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IMPROVING THE ADR REGULATIONS
Page 78
Page 79
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by John Darker, AMBIM FLEET ENGINEERS, tank designers and specialist operators of vehicles carrying dangerous substances and articles have a direct interest in current moves to revise the ADR convention. The range of substances and products which qualify for the "dangerous" label currently numbers more than 2000; the number is constantly rising. There are some 12,000 petroleum tanker vehicles in the UK and 2000 or more special product tankers carrying propane, toxics and corrosives.
Although domestic requirements are different in many respects from the ADR rules for international movements by road, Britain's accession to the Common Market will increase the number of cross-Channel movements and this strengthens the case for international standardization of technical design and operational procedures.
Varying views The great variety of products involved and the special interests of particular carriers adds to the difficulty of arriving at consensus policies. Public safety is the object of the exercise but there are varying views as to the standards that should apply; for example, some British operators feel that the present ADR requirement for vehicles to carry at least one wheel scotch should be dispensed with.
There has been recent controversy over the issue of a directive by the European Commission aimed at establishing common standards for plastic petro-chemical road vehicle tanks; the British delegation wanted work already in progress on the subject within the context of the UNO Economic Commission for Europe to proceed without an EEC initiative at this moment in time.
There will, I understand, be provision in the revised ADR for grp tanks, currently popular in Belgium. Italy and France; grp tankers increased from 875 to 1350 (Belgium); 360 to 1450 (France) and 1100 to 3500 (Italy) between 1968/71.
With a wider prospect of international co-operation, and export sales of equipment, the possibility of standardized tanker vehicle designs must be considered. I am told that the detailed design of some UK tanks is not acceptable in Europe. Filling ratios and designed pressures will need to be reconciled.
The minimum tank wall thickness permitted by ADR is 2.5mm. Current cross-Channel shipping regulations require a minimum tank wall thickness of kin. for stainless steel and +in. metal for mild steel, Differing national requirements and attitudes make the task of reconciling equipment specifications and operating modes very difficult. German tanker operators follow a code even more stringent than ADR. New British regulations may exceed the ADR rules in some particulars. Special-purpose tanker designs made in Britain are said to be more flexible and efficient in operation than the standard tanker designs made in Europe. Considerable payload would be lost by some British operators if they used Continental tanker vehicles.
But prices and delivery of tankers built in the UK to standard designs satisfying major users could well improve. Such designs would present major problems if the equipment was intended for use throughout Europe because of the different pipe layouts and valve equipment used.
Payload limitation resulting from more stringent design or legal requirements could prove costly. A reduction of 1-ton payload on a propane tanker normally carrying 15 to 16 tons could reduce carryings by 250 tons a year, or by some 2500 tons over a 10-year vehicle life. Large-scale operators could be faced with the need to buy additional vehicles to move the "lost" tonnage.
"Blue Book" regulations Designers of tanker vehicles for international operations need to have regard to the maritime regulations laid down by the Department of Trade and Industry's "Blue Book". These shipping requirements are more onerous than the ADR rules. Toxic and inflammable cargoes are usually carried on deck though ships with well ventilated holds may be able to accept them below deck.
Not all shipping routes will accept vehicles carrying a hazardous cargo and there are limitations on the amount of such cargo that a ship will carry on any one voyage.
C ran age — when roll-en/roll-off facilities are not available — may present difficulties. Some ships have internal lifts and others use ramps for deck-carried vehicles. The largest road tankers, I understand, cannot be accommodated by the lifting facilities at Stranraer.
British road tanker operators are prone to complain that the IMCO (InterGovernmental Maritime Consultative Organization) regulations set out in the Blue Book are not enforced so rigorously by France as by Britain. There have been instances of 40-ton-gross tankers arriving at British ports and having to be escorted by police to their destination. Port authorities might wish to send such an illegal vehicle back on the next ship but captains have discretion to refuse a hazardous cargo!
The 30cm orange band painted around some tanker vehicles will be dispensed with, I gather, under the revised ADR. New symbols identifying hazardous cargoes in packages will be based on the Dangerous Goods Code recommended by IMCO in 1960. It would make sense if the same codings apply to vehicles. This classification system is identical to that established by the United Nations in 1956, and for which an internationally agreed labelling system exists. The new diamond-shaped symbols may be introduced in January 1973.
Time-lag The time-lag in aligning the ADR and IMCO hazardous goods identification system is understandable in view of the many separate interests needing to be consulted.
Subject to the paramount importance of safety of operating crews, shipping services and the general public, the maximum simplification and standardization of procedures enjoined by law is desirable, and in the commercial interests of all concerned.
The ADR European Agreement, published by HMSO, is in the form of two annexes. Annex A sets out the provisions soncerning dangerous substances and articles and Annex B details the 7equirernents for transport equipment and 3perations. European operators whose activities are exclusively on the mainland are spared involvement with the maritime -egulations which must be complied with by zoss-Channel operators. The Blue Book, ;overning maritime requirements, has -ecently been revised and reprinted. An additional Protocol to the ADR and RID rail) agreements requires compliance with he Blue Book.
Several powerful ministries are involved n the regulation of dangerous goods novement over land and sea. The Home Dffice was involved with the Explosives. Act n 1875 and with the storage aspects of petroleum under the Petroleum Act 1928. The Ministry of Transport (as it then was) sras given responsibility for safely regulating :he carriage of radio-active substances ander a 1948 Act — a responsibility it .etains within the Department of the Environment.
Mr Graham Page, MP — now a DoE Minister — once urged that the responsibilities of the Home Office for regulating the storage and movement of dangerous substances and articles should be vested in the DoE, but that very large ministry, concerned only in part with transport, would not presumably wish to . take over responsibility for supervising explosives manufacture!
Civil Service co-ordination
In fact, there is some sensible civil service co-ordination of responsibilities; a' neatly packaged administrative solution bringing surface, water, employment and the many technical aspects under a single control might cause more problems than the present, admittedly complex, arrangements.
Multiply the problems of co-ordination in Britain by the number of countries who are parties to ADR and RID and it is obvious that those involved in drafting agreed, mandatory legislation have an immensely difficult task. To please all concerned — operators, maritime authorities, labour ministries, etc — is impossible. Compromise is of the essence of any viable solution.
Although the existing ADR agreement eased many practical operating difficulties of international hauliers, it is far from perfect. There are conflicting domestic regulations between France and Britain. A French tanker vehicle could comply with ADR in France and, subject to axle weight limitations, undertake cross-frontier movements in Europe. But its constructional details would not be approved for operation within the .UK nor — a material consideration — for the cross-Channel trip under Blue Book rules.
Domestic law differences naturally vary since legislators were Moved by historical factors and were under varying technical and industrial pressures. The convenience of the international road trail operators was not a factor with which early legislators needed to be concerned. In Britain, some of our requirements for movement of explosive or inflammable products are more stringent than in certain European countries.
National requirements The ADR manual itself bears witness to varying national requirements. For example, the carriage of inflammable liquids of class 1 1 la whose flash point is below 23deg C "shall be subject in the territory of the United Kingdom to the regulations in force in that country at the time of transport". There is a similar dispensation for operation within the UK of vehicles carrying compressed or liquefied gas or explosive substances in classes la, b and c.
Different national rules for flashpoints have commercial implications for many products. Germany specifies a flashpoint for paint products of 21deg C. If the British requirement was 25deg C instead of 23deg C (73deg F) paint would be a dangerous commodity subjected to additional safety precautions.
Ullage — the tank volume unfilled to permit expansion of cargo with temperature changes — is an important commercial
consideration. British operators who can fill tanks to 93 per cent capacity in the UK may resent the wasted pay load on a trip to Scandinavia — a colder climate — since they must also conform to onerous shipping requirements. In Europe, ullage volume is related to a temperature of 70deg F and I understand there is little pressure from British operators to alter this. However, the British delegates to the ECE Working Party considering revisions of ADR intend to recommend standard world reference temperatures and internal pressures. The United Nations, of which ECE is part, have already considered this problem in their publication Transport of Dangerous Goods issued in 1970.
The ullage problem for operators is the more critical since countries like Iran, Irak and Morocco — now parties to RID — have very different average temperatures. from Scandinavian countries (RID and ADR conditions are closely aligned). Some British operators complain that ADR has been "written round Italy", one of the hotter countries involved.
Temperature/pressure problems Temperature /pressure problems involve many technicalities and "rule of thumb" safety margins assist practical operators. Despite what was thought to be a safe guideline, there was a serious tanker explosion in Germany when the temperature of a product rose above 122deg F, owing to hot sun in a concentration of buildings.
In drawing up proposed revisions of ADR the Home Office, I understand, will bear in mind the representations from British operators that the provision requiring at least one wheel, scotch should be dispensed with.
There will be more sensible grouping and cross referencing of information when the annexes are reprinted. The Federal Republic of Germany has prepared a revised draft for toxic substances. The UK delegation, with specialized knowledge of radio-active substances, and Italian experts, with much experience of corrosives, may suggest detailed revisions.
The Geneva Working Party has agreed in principle to adopt the United Nations classification to define inflammability, toxicity, etc, and the United Nations load identifications symbols are likely to be adopted, with effect from January 1 1973. The UN has done much research on tests for packaging; the revised ADR will lay down detailed specifications for vehicle tanks, and specify performance tests for containers, steel drams and ancillary equipment.
Public safety
Public safety underlies international, collaboration for the safe movement of dangerous goods. Fire brigades in all countries party to the ADR convention will have copies of a new manual prepared by Counseil Europeen des Federa tions de l'Industrie Chimique (CEFIC). Vehicles will carry identification numbers so that fire brigades will merely have to consult a manual of hazardous cargoes to determine corrective action.