UP FRONT
DOT (Department of Transportation) and Class 9 Chemical Kits. But it’s not just a small accumulation of occurrences, over the years we’ve done this for quite a many articles, from batteries to fuel cells, from engines to vehicles, from safety devices to life-saving appliances, and more. We’ve agreed, or perhaps I should say the regulators have agreed, because I don’t agree, that whenever an article requires packaging that must meet some particular performance level, PG I or II or III, we will consciously, intentionally, omit that PG from the Table/List of Dangerous Goods. Really? How does one explain to a classroom full of novice students, who are desperately trying to find and understand the underlying principles and concepts of the DG transport regulations, so that they can more effectively apply them in real life, that both chemicals and their packages both get PGs, but that for articles, we don’t allow them to have PGs even when their packaging requires it? It defies common sense. Eh, who cares about the problems of a few
hundreds of DG trainers? We’re paid to make the regulations comprehensible, or at least point out the inconsistencies (absurdities?) while saying “it may not make sense, but just do it because the regs say to”. But how about DG acceptance agents? Whether road, rail, air, or water, wouldn’t it be great to have a compliance check, even a rudimentary one, on packaging before the package gets moved? For chemicals, we have that. An acceptance agent or driver (it’s usually going by road before it gets to an airport, seaport, or rail hub) compares the PG on the paperwork to the X, Y, or Z on the drum, box, bag, or jerrican. Then they compare, at least for solids and for combination packagings, the listed weight on the shipping papers to (against) the maximum gross weight in the UN-specification mark. But for articles, the absence of a PG on the paperwork prevents an acceptance agent from knowing whether UN-specification packaging is required, and if required, whether it’s capable, both from a PG and weight standpoint.
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“Don’t complain without offering a potential solution!” Yes, I’ve heard that before. Perhaps, as we now list multiple PGs in the DG Lists for some classifications, e.g., Alcohols, n.o.s. as PG I or PG II or PG III, we could list multiple PG choices for articles? Perhaps as PSN Article… n.o.s., PG none or PG II, and then require the shipping document match the appropriate entry? In the meantime, requiring a PG for a packaging but refusing to list it in a HazMat Table or on a shipping document is at best inconsistent, and, at least in my ponderings from my porch swing, at worst and quite likely, unsafe. Really? Yes, really. Don’t say I can’t be serious John McEnroe and DG regulators, because I am serious. This is the latest in a series of musings from the porch swing of Gene Sanders, principal of Tampa-based WE Train Consulting; telephone: (+1 813) 855 3855; email gene@wetrainconsulting.com.
DAVID JENKINS – 20 JANUARY 1939 TO 11 MAY 2020 The legacy of anybody is what they leave behind in thoughts and memories. David was someone who lived a full life with no apology and no regrets, a father, partner, friend and (often secret) philanthropist. David also leaves behind the amazing M&S Logistics. M&S Logistics has thrived with a backbone consistent with the values found in this London East End, Saville Row clad Englishman who retired to the wine district of South Africa. An amazing mix of long established British values, and a frontier South African mindset. These values are very much behind the M&S Values & Behaviours. It is with great pride in not only what David Jenkins started, but in also what the entire current and historic teams behind M&S Logistics represent, that we wish to confirm that the ownership structure and values behind M&S Logistics and Multistar are not going to change.
Dave Kew, Myles Jenkins, Rory Jenkins
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