evatech
Safety Management Services
Nelson, New Zealand
AgriBusiness. Issue 71. Sept/Oct 2008 HSNO-Series. Bruce Evans
Casting more light on transport and hsno documentation
Transport compliance often gets confused with HSNO compliance. Documentation and labelling explained.
In the last issue of this column I touched on the perceived complexity of transport compliance and confusion with HSNO. There wasn’t enough space to expand at that time, but judging by feedback at recent courses, more information is needed on this topic, so by popular demand we’re back on transport in this column.
Confusion over the two Class 9's:
The first thing to be aware of is that there are two ‘Class 9’ product labels, one for Dangerous Goods and one for HSNO. DG transport labels are overseen world wide by the United Nations, and locally by Land Transport New Zealand to make everybody involved in the transport chain aware of the hazards involved in carrying closed, factory-sealed containers that have passed UN packaging specifications.
These labels are also handy prompts to rural retailers and vets that many agrichemicals are Class 9 DG’s and as a consequence suppliers are required to provide documentation as a first step in meeting transport compliance (more on documentation later). At the same time all three of the products pictured are typical of many agchems in that they are also Class 9 Ecotoxic products under the HSNO legislation.
The UN also oversees this through its Geneva-based Globally Harmonised system the ‘GHS’. Locally it is HSNO driven by ERMA to make sure everybody else other than transporters is aware of the hazards that may occur when the same products are stored or used and the factory sealed containers are opened; allowing their contents to enter the wider environment. Thus it is very common for agrichemicals to be both Class 9 Dangerous Good’s for transport purposes and also Class 9 Ecotoxicants under HSNO.
Differing documentation required:
In each case documentation is required at point of sale. This is when confusion can set in, and suppliers staff can get tangled up over what type of information to supply, and when. The ‘DG’ or transport bit requires a Dangerous Goods Declaration or DGD which is usually – but not always - a document with red hatched or striped red borders. Alternatively the border may be black and white hatching, or there may be no hatching at all, simply a bold DGD heading at the top.
So guess what happens? The familiar red bordered documents that provide the very awareness that Land Transport wants are quickly photocopied out. More typically the transport companies computer systems don’t handle the hatched documents, thus bland looking monochrome documents with ‘Dangerous Goods Declaration’ on top are what most suppliers receive. The requirement for DGD’s is largely dependent on quantity and the degree of hazard shown in the Packaging Group status of the product.
You need to know about hazard thresholds and have some ‘D’ endorsement training or have completed a National Certificate in Agrichemical Supply course to learn packaging group criteria. Section 14 of modern Safety Data Sheets (SDS) should have packaging groups in them. For Group III, which is very common, when a sale above 250 litres is made a DGD must be provided to a customer or a sales rep or vet transporting the goods. Remember a supplier must provide the DGD to trucking companies or couriers in every DG case irrespective of quantity and packaging group.
DGD's,SDS,EPG, PSC, ERI & HazNote's are all Level 2 Documentation
To further complicate things, since the 1999 version of the Transport Rule came out, Transport NZ has required an additional document to be provided on top of the DGD. This is known as ERI or Emergency Response Information which can be provided in many different ways including the supply of multi-page Safety Data Sheets, Emergency Procedure Guides (EPG), Product Safety Cards (PSC), or relevant guides out of SNZ HB76.
But more commonly in agriculture the industry has increasingly seen the wisdom of using HazNotes, an Agcarm led initiative to provide a multi-use combination document. The extra documentation on top of the DGD is necessary to provide specific information to enable emergency services to make effective judgements on what to do at a roadside incident.
A HazNote meets the requirements for both DGD and ERI when it is filled in and signed. Great, some savings in the paper proliferation war! When a HazNote is not signed it then becomes just an Emergency Response document and not a DGD and can fulfill its function as a source of emergency management information under HSNO Emergency Management Regulations. Which brings us nicely to the Level 2 requirements mentioned briefly in the last issue.
When the Dangerous Goods are safely off the road and in store or on farm the HSNO Regulations kick in and the substance turns from a DG into a hazardous substance. ERMA then expects the handler to have ready access to emergency information. Described in the ERMA Approved Agrichemical Code of Practice NZS 8409:2004 which states: ‘Level 2 information can be found on a SDS or PSC.’ (PSC was an earlier name for HazNote).
Table K1 in that Code shows which amounts trigger the provision of HazNotes and PSCs. Retailers may also need to heed the advice given under L.3 (pp 138-39) NZS 8409 regarding the supply of information. HazNotes are proving a popular means of meeting all 3 information demands.
If you are not already using them go to: http://www.msds.co.nz for a collection of 14 manufacturers under the one site. In addition many other suppliers list HazNotes or PSCs on their own websites.