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In the previous articles, we have discussed the responsibilities and obligations of consignors and carriers, the two significant roles in the road transport of dangerous goods. However, besides the two roles mentioned above, another role is emphasized in the Measures for Safety Administration of Road Transport of Dangerous Goods [1], namely, the loaders.
According to the Measures, a loader refers to an enterprise or organization that is entrusted by the consigner. The loader is responsible for loading dangerous goods into vehicles or loading containers with dangerous goods. Vehicles include tankers, portable tankers, tank containers, and bulk containers. Therefore, any enterprise engaged in manufacturing, storing, transport, using, or operating hazardous chemicals, can be also considered a loader.
After the issuance of the Measures and the MOT’s Notice [2], the role of loaders has taken on greater importance. Loaders now serve as a vital link between the consignors and the carriers.
The Measures pose two new requirements for loaders. These two requirements are the establishment of a verification system and the establishment of a record-keeping system.
Verification system
The verification shall be conducted before the loading of dangerous goods. According to Article 28 in the Measures, the following five kinds of information are required to be checked by loaders:
whether valid certificates of roadworthiness and operating licenses have been obtained for vehicles carrying dangerous goods;
whether drivers and escorts have valid qualification certificates;
whether the inspection certificates of transport vehicles, tanks of tank vehicles, portable tanks, and tank containers are valid
whether the dangerous goods to be filled or loaded are consistent with items specified on the dangerous goods waybills
Whether the dangerous goods filled are included in the certificate of fitness product list of tanks of tank vehicles, or whether they satisfy the requirements in portable tank codes and tank container codes.
As regulated in the Measures, the loaders shall not load or fill the goods if any non-compliance is found during the verification. The verification system standardizes operations and prevents risks. In the event of an accident investigation or liability investigation, the record-keeping system will be used.
Record-keeping System
The loading record shall be conducted before transport, and the following information is required to be recorded and adequately kept for no less than 12 months. The required information includes the class, name, quantity, and waybill number of dangerous goods filled or loaded, consignors, carriers, transport vehicles, and drivers. (Article 31 in the Measures)
After the verification and loading record has been made, goods can finally go on their way. Normally, the carrier shall not load or fill dangerous goods without authorization by the loader and before the consignee receives the goods. Refilling is only permitted to ensure the safety of transportation. Permitted activities include supplementing inhibitors or stabilizers. Loaders must also strictly implement the inspection, approval, and record system and must operate under the consignor's guidance.
Dangerous Goods Port Operator
In the MOT’s Notice on implementing the Measures, the responsibilities of dangerous cargo port operators who are loaders were emphasized. For the port operators who are engaged in the loading or filling of dangerous goods, they play the loader's role. So the port operators shall strictly obey the safety management responsibilities stipulated in the Measures, including the verification system, record-keeping system, safety education and training for personnel, equipment management, and Standard Operating Procedures. For dangerous goods that need loading or unloading at the port, the consignor shall provide the waybill of the goods for the port operator per the regulations.
The Measures for Safety Administration of Road Transport of Dangerous Goods have greatly improved the safety of road transportation of dangerous goods by putting forward more complete operation requirements for loading. For the consignee, after confirming that the goods are correct, they should sign in time and ensure the safe operation of the unloading operation.
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