Coatings and transport: On the way
What is the current status on the IMDG code harmonisation of the viscous flammable liquid exemption?
Loes Brust and Janice Robinson: The harmonisation of the viscous flammable liquid exemption this summer was a great success for us. While the exemption was 450 l in the UN Model Regulations and for road and rail transport, due to the International Maritime Dangerous Goods (IMDG) code transport by sea was limited to 30 l. Companies can make use of the new higher limit from 2019 on.
You also worked towards transport packaging no longer requiring CLP labels. What was the issue here?
Brust and Robinson: There was long-standing confusion and difference of opinion over the interpretation of CLP Article 33(2), namely whether the outer transport packaging also needs to carry CLP labels (when not dangerous goods for transport). This was posing many difficulties. Transport packages often contain different products and would therefore have to be provided with many CLP labels. Since 2011, our CEPE group has been working on this topic. In 2013, a position of the DUCC (Downstream Users of Chemicals Co-ordination group) matching our viewpoint was published. After lobbying for years, it has been a great relief to see that the new ECHA guideline on labelling and packaging in accordance with Regulation (EC) 1272/2008 – version 3 (article 33) includes the clarification that transport packaging is not within the meaning of CLP and does not need to carry CLP labels.
What projects is the Transport Committee mainly working on at the moment?
Brust and Robinson: Our main concern at the moment are the requirements for environmentally hazardous materials. There is no specific Dangerous Goods List entry for such paints and coatings, they are simply transported as ‘environmentally hazardous substance’. But there is also a requirement to identify the hazard inducing component, which we disagree with. We have spoken to emergency responders and transport authorities – e.g. from the United States where this requirement is not in place – about this issue. They backed our opinion that indicating the hazard inducer is unnecessary, as the protocol of emergency is the same and an indication as environmentally hazardous does suffice.