30 YEARS AGO

A Look Back At May 1993

THIRTY YEARS AGO, the grand plan for regulatory harmonisation was beginning to come together. The UN Committee of Experts on the Transport of Dangerous Goods (which later became the Sub-committee of Experts once it had to share space with the GHS experts) had finalised the eighth revised edition of the UN Model Regulations in December 2022 and the modal authorities – ICAO, IMO and RID/ADR – were working hard to align their various modal rulebooks with the new edition on the same day, 1 January 1995.

That process was not without its problems, however. In particular, a great deal of the UN Committee’s work over the previous biennium had involved a revision of Chapter 9 of the Orange Book, which covered packaging. Since the previous revision in 1982, the UN package performance testing scheme had become mandatory around the world and it was expected that the intervening decade would have raised serious deficiencies. In the event, few problems had been encountered.

However, as Martin Castle, then chief officer, dangerous goods at Pira, the UK’s packaging certification competent authority, explained, transposing those new provisions into the modal regulations was proving problematic. Legislation for national quality assurance programmes would have to be put in place; the concept of ‘test report’ still had to be defined; there was a lack of guidance on drop tests and ‘cold drop’ tests; there was no specific size for packaging markings; the position regarding remanufactured drums required clarification; and there was no allowance for boxes to feature holes. Clearly the path to modal and international harmonisation was going to be a long one.

In the UK, planned implementation of ADR in 1995 was raising the spectre of additional costs for operators, especially in terms of the replacement of non-UN certified packagings. The issue was highlighted by the British Chemical Distributors and Traders Association (BCDTA), now the Chemical Business Association (CBA). Ironically, perhaps, nearly thirty years after the UK joined in with other countries in Europe in applying ADR to domestic transport, CBA was lobbying hard on behalf of its members to persuade the British government to provide assistance in complying with new requirements imposed as a result of Brexit.

Industry – and not just in the UK – was facing another emerging cost in the 1990s as a result of growing pressure (and legislation) to reduce the volume of emissions of volatile organic compounds (VOCs) during product transfer operations. At the time there were several different technologies being developed, variously suitable for use in bulk liquids storage tanks, at marine docks, at road tanker loading points and at fuelling stations. These now seem normal but back then the world was a rather different place.

Or maybe not. The May 1993 issue of HCB had an interesting item reporting on a call from the US National Transportation Safety Board (NTSB) for tougher inspection programmes for the nation’s 104,000-strong fleet of rail tank cars. NTSB had realised that hydrostatic and visual testing at arbitrary intervals was not an effective way to detect structural defects, which had been responsible for 41 of the 91 accidental releases of hazmat from rail tank cars in the five years to 1991. There were changes but, as the recent incident in East Palestine, Ohio demonstrates, regulators have failed to completely remove the risk of releases.