China is tightening its administration and management of transport of dangerous goods. To avoid incurring the wrath of China’s central government, relevant enterprises and provincial administrative authorities tend to be extremely polarized in their response to heightened administrative requirements. They either refuse to transport dangerous goods, or adopt a "one size fits all approach" in which all dangerous goods are managed using the same strict standards applicable to higher risk dangerous goods. These approaches have hampered trade and transport of dangerous goods.
During CRAC 2018, REACH24H Group invited Mr. Chan (former MOT official) to share his opinion and suggestion on the transport and use of small packages of dangerous goods. The official recommended that enterprise use Limited Quantities and Excepted Quantities Standard (which is introduced in the "United Nations Recommendations on the Transport of Dangerous Goods Model Regulations") (联合国危险货物运输建议书规章范本) as their primary reference. Based on the UN model, China combined its own practice and published two national standards implementing UN Limited Quantities and Excepted quantities Standard:
- GB 28644.1-2012 the List of Excepted Quantities of Dangerous Goods (危险货物例外数量及包装要求)
- GB 28644.2-2012 the List of Limited Quantities of Dangerous Goods (危险货物有限数量及包装要求)
These two standards outline the stipulations associated with transport of small packages of dangerous goods. The Measures for the Safety Administration of Road Transport of Dangerous Goods (危险货物道路运输安全管理办法) also includes a new chapter focusing on LQ and EQ standard.
In the delivery industry, there is an urgent need for LQ and EQ Standard. In 2018, China released the Provisional Regulation for Express Delivery (快递暂行条例). The Regulations do not mention LQ and EQ Standard even though stakeholders strongly recommended the development and implementation of the standard during the public consultation period on the draft standard. An important part of the Regulation-the Item List for Prohibited Delivery and Its Measure (禁止寄递物品的目录及管理办法) are being drafted. Currently, the Regulations on Items Prohibited for Delivery is in force. Items that are explosive, flammable, corrosive, poisonous, infectious and radioactive are banned from delivery. It is not practical to fully ban the delivery of dangerous goods. China referenced UN standards during the development of its own domestic regulations on dangerous goods transport via sea/air China GB 28644.1-2012/GB 28644.2-2012. In these sectors development of LQ and EQ Standard would also surely help tackle the difficulties inherent in transport of small packages of dangerous goods.
To further implement the LQ and EQ standard, Mr. Chan made the following suggestions:
- Authorities are urged to introduce and apply the LQ & EQ standard to the delivery sector. Rules could be written on the List of Prohibited Items for Delivery and Management Measures.
- Promoting the implementation of GB 28644.1-2012 and GB 28644.2-2012. It is suggested that relevant regulatory authorities include these two standards in the road transport regulatory system.