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UN Recommendations

A wide range of requirements apply when transporting dangerous goods. Most are imposed by international conventions and codes to which New Zealand is a signatory. The most significant is the United Nations Recommendations on the Transport of Dangerous Goods – Model Regulations (the UN Recommendations). These recommendations aim to eliminate or minimise risks, promote safety and facilitate the transport of dangerous goods.

Prior to the UN Recommendations of 1957, each nation developed its own regulations for identifying, classifying and transporting dangerous goods. This caused several problems for international transport. The UN Recommendations take into account land, sea and air transport and form the basis for uniform national and international regulations. The UN Recommendations are updated every two years.

The term ‘Dangerous Goods’ is used internationally to describe the goods covered by the UN Recommendations. These goods are divided into nine classes based on their hazardous properties:

Class 1  Explosives
Class 2  Gases
Class 3 Flammable Liquids
Class 4 Flammable Solids
Class 5  Oxidising Substances
Class 6 Toxic and Infectious Substances
Class 7 Radioactive Material
Class 8 Corrosives
Class 9 Miscellaneous Dangerous Substances

The UN Recommendations also include procedures and requirements for marking, labelling, packaging, segregation, special marks (such as the environmentally hazardous mark and orientation arrows) and documentation. The next section includes examples of some common dangerous goods within each of the classes above.

Common dangerous goods

Common dangerous goods include the following goods listed by UN Class and Division:

  • Class 1 Explosives - rifle ammunition, fireworks, flares, blasting explosives and toy caps. 
  • Class 2.1 Flammable Gases - disposable cigarette lighters and refills for gas lighters, acetylene (for oxy-acetylene welding and brazing), ethylene (for ripening fruit) and hydrogen (for university and some industry use).
  • Class 2.2 Non-Flammable Non-Toxic Gases - carbon dioxide (found in soft drink dispensing machines), oxygen (for hospitals and oxy-acetylene welding), compressed air, freons (for refrigeration, air conditioning and polyurethane manufacture), compressed nitrogen and argon (for welding). Also, liquid oxygen and liquid nitrogen (for industrial applications).
  • Class 2.3 Toxic Gases - methyl bromide and ethylene oxide (for fumigation), chlorine (for commercial swimming pool water sanitation) and ammonia (for industrial freezing works).
  • Aerosols - fly sprays, room fresheners, aerosol deodorants and some oven cleaners etc, are assigned to Division 2.1 or 2.2 depending on their properties.
  • Class 3 Flammable Liquids - petrol, mineral turpentine, kerosene, methylated spirits, enamel paints, car lacquers, polyurethane varnish, two-pot polyurethanes and their solvents, most varnishes and some dry-cleaning fluids, methanol, methyl ethyl ketone and polyester resin kits.
  • Class 4.1 Flammable Solids - fire lighters (Little Lucifers etc), matches, sulphur powder, synthetic camphor and naphthalene (moth balls).
  • Class 4.2 Substances Liable to Spontaneous Combustion - white or yellow phosphorous, copra and unstabilized fish meal.
  • Class 4.3 Dangerous When Wet - Sodium and Potassium metals and Calcium carbide - used to produce acetylene gas.
  • Class 5.1 Oxidisers – Calcium hypochlorite (pool chlorine HTH), some home bleaches and nappy sanitisers, hydrogen peroxide for swimming pool treatment and some fertilisers such as ammonium nitrate. Products used for stripping printed circuit board.
  • Class 5.2 Organic Peroxides - the hardeners from products such as Plastibond, Bondofill etc. Larger quantities are used in manufacturing industries.
  • Class 6.1 Toxic - some pesticides (e.g. most agricultural insecticides and some weed killers), and industry products such as sodium cyanide for metal treatment. Several metal degreasers are poisons, such as chromium salts in electroplating and copper chrome arsenate mixtures for timber preservatives. There are many, many more examples in this class.
  • Class 6.2 Infectious – examples are blood samples from people with infectious and/or notifiable diseases, septic tank effluent wastes, cultures containing pathogen(s) which may cause infection, needles and syringes under the ’needle and syringe programme’.
  • Class 7 Radioactive materials - used in industrial thickness measuring devices, for the sterilisation of medical products and as a treatment for cancer.
  • Class 8 Corrosives – car and truck batteries, glacial acetic acid used for peeling processed fruit, caustic soda (sodium hydroxide) and caustic potash (potassium hydroxide), and acids such as hydrochloric, sulphuric and nitric used in many industrial processes. Many dairy sanitisers and industrial cleaners are corrosive.
  • Class 9 Miscellaneous dangerous goods - a diverse range of substances or articles that have dangerous properties not covered by Classes 1 to 8. The 15th edition of the UN Recommendations lists 34 entries. Class 9 should not be regarded as presenting a lower risk than Classes 1 to 8. It includes blue, brown and white asbestos (cancer hazard), PCBs (environmental and health hazards), some ammonium nitrate fertilisers and Environmentally Hazardous Substances, and lithium ion batteries. Aquatic environmentally toxic substances equivalent to HSNO ecotoxic classification 9.1A and 9.1B are classified as UN Class 9 packing group III for transport. UN Class 9 also includes substances transported at elevated temperature and genetically modified organisms.

Air and Sea Dangerous Goods Codes

International air transport is regulated by the International Civil Aviation Organisation (ICAO) Technical Instructions at government level and the International Air Transport Association (IATA) Dangerous Goods Regulations at the industry level. The ICAO Technical Instructions are incorporated by reference in New Zealand Civil Aviation Rules, Part 92, Carriage of Dangerous Goods. The Civil Aviation Authority acknowledges that compliance with the IATA Dangerous Goods Regulations will result in compliance with the ICAO Technical Instructions.

International sea transport is regulated by the International Maritime Organisation’s (IMO) International Maritime Dangerous Goods (IMDG) Code. The IMDG Code is incorporated by reference in Maritime New Zealand Rules, Part 24A.

These organisations publish Dangerous Goods Codes based on the UN Recommendations which outline the requirements for safely transporting dangerous goods by sea and air. The ICAO Technical Instructions and the IMDG Code are now closely aligned with the UN Recommendations with the text for classification, identification, marking and labelling reproduced from the UN Recommendations. However, there are still some significant differences between the codes, especially in packaging and segregation requirements. These differences usually arise due to the different conditions encountered during transport. This guide identifies these differences.
ICAO and IATA have almost identical requirements. However ICAO recognises state variations while IATA recognises state and operator variations. An example of a state variation is USG 12, which requires all consignments passing through the USA to have emergency response information on the dangerous goods declaration. This information must include a 24-hour emergency contact phone number that provides immediate access to a knowledgeable person. An example of an operator variation is Qantas variation QF-02. The IATA Regulations permit passengers and crew to bring book matches onto aircraft for personal use. QF-02 prohibits this.

All signatory countries to the IMDG Code have almost identical requirements .

New Zealand Transport Legislation

HSNO regulates hazardous substances in all parts of the lifecycle, including transport. In most instances HSNO accepts compliance with the relevant transport rule as providing compliance with HSNO. Not all hazardous substances are dangerous goods for transport, and some dangerous goods for transport (Radioactive Substances and Infectious Substances) are not HSNO hazardous substances.

Maritime Transport Rule 24a regulates the transport of dangerous goods by sea and incorporates by reference the IMDG Code.

Civil Aviation Rule Part 92 regulates the transport of dangerous goods by air and incorporates by reference the ICAO Technical Instructions. Civil Aviation accepts that compliance with the IATA Dangerous Goods Regulations will result in compliance with ICAO.

Land Transport Rule: Dangerous Goods 2005 (Rule 45001/1) incorporates by reference specific parts of the UN Recommendations on the Transport of Dangerous Goods – Model Regulations, the IMDG, ICAO Technical Instructions, IATA Dangerous Goods Regulations and New Zealand Standard - NZS 5433: 2007.

As the specific detail is mandated in the incorporated codes, this document will refer to those codes.

The ICAO and IMDG Codes apply to both domestic and international transport.

The Land Transport Rule requirements (based on the UN Recommendations) have much in common with the IMDG Code. However, there are many significant differences, especially in relation to the size and style of packaging that is acceptable, and some differences in segregation, placarding and documentation requirements. These differences are dealt with in more detail later in the guide.

The HSNO Act and Regulations only apply within New Zealand and on New Zealand aircraft and ships.

Table 1 provides a summary of the codes, regulations and rules that apply to the transport modes.

 

Table 1 Summary – Jurisdiction of Codes
ClassesModeCodeTerminologyJurisdiction
1 to 9* Sea Maritime Rule 24A and IMDG Dangerous Goods NZ and International
1 to 9* Air Civil Aviation Rule Part 92, ICAO Dangerous Goods NZ and International
1 to 9* Rail Land Transport Rule 45001/1 & NZS 5433 Dangerous Goods NZ
1 to 9* Road Land Transport Rule 45001/1 & NZS 5433 Dangerous Goods NZ
1 to 6, 8 and 9* All Hazardous Substances and New Organisms Act 1996 & Regulations Hazardous Substances NZ
6.2 All Health Act 1956
Medicines Act 1981
Infectious Substances affecting Humans NZ
6.2 All Biosecurity Act 1993 Infectious Substances affecting Humans NZ
7 All Radiation Protection Act 1965 & Regulations Radioactive materials NZ
1 to 9* All Health and Safety in Employment (Pressure Equipment, Cranes and Passenger Ropeways) Regulations 1999 Pressure Equipment NZ


* Class 9 under HSNO is ‘Ecotoxic Hazardous Substances’. There are differences between Class 9 Miscellaneous dangerous goods for transport and HSNO Class 9.

Hazardous Substances and New Organisms Act

The Hazardous Substances and New Organisms (HSNO) Act 1996 manages the introduction of new hazardous substances and new organisms (including genetically modified organisms) into New Zealand and manages hazardous substances through their whole lifecycle. From this point on we will only be referring to the hazardous substances part of the legislation.
The Act requires a hazardous substance to be approved by the Environmental Risk Management Authority before it is imported or manufactured. Once an approval is granted, it is generally available for anyone to use to import or manufacture the substance. However, there are some exceptions. Proprietary agricultural compounds and medicines require an additional approval from the appropriate authority. In the case of explosives, each importation of an approved explosive requires a HSNO import certificate.

The HSNO classification criteria are very closely aligned with the criteria specified in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). In addition to the criteria adopted by the GHS, HSNO sets criteria for terrestrial ecotoxicity, which are largely based on USA criteria.

Transport constitutes only part of a substance’s lifecycle. During this phase of the lifecycle a substance is contained in some form of containment (such as packaging). Because HSNO takes account of all stages of the lifecycle, including those parts where the hazardous substance is taken out of its packaging and used, there are several HSNO classifications that are not considered to present a danger during transport. HSNO classifications that are not regulated in the transport codes include: 

  • Category 2.1.1B (medium hazard flammable gases)
  • Category 3.1D (low hazard flammable liquids) 
  • Category 4.1.2G (self-reactive flammable solids, type G)
  • Category 5.2G (organic peroxides, type G)
  • Categories 6.1D & E (low acute toxicity)
  • Classes 6.3, 6.4, 6.5, 6.6, 6.7, 6.8, 6.9 (irritants, sensitisers, chronic toxicity) 
  • Category 9.1C & D (low aquatic ecotoxicity)
  • Classes 9.2, 9.3, 9.4 (terrestrial ecotoxicity).

Compliance with IATA, Civil Aviation Rule Part 92, IMDG, Maritime Rule 24A or the Land Transport Dangerous Goods Rule and NZS 5433 generally ensures compliance with HSNO for packaging, marking, labelling and documentation while being transported.

Note: HSNO labelling, documentation and segregation requirements may apply outside transport modes at transit depots (including ports and airports), and the standard of the inner or consumer package .

Aerosols
The definition of a flammable aerosol under HSNO is now significantly different from the definition applicable for all modes of transport. Many aerosols classified as non-flammable under HSNO will be flammable aerosols for transport, thus HSNO classifications must not be relied upon for transport classification.
 

Significant changes in Dangerous Goods Codes

This section highlights the significant changes that have occurred in the Dangerous Goods Codes in recent years.

The 15th revised edition of the UN Recommendations 2007

This includes numerous amendments, corrections and additions. These changes will appear in the subsequent editions of the IMDG and IATA Dangerous Goods Regulations. It is vital to check the relevant modal code to determine when these changes become effective.

1. Dangerous goods in ‘Excepted Quantities’ have been added in a new Chapter 3.5. Excepted Quantities have been available in air transport for many years. The introduction into the UN Model Regulations and the proposed adoption into the IMDG is another step toward harmonising multi-modal transport requirements.
 
Excepted Quantities Mark
* The Class or Division
** Name and address, or the consignor or consignee, if not shown elsewhere on the package

Excepted Quantities are not available for some dangerous goods e.g. Class 1, 2.1, 2.3, 5.2, 6.2 and 7 may not be transported as Excepted Quantities. There are also numerous specific items that may not be transported as Excepted Quantities. You must refer to the specific modal transport codes for full details.

2. Changed requirements for Lithium Batteries in SP 188.

The 14th revised edition of the UN Recommendations 2005

This includes numerous amendments corrections and additions. The 2006 edition of the IMDG Code, ICAO Technical Instructions 2007-2008 and IATA Regulations 2008 reflect these changes. 
Some significant changes include:

  • Division 6.1 Packing Group III definition aligned with Category 3 in the GHS
  • definitions of Diagnostic Specimens, Biological Products and packaging requirements for Infectious Substances. A test report for Infectious Substances packaging has been introduced
  • introduction of the optional dangerous goods ‘Limited Quantities’ mark. This consists of a line forming a diamond (minimum thickness 2mm), enclosing the UN numbers of all of the dangerous goods in Limited Quantities. Minimum sizes are specified for the lettering.

Limited Quantities Mark

  • This replaces the requirement to mark the proper shipping name and UN number of each dangerous good.
  • The quantity limits for inner packages of dangerous goods in Limited Quantities (Ltd Qty) have been increased as follows:

 

4.1 PG II

from 500 g to 1 kg
4.1 PG III from 3 kg to 5 kg
5.1 PG II from 500 ml or g to 1 litre or kg
5.1 PG III from 1 litre or kg to 5 litres or kgs
6.1 PG III from 3 litre or kg to 5 litres or kgs
8 PG II from 500 ml or g to 1 litre or kg
8 PG III from 1 litre or kg to 5 litres or kgs

Note that some products with these classifications are not permitted to be transported as dangerous goods in Limited Quantities. You must refer to the list of dangerous goods in the UN Recommendations on the Transport of Dangerous Goods or appropriate modal code for details.

NZS 5433

The 2007 edition of NZS 5433 was published in December 2007. There have been a number of amendments and additions since the 2001 revised edition. These include:

  • re-structuring of the Standard into two volumes
  • new information explaining the relationship between HSNO and the dangerous goods Rule (Introduction, Section 2.0.6 and Table 4)
  • revised summary of requirements of the DG Rule (Section 1.4)
  • updated classification information (Section 2)
  • guidance on the use of empty packagings (Section 5.6)
  • information about tracked substances (Section 6.5)
  • new list of segregation groups (extract from IMDG) (Section 8.5)
  • updated segregation table (Table 25)
  • new information on transport procedures for self-reactive substances and organic peroxides (section 10.1)
  • new section on training (Section 12)
  • updated information on the Hazchem code (Appendix A)
  • updated information on labels e.g. new Table C1 (Appendix C)
  • updated dangerous goods declaration form (Appendix D)
  • revised information on infectious substances (Appendix F)
  • complete re-formatting and update of the list of dangerous goods by UN Number, including reference to UN packing instructions (Section 1, Part 2)
  • updated list of special provisions (Section 2, Part 2).

     

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