Change has come
Responsible Care – a global chemical industry initiative by the Chemical and Allied Industries’ Association (CAIA) – recently held a Transportation of Dangerous Goods seminar, at which a range of challenging topics and changes in legislation were diiscussed. THATO TINTE reports.
Through its Responsible Care initiative, CAIA aims to help improve health and environmental performance in the chemical industry and, ultimately, reduce accidents and undesirable events during the transportation and handling of dangerous goods.
Tommie Muller, an independent CAIA-approved auditor, discussed changes made to the Safety and Quality Assessment System (SQAS).
The assessment, which is carried out by an independent assessor approved by CAIA, uniformly evaluates the quality, safety, security and environmental performance of logistics service providers (LSP’s) and chemical distributors.
There are four types of SQAS assessments: tank cleaning (wash bays), warehouse, rail, and road transport services.
Once assessed, the company is offered a detailed, factual and objective report, which indicates the areas for improvement. Guidelines are also offered to achieve these improvements.
Each of a company’s depots must also be audited and all subcontractors must be SQAS assessed.
Transport companies being audited for the first time need to have statistics and records covering a minimum of three months; while companies requiring re-auditing (two yearly) must ensure this is done within two months after the existing certificate expires.
An electronic database of all approved and registered companies that are “responsible care” verified, is stored by the CAIA. Failing to re-audit before the maximum period lapses will result in the company’s name being deleted off the CAIA database.
Fire permits, which were required previously, have been phased out and a dangerous goods certificate is now required. This amendment is indicated in the Fire Brigades Services Act. Changes have also been made to the layout of the tram card.
Evaluations are carried out against each company’s own standards, and no company is evaluated against another.
Muller identified three issues of importance, which form part of the new changes: For a status of “approved” to be granted, a minimum pass rate of 90 percent overall is required; auditees must obtain a minimum of 95 percent on the mandatory questions; and a time frame of 30 days will be allowed for companies to achieve these grades.
The assessment weightings have also been increased in some questions.
One of the important amendments is that, if companies do not obtain the score of 95 percent on the mandatory questions, a grace period of two months will be given to allow the company to “get things in order”.
Muller added that, thereafter, a “re-visit by the auditor, re-assessment and re-submission” will take place.
Once final scores have been obtained and the company has passed its assessment, the auditor will issue a certificate of “Approved Supplier” and the company name will be listed on the CAIA supplier and registration base.
The name and contact information of the auditor who conducted the audit will also now appear on CAIA’s electronic database.
Transport companies that have been SQAS audited and are contracted to Sasol will receive two-yearly audits with a minimum score of 85 percent required. Should a company fail to obtain this minimum score, it will immediately be suspended for a period of three months. These companies should also expect unannounced spot audits twice a year.
Eddie Crane, CEO of EC Logistics discussed the revised South African National Standards (SANS) codes and legal updates.
SANS10231 establishes rules and procedures for the safe operation and handling of all road vehicles used to transport dangerous goods in accordance with the vehicles’ load constraints.
Amended procedures include requirements for the consignor, consignee, operator, driver, and qualified persons – and include en-route procedures and cargo handling. These roles are all clearly defined in the respective SANS.
The National Road Traffic Act 93 of 1996 and its amendments make reference to dangerous goods in Chapter VIII (8). Regulations, along with SANS standards, are also referenced in the Act and the Chapter.
Crane listed the following Acts and their amendments as being relevant to the transportation of dangerous goods in South Africa: National Road Traffic Act; Occupational Health and Safety Act (OHSA); Fire Brigade Services Act; Explosives Act; Nuclear Energy Act; Customs and Excise Act; National Environmental Management Act; Fire Arms Control Act; National Water Act and the Hazardous Substances Act.
The Act also lists parties affected by Chapter VIII as: manufacturers; operators; consignors; sub operators; warehouse operators; marketing agents; transport brokers; courier companies; wholesalers; vehicle hire companies and commercial farmers among others.
Crane noted that it is important for all entities and individuals earning financial rewards to comply fully with the legislation and that only a few categories are exempt from this.
SANS 10229 identifies various methods of packaging that are suitable for prescribed maximum quantities of dangerous goods that are transported road or rail.
It gives minimum performance requirements for packaging procedures to be followed for testing or certification approval, and provides details on labels and marking to be displayed on the packaging.
In terms of skills and training, the driver of the dangerous-goods vehicle must have a Category D Professional Driving Permit (Pr-DP-D), be over 25 years of age and be able to implement instructions on the transport emergency card.
Annual training of drivers of both light and heavy vehicles must be conducted by accredited and approved training providers.
Drivers of vehicles with a gross vehicle mass (GVM) in excess of 3 500 kg, who convey dangerous goods of Class 1 to Class 9, are required to have the Pr-DP-D. This also applies to packaged and bulk transportation.
New globally harmonised UN packaging markings for all hazardous material are also available. All over packs are to now be marked with the word “over pack”, proper shipping name, UN number and hazard-class decals for each item of dangerous goods contained in the over pack.
Over packs must not contain goods that can interact dangerously in the event of leakage. The total gross weight of the over pack must also not exceed 30 kg. Mixed loads of dangerous goods transported on a vehicle must also be compatible.
A load-constraints calculation has been given to ensure substance compatibility. A warehouse class-compatibility chart is also provided. Vehicle design requirements and cargo containment for vehicles transporting packaged goods have also been highlighted.
This noteworthy and highly insightful presentation for all chemical and transportation industry members is available for download here.