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On the Chemical Regulatory Annual Conference 2019 held in Xi’an, Mr. Wu Jinzhong from the Highway Research Institute under the Ministry of Transport (MOT) clarified China’s institutional endeavors to regulate road transport of dangerous goods and offered his insights into considerations underlying relevant rules.
The aim of China’s legislations and standards in this regard is to strike a balance between safety and facilitation: they are devised to not only ensure safe and well-regulated transport with requirements for technical processes and equipment, but provide facilitation for relevant businesses in the industry with rules regarding transport permits, exemptions, etc.
With such a consideration in mind, China issued the Regulations Concerning Road Transportation of Dangerous Goods (JT/T617-2018 [1]) by using the EU ADR as a reference last year. Meanwhile, the Measures for Safety Administration of Road Transport of Dangerous Goods (hereinafter referred to as the Measures, see CL news on its third draft [2]) is expected to be officially released soon and take effect on December 1 this year, according to Mr. Wu. The two documents together will constitute an overarching regulatory tool for road transport of dangerous goods in the country.
With the two documents as the focus, Mr. Wu explained major progress made in regulating road transport of dangerous goods by summarizing it into five aspects.
Enhanced Regulation of Shipments
Previously, there existed some regulatory gap with regard to shipment, because several authorities concerned had overlapping responsibilities and thus could not fully play their role in regulating relevant businesses. To address this issue, the draft Measures proposed explicit safety requirements for both shippers and loaders.
For instance, shippers are demanded to entrust goods to a qualified carrier and make sure the classification, name, packaging, etc. are compliant with relevant standards in JT/T617; and loaders are required to check four items, including goods stored in tanks, inspection date, personnel qualification and special certificates, and keep goods loading records for no less than one year.
Moreover, stringent punishments, including fines and even criminal penalties, will be imposed on shippers violating the Measures and causing accidents.
Strengthened Management of Tank Vehicles for Transporting Dangerous Goods
Vehicles play an essential part in transport of goods. The draft Measures provided that manufacturers of atmospheric tank vehicles should have their tanks inspected by inspection agencies which are certified by the General Administration of Quality Supervision, Inspection and Quarantine and the MOT, so as to ensure that only tank vehicles that meet relevant standards can be sold in the market. Moreover, they are required to provide a list which specifies dangerous goods which can be stored in their tanks.
In addition to the Measures, the revised standard Technical Requirements for Atmospheric Metal Tanks (GB 18564.1-2019) is to be released to guide tank vehicle manufacturers to design and manufacture tank vehicles in line with new standards. Moreover, several documents published by the State Council and ministerial departments have noted that focused actions should be taken to further regulate the operations of tank vehicles.
A Transport Documents Management System
There are majorly two types of documents in road transport of dangerous goods. The first is a shipment inventory, which should include information of shipper, carrier, goods, etc. A shipment inventory, in either paper or electronic form, should be given to carriers by shippers before shipment and kept by carriers for no less than one year. Meanwhile, parties concerned should be able to offer a shipment inventory at the request of regulators.
The second is a waybill which is prepared by carriers in a unified format. A waybill, in either paper or electronic form, should be given to vehicle drivers before shipment and subject to inspections by regulators.
A More Solid Training Management System
The standard JT/T 617.1-2018 [3] lists training requirements for various types of personnel engaging in road transport of dangerous goods. For instance, personnel which are responsible for classifying dangerous goods need to learn about physio-chemical and toxicological properties of dangerous goods, principles for their classification, procedures for classifying solutions and mixtures, etc.
The draft Measures also proposed that shippers and carriers should provide employees who work on shipment and carriage of dangerous goods with pre-service safety training and routine safety training on an irregular basis.
An Improved Exemption System for Dangerous Goods
It is clearly stated in the draft Measures that dangerous goods packed in a relatively small quantity can be exempted from certain requirements. For requirements and exemptions prescribed in the draft Measures for dangerous goods packed in LQ or EQ, see the table below.
| EQ | LQ |
Standards for packaging, labeling, package testing, quantity limit of each inner package and outer package |
| |
Shipping documents |
|
|
Mixed stowage and segregation |
| |
Quantity limit for per transport vehicle | Number of packages offered as EQ ≤ 1,000 | Gross mass (packaging included) of packaged offered as LQ ≤ 8,000 kg |
Mr. Wu noted that the implementation of this exemption system must be bolstered by supporting documents, and its application scope will be gradually expanded. But given the grim situations regarding road transport safety of dangerous goods, the authorities have decided to ease the restrictions at a slow pace, so as to avoid hasty implementation of relevant arrangements.
