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W. C. R. DALE
Came into force on lst October, 1968, and make requirements for labelling vehicles and containers used for all the liquids mentioned above (Para. 1) and, in certain cases, Petroleum Spirit (and Mixture), and Carbon Disulphide.
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REQUIREMENTS
Reference: Regn. 2, Schedule I Part I
Schedule 4 Regn. 2(2) Schedule 1, Part 2 Regn. 3
Details: All Vehicles including Tank Wagons and Petroleum, to display "Flame Symbol" (20 ems. sq.) fore and aft, centrally, high as possible. Flame Symbol-details and sizes. Tank Wagons only, not Petroleum, labeJied with name of substance carried (letters 10 or 5 ems.). Containers, including Petroleum, must display Schedule 2, Para. 3 "Flame Symbol" (10 ems. sq.). Regn. 3, Schedule 2 Containers, excluding Petroleum must be Paras. 1 and 2 labeIIed with name of substance. ' Regn.4 Owners must ensure that employees are acquainted with Regulations. Regn. 5(1) Regn. 5(2) Schedule 3 Regn. 3 Regn. 6(a) Schedule 3 Regn. 6(b) Schedule 3
EXEMPTIONS Vehicles not Tank Wagons: If total quantity not more than 250 kilos provided containers comply with Regulations, or if all the liquid is contained in "Receptacles" as defined. Containers, if they contain not more than I kilo or if a "Receptacle" as defined tainer with not more than 30 or an outer conkilos of "Receptacles". Winchesters: "Flame Symbol" only required.
Note.-None of the above exemptions apply to Acetaldehyde, Carbon Disulphide or to Tank Wagons.
Petroleum Spirit
Labelling containers is required by Section 5 Petroleum Act. The above Regulations require that the "Flame Symbol" also be displayed if they apply to the conveyance of that Petroleum Spirit.
The of petroleum spirit is subject to the Spmt (Conveyance by Road) Regulations, 1957, however, do not apply if the quantity conveyed ts not more than 32 gallons in cans or 50 gallons in one steel barrel. exemption is _carried on in the above Regulations, so tf the total quantity of Petroleum Spirit carried is not more than these amounts, none of the Regulations apply to the Petroleum Spirit (or mixture).
Carbon Disulphide
The Conveyance of Carbon Disulphide is subject to the Carbon Disulphide (Conveyance by Road) Regulations, 1958, as amended by the Regulations of 1962.
The exemption under these regulations is not more than 28 lbs. total with not more than 7 lbs. in one container. This exemption is continued.
Hence the above Regulations (i.e. The Inflammable (Conveyance by Road) (Labelling) Regulat10ns). will not apply to Carbon Disulphide if the total quantity on the vehicle is within the exemption quoted.
A.D.R.
W. C. R. DALE. A.F.lnst.Pet.
On 29th December, 1967, Portugal acceded to a European Agreement concerning the International Carriage of Dangerous Goods by Road (A.D.R.). She was the fifth country to do so. This meant that the Agreement came into force one month later on 29th January, 1968, and the technical Annexes to the Agreement became operative a further six months afterwards on 29th July, 1968.
The British Government has made no secret of its intention to adopt and adapt suitable provisions of the Annexes and to include them in domestic legislation. It has been part of the task of the Standing Advisory Committee on Dangerous Substances to advise the Home Secretary on this matter.
The Petroleum (Inflammable Liquids) Order, 1968
The A.D.R. Annexes became operative on 29th July, 1968. It is not surprising therefore to find the Petroleum (Inflammable Liquids) Order, 1968, taking effect from lst August, 1968.
The Order applies some of the of the Petroleum (Consolidation) Act, 1_928, to liquids and 5 solutions, all of which are hsted (with alternative names) in the to the Order. Most ticularly the provisions _of Sect10n 6 of the Act are apphed to the liquids and solut10ns. '!'he of 1s thus empowered to make Regulat10ns govermng their conveyance be road.
The Petroleum (Carbon Disulphide) Order, 1968
Jn order to clear the way for Regulations, a little tidying up operation was necessary. The Petroleum (Carbon Disulphide) Order, 1968, achieves this by excluding disulphide in cou.rse of conveyance from the provisions of Sect10n 5 c:>f Petroleu_m (Consohdat1<;m) Act, 1928. Thus the of yarymg sets of labellmg requirements to carbon disulphide m course of conveyance is avoided. It will be recalled !hat the (Carb?n Disulphide) Order, 1958, apphed Sect1011 5 (with some modification) and Sectton 6 of the 1928 Act to carbon disulphide. The Inflammable Liquids (Conveyance by Road) Regulations 1968
The Secretary of State has . not been slow to make Regulations in pursuance of his new powers the Inflammable Liquids Order. The of what promises to be a series is the Inflammable L1qu1ds (Conveyance by Road) Regulations, 1968.
The purpose of the Regulations is to impose certain elementary safety preca_uti<;>ns in co1?nection with the carriage of There is the usual ban on smoking and potential 1gmt1on sources; care must now be taken to avoid spilling, and a fire extinguisher must be carried. The owner of a vehicle has a duty to acquaint his employees with the provisions of the Regulations.
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If one is conveying acetaldehyde, there is no exemption which one may enjoy. The same is true if one uses a tank wagon or tank trailer for the conveyance of any quantity, no matter how small, of an inflammable liquid. On the other hand, one is not caught by the Regulations if: either (a) all inflammable liquids (except acetaldehyde) conveyed are in receptacles containing not more than 1 kilogram, the receptacles are packed according to the
Schedule and each package contains not more than 30 kilograms; or (b) the total quantity of inflammable liquids (except acetaldehyde) conveyed does not exceed 250 kilograms.
These Regulations do not apply to petroleum spirit, petroleum mixture or carbon disulphide. This might be expected because adequate similar provision is already made in respect of these substances by the Petroleum Spirit (Conveyance by Road) Regulations, 1957, and the Carbon Disulphide (Conveyance by Road) Regulations, 1958 and 1962. The effect, however, is that one can convey on a single vehicle, 50 gallons of petrol in a barrel, 28 lbs. of carbon disulphide in seven pound containers and 250 kilograms of any other inflammable liquid except acetaldehyde and yet have no need to comply with the safety requirements of any of the three sets of Regulations.
The Regulations are effective from lst October, 1968.
The Inflammable Substances (Conveyance by Road) (Labelling) Regulations, 1968
To meet a long felt need that the fire service, the police and any other emergency service should have adequate warning that a particular vehicle is carrying a dangerous load of inflammable liquids, the Secretary of State has introduced the Inflammable Substances (Conveyance by Road) (Labelling) Regulations, 1968.
The purpose of the Regulations is to ensure that vehicles conveying inflammable liquid by road are marked with a suitable fire service symbol and the name(s) of the liquid(s) being conveyed. Containers have to be similarly marked but the size of the required symbol is reduced. The symbol selected is the "Flame" sign which is recognised internationally as indicating that a container has inflammable contents.
On a vehicle, the "Flame" symbol has to be placed in a clearly visible position at the front and rear. The positions selected must approximate to the front centre or the rear centre of the vehicle and each must be at the highest practicable point. If the vehicle is a tank wagon or tank trailer, the carrying tank has to be marked with the name of the substance conveyed. Moreover, ifthe carrying tank is compartmented and each compartment contains a different inflammable liquid, then each compartment has to be separately marked with the name of the liquid.
Each outer container of an inflammable liquid has to be marked with the "Flame" symbol and the name of the liquid within it. There is a minor relaxation of this requirement where an outer container encloses not more than six Winchester Quarts packed in the special way laid down in Schedule 3. Jn such a case, the name of the substance can be omitted from the container if no acetaldehyde or carbon disulphide is in the package; this should be a great help to suppliers of laboratories who frequently need to send out Winchester Quarts of various liquids in a single package.
If a container holds not more than 30 kilograms in individual 1 kilogram units packed in the manner specified in Schedule 3 and does not include acetaldehyde or carbon disulphide, the container does not have to be marked. Moreover, if the only containers on a vehicle comply with the provisions of Schedule 3 and do not contain acetaldehyde or carbon disulphide, the vehicle itself does not have to be marked. The vehicle similarly does not have to be marked if (a) the total quantity of inflammable liquids conveyed does not exceed 250 kilograms, (b) the load does not include acetaldehyde or carbon disulphide and (c) each individual vessel exceeding I kilogram is marked.
Vessels containing acetaldehyde or carbon disulphide or more than I kilogram of other inflammable liquid have to be marked except that vessels in an outer container do not have to be labelled if the outer container is itself marked as required.
Under Section 5 of the Petroleum (Consolidation) Act, 1928, petroleum spirit or mixture containers in course of conveyance have to have a statutory label affixed. There is therefore little point in marking them additionally with the name of the spirit, etc. Suitable exemption is therefore made from this requirement of the Regulations. However, if the vessels exceed 1 kilogram in capacity, they still have to exhibit the "Flame" symbol.
It should be noted that the Regulations do not apply at all to petroleum spirit or petroleum mixture or carbon disulphide if the quantity conveyed is less than the exemption limits laid down in the Petroleum Spirit (Conveyance by Road) Regulations or Carbon Disulphide (Conveyance by R?ad) Regulations, as appropriate. Thus, a vehicle carrymg 50 gallons of petrol in a barrel, 28 lbs. of carbon disulphide in seven pound containers and 250 kilograms of any other inflammable liquid except acetaldehyde need not be marked. The appropriate marking would, however, appear on all vessels exceeding I kilogram in capacity containing the inflammable liquid.
The Regulations are effective from lst October, 1968. General
There will be more Regulations dealing with. the con~eyan.ce by r?ad of inflammable liquids. Regulat~ons d.eal111g with vehicle construction are already under d1scuss10n. Reg~lations laying down operational safeguards in.greater detail have yet to be considered. At the same time the task of defining other classes of hazardous substances is proceeding.
Enforcement
The duty of enforcing the Inflammable Liquids (Conveyance by Road) Regulations and the . Inflammable Substances (Conveyance by Road) (Labelling) Regulations in a district is laid on the local authority empowered to grant petroleum spirit licences in that district. It is likely that new Orders dealing with other classes of haz<~rdous substances will be made in due course under Sect1011 19 of the Petroleum (Consolidation) Act, 1928. If this happens then the petroleum spirit licensing authorities may confidently expect further duties in this field to be laid upon them.
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