China Ministry of Transport (MOT) published the second draft of Measures for the Safety Administration of Road Transport of Dangerous Goods for public consultation on Jun 28, only three months after the issuance of the first draft. (See Chemlinked news)
Chapter 3 of the draft Measures has been one of the focal points as it stipulates the criteria consignors should meet to avail of limited quantity (LQ) and excepted quantity (EQ) exemptions. Carriers transporting dangerous goods packed in EQ or LQ are exempt from requirements on road TDG license, special vehicle and placarding, personnel qualification and transportation control (e.g. route, time period, speed, etc.). Training of relevant employees and archiving of the training records are not exempted.
In the 2nd draft we see a favorable change that in addition to safe production license holders and academic, researching or military institutions, operators who have acquired hazardous chemicals operation license in accordance with SAWS Order 55 are also eligible to LQ/EQ exemptions.
Table 1 - Requirements and exemptions for road transport of dangerous goods packed in EQ/LQ
| EQ | LQ |
Eligible consigners | • Holders of safe manufacturing license (SAWS Order 41) • Holders of hazardous chemicals operation license (SAWS Order 55) • Academic, researching, military, etc. institutions | |
Standards for packaging, labeling, package testing, quantity limit of each inner package and outer package | • GB 19269 Safety Regulations on the Package Inspection of Dangerous Goods for Road Transport | |
• GB 28644.1 Exception Quantity and Package Requirements of Dangerous Goods | • GB 28644.2 Limited Quantity and Package Requirements of Dangerous Goods | |
Quantity limit for each transport unit | Number of packages offered as EQ <= 1000 | Gross mass of dangerous goods offered as LQ <=1000kg |
Mixed stowage and segregation | • JT 617 Rules of Transportation of Dangerous Goods by Vehicles • JT 618 Operation Procedures of Motor Transportation, Loading and Unloading of Dangerous Goods | |
Shipping documents | • Packaging performance test report, or written self-statement of compliance with GB 28644.1 & GB 19269 • Inventory for TDG consignment which includes indication of “dangerous goods packed in excepted quantities” and the number of EQ packages | • Packaging performance test report, or written self-statement of compliance with GB 28644.2 & GB 19269 • Inventory for TDG consignment which includes indication of “dangerous goods packed in limited quantities”, and the number and the gross mass of LQ packages |
Industry stakeholders are disappointed to see the quantity limitation that the gross mass of all LQ packages carried in one transport unit shall not exceed 1000 kg remains unchanged and too strict as compared with internal practices. However, the authority believes prudence is necessary and reasonable when inaugurating the LQ/EQ exemption policies for the first time in China.
* Mr. Jinzhong Wu, a core participant of the drafting committee of the Measures, will give a presentation on REACH24H's Chemical Regulatory Annual Conference 2016 (Sep 20~21, Shanghai). Please click here to find out more about the conference.
