised
material and environmentally hazardous substances.

The principal of segregation and mixed loading applies not only when storing cargo but also when
transporting it. For example, it is never a good idea to transport detonators in the same vehicle as
explosives. Often, common sense should dictate but comprehensive training is preferred. Would
you store your fireworks right next to the petrol for your lawn mower in your garage or garden shed?

__________________________________________________________________________________ 141

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

In your kitchen do you store the bleach or ant poison with your cereals? Is your toothpaste stored
next to your toilet cleaner?
Cargo must be stored or placed so that their labels and packaging signs are facing outwards so that
these can be seen. Direction labels are of the utmost importance so that all those working with the
cargo know how to correctly place the cargo to avoid spillage and leakage. “This side up” labels and
arrows mean exactly that and must be complied with.

Both the main hazard class as well as any subsidiary risks must be considered in the load
compatibility and the segregation of cargo, based on the diamonds displayed on packages and
containers. For packages required to bear a subsidiary risk label, the segregation appropriate to the
subsidiary hazard shall be applied when it is more stringent than that required by the primary
hazard.

The labelling system is based on the classification of dangerous goods and was established with the
following aims in mind:

• to make dangerous goods easily recognizable from a distance by the general appearance
(symbol, colour, and shape) of the labels they bear

• to provide, by means of colours on the labels, a useful first guide for handling, stowage, and
segregation

__________________________________________________________________________________ 142

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

In certain cases, where the danger of an item of dangerous goods
is considered low, or the goods are packed in a limited quantity,
exemptions from labelling may be provided. In such cases,
marking of packages with the class or division and the packing
group number may be required.

Remember we have discussed Limited Quantity in US 242986 and
the label here is another example of the limited quantity label.

There is a difference between a placard and a label. A placard is a
notice posted in a public place or a small card or metal plaque attached to a vehicle. A label is a
printed sign affixed to a carton.

Placards of the relevant dangerous goods diamonds provide a visual warning of the hazards
associated with the storage of dangerous goods. These are particularly important for emergency
services personnel such as the fire brigade. Placards must be installed where dangerous goods are
stored for an extended period of time.

A risk assessment should be carried out for each storage location or process (i.e. transport process)
for the movement of dangerous goods. This must take into account not only the actual dangerous
goods but also the nature of the other general cargo being stored or transported together with the
dangerous goods.

The risk assessment must address:

• identification of dangerous goods

• mode of transport

• site classification

• potential spillage or leakage

• fires and explosions

• incompatibility and segregation of goods

• machinery used in or around the storage area (e.g. welding equipment produces flame)

• the impact of an incident on the surrounding area (including adjacent buildings for example
where a petrol station may be located)

• the risks associated with occasional work such as repairs and maintenance

• the security of the dangerous goods being stored or transported

__________________________________________________________________________________ 143

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

• provision of safety equipment and personal protective equipment
Correct loading and stowage (lashing and securing of the cargo to prevent movement of the cargo)
can prevent accidents arising from the load shifting.
The relevant regulations such as the IATA Dangerous Goods Regulations and the IMDG Code provide
information on storage compatibility and transportation and segregation of different classes of
dangerous goods and these must be conformed to.
Load compatibility charts also exist and can be consulted.
Incompatible goods must be segregated from one another during storage and transport. For the
purposes of segregation, two substances or articles are considered mutually incompatible when
their stowing together may result in undue hazards in the case of leakage, spillage, or any other
accident.
The extent of the hazard arising from possible reactions between incompatible dangerous goods
may vary and the segregation arrangements required shall also vary as appropriate. In some
instances, such segregation may be obtained by requiring certain distances between incompatible
dangerous goods. Intervening spaces between such dangerous goods may be filled with cargo
compatible with the dangerous substances or articles in question.
The special marking and labelling of packages indicates the hazards of a consignment. The inclusion
of relevant information in the transport documents and the affixing of placards to transport units
communicate to all who may come into contact with the goods the special precautions that need to
be taken.
The International Maritime Organization (IMO) has its headquarters in London, United Kingdom
and is a specialized agency of the United Nations (UN).

The International Maritime Organization primary purpose is to develop and maintain a
comprehensive regulatory framework for shipping which includes safety, environmental concerns,
legal matters, technical co-operation, maritime security, and the efficiency of shipping.

__________________________________________________________________________________ 144

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

The International Maritime Organization is governed by an Assembly of members and is financially
administered by a Council of members elected from the Assembly. The work of the International
Maritime Organization is conducted through five committees, and these are supported by technical
subcommittees. Member organizations of the UN organizational family may observe the
proceedings of the International Maritime Organization. Observer status is granted to qualified non-
governmental organizations.

The International Maritime Organization is supported by a permanent secretariat of employees who
are representatives of its members. The secretariat is composed of a Secretary-General who is
periodically elected by the Assembly, and various divisions such as those for marine safety,
environmental protection, and a conference section.

The International Maritime Organization regularly enacts regulations, which are broadly enforced
by national and local maritime authorities in member countries, such as the International
Regulations for Preventing Collisions at Sea (COLREG). The International Maritime Organization has
also enacted a Port State Control (PSC) authority, allowing domestic maritime authorities such as
coast guards to inspect foreign-flag ships calling at ports of the many port states. Memoranda of
Understanding (protocols) were signed by some countries unifying Port State Control procedures
among the signatories.

The technical work of the International Maritime Organisation is carried out by a series of
Committees.

The Maritime Safety Committee is the most senior of these and is the main Technical Committee; it
oversees the work of its nine sub-committees and initiates new topics. The Maritime Safety
Committee has developed a code for the management of ships which will ensure that agreed
operational procedures are in place and followed by the ship and shore-side staff.

The work of the nine sub-committees is described by their titles, as follows:

• Safety of navigation

• Radio communications and, search and rescue

• Standards of training and watch keeping

• Ship design and equipment

• Fire protection

• Stability, load lines and fishing vessel safety

• Flag state implementation

• Dangerous goods, solid cargo, and containers.

__________________________________________________________________________________ 145

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

• Bulk liquids and gases
The sub-committees work on numerous topics, including, for example, improvements in the design
of passenger ships and the requirements for the stowage and packaging of the vast range of
dangerous goods carried by sea.
SOLAS – International Convention for the Safety of Life at Sea, is an international convention that
was adopted in 1974 and became compulsory in 1980.
“The main objective of the SOLAS Convention is to specify minimum standards for the construction,
equipment and operation of ships, compatible with their safety.”
Please follow this link to read additional information on SOLAS:
https://www.imo.org/en/About/Conventions/Pages/International-Convention-for-the-Safety-of-
Life-at-Sea-(SOLAS),-1974.aspx
The International Maritime Dangerous Goods (IMDG) Code was developed as a uniform
international code for the transport of dangerous goods by sea covering such matters as packing,
container traffic and stowage, with particular reference to the segregation of incompatible
substances. Imagine a container vessel and the amount of movement that take place on the high
sea.

__________________________________________________________________________________ 146

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

Below is the IMDG segregation table according the IMDG section 7.2.4.

In order to apply the table, cross reference each primary row and column to find the intersecting
point which will show the necessary instruction regarding segregation. Here is the key used to apply
the table.
“X” – No segregation needed
“1” – “away from” (normally, CTUs at least 3 metres apart)
“2” – “separated from” (normally, CTUs at least 6 metres apart)
“3” – “separated by a complete compartment or hold from”
“4” – “separated longitudinally by an intervening complete compartment or hold from”

In contrast to the IATA DGR, the IMO IMDG regulations have an additional column in the
identification section which provides further details on segregation. Here is an example of Ethanol
UN 1170. Column 16b is blank, meaning that UN 1170 does not have any specific extra segregation
requirements.

__________________________________________________________________________________ 147

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

In contrast, let us look at Nitrocellulose with Water, UN 2555. Under column 16 b there are
additional “segregation codes” which must be cross referenced according to the information
provided in the IMDG.

Here are the additional segregation codes specific to the above example. The full list can be found
in the IMDG code section 7.2.8

Source: thecompliancecenter.com

The Environmental Protection Agency (EPA) has defined hazardous waste as any material that no
longer has a use and is either specifically listed in the regulations or meets defined hazard
characteristics.
Some examples of characteristic waste are wastes exhibiting any of the following characteristics:
Ignitable

• Liquids that have a flash point less than 140°F (60°C)
• Flammable solids
• Flammable compressed gases
• Oxidizers

__________________________________________________________________________________ 148

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

Corrosive

• Aqueous solutions with pH less than 2 and greater than 12.5

• Corrodes steel

Reactivity

• Water reactive substances

• Unstable or explosive chemicals

• Cyanide or sulphide containing chemicals that generate toxic gases when exposed to
corrosive substances

Toxic

• Materials that have certain heavy metals or organic constituents above regulated
limits

• Specifically, listed chemicals - the EPA has specifically listed approximately 500
chemicals as hazardous waste.

Pollution is an unwelcome concentration of substances that are beyond the environment's capacity
to handle. These substances are detrimental to people and other living things.

In an undisturbed ecosystem, all substances are processed through an intricate network of
biogeochemical cycles, such as the nitrogen and carbon cycles. During these cycles, substances are
taken up by plants, move through the food chain to larger and more complex organisms, and when
the latter die, are decomposed (broken down) into simpler forms to be used again when they are
taken up by plants.

Biodegradable substances are those that can be broken down by the environment's biological
systems. Pollution occurs when the environment becomes overloaded beyond the capacity of these
normal processing systems.

Pollutants can be grouped according to the main ecosystem which they affect. One pollutant often
affects more than one ecosystem.

Air
Sulphur dioxide produced through the burning of coal causes acid rain and respiratory problems.
Nitrogen oxides and volatile hydrocarbons from vehicle emissions combine to form photochemical
smog which causes respiratory problems. Carbon monoxide from vehicle emissions restricts oxygen
uptake, causes drowsiness, headaches, death. Carbon dioxide produced during the burning of coal
enhances global warming.

__________________________________________________________________________________ 149

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT

ADVANCED

CFCs used and aerosols, refrigeration, air-conditioning, and foam- blowing industries destroys the
ozone layer. Methane from feedlots and rubbish dumps enhances global warming. Noise from
industry and traffic affects hearing and is stressful.

Fresh Water

Sewage contains pathogens which cause typhoid, cholera, and gastroenteritis if there is inadequate
sanitation. Nutrients in sewage cause eutrophication (eutrophication is the process by which a body
of water becomes enriched in dissolved nutrients such as phosphates for example that stimulate
the growth of aquatic plant life usually resulting in the depletion of dissolved oxygen). Fertilizers
used in agriculture cause eutrophication. Silt build up in freshwater ecosystems, caused by
inappropriate agriculture, smothers aquatic organisms. Pesticides used in agriculture and by the
health services are toxic and interfere with breeding of mammals and birds. Toxic metals which are
produced by industry are health and life threatening.

Marine
Sewage released into marine systems due to inadequate sanitation will cause the diseases
mentioned above. Fertilizers used in agriculture cause eutrophication. Oil spills from tankers
smother marine plants and animals. Plastics in the sea cause the death of marine animals. Pesticides
used in agriculture and by the health services also cause the death of sea life.

Land
Solid waste is classified as hazardous (radioactive, pesticides, medical, poisons) which is health and
life threatening; or non-hazardous (domestic, urban, mining, industrial, scrap metal) which is
unsightly, and disposal takes up much space.

In the past, most approaches to handling pollution could be summed up by the phrase dilution is
the solution to pollution'. However, pollution levels have increased so much in amount and toxicity
that this approach is no longer acceptable. An alternative approach is source reduction, i.e. a
reduction in the amount of pollution where produced.

Source point pollution is pollution produced from a stationary location, e.g. industrial plants, mines,
and municipal sewage works. Non-point source pollution cannot be traced to a specific point of
origin, and is far more difficult to monitor and control. Common examples are veld fires, motor
vehicle emissions, fertilizer runoff, sediment from construction and erosion, plastic packaging, and
gases from aerosol cans. Some non-point sources can be addressed by laws, such as banning CFCs
(chlorofluorocarbons), or requiring car manufactures to install emission controls.

The polluter-must-pay principle means that a polluter should bear the costs of avoiding pollution,
or remedying its effects. This principle is difficult to apply when the source of pollution cannot be
identified, as is often the case with atmospheric pollution.

__________________________________________________________________________________ 150

©Global Maritime Legal Solutions (GMLS) Version 1_2022

THIS IS ACCREDITED MATERIAL THAT IS COPYRIGHTED TO GMLS AND AS SUCH SHOULD NOT BE COPIED OR DISTRIBUTED WITHOUT THE EXPRESS
WRITTEN PERMISSION FROM GMLS MANAGEMENT


Click to View FlipBook Version