30 Years Ago

A LOOK BACK AT OCTOBER 1992

LEAFING THROUGH THE pages of the October 1992 issue of HCB, one lights upon a note that the UN Sub-committee of Experts’ sixth session agreed new special provisions for both rechargeable and primary lithium batteries; clearly this was not the first time that these articles had been covered in the Orange Book, as the criteria for determining which lithium batteries could be regarded as ‘nondangerous’ were also revised. Nevertheless, one cannot help but wonder if a biennium has gone by since then when the provisions for lithium batteries and cells (as well as packed with/contained in, disposal/damaged etc etc) have not been further revised.

Also among the outcomes of the UN Experts’ meeting were new provisions governing the packaging and transport of medical and clinical wastes. The regulators do not have access to a crystal ball and could not then have known that those provisions would also have to be revised, not least to take account of the large volumes of wastes that would be generated during large-scale viral outbreaks. Ebola kicked that off, and the changes made then came in useful when Covid came along; doubtless they will be too for Monkeypox.

One illuminating – if rather depressing – report in that issue concerned a container inspection programme undertaken by a group of ports in north-west Europe in the latter part of 1990; nearly 3,000 containers (including 473 tank containers) had been inspected, of which around half were non-compliant in some way. Almost 800 had placards and marks that did not meet IMDG Code requirements: the wrong size, the wrong location, not matching the hazards of the goods contained, empty containers still bearing placards from their last load, and so on. This failure extended to tank containers too, although in most other respects compliance was much higher for tanks – excepting that a number were found to have frames so badly corroded that they were barred from onward transport. It is sad to report that those container inspection programmes being carried out thirty years later still reveal a similar level of non-compliance.

Elsewhere, the October 1992 issue of HCB focused very much on European logistics, to coincide with EPCA’s annual logistics meeting in Monte Carlo (those were the days!). However, there were two important developments in the US that could not be overlooked. The first of these was the ground-breaking HM-181 rulemaking, which brought a fundamental shift in the way hazardous materials were regulated – bringing in the idea of ‘performance-oriented packaging’ as well as changes to classification, hazard communication, packaging and handling requirements to harmonise more closely with UN and international modal rules.

Of course, the US Hazardous Materials Regulations were not then fully harmonised with the UN Model Regulations – nor are they today – and HCB focused on some areas where there were differences, not least in the hazardous communication and packaging requirements for poison-inhalation hazard (PIH) materials. The US DOT’s definition of Division 4.3 differed, tank containers needed additional certification for PG I and II substances, and combustible liquids were also included.

HM-208 had also just entered into force, implementing a registration system for shippers and carriers of hazardous materials – including non-US companies, which caused some issues. Thirty years later, Canada is only just now catching up with the system south of the border.