The China SAWS is inviting public commentary on a guideline for the traffic safety management of hazardous chemicals. The consultation will be open for about 30 days till 8 Feb 2013. This guideline is aimed to instruct companies of hazardous chemicals (HC) transport to achieve the whole process safety management and help eliminate road accidents involving hazardous chemicals.
This document comprises eleven chapters specifying main technical requirements for hazard identification and risk assessment, transport packaging, specialized vehicles, transport workers, contractor management, loading and unloading operation, itinerary management and emergency control. Three annexes along with three check-up sheets are attached to the body part, illustrating respectively the examination key points on departure preparations of HC vehicle driver, daily checkup lists for the HC tanker, and HC tanker filling check-up list. All provisions in the Guideline except the annexes will be compulsory upon its entry into force.
This article hereby attempts to give a brief introduction on a few important elements of the draft Guideline.
Applicable Scope
The draft Guideline is designed to address the safety control of Hazardous Chemicals road transport so the concerned transport companies must be aware of the differences between hazardous chemicals and hazardous (or dangerous) goods. It is important to note that some chemicals which may not fall under the group of dangerous goods are identified with known hazardous properties and therefore be regarded as hazardous chemicals subject to the draft Guideline.
The document adopts the internationally popular norms of the whole process safety management, which consists of three interrelated aspects of regulatory requirements: loading operation, itinerary management and unloading operation. Therefore, the HC transport companies should make the three requirements the key focuses in their practical business activities.
Hazard Identification and Risk Assessment
The main purpose of the hazard identification and risk assessment is to carry out systematic identification for all possible risks and potential damages during the process of road transport. This enables the pertinent prevention and control measures to be worked out in advance. Proposed in the draft Guideline, the methods of risk assessment cover but are not limited to the four items listed as follows:
a) Fault hypothesis analysis;
b) Approach of fault hypothesis/Checklist analysis;
c) Safety Checklist Analysis (CSA) Approach;
d) Preliminary Hazard Analysis (PHA).
Results of the risk assessment should be generated into written documentation and be made acquainted to all affected personnel. The draft Guideline also illustrates what negative factors or impacts have to be taken into account in the risk assessment of loading/unloading operation and road transport.
Transport Packaging
Basically, consigners of hazardous chemicals are required to determine the HC package category (or packing group) based on the status and hazard properties of a chemical as per GB/T 15098 and GB 12268. For HCs not included in GB 12268, consigners have the responsibility to ask a MOT-approved institute to identify its transport conditions.
Technical conditions of the HC containers should be consistent with the requirements specified in GB 12463. The HC precautionary label aligned with the China GHS system, the DG packing symbol as well as the storage and transport symbols attached outside the HC containers need to be consistent with the technical requirements specified in GB 15258, GB 190 and GB/T 191.
In this chapter, the draft specifies in particular some transport packaging requirements for different hazardous chemical tanks, including atmospheric tank, pressure tank, tank or bulk container, etc.
Other specifications of the draft formulation
According to the China SAWS, there are 6,800 HC transport companies currently registered in China, with 120,000 HC vehicles and 353,000 HC transport workers. Around 0.2 billion tons of HC products covering over 3,000 categories are transported by road every year in the country. Statistics show that the main causes of HC road accidents are, in sequence according to their influence,, weak (corporate) management, personnel delinquency, faulty transport package, faulty of specialized vehicles and equipment, and negative traffic and environmental factors, etc.
On the other hand, multiple enforcing authorities are involved in the regulation of HC road transport, including the SAWS, MOT, MPS, AQSIQ, MEP, MOFCOM, FDMPS and more. Due to the reasons of overlapping management, vague enforcement margin and the absence of collective and systematic collaboration, the integrated and consistent pattern of enforcement are hard to achieve in this field. For this reason, the draft Guideline makes necessary the concept of systematic management.
Finally, the draft has consulted the relevant internationally acknowledged regulations, standards of other countries as well as safety management practice of some foreign-funded companies in China, mainly the UN Recommendations on the Transport of Dangerous Goods and the Safety and Quality Assessment (SQAS) system that has been running successively among the European logistic suppliers over the last two decades. Based on that, the editor team has further conducted some on-scene investigations upon six HC manufacturers and collected valuable data. Shanghai SECCO, Dow China, BASF China and other leading chemical companies have participated in the formulation of the draft.
