UP FRONT 01
EDITOR’S LETTER
I have a confession to make. Don’t tell anyone, but every
and corrected it, but my copy of ADR 2021 certainly has
month I have a sense of dread when the new issue of HCB
the wrong information and other rulebooks may well do
arrives back from the printers. Too often – at least in my mind
too. Will the respective regulatory authorities issue
– I spot a mistake I should have picked up on the last set of
corrigenda? Or will shippers looking to take advantage
proofs. Sometimes it’s my error (spelling mistakes in headlines
of the Excepted Quantity relief for UN 3208 have to go
are the worst) but as I’m responsible for everything that goes
through an approval process?
out under the HCB name, any mistake is down to me. So you could imagine the Schadenfreude (there is an English
Putting my editor’s hat on, I know only too well that mistakes can be costly. Publishing material carries
word for it, ‘epicaricacy’, but no one I know ever uses it, or even
responsibilities, not least the risk of libel. But publishing
knows how to pronounce it) I felt when going through the report
incorrect information can also raise liabilities – which is why
of the last meeting of the UN Sub-committee of Experts. China
pretty much any technical or market publication includes
had put in a paper wondering why the Excepted Quantity limit
a disclaimer, which readers can in HCB’s case find at the
for UN 3208 (metallic substance, water-reactive, nos) was
bottom of the Contents page. What it says, in effect is that if
shown as ‘E0’ when the other five generic entries for water-
you, as the reader, make a commercial decision on the basis
reactive substances (all Division 4.3, packing group II) have
of information in HCB and it goes wrong, it’s not our fault.
‘E2’. China thought this might be a mistake, not least since the ICAO Technical Instructions have ‘E2’ against UN 3208. ICAO chipped in at this point, noting that UN 3209 (metallic substance, water-reactive, self-heating, nos) had ‘E2’ when it should be ‘E0’. It reckoned there had been a typing
Here at HCB we do take a great deal of effort to ensure that what we write is correct before it gets published, though as I noted above, it’s not always possible to get everything 100 per cent right all the time. Having flicked through the opening pages of ADR,
error when the Excepted Quantity codes were added and
I don’t see any such disclaimer. Does that mean, therefore,
UN 3208 and 3209 were given each other’s values. The
that shippers that have had to spend extra cash due to the
Sub-committee agreed this was an error, which was easy
erroneous absence of an Excepted Quantity provision for
enough to put right. As a result, the correct values will be
UN 3208 have a potential case for compensation? I suspect
shown in the 22nd revised edition of the UN Model Regulations,
that would be a difficult case to pursue in the courts and
due for publication later in the year.
I sincerely hope it doesn’t come to that. We are all human,
So far, so good. However, it does mean that the current
even regulators.
modal regulations, which are based on the 21st revised edition, have got the wrong numbers. ICAO may have spotted the error
Peter Mackay
WWW.HCBLIVE.COM
