Sticking to the letter of the law

Transporting hazardous goods and chemicals requires not only careful handling but also strict adherence to legislation on labelling and documentation. James Killerby, explains how to stay within the law and how to choose labels that are fit for purpose One of the most powerful tools in ensuring the safety of anyone coming into contact with hazardous goods is knowledge of exactly what they’re dealing with. This is at the heart of the new European laws and UN classification, to ensure common understanding of a hazard. It also explains the requirement for increased documentation when transporting these goods. The legislation relating to correct labelling is complex and changes frequently. Countries have their own differing laws on the classification of chemicals so, to avoid confusion, the United Nations has created the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). Countries must create their own legislation to implement this. CLP, the European legislation, came into force in January 2009 and companies had until 2010 to ensure that any labels for single substances were updated to the new regulations. By 1st June 2015, they must do the same for mixtures. CHIP (Chemicals Hazard Information and Packaging for Supply) is the law that has applied to suppliers of dangerous substances and mixtures for many years and will continue to be applied to mixtures until their reclassification to CLP in 2015. There are separate legal considerations for transporting hazardous goods by road, rail, air and sea. International journeys by road through Europe are covered by the ADR Regulations. Hazchem panels on the side of the vehicle must identify the hazardous substance being carried and how to respond in the event of an accident. Rail movement is governed by RID regulations and air transportation by the International Civil Aviation Organisation, with additional requirements from the International Air Transport Association. The International Maritime Dangerous Goods Code informs sea transport. Finally, REACH is a European Union regulation intended to make manufacturers and importers responsible for understanding and managing the risks associated with the use of dangerous substances. It also helps to allow the free movement of substances on the EU. Hibiscus supplies the documentation that may be required for all these processes. When transporting hazardous goods, every situation is unique and labels can serve very different purposes. A bespoke service, taking account of how labels will be used, what they will be exposed to and the company’s corporate image will ensure that they are fully customised to fit the job. To meet the standard BS5609 for marine labelling for example, which includes three months’ immersion in seawater, three parts of the label need to comply – the face, the backing and the adhesive. It is the combination that has to be correct and expert knowledge is required. For example, some adhesives work better on certain surfaces – emulsion acrylic works better on PE better than PP. When commissioning labels, businesses should consider what heat and humidity they will be expected to withstand, and what their life cycle will involve. Hibiscus, for example, has been called on to label goods that are able to cope with the huge temperature shift of being shipped from winter in Wigan where it is -2?C to Qatar where it is 45?C. Choosing the right time to apply the label can also be crucial. If it is stuck to a drum and then immediately filled with a hot product, the surface will expand. If it’s then taken out into a cold yard it will shrink back quickly which could lead to labels wrinkling or even coming off completely. There is an adhesive product that will stand that extreme variation in temperature but, as a higher specification, it is more expensive. If the most expensive consideration is your production time however, this product would be the one to choose. Companies using a lot of varying labels may find that the most efficient solution for them is to print their own. In addition to supplying bespoke or part-printed labels, Hibiscus can provide software and advice on printers so that companies can be self-sufficient. Taking into account the complex and frequently changing legislation surrounding the transportation of hazardous goods plus the physical demands of ensuring compliance, expertise and experience are essential. Businesses commissioning labels should ensure that they stick only with the best.  Author James Killerby is director of Hibiscus Plc, a leading supplier of labels, warning diamonds and documentation for the chemical and transport industry