The Australian National Transport Commission (NTC) is currently consulting on the draft revision to Part 4 “Packing and Tank Provisions” of the Australian Code for the Transport of Dangerous Goods by Road and Rail (ADG Code). The period for comments will be due by January 25, 2024.
The ADG Code is updated every two years, with a one-year transitional period for each new edition. Edition 7.8 of the ADG Code published in December 2022 is the current edition with updates to align with the 22nd revised edition of the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations (UN Model Regulations). As scheduled, Edition 7.8 will be mandatory from April 1, 2024. However, the industry and regulators noted that many Australian-specific chapters in the ADG Code were carried over from Edition 6 without critical review. They are now outdated. To ensure that the ADG Code is reflective of the Australian transport environment, drawing upon similar regulations used elsewhere in the world where appropriate, the NTC has broken the content of the ADG Code into a series of topics for critical review.
Till now, the NTC has published 8 consultation papers for the review, covering topics of classification and list of dangerous goods, vehicles and tanks used for dangerous goods transport, safety equipment, consignment procedures, etc. On November 22, 2023, the NTC issued the ninth discussion paper, regarding packing and tank provisions in Part 4. According to the NTC, the current version of Part 4 of the ADG Code is replicated from Part 4 of the UN Model Regulations in a significant proportion. However, many provisions in this regard were either omitted completely, or dispersed through other parts of the ADG Code, which has created gaps in requirements and difficulty in navigating this code. To address the regulatory gaps, the draft revision of Part 4 further clarifies the procedures for the use of packagings, including intermediate bulk containers (IBCs) and large packagings, tanks, multiple-element gas containers (MEGCs), mobile explosive manufacturing units (MEMUs) and vacuum operated waste tanks.
Major updates proposed in the draft revision of Part 4 include:
Providing additional guidance to assist duty holders in meeting the requirements for determining the degree of filling.
Adding additional text specifying the conditions and restrictions on the use of UN 3509.
Clarifying the provision that the only IBCs permitted to be used as salvage packaging are IBCs of type 11A, which are steel for solids, filled or discharged by gravity.
Adding additional text specifying the criteria for determining if a substance is likely to become liquid during transport, i.e., “For the purposes of this paragraph, substances and mixtures of substances having a melting point equal to or less than 45 °C shall be treated as solids liable to become liquid during carriage.”
Adding the requirements for unpackaged articles other than Class 1 (explosives) articles.
Adding the verification of the chemical compatibility of plastic packaging, including IBCs, by assimilation of filling substances to standard liquids. This includes an assimilation procedure and scheme for the assimilation of filling substances to standard liquids, as well as rules and examples for aqueous solutions, collective entries.
Adding requirements relating to the use and operation of vacuum operated waste tanks.
Adding requirements for the use of fixed tanks (tank vehicles and tank wagons), demountable tanks, tank containers and tank swap bodies with shells made of metallic materials, and tube-vehicles and tube-wagons and multiple-element gas containers (MEGCs).
For more details, please refer to the discussion paper: Part 4 – Packing and tank provisions.
ChemLinked published an article in February this year regarding the draft revision of Part 2 – Classification of the ADG Code: Australia to Provide Additional Classification Information for Dangerous Goods Transport. Opportunities to comment on other provisions in the ADG Code will be provided over the coming months. A complete draft of this code will be released for public comment in 2024. ChemLinked will keep a close eye and update the latest information.
