China MOT: Improving Road Transport Safety and Removing Compliance Hurdles

More than 5,000 varieties of chemical materials are transported in China. When you consider the large variety and volume of these chemicals in the context of China’s gargantuan landmass, regional capacity and resource disparities and the uneven geographical concentration of chemical manufacturing facilities we can see how Chinese authorities face a unique array of challenges to effectively regulate the transport of dangerous goods in China. Statistics show that from 2008 to 2012, approximately 10,000 Hazchem accidents have occurred in China every year with a daily average of 27. Of greatest significance is the fact that transport accidents account for over 76% of the total number.

During REACH4Hs annual regulatory conference 2016 Mr. Jinzhong Wu from the Highway Research Institute under the Ministry of Transport explained that to tackle the problems in China’s road transportation of dangerous goods, China MOT has identified six prioritized tasks including:

1. Enhancing supervision on consignment of dangerous goods

2. Researching and implementing exemption policies

3. Improving management of road tankers

4. Establishing rationalized orders to restrict the use of roads/highways by vehicles carrying dangerous goods

5. Formulating and improving The Regulation of Automobile Transportation of Dangerous Goods (JT 617)

6. Building emergency response capacity

Regulatory requirements on consignment of dangerous goods

It is believed that through enhanced supervision on the consigning processes the transport safety risks can be controlled from the source. Under the forthcoming Measures for the Safety Administration of Road Transport of Dangerous Goods (hereinafter referred to as the “Measures”, which should be implemented this October or at latest by the end of 2016), shippers should consign dangerous goods only to carriers with DG transport licenses (of corresponding class or division) and are responsible for classification, packaging and providing SDS and consignment inventory. Loaders should make sure the materials are compatible, both the vehicles and workers (including drivers and escorts) are licensed and the filling/loading records are properly archived. Mr. Wu advised that there would be increased compliance costs but it was a small price to ensure the safe and steady growth of the industry.

LQ/EQ exemptions

As previously reported, some exemption policies are being developed under the new Measures to make the regulatory requirements feasible and bring more convenience to business and life, such as the exemption to individuals carrying dangerous goods in retailing packages (≤ 60L per package and ≤ 240L per transport unit) for personal or family uses, and the exemption to hazardous chemicals not classified as dangerous goods in accordance with GB 6944 and GB 12268.

Among these exemptions the one that aroused the most heated discussion is the exemption to dangerous goods transported in limited quantities (LQ) or “exempted quantities (EQ)”. REACH24H has actively participated in providing technical consultancy to the drafting authority on improving some detailed requirements. Though not yet officially announced, it is believed the following changes will be seen in the finalized Measures based on the previous 2 drafts:

• Requirements on shippers eligible for LQ/EQ exemptions will be eliminated, which means safe manufacturing license or Hazchem operation license will not be required;

• LQ packages will be allowed to be shipped by carriers without DG licenses of any class or division, the same as EQ packages

• The maximum gross mass of LQ packages that can be shipped in one transport unit will be increased from 1000 kg to 8000 kg.

However, the rules will not be applicable to mail and parcel delivery businesses, which are subject to Regulations on Express Delivery accounted for by the State Post Bureau (SPB).

JT 617 The Regulation of Automobile Transportation of Dangerous Goods

Mr. Wu introduced in his presentation that there are over 120 effective national or industrial standards in China that are related to road transport of dangerous goods. These standards were developed at different times and by different work groups, resulting in overlaps, gaps and conflicts. To solve the problem, JT 617-2004 The Regulation of Automobile Transportation of Dangerous Goods has been totally revised. The new JT 617 contains over 800 pages divided into the following 9 parts:

1. General provisions

2. Class and division

3. List of dangerous goods for road transport

4. Packing and tanking provisions

5. Consignment procedures

6. Requirements for the construction and testing of packagings and containers

7. Requirements on the conditions of loading and unloading

8. Requirements on the conditions of carriage

9. Technical requirements of vehicles

EU ADR (2015) and 49CFR of the US were referenced during the formulation of new JT 617. Again, publication of this standard can be expected by the end of 2016.