30 Years Ago

A LOOK BACK TO APRIL 1988

By the standards of the day, the April 1988 issue of HCB was a bumper event, weighing in at 106 pages and featuring plenty of full-colour advertisements. As is still the case, much of the coverage was designed to tempt interested new readers picking up a copy at one or other of the various trade shows and conferences lined up for the second quarter, but the size of the issue also had a lot to do with the sheer amount of regulatory and industry news there was to report.

Some months earlier we had waded inadvertently into issues surrounding the regulation of the transport of dangerous goods by air and in the April issue Andy Altemos felt compelled to write from the US to confirm that the Federal Aviation Administration would not – and as far as he was concerned never would - consider the IATA Dangerous Goods Regulations to have any legal basis.

There was a lot of coverage of tank containers in the April 1988 issue, with a strong focus on the growing penetration of this relatively new mode of transport in the North American market. But the market was about to be confused by the US Department of Transportation’s (DOT) plans to harmonise more closely with the UN Orange Book – albeit partly on the basis of “if you do what I do then we’ll be harmonised”.

In particular, European tank container operators were somewhat alarmed at the amendments to the UN provisions that the US was considering in order to help it achieve harmonisation. One of those, for instance, was that Class 2 should be sub-divided so as to recognise the very different hazards posed by flammable, non-flammable and toxic gases, respectively. That seems quite sensible today (as, indeed, do several other changes) but it was somewhat alarming for tank container operators, who felt that the legal basis upon which they had planned their tank investments was about to be shifted.

The US view was that its own specifications for ‘bulk packagings’ – tank cars, cargo tank motor vehicles and tank containers – had evolved in a haphazard fashion and that it was probably about time that they were straightened out. The International Maritime Dangerous Goods (IMDG) Code had also developed its own approach to the specification and stowage/segregation of tank containers, and it would take many more years before the various systems could be fully aligned.

Another element of DOT’s harmonisation project was to be the new ‘performance-oriented packaging’ standards, or POPs, which are to a large extent still with US industry today. Thirty years ago we had an article on the new UK quality assurance standard BS 5750 (‘BS’ referring to ‘British Standard’ rather than to a term more widely used in the US). This standard was designed in part to ensure regular testing of “a company’s ability to consistently manufacture products to a defined specification”.

Such consistency is a fundamental assumption of the process, still in place today, of design approval of packagings (as well as larger containers) for dangerous goods. BS 5750 required (and still does) that a manufacturer’s management and quality assurance procedures be kept up to date and be followed and that such procedures should be audited.

In a way, BS 5750 was the forerunner of today’s ever-expanding list of safety, quality, environmental protection and process safety management standards.