30 Years Ago

A LOOK BACK AT FEBRUARY 1988

Sometimes when we look back at what we were writing about thirty years ago, one cannot help but feel a sense of sorrow at the hours of wasted effort that went into developing new regulatory provisions that, however sensible they might have seemed at the time, have since been superseded.

That was surely the case back in February 1988, when HCB reported on the outcome of the December 1987 meeting of IMO’s Marine Environment Protection Committee (MEPC), where a longstanding logjam over the selection of marine pollutants under the IMDG Code had at last been cleared. One outcome of that was the agreement of the new mark for marine pollutants: the ‘fish and chips’ triangle.

The concept of identifying marine pollutants has stuck with us but there are constant discussions about specific aspects and substances and, for some reason we fail to recall, the mark was eventually declared unsuitable and replaced with the rather more apocalyptic ‘dead fish and tree’ mark now in use.

During 1987 MEPC, in cooperation with the CDG Sub-committee, had gone a long way to establishing the ground rules for the new Annex III to Marpol but it was clear from the February 1988 issue that there was still work to do to get Annex II fully adopted – and some of its provisions are still not fully in place even now. An interesting piece by HH ‘Curly’ Cail looked at the number of legislative changes that the UK was having to make and the operational arrangements that needed to be put in place at the ship/shore interface.

The February 1988 issue was something of a regulatory smorgasbord, morphing in the turn of a page from the IMDG Code and the IBC and BCH Codes to the latest amendments to the tank provisions in ADR and RID. This took the form of two pages of changes arranged by Marginal – how happy we should all be that we do not have to wrestle with those any longer!

Following that, regular contributor HJK reported on the steady progress being made in the revision of ADR and RID, not least in terms of coping with the need to regulate those new-fangled IBCs. Perhaps irked by the fact that he only had three pages’ worth of contribution in this issue, HJK also sent a letter, warning against the possibility that the European Commission would meddle in the well established system of regulating dangerous goods in transport. That is an idea that cropped up every so often and was normally headed off at the pass; HJK felt that the Commission was prone to confusing regulations for transport with those for supply and use, something that is less likely since the agreement of GHS.

The final item in the February 1988 issue, again on the subject of regulations, was another letter, this from Kaye Warner, head of the Dangerous Goods Section at the UK Civil Aviation Authority. She wanted to alert readers to the fact that a couple of new entries in the Dangerous Goods List in the latest IATA DGR (ID 8035 and 8036, Extracts) did not appear in the ICAO Technical Instructions; anyone using those entries would therefore be in contravention of national legislation and subject to legal penalties.