30 Years Ago

A LOOK BACK AT FEBRUARY 1991

By 1991, the regulations governing the transport of dangerous goods around the globe were beginning to take on the form we know and love so well today. Our February issue reported on some significant recent and upcoming changes, none more significant – at least it seemed so at the time – than the entry into force of the HM-181 rulemaking in the US.

First proposed in 1982, HM-181 saw the US bite the bullet and join the international approach to packaging approvals, moving away from the tried and tested DOT-specification system. Industry in the US was not happy; after all, around 90 per cent of all US hazmat shipments at the time were purely domestic, so why change it? There were some compelling arguments, quite apart from the question of international harmonisation, not least the fact that US DOT realised that its prescriptive approach to hazmat packaging was a barrier to innovation, as any new ideas could only be put into practice through a cumbersome case-by-case approvals procedure.

That move to what became known as ‘performance-oriented packaging’, under which manufacturers (and their customers) had a duty to ensure that packagings could withstand a series of tests, rather than match a specification, is still with us. Elsewhere, decisions were being made that would have a long-term impact and HCB’s February 1991 issue reported back from Geneva, where in September 1990 the joint RID/ADR meeting (there being no ADN in those days) had continued its long-running deliberations over Divisions 4.1, 4.2, 4.3, 5.1 and 5.2.

One issue was this: where is the dividing line between solids and liquids? Happily, the UN Sub-committee of Experts on the Transport of Dangerous Goods had recently come up with a definition. Less happily, this meant that, if adopted for RID/ADR, it would mean that the definitions for classification purposes would differ from those used for packaging purposes. Work was clearly needed, which initially at least would take the form of a new marginal (remember those?).

That joint meeting also adopted the ‘new’ Class 5.1 label, still in use today, though it was not until much later that the different hazards posed by organic peroxides were recognised through the adoption of a yellow/red label.

In December 1990 the UN Sub-committee had also agreed some significant changes, not least the inclusion of a new paragraph on training in Chapter 1 of the Orange Book. There were also substantive changes to the requirements for Division 4.1 substances, in particular relating to self-reactive substances, which came with new nos entries throughout Classes 4 and 5.

An increasingly high profile item on all the regulators’ agendas concerned environmental protection, especially in the realm of air pollution, which also strayed into the area of worker safety. Europe’s rulemakers were about to embark on discussion of vapour control measures, which was also of concern to the IMO’s Marine Environment Protection Committee. The February 1991 issue of HCB included a report from the Committee’s session the previous December, which covered a huge amount of ground, including the reduction of air pollution from ships to meet the provisions of the Montreal Protocol. At the time, there was a major focus on ozone-depleting substances (CFCs, halon, etc) but it was only the start of a long journey to clean up shipping that is still continuing.