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On December 1st, 2020, Mr. Wu Jinzhong from the Highway Research Institute under the Ministry of Transport (MOT) introduced the highlights of the Measures for Safety Administration of Road Transport of Dangerous Goods [1], which was introduced in late 2019 and took effect on January 1st this year (for more details, see CL news [2]), at CRAC-HCF 2020 [3]. Notably, he laid particular emphasis on the exemption granted to dangerous goods packed in limited quantities (LQ) and excepted quantities (EQ) in the Measures.
In recent years, the transport of dangerous goods with low hazards and in small quantities has always been a topic of heated discussion in the industry. If such goods can be transported using reliable and durable packages or following certain conditions, they will pose much less danger. In response to such discussions, the Measures states that “dangerous goods can be transported as general goods if the number of packages of dangerous goods packed in EQ does not exceed 1000, or the gross mass (packages included) of dangerous goods packed in LQ carried does not exceed 8 tons per transport unit”.
With this exemption system, the Measures manages to significantly lower the transportation costs associated with dangerous goods which qualify for the exemptions. As enterprises still have many questions surrounding the detailed arrangements for LQ and EQ, Mr. Wu responded to industry concerns in the regard during the Q&A session.
The following is a selection of the most relevant questions with Mr. Wu’s responses.
The introduction of the two Guidelines has been delayed as a result of the pandemic. Currently, the two Guidelines are in the middle of final review. They are expected to be published before the end of this year.
According to what the MOT has learned, the system has been practiced in virtually all localities. If it is found out that any local authorities do not grant exemption to qualified businesses, they can report to local administrations of transport.
The requirements for testing of LQ packaging will be further clarified in the Guidelines. Before the Guidelines comes out, businesses can conducts tests referring to Safety Code for Inspection of Packaging of Dangerous Goods Transported by Road (GB 19269) [4].
According to the Regulations Concerning Road Transportation of Dangerous Goods (JT/T617) [5], dangerous goods can be mixed together with general goods for transport in some cases. But currently in practice, the mixed stowage of dangerous goods and general goods is not allowed. Will the authorities makes relevant provisions more explicit in the future?
The provisions on mixed stowage in JT/T 617 are not adopted in the Measures. So we will make further improvements in the future. For instance, we are working to revise the Provisions on the Administration of the Road Transport of Dangerous Goods [6], in which the requirements on mixed stowage will be made clear. An exposure draft of the revision will be published soon.
