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The principle can be usefully applied following a pollution disaster, such as an oil spill from a tanker.
However, the consumer often pays for such pollution costs.
The polluter-must-pay-principle is implemented in Europe and North America, and is increasingly
applied in South Africa. Pollution does not stay in one place but is moved around the world by air
and water, as well as by living organisms. Even in Antarctica, birds and marine mammals show traces
of pollutants such as DDT and PCBs (polychlorinated biphenyl are toxic environmental pollutants
which tend to accumulate in animal tissues also called PCB).
Always refer to the South African Government Department of Environmental Affairs or their website
for the latest information and legislation regarding safety standards, pollution, and environmental
requirements.
Here is the label for goods that are hazardous to the environment as extracted from the IATA DGR,
however the same label is applicable to other modes of transport as per the example of a tanker
vehicle for road freight.
AC 2 – Safe working procedures and practices in the handling and storage of dangerous goods are
identified, explained, described, and applied according to national codes of practice and legislation
The below content has been covered in the learner guide already, however, below is a useful
summary for this section.
The South African Occupational and Safety Act (No. 85 of 1993) is summarised as follows:
“To provide for the health and safety of persons at work and for the health and safety of
persons in connection with the use of plant and machinery; the protection of persons other
than persons at work against hazards to health and safety arising out of or in connection with
the activities of persons at work; to establish an advisory council for occupational health and
safety; and to provide for matters connected therewith.”
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Further details and information can be found on the website of the department of Labour
(www.labour.gov.za).
Even if a chemical is not a dangerous good or hazardous substance, the risks associated with the
storage and use of that chemical will still need to be effectively controlled.
Hazardous substances are classified on the basis of their health effects, both short and long term.
They can enter the human body in a number of ways including inhalation, ingestion and contact
through the skin and mucus membranes such as the eyes. The level of subsequent risk depends upon
both the substance itself and the nature of the work being done with it.
Not all products used in the workplace would be classed as a hazardous substance.
Examples of types of hazardous substances (depending on their concentration) include:
• Acids
• Caustic substances
• Disinfectants
• Agricultural type products
• Solvents and thinners
Locations and venues where dangerous goods and hazardous substances may be found can include:
• Laboratories and science areas
• Photography dark rooms
• Technology and automotive areas
• Art classrooms and storerooms
• Cleaner’s storeroom and maintenance sheds/rooms
• Kitchen cupboards
• Gas storage tanks
• Swimming pools
Material Safety Data Sheets (MSDS) for all chemicals stored and used on site must be maintained.
The MSDS must be kept in the same location where the chemicals are stored to provide information
on how to manage the risk associated with their use and in the event of an incident or emergency.
MSDS must also be stored in a central (separate) location.
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The Material Safety Data Sheets will provide 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.
Safe Working Procedures (SWP) must consider the following factors:
• Potential hazards associated with each dangerous goods item or substance or hazardous
chemical
• Appropriate storage and handling requirements
• Whether local exhaust ventilation is required
• The type of Personal Protective Equipment (PPE) such as gloves, glasses, face masks etc that
may be required
• Spill management responses.
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.
Risk controls may include, but are not limited to:
• Provision of appropriate storage areas
• Ensuring that the safe storage of particular combinations of substances occurs in accordance
with the Segregation of Dangerous Goods Chart
• Provision of appropriate fire detection and firefighting equipment is available
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• Ensuring appropriate emergency management procedures are in place (e.g., fire wardens,
evacuation points etc)
• Ensuring that appropriate ventilation (mechanical and natural) is in place for the safe use and
storage of chemicals (e.g., fume cupboards, exhaust fans)
• Storing minimal quantities of chemicals on site (e.g., quantities sufficient for quarterly use)
• Provision of spill kits/containment areas (e.g., drip trays, shelving/cabinets with built in spill
retention
• Providing training and instruction to relevant employees in the safe storage of dangerous
goods
• Ensuring appropriate manual handling techniques are employed when transporting and
storing goods
• Provision of Personal Protective Equipment/PPE (gloves, goggles, lab coats/overalls etc)
• Ensure fire risk dangerous goods are stored away from any potential source of ignition or heat
and other combustible matter or refuse
• Ensure chemical containers and their seals or stoppers are checked regularly for deterioration
and replaced as necessary
• Investigate incidents, review risk controls, and keep records of process
• Regularly review the chemicals held in storage and correctly dispose of those no longer
required
• Ensure safe disposal of any chemicals in the workplace (for advice on the correct disposal of
specific chemicals contact your local Council, Water or Municipal authorities
• Ensure suitable means of identification includes labels and placards
• Monitor and review the safety systems to make sure the risk is being appropriately managed
AC 3 – Potential hazards in the working environment are identified, explained, and described
according to codes of practices and national legislation
The five main kinds of hazards in the workplace are chemical, physical, biological, psychosocial, and
ergonomic:
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➢ Chemical hazards - these can occur in warehouses, hospitals, clinics, factories, garages,
laboratories, and farms. They can be in form of liquids, vapours, gases, or dust particles. Direct
contact with chemicals can cause skin irritation or burns. They could affect your lungs and affect
your ability to breath. They also have the potential to cause explosions or fires.
➢ Physical hazards - include high or very low temperatures, high levels of noise or vibration. Too
much heat can cause heat sickness and lead to dehydration. Low temperatures can affect your
ability to concentrate. High levels of noise can damage your hearing and lead to deafness.
Regular exposure to very bright light can also be a hazard to the eyes and cause partial or total
blindness.
➢ Biological hazards - often occur in places such as hospitals and clinics where viruses and
bacteria are present and which can be passed from one person to another. In these workplaces
people can be exposed to infected needles, surfaces, or people. People who work with sewage
or animals are also at risk of getting infected with such contaminants.
➢ Psychosocial hazards - Excessive work pressure, such as meeting unrealistic deadlines can lead
to stress, depression, anxiety, and other forms of mental illness. Mental illness is being much
more serious consideration as the effects this can have in the workplace can be dangerous. For
example, loss of concentration due to lack of sleep or unstable behaviour as a result of
underlying psychological conditions can be harmful in the workplace.
➢ Ergonomic hazards - these often occur where people work in cramped spaces or uncomfortable
positions such as poor seating or standing for long. These conditions could result in backache,
wrist strain, shoulder pains, etc. This can also include environments that are not temperature
regulated resulting in staff being uncomfortably hot or cold.
Some hazards affect your body immediately. For example, chemicals can cause skin burns, dust can
make you cough or cause/trigger an asthma attack (shortness of breath). Some may take longer,
where, for example, you may become deaf after exposure to excessive noise for an extended period.
If you are ever at the airport, take note of the ground handling staff working around the aircraft, they
are all taking the necessary processions by wearing ear protection in the form of earmuffs.
Other hazards, such as radiation from X-ray machines or electricity power plants may not be felt but
may cause cancer after some time.
In order to make your workplace safer:
• Be alert and take note of what is going on in your workplace so that you can identify potential
hazards. Use your eyes, nose, and sense of feel. Use common sense.
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• Look out for chemicals spillage and badly labelled containers. Make sure chemicals are
properly closed and kept in safe places.
• Listen to the level of noise in your workplace. Is it too noisy? Do you struggle to hear each
other when you speak? Do you have pain or ringing sensations in your ears?
• Do you smell chemicals in the air? Do you get stuffy or irritating nose? Do you have difficulty
in breathing?
• Does it feel too hot or too cold in your workplace? Does your chest burn when you
breathe? Do you sweat a lot at work?
In order to gauge whether the health problem is caused by your workplace:
• Consider if the health problem only started after commencing this kind of work (e.g., burning
eyes, headaches, lack of concentration, etc.)
• Consider whether the health problem gets worse when you are at work and better when you
are on holiday (e.g., may have difficulty in breathing/ asthma at work but not when on holiday
or at home).
• Consider if other workers working in same place as you experience similar health problems.
The aim should be to control the workplace hazard or to remove it completely, if possible. Work
processes and procedures or machinery could be replaced, upgraded, or made safer. If possible,
replace the hazardous substance with a less hazardous one. Extractors or ventilators could be used
to remove dangerous gases; however the filters need to be properly maintained so as not to cause
further harm at a later stage. Personal protective equipment (PPE; e.g. gloves, head helmet, boots,
or ear plugs, etc) may also be necessary. The workplace should be kept clean and tidy. The guiding
principles should always be that you first control the source of the problem, if this is not possible,
then control hazards from source to worker, and as a last resort, or as an additional measure, provide
personal protective equipment e.g. boots, ear plugs, glasses, etc.
Examples of more specific potential hazards include:
o Hazardous substances
o Blood borne viruses
o Confined spaces
o Driving vehicles at work
o Operating machinery
o Electricity and electrical faults
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o Fire
o Gas
o Asbestos
o Heights and dangers of falls from height
o Noise
o Skin and respiratory sensitizers
o Slips, trips, and falls
o Smoking and passive smoking
o Transport and vehicles (including forklifts etc)
Hazardous substances (the first example mentioned above) are used in many workplaces and take
many different forms. Solids, liquids, gases, mists, and fumes can be present in the workplace.
There are legal obligations on employers to control exposure to hazardous substances to preserve
the health of their employees.
Anyone who works with or is exposed to hazardous substances is at risk. Those exposed to more
hazardous substances for long periods of time are more at risk than those exposed for short periods
or to less hazardous substances.
The aim should be to prevent exposure to hazardous substances. Where exposure cannot be
avoided, then adequate controls should be put in place.
Examples of those who could be exposed to hazardous substances include:
• cleaners – common-cleaning materials can cause localised burns and skin complaints
• hairdressers – a number of hairdressing products contain bleaching agents that can damage
skin
• welders – dangerous fumes from welding can damage their lungs, as well as the light that can
damage the eye.
• bakery workers – flour and bakery dust can cause irritation of eyes and nose, skin problems
and asthma
• garage workers – paints, solvents, oils and grease, and exposure to exhaust fumes can all
damage their health
• medical or healthcare staff – exposure to biological agents can cause infection
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In reality, the list is endless, and many workers may be exposed to hazardous substances at some
time during the course of their work.
Substances hazardous to health can be defined as those that are:
➢ toxic
➢ very toxic
➢ corrosive
➢ harmful
➢ irritant
Employers should ensure that the following measures are taken into account to reduce risk:
• operate processes and activities are designed to minimise emission, release, and spread of
substances hazardous to health
• all relevant routes of exposure – inhalation, skin absorption and ingestion – when developing
control measures
• control exposure by measures that are proportionate to the health risk
• choose the most effective and reliable control options, which minimise the escape and spread
of substances hazardous to health
• where adequate control of exposure cannot be achieved by other means, provide, in
combination with other control measures, suitable personal protective equipment
• check and review regularly all elements of control measures for their continuing effectiveness
• inform and train all employees on the hazards and risks from the substances with which they
work, and the use of control measures developed to minimise the risks
• ensure that the introduction of control measures does not increase the overall risk to health
and safety
The risks associated with the hazardous substances present in your workplace must be assessed. The
employer has the responsibility for the risk assessment. They may call on assistance (from experts
and specialists) if it is required.
The person conducting the assessment must have a knowledge and understanding of the process
and the requirements of the regulations. They must make use of the existing knowledge within the
workplace before deciding whether outside assistance is needed.
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Most simple assessments can be carried out in-house:
• make a list of all the substances and products in the workplace
• gather as much information as you can on each substance and the risks associated with them
• look at information on labels, in suppliers' catalogues and material safety data sheets
You then need to assess how these risks relate to the specific circumstances of your workplace.
Consider how much of each substance is used and how often. Larger quantities or substances that
are used often will increase the risk of exposure. Consider how each substance is used and whether
they are mixed, poured, sprayed, piped, heated, cooled, etc.
The way they are used will determine how you will control exposures. Consider how staff or other
people could be exposed and what effect it could have on their health.
Whether the substance a solid, liquid, gas, mist, or fume needs to be taken into account as well as
whether the substance will damage their skin, lungs, eyes through skin contact, absorption,
ingestion, inhalation, or injection.
These considerations will help you carry out the risk assessment and determine the measures you
need to take to protect the health of those people who could be exposed.
The hierarchy of control measures can be summarised as follows.
❖ Eliminate – do not use the hazardous substance or avoid the procedure which causes
exposure.
❖ Substitute - change the material or working practice to one less hazardous.
❖ Enclose - enclose the hazardous substances or process in a closed system.
❖ Control - control exposure to the hazardous substance by using one of the following methods:
• Engineering Controls: Control the exposure at source with local exhaust ventilation or
increased dilution ventilation to lower concentrations in the atmosphere.
• Procedural Controls: Reduce the numbers exposed or the time spent on the
procedure, carry it out in specified areas and carry out routine monitoring and health
and medical surveillance if needed.
• Personal Protective Equipment (PPE: Provide gloves, impervious aprons, or overalls
and/or respiratory protection to minimise the effects of exposure to hazardous
substances.
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Emergency procedures must be put in place to cope with accidents and emergencies. Controls
already in place may be adequate for normal activities but there also needs to be procedures for
emergencies like a major spillage or release of a substance. It is vital that there are contingencies to
deal with these circumstances.
AC 4 – The choice of a particular method of handling and storage (in relation to the classification of
dangerous goods), the precautions to take and the aspects of applicable legislation and codes of
practice are explained, described, and applied
When storing and handling dangerous goods the following factors must be taken into account:
• the severity of the hazard or risk in question, i.e. what is the likelihood that the storage and
handling of the dangerous goods will result in injury to people, or the likelihood of damage
occurring to property
• what the severity of the injury and property damage is likely to be and how many people
could be affected
• the state of knowledge about the hazard or risk and ways it may be removed or mitigated,
i.e. what is known about the hazards or risks associated with the storage and handling and
the ways to control the risk
• possible knowledge manufacturers and suppliers of dangerous goods know about the hazards
and risks
• the methods which other workplaces have in place to deal with similar dangerous goods to
control the risk
• the information industry professionals and organisations and government agencies can
provide
• the availability and suitability of ways to remove or mitigate the hazard or risk, i.e. whether
the risk controls that have been identified are readily available and whether they are suitable
for the premises and the employees involved
• the cost of removing or mitigating the hazard or risk, i.e. whether the costs of implementing
the risk control are commensurate with the benefits gained
• whether time and money invested in selecting and implementing risk controls results in the
elimination or significant reduction in risks and, if not, then more cost-effective risk controls
should be identified
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The supplier of dangerous goods should ensure that:
1. the goods supplied are packed in accordance with the applicable dangerous goods regulations
with particular importance given to the need for the packaging to be in sound condition and
compatible with the goods
2. the goods supplied are in all respects in accordance with any specific storage and handling
requirements specified by the manufacturer
3. where packages are prepared for transport that require marking, they are marked with South
African shipper contact name and address, plus, for each type of dangerous goods in the
package:
(i) the Proper shipping name
(ii) the UN Number
(iii) the Class label
(iv) all applicable Subsidiary Risk labels (i.e. standard marking for a package as per DG
regulations)
4. where inner packaging’s are marked, they are marked with the:
(i) Proper shipping name or technical name for the dangerous goods
(ii) Class label
(iii) applicable Subsidiary Risk labels (i.e. inner package marking as per DG regulations)
For dangerous goods that may be unstable except under controlled conditions, it is essential that the
Material Safety Data Sheets (MSDS) provide full details of those conditions and specify the
recommended proportion and safe limits for every ingredient that stabilises the dangerous goods.
Manufacturers and importers of dangerous goods are required to review MSDS as often as necessary
to ensure the information remains accurate and current.
Review of Material Safety Data Sheets (MSDS) should take place:
(a) whenever there is a change in the formulation of a product
(b) whenever new information on the hazardous properties or the health effects of the product
or one of its ingredients becomes available
(c) whenever, through review or other means, it becomes apparent that the information
provided may not be completely accurate, current, or comprehensive.
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The physical properties of the dangerous goods may represent or contribute to hazards in the
particular storage and handling situation. Relevant physical properties include:
a. physical state solid/liquid/gas
b. flashpoint
c. viscosity
d. density
e. particle size
f. vapour pressure
g. solubility and pH
h. reactivity
i. boiling and/or freezing point or range
j. electrical and/or heat conductivity
k. the nature and concentration of combustion products
Some activities, systems of work, structures and equipment that are not directly involved with the
storage and handling of dangerous goods, may constitute a hazard for that storage and handling.
Potential external hazard sources include:
(a) any adjacent dangerous goods storages
(b) the proximity of other work areas, including on-site offices
(c) other activities on the premises such as:
• the operation of plant/machinery
• the movement of vehicles
• deliveries of other dangerous goods or hazardous materials
• personnel movements in normal and emergency situations
• visitor access
• portable sources of ignition
(d) fire risks, including concentrations of combustible material or uncontrolled vegetation on or off
the premises.
(e) activities and installations on neighbouring premises
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(f) possible weather conditions, such as temperature extremes, wind, lightning, or rainfall, including
the potential for flooding.
(g) activities off the premises such as the location of a main road, railway line, airport, gas pipeline,
water main, high voltage power lines, and radio transmitters, including mobile phone repeater
towers.
(h) the proximity of sensitive facilities which may be put at risk by the presence of dangerous goods,
such as schools, hospitals, child and aged care facilities, theatres, shopping centres and
residences.
The safety of explosive substances (Class 1) and articles would be enhanced by storing and
transporting each kind separately, but considerations of practicability and economics preclude such
an ideal. In practice, a proper balance of the interest of safety against the other relevant factors
necessitates a degree of mixing in the storage and transport of explosive substances and other goods.
The extent to which goods of Class 1 (Explosives) may be loaded together in transport is determined
by the "compatibility" of the explosives. Goods of Class 1 are considered to be "compatible" if they
can be transported together without significantly increasing either the probability of an accident or,
for a given quantity, the magnitude of the effects of such an accident.
This is taken much further into far greater detail where compatibility tables must be consulted but
we do not go into that detail here.
Toxic substances of Class 6, Division 6.1, must be segregated from foodstuffs. Substances marked as
or known to be toxic (Packing Groups I, II and III) shall not be carried in the same railway wagon,
lorry, hold of a ship, compartment of an aircraft or other transport unit with substances marked as
or known to be foodstuffs, feeds or other edible substances intended for consumption by humans or
animals.
Relaxation of this position may be allowed for substances of Packing Groups II and III provided the
competent authority is satisfied that the packing and segregation are adequate to prevent the
contamination of foodstuffs, feeds or other edible substances intended for consumption by humans
or animals.
A railway wagon, lorry, cargo space of a ship, compartment of an aircraft or other transport unit
which has been used to carry substances marked as or known to be toxic (Packing Groups I, II and III)
shall, before re-use, be inspected for contamination. A railway wagon, lorry, hold of a ship,
compartment of an aircraft or other transport unit which has been contaminated shall not be
returned to service until it has been decontaminated.
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For substances of Division 6.2 (infectious substances), carriers and their staff shall fully understand
all applicable regulations for the storage, handling, packing, labelling, transport, and documentation
of consignments of infectious substances. The carrier shall accept and expedite the transport of
consignments conforming to the rules in force. If the carrier finds any error in the labelling or
documentation, he shall immediately notify the consignor or consignee so that the appropriate
corrective measures may be taken.
Radioactive material of Class 7 shall be segregated sufficiently from workers and from members of
the public. Radioactive material shall be sufficiently segregated from undeveloped photographic film.
Once again, this goes into far greater in-depth detail where tables must be consulted to ascertain the
safety distances for the various categories depending on the activity of the radioactive material, but
we do not go into that detail here.
AC 5 – The handling/storage operation, and the ways in which the process could be compromised are
described and explained as it relates to codes of practice and national legislation
The section heading above refers to “National Legislation” however this is a bit vague because
consider just some of the National Legislation here and you will see exactly what we mean:
o Compensation for Occupational Injuries and Diseases Act No. 130 of 1993;
o Disaster Management Act No. 57 of 2002;
o Explosives Act No. 26 of 1956;
o Hazardous Substances Act No. 15 of 1973;
o Merchant Shipping Act No. 57 of 1951;
o National Environmental Management Act No. 107 of 1998;
o Nuclear Energy Act No. 46 of 1999;
o Occupational Health and Safety Act No. 85 of 1993;
o Atmospheric Pollution Prevention Act No. 45 of 1965;
o Dumping at Sea Control Act No. 73 of 1980;
o Explosives Act No. 26 of 1956;
o Hazardous Substances Act No. 15 of 1973;
o Marine Pollution (Prevention of Pollution from Ships) Act No. 2 of 1986;
o Maritime Transport Security Bill, 2009;
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o Merchant Shipping Act No. 57 of 1951;
o National Road Traffic Act No. 93 of 1996;
o National Road Traffic Amendment Act, 2008;
o Road Traffic Act No. 29 of 1989;
o Shipping Laws Amendment Act No. 57 of 1998;
o South African National Roads Agency & National Roads Act No. 7 of 1998;
o Fire Brigade Services Act No. 99 of 1987;
o National Environmental Management Amendment Act No. 46 of 2003;
o National Water Act No. 36 of 1998;
o Environment Conservation No. 73 of 1989;
o Environment Conservation Amendment Act No. 50 of 2003;
o National Environmental Management Biodiversity Act, 10 of 2004;
o National Environmental Management Act No. 107 of 1998;
o Nuclear Regulatory Act No. 47 of 1999;
o Atmospheric Pollution Prevention Act No. 45 of 1965;
o Dumping at Sea Control Act No. 73 of 1980;
o Environment Conservation Act No. 73 of 1989;
o Gas Act, No. 48 of 2001;
o Marine Pollution (Control & Civil Liability) Act No. 6 of 1981;
o Marine Pollution (Intervention) Act No. 64 of 1987;
o Marine Pollution (Prevention of Pollution from Ships) Act No. 2 of 1986;
o National Environmental Management;
o Protected Areas Act No. 57 of 2003;
o National Environmental Management Waste Act No. 59 of 2008;
o National Environmental Management:
o Air Quality Act No. 39 of 2004;
o National Radioactive Waste Disposal Institute Act No. 53, 2008;
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o National Water Act No. 36 of 1998;
o Water Services Act No.108 of 1997;
o Foodstuffs, Cosmetics and Disinfectants Act No. 54 of 1972.
Fortunately, you do not have to know any of these acts. The above is simply to illustrate the vast
network of rules and regulations which have to be complied with and why reference to “National
Legislation” is too vague.
An approved code of practice gives practical guidance on how to comply with a general duty. Codes
of practice may be written to provide practical guidance for any person such as, for example,
occupiers, manufacturers, and employees. Each approved code of practice will state the people for
whom the guidance is intended.
The provisions in a code are not mandatory. That is, a person may choose to comply with the relevant
provision of the Regulations in some other way, provided that the method used also fulfils the
requirements of the Regulations. A person or company cannot be prosecuted simply for failing to
comply with an approved code of practice.
However, in legal proceedings, failure to observe a relevant approved code of practice can be used
as evidence that a person or company has contravened or failed to comply. If a person has not
adopted the method described in the code, it is up to that person to show that the legal requirement
has been met by an alternative method. Therefore, an approved code of practice should be followed,
unless there is an alternative course of action that would also fulfil the requirements of the Act or
Regulations.
For safe handling and storage follow the codes of practice as published in the applicable regulations
which deal with the relevant mode of transport such as:
• International Air Transport Association (IATA) Dangerous Goods Rules and Regulations
• International Civil Aviation Organization's (ICAO) Technical Instructions
• International Maritime Organization Dangerous Goods Code (IMDG Code)
• Intergovernmental Organisation for International Carriage by Rail Regulations ("RID", part of
the Convention concerning International Carriage by Rail)
• The European Agreement Concerning the International Carriage of Dangerous Goods by Road
(ADR Regulations)
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The “United Nations (UN) Recommendations on the Transport of Dangerous Goods - Model
Regulations” is a good publication on which many other publications are based (i.e. air, road, rail,
sea). The Recommendations are addressed to governments and international organizations
concerned with the safety and the regulation of the transport of dangerous goods.
The Recommendations do not apply to the bulk transport of dangerous goods in sea-going or inland
navigation bulk carriers or tank-vessels, which is subject to special international or national
regulations.
The Recommendations on the Transport of Dangerous Goods are presented in the form of “Model
Regulations on the Transport of Dangerous Goods”, which are an annex to the Recommendations.
The Model Regulations are a scheme of basic provisions that will allow uniform development of
national regulations and international regulations governing the various modes of transport.
However, the Model Regulations are intended to be flexible enough to accommodate any special
requirements.
The United Nations Economic and Social Council expects that governments, intergovernmental
organizations, and international organizations, when revising or developing regulations regarding the
transport of dangerous goods will conform to the principles set out in these Model Regulations, thus
contributing to worldwide harmonization in the transport of dangerous goods. Furthermore, the
structure, format and content should be followed to create a more user-friendly approach, to
enhance harmonization of regulatory requirements, to facilitate the work of enforcement bodies and
to reduce administrative burdens.
The Model Regulations have been drafted in the mandatory sense (i.e., the word “shall” is used
throughout the text rather than “should”) to facilitate direct use of the Model Regulations as a basis
for national and international transport regulations.
To control risk associated with minor storage of dangerous goods, implement the following
measures:
i. Follow the Material Safety Data Sheet (MSDS) instructions. Where the label or MSDS for
dangerous goods specifies measures and/or equipment to be used for the storage and
handling of the dangerous goods then you should adopt those measures.
ii. When storing and handling packages they should be stored on surfaces that are resistant to
attack by their contents if spilt, and will not react dangerously with spilt dangerous goods.
iii. Stow packages in a way that minimises the risk of them falling or being dislodged.
iv. Store packages so that leakage cannot adversely affect other dangerous goods in the storage
area.
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v. Liquid dangerous goods in packages should not be stored above solid dangerous goods in
paper or absorbent packaging.
vi. Glass containers of liquids should be stored at lower levels.
vii. Where dangerous goods require special storage conditions to ensure their stability (i.e. to
eliminate the risk of hazardous reaction), make regular checks to ensure that these special
conditions are maintained. Examples of special storage conditions are the need for stabilisers
or refrigeration.
viii. Where aerosols are stored together in outer packaging, enclose the storage area in a strong
mesh enclosure to reduce the risk from projectiles in the event of a fire involving the aerosols.
Where dangerous goods need to be transferred (by pumping, decanting, dispensing, and filling) into
or from a container or moved from place to place in a minor storage area, ensure that:
❖ spill containment is provided that can hold at least the quantity of the largest container
❖ the container being filled, and any transfer equipment is earthed, if there is a likelihood of
static electricity being generated and risk from ignition of flammable vapours during the
transfer
❖ the transfer is done in a manner which reduces the generation of any vapours and avoids
splashing or spillage of the dangerous goods
❖ the place where the transfer is carried out is:
• set aside for that purpose
• not within the storage area but adjacent to it
• free of ignition sources
• free of obstructions with sufficient room to enable the transfer to be carried out and
to hold containers and associated equipment
• any decontamination materials or clean-up equipment is kept close by
• where dangerous goods are to be transferred into containers at the premises, the
container is suitable and cannot be damaged by the dangerous goods. For example,
do not use a plastic container that could be softened or made brittle by the dangerous
goods
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Segregate any dangerous goods that are incompatible to prevent them mixing. This may be achieved
by the use of an impervious barrier or by a separation distance sufficient to prevent contamination
(a distance of 1.5 metres should be sufficient in most circumstances).
You must provide separation of the dangerous goods from people or property at or beyond the
boundaries of the premises.
Avoid sources of heat and ignition. Keep ignition sources away from flammable or combustible
dangerous goods (dangerous goods of class or subsidiary risk 2.1, 3, 4. 1, 4.2, 4.3 or combustible
liquids).
Naked flames emanating from direct fired heaters and any flames associated with maintenance work
should be kept at least 5 metres from the goods. Always store dangerous goods away from sources
of heat (e.g. heating appliances).
When dangerous goods which are being stored or handled can generate flammable or explosive
atmospheres, use electrical equipment that is compatibly safe or flameproof.
Prevent any potential flow of dangerous goods to other parts of the premises that could create a risk
or reach any watercourse or the property boundary. Possible means are provision of channels and
utilising the slope of the land. Where spill containment is required, it should have a sufficient capacity
to contain the dangerous goods spillage.
Keep equipment and materials for clean up at the premises to cope with spills from the largest
packages kept at the premises. Immediately clean up any spills and leaks.
Contaminated, spilt, or leaked goods should not be returned to their original packaging except for
the purposes of disposal or where it is known that this will not increase the risk. Safely dispose of
waste generated after the clean-up of a spill or leak.
Ensure that any container or piece of equipment that has been used to store or handle dangerous
goods, and which is no longer required for that purpose, is cleaned free of dangerous goods, or
otherwise made safe.
Provide the areas in which dangerous goods are stored and handled with adequate natural or
mechanical ventilation sufficient to prevent the generation of a flammable or harmful atmosphere.
The level and type of ventilation will depend on the nature of the goods and whether they are being
stored or used.
Ventilation is not required where the documented assessment of the risks indicates that the
likelihood of the release of flammable or harmful dangerous goods into the atmosphere in the
storage area is negligible.
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If you intend to rely on natural ventilation and need to install vents to achieve the necessary airflow
to maintain a safe atmosphere in the room being ventilated, you should consider the following:
• The need to provide vents at floor level and near the ceiling. Most dangerous goods gases
and vapours are heavier than air and will vent through the floor level vents. The high-level
vents allowing fresh air to circulate into the room.
• The need to ventilate directly to the outside and not into another room.
• The need to provide a minimum amount of vent area and the spacing of vents to ensure
effective airflow. A useful guide is to allow at least 1 square meter of vent area for each 50
square meters of floor area. The actual amount of vent area and the number of vents that
should be provided will be dependent on the size of the room to be vented and whether there
are restrictions to the free circulation of the air within the room.
Provide sufficient lighting of areas where dangerous goods are stored and handled to allow normal
work to be undertaken safely.
Ensure that storage areas for dangerous goods are secured against unauthorised entry.
Ensure Personal Protective Equipment (PPE) appropriate to the goods being handled, is worn when
people are handling dangerous goods. Personal Protective Equipment (PPE) needs to be periodically
checked and maintained.
Do not block entry or access routes and do not store dangerous goods where they could hinder
escape from the building or area in the event of a fire, spill, or leak.
Keep areas in which dangerous goods are stored or handled clear of combustible matter and refuse.
In the case of storage or work outdoors, the surrounding area should be cleared of combustible
vegetation for a distance of at least 3 metres.
A supply of water should be available, at a nearby location for emergency use. Portable fire
extinguishers appropriate to the type and quantity of dangerous goods being stored and handled at
or near to the place where the dangerous goods are stored or handled must be provided. All fire
protection equipment must be maintained in an operable condition.
Establish procedures for responding to all emergencies, taking account of:
• the nature and quantity of dangerous goods
• the types and likelihood of emergencies
• the fire protection and other emergency equipment provided
• the physical features of the site
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• access to the premises
• the number of people on the premises and adjoining premises
Ensure that all relevant emergency contact telephone numbers are displayed in a prominent location
at the premises and ensure that there is an emergency evacuation plan clearly displayed for
instruction purposes.
SO3 - PREPARE THE DANGEROUS GOODS FOR TRANSPORTATION
AC 1 – The compatibility of the dangerous goods is explained and described according to South African
National Standards code of practice
Compatibility and segregation have been covered in earlier US 242986 , below is a brief summary.
‘Compatible’ in relation to two or more substances or items, means that they will not react together
to cause a fire, explosion, harmful reaction, or the evolution of flammable, toxic or corrosive vapours.
Before goods are loaded for transport the compatibility table needs to be consulted otherwise a
possible chemical or physical reaction between dangerous goods and other substances and articles
is a reality. Physical reactions include dilution, dissolution, abrasion, phase change, leaching and
adsorption. Chemical reactions are reactions that result in a chemical change in one or more of the
goods when they come into contact with one another.
Consider:
▪ if there is a possible hazard as a result of a physical reaction from incompatible substances
coming into contact (e.g. an explosion or heat rapidly generated from acid mixing with water.
▪ if there is a possible hazard as a result of a chemical reaction from different substances
coming into contact (e.g. an oxidising agent such as pool chlorine mixing with a hydrocarbon
such as oil or brake fluid)
Control measures for transport storage areas containing dangerous goods:
• The length of time that dangerous goods are held is kept to a minimum.
• All dangerous goods that are assembled in loads ready for transport are packaged or
contained, marked, stowed, secured, placarded, segregated and documented.
• Incompatible dangerous goods are segregated according to particular transport mode.
• Dangerous goods are kept apart from foodstuffs (including stock feed), so as to avoid any
potential contamination.
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• Ignition sources are controlled provision is made for dealing with spills appropriate fire
protection is provided.
It is recommended that a MSDS be consulted to ensure the materials are compatible. Goods with
different UN numbers within the same class may be incompatible.
Follow directions provided using the compatibility chart key, checking all guidance notes and
supplementary notes.
Where goods are incompatible consider greater separation if the packing group is PG I (high danger)
or II (medium danger) irrespective of the symbol used to account for the higher level of danger.
Always consult the segregation tables regarding the rule of packing dangerous goods of multiple
hazards.
AC 2 – The relevant documentation for the transportation of dangerous goods is identified, explained,
described, and completed according to national legislation
Most of the documentation required for the movement of dangerous goods has been covered in US
242986 (SO4). Below is additional information regarding the requirements for road freight.
For road freight a TREMCARD (Transport Emergency Card) is required.
The TREM card contains important safety information about the vehicle’s load. The TREM card is a
tool for the driver of the vehicle to use in the event of an emergency scenario. This document can
also be used by rescue personnel to see what is being transported and how it should be treated. If
multiple dangerous goods are in the same load, then each one will require a TREM card.
The requirements of a TREMCARD are:
➢ The TREMCARD must detail the substances being carried and its hazard(s)
➢ It must state what actions should be taken in the event of an emergency
➢ It is for use by the driver during an incident, or by the emergency services, if required
➢ Any vehicle used for the transport of dangerous goods shall have a transport emergency card
for each dangerous goods item in the load
➢ The transport emergency card must be kept in the cab of the vehicle
➢ The transport emergency card must be in English
➢ The transport emergency card must be clean and legible and an original (not a photocopy)
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➢ The validity of the TREMCARD shall be three years from the generation date as stated in the
bottom left-hand corner of the TREMCARD.
Here is an example of a TREM card for Kerosene:
Source: https://dgrcompliance.co.za/media/
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In addition to the TREM card there is an Emergency Response Guidebook of Southern Africa which
first responders will receive training on in order to handle each accident or incident according to
National and International safety regulations.
Source: http://www.foresightpublications.co.za/DGD.html
AC 3 – The applicable Dangerous Goods Placards are identified and explained as required by South
African National Standards codes of practice and national legislation
Transport units comprise road transport tank and freight vehicles, railway transport tank and freight
wagons, and multimodal freight containers and portable tanks.
Placards shall be affixed to the exterior surface of transport units to provide a warning that the
contents of the unit are dangerous goods and present risks.
Placards shall correspond to the primary risk of the goods contained in the transport unit except that:
a) Placards are not required on transport units carrying any quantity of explosives of Division 1.4,
Compatibility Group S, dangerous goods packed in limited quantities, or excepted packages of
radioactive material (Class 7)
b) Placards indicating the highest risk only need be affixed on transport units carrying substances
and articles of more than one division in Class.
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Placards shall be displayed for those subsidiary risks of substances or articles specified in Column 4 of
the Dangerous Goods List (Column 4 = 'Subsidiary risk' - this column contains the class or division
number of any important subsidiary risks which have been identified by applying the classification
system described in Part). However, transport units containing goods of more than one class need not
bear a subsidiary risk placard if the hazard represented by that placard is already indicated by a
primary risk placard.
Transport units carrying dangerous goods or the residue of dangerous goods in unpurged tanks shall
display placards clearly visible on at least two opposing sides of the units and in any case in such a
position as may be seen by all those involved in the loading or unloading process.
Where the transport unit has a multiple compartment tank which is carrying two or more dangerous
goods and/or the residues of dangerous goods, appropriate placards shall be displayed along each
side at the position of the relevant compartments.
There are special provisions for Class 7 (Radioactive materials) placards. Large freight containers
carrying packages other than excepted packages, and tanks shall bear four placards which have
minimum dimensions of 250mm per side of diamond shape. and a border width of 5mm.
The placards shall be affixed in a vertical orientation to each side wall and each end wall of the large
freight container or tank. Any placards which do not relate to the contents shall be removed.
Instead of using both labels and placards, it is permitted as an alternative to use enlarged labels only
with dimensions of 250mm per diamond side.
In the case of a vehicle without sides the placards may be affixed directly on the cargo-carrying unit
provided that they are readily visible; in the case of physically large tanks or freight containers, the
placards on the tanks or freight containers shall suffice. In the case of vehicles which have insufficient
area to allow the fixing of larger placards, the dimensions of the placard must be 250mm per diamond-
side.
Any placards which do not relate to the contents shall be removed. Special care needs to be taken
when reusing packaging that contained dangerous goods. The shipper or packer need to ensure that
the label affixed are relevant to the contents.
Except as provided for placards of Class 7 (Radioactive materials), a placard shall:
(a) Be not less than 250 mm by 250 mm, with a line of the same colour as the symbol running 12.5
mm inside the edge and parallel with it
(b) Correspond to the label for the class of the dangerous goods in question with respect to colour
and symbol
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(c) Display the number of the class or division (and for goods in Class 1, the compatibility group letter)
of the dangerous goods in question
Except for goods of Class I, UN numbers shall be displayed as required on consignments of:
(a) Solids, liquids, or gases transported in tank transport units including on each component of a
multi-compartment tank transport unit
(b) Packaged dangerous goods of a single commodity which constitute a full load for the transport
unit
(c) Unpackaged LSA-1 or SCO-1 material of Class 7 in or on a vehicle, or in a freight container, or in a
tank; and
(d) Packaged radioactive material with a single UN number under exclusive use in or on a vehicle, or
in a freight container.
The UN number for the goods shall be displayed in black digits not less than 65 mm high, either:
(a) Against a white background in the lower half of each placard or.
(b) On an orange rectangular panel not less than 120 mm high and 300 mm wide, with a 10mm black
border, to be placed immediately adjacent to each placard.
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SO4 - TAKE APPROPRIATE ACTIONS IN THE EVENT OF ACCIDENTS IN THE HANDLING
AC 1 – The accident/incident reporting is defined as required by national legislation
Accident and Incident reporting has been covered in US 242986 (SO 1 – AC 4).
AC 2 – The accident/incident appropriate actions are explained and demonstrated according to
national legislation
Accident and Incident appropriate action has been covered in US 242986.
AC 3 – Safety procedures are explained and described according to South African Bureau of Standards
0232 part 3, annexure A
SABS Standards and Code of Practices
The South African Bureau of Standards (SABS) is the national standards organisation of South Africa.
Its technical departments publish the work of its technical committees as South African national
standards. The technical committees are active members of technological associations, consumer
associations, manufacturers, industrialists, government officials, educators, and others. It is also the
SABSs policy to adopt International and European standards when these are found to be applicable
to the South African situation.
During the development of South African National Standards, documents are circulated for study
within the technical committees or subcommittees. These documents have to pass through a number
of stages before they can be approved as South African National Standards. This procedure is designed
to ensure that the final result is acceptable to as many interest groups as possible.
SANS 10232-3:2007
This is South African National Standards (SANS) number 10232, Part 3, date approved 2007 (30-03-
2007).
The title is Transport of Dangerous Goods - Emergency Information Systems Part 3: Emergency
Response Guides (ERG’s) and it specifies a standard procedure of initial response, in the form of
emergency response guides which are to be followed by a first responder upon arrival at the scene of
an incident that involves the transport of materials that are classified as dangerous goods in
accordance with SANS 10228. ERGs facilitate the early assessment of the potential hazards and
indicate a response that should be taken to mitigate the incident.
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The "Emergency Response Handbook", Annex A of SABS 10232-3 Code of Practice is a guidebook for
first responders during the initial phase of a dangerous goods incident and is obtainable from the
South African Bureau of Standards. It can only be read in conjunction with the U.S. Department of
Transportation Research and Special Programmes Administration Emergency Response Guidebook.
SANS 10232 consist of the following parts, under the general title Transport of dangerous goods
Emergency information systems:
Part 1: Emergency information system for road transport.
Part 2: Emergency information system for rail transport.
Part 3: Emergency response guides.
Part 4: Transport emergency card.
Annexes A and B form an integral part of SANS 10232.
Annex A (which is dealt with in this section) is the Emergency response guidebook. This is the U.S.
Department of Transportation, Emergency Response Guidebook, in a format that is suitable for use in
an emergency situation.
NOTE: The Emergency Response Guidebook (ERG) is constantly being updated, is FREE, and available
online at website address http://hazmat.dot.gov/pubs/erg/gydebook.htm
Annex B is the Incident report format for an accident involving the transport of dangerous goods by
road, and is not dealt with here.
In 3.1.15 of SANS 10232 reference is made to “the relevant national legislation”. In South Africa this
means the National Road Traffic Act, 1996 (Act No. 93 of 1996).
In 4.2.1 of SANS 10232 and in annex A reference is made to “the relevant government department”.
In South Africa this means the Department of Transport, Dangerous Goods Inspectorate.
Part 3 of Standard 10232 is the Emergency Response Guide (ERG)
Part 1 of SANS 10232 deals with Scope
Part 1.1 covers standard procedures of initial response, in the form of Emergency Response Guides
(ERGs) that are to be followed by a first responder upon arrival at the scene of an incident which
involves the transport of materials that are classified as dangerous goods in accordance with SANS
10228. The ERGs are intended to be used by the first responder or by the emergency services until
more detailed information on the properties of each material and its treatment becomes available.
An ERG is compiled for a group of materials that share the same emergency response.
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ERGs facilitate the early assessment of the potential hazards and indicate the response that should be
taken to mitigate the incident.
Part 1.2 of SANS 10232 is Annex A (Emergency Response Guidebook) of SANS 10232 and is a separate
document in a format that is convenient for the personnel of certain services, who, by the nature of
their duties, are likely to encounter situations where they might be required to assume the role of
first responder. The Emergency Response Guidebook is intended for use in incidents that involve the
transport of dangerous goods by road, in accordance with SANS 10232-1, or by rail, in accordance with
SANS 10232-2 and, to a limited extent, incidents that involve goods in storage, in accordance with
SANS 10263.
Part 2 of SANS 10232 deals with normative references.
The following referenced documents are indispensable for the application of SANS 10232. All
normative documents are subject to revision and, since any reference to a normative document is
deemed to be a reference to the latest edition of that document, parties to agreements based on
SANS 10232 document are encouraged to take steps to ensure the use of the most recent editions of
the standards indicated below. Information on currently valid national and international standards
can be obtained from Standards South Africa.
SANS 10228, The identification, and classification of dangerous goods for transport.
SANS 10232-1, Transport of dangerous goods – Emergency information systems – Part 1: Emergency
information system for road transport.
SANS 10232-2 (SABS 0232-2), Transport of dangerous goods – Emergency information systems – Part
2: Emergency information system for rail transport.
SANS 10232-4, Transport of dangerous goods – Emergency information systems – Part 4: Transport
emergency card.
SANS 10263 (SABS 0263), The warehousing of dangerous goods – Enclosed storage areas and covered
and uncovered outdoor storage yards.
United States Department of Transport. Research and Special Programmes Administration.
Emergency Response Guidebook. Washington.
NOTE: The Emergency Response Guidebook (ERG) is constantly being updated and the documents are
freely available online at website address http://hazmat.dot.gov/pubs/erg/gydebook.htm
Part 3 of SANS 10232 deals with definitions and abbreviations
Part 3.1 of SANS 10232 covers definitions and for the purposes of this document, the following
definitions apply:
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❖ base station - local branch of the emergency service to which the first responder belongs, and
from which he normally operates;
❖ dangerous goods - commodities, substances and goods listed in SANS 10228;
❖ dangerous goods declaration - document that describes and quantifies the dangerous goods
being transported from a consignor to a consignee;
❖ dangerous goods placard - single placard with separate, delineated zones for goods
identification, telephonic advice numbers and the appropriate hazard class diamond;
❖ emergency response guide (ERG) - list of potential hazards and appropriate emergency
responses associated with dangerous goods and applicable in an incident.
❖ first responder - first person to arrive at the scene of an incident, who is able to correctly
identify the goods and hazards, and to communicate with an emergency service, either directly
or through a base station.
❖ first response - response(s) of a first responder on arrival at the scene of an incident.
❖ incident - unplanned event during the transport or storage of dangerous goods which involves
incidents such as leakage, spillage, fire, or other unplanned events.
❖ initial isolation distance - minimum distance, in metres, at which people have to be kept from
the spill.
❖ in-place protection - protection that involves moving persons into buildings and keeping them
inside until the danger has passed.
❖ protective clothing - special clothing required for protection against the direct or indirect
effects of dangerous goods at the scene of an incident.
❖ small spill - leakage from a single package of capacity not exceeding 200 kg or 200 L, or from a
small cylinder, or a small leakage from a package exceeding 200 kg or 200 L.
❖ transport emergency card - card that lists the hazards and emergency information for a
dangerous substance being transported, and that is intended for use by the driver during an
incident, or by the emergency services, if required.
NOTE: The transport emergency card can either be generated from the European Council of
Chemical Manufacturers' Federation (CEFIC) system, called a TREMCARD, or in accordance with
SANS 10232-4, called a TREC.
Part 3.2 of SANS 10232 deals with abbreviations:
❖ ERG - Emergency response guide (see annex A)
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❖ TREC - Transport emergency card in accordance with SANS 10232-4
❖ TREMCARD - Transport emergency card generated from the European Council of Chemical
Manufacturers' Federation (CEFIC) system
❖ UN No - United Nations number
Part 4 of SANS 10232 deals with requirements, which includes first response procedures and reporting
the incident.
Part 4.1 of SANS 10232 deals with first response procedures. The steps to be taken to identify the
appropriate ERG for implementation at the scene of an incident are described in annex A (see p. 1 of
the Emergency Response Guidebook). The safety precautions outlined in the Emergency Response
Guidebook shall be strictly adhered to. No person shall make any attempt to approach a spill or
suspected leakage unless he is equipped with the appropriate personal protective clothing in
accordance with the information given under the heading “Public safety” of the appropriate ERG.
Part 4.2 of SANS 10232 deals with reporting the incident.
A written report (in the format given in annex B of SANS 10232 but not dealt with here in further
detail) shall be completed and signed by the first responder and forwarded to the relevant
government department (this means the Department of Transport, Dangerous Goods Inspectorate)
within 24 hours of the incident. A report is required in respect of any incident involving a vehicle that
carries a dangerous goods placard. A separate report shall be completed for each vehicle carrying a
dangerous goods placard and involved in the same incident.
NOTE 1: If a driver is stopped by a law enforcement officer for inspection, for example at a weigh
bridge, the event will constitute an incident if any spillage or risk thereof is noted (overloading
represents a risk of spillage). The law enforcement officer will then be regarded as the first responder
and will be required to complete the report on the incident.
NOTE 2: If a driver has pulled off the road for a scheduled rest period and has entered the rest period
in his log, the rest period will not be regarded as an incident.
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ADDITIONAL READINGS
• www.labour.gov.za
• http://hazmat.dot.gov/pubs/erg/gydebook.htm
US 242987 – Identify, pack, mark, and label dangerous goods for transportation by
air
• Identifying dangerous goods for transportation by air.
• Identifying and applying packaging requirements for the transportation of dangerous goods by
air.
• Identifying and applying the marking and labelling of dangerous goods for transportation by air.
SO1 IDENTIFY DANGEROUS GOODS FOR TRANSPORTATION BY AIR
AC 1 – Dangerous goods are identified and described according to un/id number and by name as it
relates to international codes and regulations.
This has been covered in US 242986 – SO 3
AC 2 – The proper shipping name, class, division, and sub risk are identified as it relates to
international codes and regulations
This has been covered in US 242986 – SO 3
AC 3 – Packaging group, limitations on passenger and cargo aircraft as well as limited quantities are
identified as it relates to the International Civil Aviation Organisation regulations
This has been covered in US 242986 – SO 3
AC 4 – Special provisions and emergency response procedures are identified, described, and applied
according to the International Civil Aviation Organisation regulations
This has been covered in US 242986 – SO 3
SO2 - IDENTIFY AND APPLY PACKAGING REQUIREMENTS FOR THE TRANSPORTATION
OF DANGEROUS GOODS BY AIR
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AC 1 – The shipper's responsibility in the packaging of dangerous goods for transportation by air is
described according to the International Civil Aviation Organisation regulations
This has been covered in US 242986 – SO 1 – AC 6
It is a violation of law to tender cargo containing dangerous goods that have not been properly
declared, identified, packaged, marked, labelled, or documented. It is the shipper’s responsibility to
ensure this has been done and that all regulations have been complied with. Failure to properly
identify a dangerous goods shipment can result in penalties or even imprisonment.
The shipping of hazardous materials can pose a serious danger to anyone who might come in contact
with the shipment. There is also the danger of damage to property.
It is the shipper’s responsibility to ensure dangerous goods have been correctly classified and that all
regulations have been complied with.
AC 2 – Types of packaging for the transportation of dangerous goods by air is identified and described
according to the International Civil Aviation Organisation regulations
With few exceptions, dangerous goods must be packed for transport, according to a specific packing
Instruction which is assigned based on the classification and identification of the material or
substance.
Source: https://chem-tran.com/
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Packaging must:
• be of good quality
• be compatible with their contents
• be able to withstand the normal conditions of air transport
They must meet general packing requirements and, in addition, most of
them are required to meet prescribed specifications and performance
tests for the design type of the packaging. This packaging must bear a
package specification marking. This is shown by the UN marking and this
will be on all packages including certain items where this will be
embossed into the metal or plastic, as per the example below.
There are 4 main types of packaging as per the following definitions from the IATA DGR.
IATA: Single packaging: Are packaging which do not require any inner packaging in order to perform
their containment function during transport.
IATA: Composite packaging: Packaging consisting of an outer packaging and an inner receptacle so
constructed that the inner receptacle and the outer packaging for an integral packaging. Once
assembled, it remains thereafter an integrated single unit; it is filled, stored, transported, and
emptied as such.
IATA: Combination packaging: Are a combination of packaging for transport purposes, consisting of
one or more inner packaging secured in an outer packaging in accordance with the relevant
provisions of Section 5 (Packing)
IATA: Intermediate Bulk Containers (IBCs): Are rigid or flexible portable packaging that:
a) Have a capacity of
Less than 3,000 L for solids and liquids of Packing Group II and III;
Less than 1,500 L for solids of Packing Group I when packed in flexible, rigid
plastics, composite, fibreboard, and wooden IBCs;
Less than 3,000 L for solids and liquids of Packing Group I when packed in metal
IBCs;
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Less than 3,000 L for radioactive material Class 7;
b) Are designed for mechanical handling.
c) Are resistant to the stresses produced in handling and transport, as
determined by tests.
Generally, on passenger aircraft only combination packaging is permitted but sometimes single
packaging is also allowed for certain low hazard (i.e. Packing Group III) dangerous goods.
Many dangerous goods in small quantities can be contained safely in good quality combination
packaging which meets construction requirements and are capable of withstanding drop and
stacking tests but are not subject to a full testing regime. Such dangerous goods are said to be in
limited quantities which has been discussed in US 242986, however as a summary;
Goods shipper in limited quantities are still classified as dangerous goods, and still need to have a
DGD (Dangerous Goods Declaration), however they are not subject to the standard packing
instructions. There are specific packing instructions for limited quantities that will always begin with
a Y e.g.: Y440
If the dangerous substance or article is not alone in the package, we have what is known as an outer
package. The package may be grouped together with other packages in an overpack or it may be
loaded together with other cargo in a container or ULD (Unit Load Device).
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IATA: OVERPACK: An enclosure used by a single shipper to contain one or more packages and to
form one handling unit for convenience of handling and stowage. Dangerous goods packages
contained in the overpack must be properly packed, marked, labelled and in proper
condition as required by these Regulations. For cooling purposes, an overpack may contain Carbon
dioxide, solid (dry ice), provided that the overpack meets the requirement of Packing Instruction 954.
(A Unit Load Device is not included in this definition).
Source: https://www.basiccrating.com/dangerous-goods-group/
All these different ways of packing imply different conditions that need to be addressed in marking,
separation, and loading.
A primary concern is to ensure that different forms of dangerous goods are kept apart if they do not
agree with one another. Some forms of explosives, for instance, should not be loaded or packed
together.
The Dangerous Goods List provides references to packing instructions. These are comprehensive
instructions on how the substance or article must be packed, including the materials to be used in
the package and provisions for ventilation, shock absorption etc.
There are generally three primary packaging options for dangerous goods shipped under the
international standards:
1) specification packaging
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2) limited quantities packaging
3) excepted quantities packaging
There are specific quantity limitations for each material under each option, this is noted in the “blue
pages” of the IATA DGR and although this has been covered, below is a summary.
Specification Packaging:
Example from the IATA DGR:
Under the international standards, specification packaging is generally performance-tested
packaging, developed and tested under the United Nations (UN) packaging specifications. As
mentioned earlier, the severity of tests used to qualify packaging is keyed, in part, to the Packing
Group of the material that is intended to go in the packaging. Internationally recognised testing
specifications are found in Section 6 (and Section 10 for radioactive materials) in the IATA Dangerous
Goods Regulations (Part 6 of the ICAO Technical Instructions). The performance testing requirements
illustrate clearly why a shipper must know the technical characteristics of the chemical being shipped.
A typical testing regime (e.g., for a drum intended to contain flammable liquid) includes a drop test,
a leak-proof test, internal pressure (hydraulic) test, and a stacking test. The Packing Group become
important with reference to the drop test, since the drop height varies with the Packing Group.
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The internal pressure test is keyed to the vapour pressure of the liquid that is to be packaged. Also,
important, and sometimes overlooked for combination packaging is the requirement for inner
packaging to satisfy an internal pressure test and this, too, is linked to the vapour pressure of the
material.
Limited Quantities Packaging:
Example from the IATA DGR:
Certain materials in Packing Groups II and III are eligible to be transported under packaging
exceptions for "limited quantities." These exceptions allow use of non-specification combination
packaging (i.e., packaging that has not been submitted for testing against the UN testing regime) for
net quantities of materials that are further limited than for specification packaging, provided that the
packages are capable of surviving a 1.2-meter (4-foot) drop test. Materials authorised for packaging
under limited quantity exceptions are shown in the IATA Alphabetical List of Dangerous Goods with
italicised packing instructions preceded by the letter "Y." (In ICAO, the limited quantities exceptions
are discussed in Part 3 Chapter 4.) Limited quantities shipments are subject to all communication and
documentation requirements.
Excepted Quantities Packaging:
Example from the IATA DGR:
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Very small quantities of certain dangerous goods are authorised to be shipped without hazard labels
or specific dangerous goods documentation under the "excepted quantity" provisions. A red-
bordered label is presented as the conventional way of satisfying the package marking requirement.
Though excepted quantities do not require the regular labelling of dangerous goods they do require
labels stating that they are “Dangerous Goods in Excepted Quantities” stating class and UN-number
of the contents. When packing these goods, it is not necessary to use the approved packages
normally required for dangerous goods. It is sufficient to use “good quality” packaging according to
the specifications in the regulations.
AC 3 – Packing groups are explained and described according to the International Civil Aviation
Organisation regulations
We have already covered the packing groups in a previous section, so just to recap here then:
Dangerous goods must always be transported in approved packages unless they are acceptable in
“Excepted quantities” or “Limited quantities”, or if they are not restricted.
Approved packages are recognised by the UN mark.
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This mark is always followed by a number of codes signifying type, packing group, limitations, year
of manufacture etc. The mark implies that the construction of the package corresponds to a design
type that has been tested according to specifications set down in the regulations. The tests are
definitely not kind to the packages. They are required to survive drops, heating, drowning, punctures,
and many other forms of torture.
❖ Packing group I – great danger.
❖ Packing group II – medium danger
❖ Packing group III – minor danger
Most substances have been assigned a packing group based on technical
criteria while some, however, have been assigned based on experience.
It is the Shipper’s responsibility to ensure that an article or substance is
identified and classified correctly and that it is packed in compliance with
the relevant regulations. The operator must comply with the
requirements for acceptance, storage, loading, inspection, provision of information, emergency
response, retention of records and training.
A primary concern is to ensure that different forms of dangerous goods are kept apart if they do not
agree with one another. Some forms of explosives, for instance, should not be loaded or packed
together.
The Dangerous Goods List provides references to packing instructions. These are comprehensive
instructions on how the substance or article must be packed, including the materials to be used in
the package and provisions for ventilation, shock absorption etc.
AC 4 – Packing instructions are applied according to the International Civil Aviation Organisation
regulations
Before we proceed with details on packing instructions, we need remember to consider the State
and Operator variations that were discussed in US 242986 SO1 – AC 7, as there may be additional
requirement applicable.
NB!! The shipper is responsible for all aspects of the packaging of dangerous goods in compliance
with the necessary regulations.
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Under section 5 of the IATA DGR is Packing. There are also the “yellow pages” which are all the
packing instructions needed for the packing of dangerous goods for airfreight. Take note that the
packing instructions will always start with the number that corresponds to the primary classification
of the cargo. For example. All class 3 goods (flammable liquids) will have packing instruction that
begins with a 3.
There are 2 types of instructions as per the below image:
1) The packing instructions specific to Limited Quantities
2) The packing instructions for specific packaging requirement for passenger and cargo aircraft.
General packaging requirements, which apply in virtually every case, are detailed in the introductions
to the Packing Instructions (Section 5 in IATA; Part 4 in ICAO). Among the general packaging
provisions are the following requirements:
1. The packaging material in direct contact with the dangerous goods must be resistant to any
chemical or other action of the goods
2. The materials of the packaging must not contain substances which may react dangerously
with the contents, form hazardous products, or significantly weaken the packaging.
Before we look at the packing instructions, we need to cover the Packaging Type and Material Codes
used as the nomenclature for the type of packaging and the construction material:
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In keeping with the above extract from the IATA DGR for UN 1203 - Petrol, we have included the 3
packing instructions as circled in yellow:
Y341 – Packing instruction for Limited quantities:
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353 – Packing instruction for Passenger and CAO:
364 – Packing instruction for CAO
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The packaging instruction is as the name suggests. This is an INSTRUCTION on how to PACKAGE the
goods in question. This will be part of the carriers checklist to ensure that all compliances are met.
Lastly we need to look at the details regarding specification marking:
Specification packaging marking:
The previously mentioned types of UN approved packaging must be marked with the appropriate
details of the packaging.
Here are a few examples.
UN Packaging Mark
Packages that meet UN’s standard are called UN Specification packages and have certain UN
Specification markings displayed on the package itself.
The UN packaging mark indicates a successfully tested design type and compliance with the
provisions of relevant international convention, if applicable, which are related to the manufacturing
(but not to the use) of the packaging. Therefore, the mark does not necessarily confirm that the
packaging may be used for any substance.
The marking is intended to be of assistance to packaging manufacturers, re-conditioners, packaging
users, carriers, and regulatory authorities. In relation to the use of a new packaging, the original
marking is a means for its manufacturer to identify the type and to indicate those performance test
requirements that have been met.
Each packaging intended for use should bear markings which are durable, legible, and placed in such
a location and of such a size relative to the packaging as to be readily visible.
Below is an extract from the IATA DGR showing various examples of the UN specification packaging
markings .
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a) The United Nations packaging symbol or the capital letters “UN”
b) The code designating the type of packaging
c) A letter designating the packaging group or groups for which the design type has been
successfully tested:
• X for packing groups I, II and III
• Y for packing groups II and III
• Z for packing group III only;
d) Single packaging intended to contain liquids, a number indicating the relative density for which
the design type has been tested, this may be omitted if the relative density does not exceed 1.2.
OR for packages intended to contain solids or inner packaging a number corresponding to the
maximum gross weight.
e) followed by: •for single packaging intended to contain liquids, the hydraulic test pressure which
the packaging was shown to withstand, in kPa, rounded down to the nearest 10 kPa; or for
packaging intended to contain solids or inner packaging, the letter “S” (all salvage packaging);
f) The last 2 digits of the year during which the packaging was manufactured
g) The state authorising the allocation of the mark shown
h) The name of the manufacturer
Below is another image as an example:
Source: https://www.thecarycompany.com/insights/articles/un-ratings-understanding-un-markings
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AC 5 – The United Nations specifications relating to packaging are identified and applied according
to International Civil Aviation Organisation regulations
This has already been covered in US 242986 and in this US 242987. All reference to ICAO and IATA
are an extension of the UN.
SO3 - IDENTIFY AND APPLY THE MARKING AND LABELLING OF DANGEROUS GOODS FOR
TRANSPORTATION BY AIR
AC 1 – The shipper's responsibilities relating to the marking and labelling of dangerous goods for
transportation by air are identified and described according to the International Civil Aviation
Organisation regulations.
This has already been covered in US 242986 SO 1, AC 6
AC 2 – The types of marking and labelling for packages are identified and described as it relates to
the International Civil Aviation Organisation regulations.
As previously covered, there are labels that correspond for the types of dangerous goods according
to the classification. This was covered in US 242986 SO 3, AC 1.
The correct marking and labelling of dangerous goods is very important. It may be the clearest way of
identifying a package containing dangerous goods in a stressful environment, especially if the package
has been damaged and there is risk of contamination.
If a specification package is selected, it must be marked to show that it has been tested in accordance
with the specifications. Details on this marking requirement are shown in Section 7 of the IATA
Dangerous Goods Regulations.
Shippers must recognise that if they are responsible for putting the specification markings on a
package, then they must ensure that the package has satisfied all requirements, including chemical
compatibility and performance of all tests. This last point on testing is essential. Careful record keeping
is required in this area since Civil Aviation Authority inspectors may want to see all evidence of
package testing when they conduct routine inspections of shipper facilities or investigate incidents.
Once the correct package has been selected and filled, it must be marked and labelled with the correct
hazard information. The required hazard labels for each proper shipping name are identified in the
IATA List of Dangerous Goods (ICAO Dangerous Goods List), and the proper shipping name and UN
number must appear on the package in association with the label.
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Handling labels, such as the CARGO AIRCRAFT ONLY and the orientation arrows, must be applied when
appropriate. Examples of which are shown in the next AC
AC 3 - The quality and specifications of markings and types of labels are explained and applied
according to the International Civil Aviation Organisation regulations
Packages are always marked and labelled for easy visibility and information on the contents. These
are very important when preparing a dangerous goods package for transportation. Labels often
communicate the hazards associated with the package, and marking ensure that the shipment is
handled so that spills accidents and exposure are prevented.
Labels:
Packages are labelled to indicate the hazard(s) the contents present in transport. We have seen the
various labels depending on the class or division of the goods in US 242986 SO 3, AC 1. In addition,
other labels may specify handling conditions. Hazard labels convey information by colour and symbol;
they are diamond shaped, with minimum dimensions of 100 mm x 100 mm. Packages may have more
than one hazard label when:
• there are different dangerous goods of different primary hazards in one package; or
• the one item of dangerous goods has a primary hazard and one or more subsidiary risks
Handling labels are affixed to a package when:
• it contains a liquid and must be kept upright (orientation label)
• it is for transport only on a cargo aircraft (cargo aircraft only label)
• it needs to be kept away from heat. Usually explosives or flammable liquid.
Handling labels vary in colour, symbol and size, and some examples are shown here below:
Package orientation labels, these will indicate which direction in order to place the goods in order to
remain upright.
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Cargo Aircraft Only (CAO) labels:
Keep away from heat:
Marks:
The standard markings found on all packages of dangerous goods are:
• proper shipping name
• UN/ID number
Other markings that may be found in specialised circumstances include:
• the net quantity and gross mass of the package for explosives
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• the type of package and identification mark and trefoil symbol (when required) for radioactive
materials
• the net mass for dry ice
AC 4 – The marking and labelling when packaging dangerous goods for transportation by air is
explained and described according to the International Civil Aviation Organisation regulations
This has been covered in the above ACs, however below is further information specifically from
Chapter 6 of Annex 18 to the Convention on International Civil Aviation deals with labelling and
marking.
• Chapter 6.1 deals with labels and Chapter 6.2 deals with markings. Chapter 6.3 deals with
languages to be used for markings.
• Chapter 6.1 (labels) states: Unless otherwise provided for in the Technical Instructions, each
package of dangerous goods shall be labelled with the appropriate labels and in accordance
with the provisions set forth in those Instructions.
• Chapter 6.2.1 (markings) states: Unless otherwise provided for in the Technical Instructions,
each package of dangerous goods shall be marked with the proper shipping name of its
contents and, when assigned, the UN number and such other markings as may be specified in
those Instructions.
• Chapter 6.2.2 (specification markings on packaging) states: Unless otherwise provided for in
the Technical Instructions, each packaging manufactured to a specification contained in those
Instructions shall be so marked in accordance with the appropriate provisions of those
Instructions and no packaging shall be marked with a packaging specification marking unless
it meets the appropriate packaging specification contained in those Instructions.
• Chapter 6.3 (languages to be used for markings) states: Recommendation - in addition to the
languages 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 markings
related to dangerous goods.
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AC 5 – The fixing of labels is described and applied as it relates to the International Civil Aviation
Organisation regulations
We have already covered this topic in the previous sections but let us just recap here. Dangerous
goods may not be loaded on an aircraft with damaged or missing labels.
Before accepting a package of dangerous goods for loading, the person supervising the loading must
inspect the goods to make sure the packages or labels are not damaged. He must also make sure all
the documentation is in order and that the goods are loaded and secured safely.
If a specification package is selected, it must be marked to show that it has been tested in accordance
with the specifications. Details on this marking requirement are shown in Section 7 of the IATA
Dangerous Goods Regulations (Part 6, Chapter 2 in ICAO).
Shippers must recognise that if they are responsible for putting the specification markings on a
package, then they must assure that the package has satisfied all requirements, including chemical
compatibility and performance of all tests. This last point on testing is essential. Careful record keeping
is required in this area since Civil Aviation Authority (CAA) inspectors may want to see all evidence of
package testing when they conduct routine inspections of shipper facilities or investigate incidents.
Once the correct package has been selected and filled, it must be marked and labelled with the correct
hazard information. The required hazard labels for each proper shipping name are identified in the
IATA List of Dangerous Goods (ICAO Dangerous Goods List), and the proper shipping name and UN
number must appear on the package in association with the label. Note that for most generic (i.e.
"n.o.s.") proper shipping names, additional technical names for the hazardous constituents are
required to appear on the package and accompanying documentation. Handling labels, such as the
CARGO AIRCRAFT ONLY and the orientation arrows, must be applied when appropriate.
To summarise:
The ability to use the ICAO Technical Instructions is important because airlines operate in a global
environment. Airlines, therefore, need to be able to keep their training as streamlined as possible,
and, to avoid costly and potentially confusing "double training" in both domestic and international
regulations, many countries will not accept shipments that are not prepared in accordance with the
international classification, packaging, and communication standards.
The ICAO standards are actually used in the air carrier industry in a form published by the International
Air Transport Association (IATA) as the Dangerous Goods Regulations (IATA DGR). These regulations
are an important airline industry reference, known world-wide, as a source of information about the
requirements and procedures recognised throughout the airline industry.
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