Driving can be hazardous at the best of times, but the safe carriage of dangerous goods requires compliance with complex regulations, an absolute commitment to best practice and extra levels of driver training and skill.
BCGA member companies co-operate with each other to ensure the safe carriage of the goods they carry and the safety of vehicle crews and the general public. Within BCGA, Technical Sub-Committee (TSC) 4 monitors activity associated with transport and is responsible for a range of publications promoting safety and best practice in transport.
Any goods that pose a risk to people, property and the environment are classified as dangerous goods. When transported these goods need to be packaged correctly to ensure that they are carried safely. Gases are classified as dangerous goods. The transport of dangerous goods is regulated in order to prevent, as far as possible, accidents involving people or property, damage to the environment, to the means of transport employed or to other goods being transported. Each mode of transport, (air, sea, road, rail and inland waterway) has its own regulations but they are now largely harmonized with the Model Regulations, published by United Nations Economic and Social Council's Committee of Experts on the Transport of Dangerous Goods.
The UN Model Regulations use a classification system in which each dangerous substance or article is assigned to a CLASS, depending on the nature of the danger it presents. Gases are assigned to Class 2, and are further sub-divided into three divisions:
- Division 2.1 - Flammable gas
- Division 2.2 - Non-flammable non toxic gas
- Division 2.3 - Toxic gas
Dangerous goods which are transported by air have to follow the International Civil Aviation Organization (ICAO) regulations. These regulations, along with national and individual airline requirements, are implemented via the International Air Transport Association (IATA) and their document the IATA Dangerous Goods Regulations. The Civil Aviation Authority (CAA) is the UK's aviation regulator.
Dangerous Goods which are transported by sea have to follow the International Maritime Organization regulations which are implemented via the International Maritime Dangerous Goods (IMDG) Code.
Dangerous goods which are transported by road or rail within Great Britain have to comply with the requirements of The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG 2009) [SI 2009, No 1348], as amended. These regulations implement the provisions of the European agreements, ADR (road transport), RID (rail transport) and the Transportable Pressure Equipment Directive (TPED). The Secretary of State for Transport, within the Department for Transport (DfT), is the competent authority for Great Britain.
Everyone transporting gas cylinders in the course of their work is required to comply with ADR and has to meet certain basic minimum legal safety requirements. A threshold level is set based on a quantity of transport units, if below the threshold you are exempt from some requirements of ADR but if you exceed the threshold level you are required to comply with the full ADR regulations. Refer to BCGA GN 27, Guidance for the carriage of gas cylinders on vehicles.
It is recommended that gas cylinders are transported in open vehicles, open containers or trailers. If it is necessary to transport gas cylinders inside a vehicle then good ventilation is required. In all spaces, the use of roof ventilators along with side vents will increase the quantity of ventilated air in the vehicle. Once the journey is completed gas cylinders should be removed from the vehicle. If there is any possibility of gas accumulating within a vehicle space then appropriate warning signs are to be displayed. Common hazards come from the use of dry ice, i.e. asphyxiant gas, and also the careless handling and use of welding gas cylinders and equipment leading to a build-up of flammable and oxidant gases. Refer to BCGA CP 31 and BCGA GN 27.
An empty, or partially filled, gas container that has contained a dangerous substance is to be treated the same as a full container and is therefore subject to all the relevant transport dangerous goods regulations. Only if adequate measures have been taken to nullify any hazard may the container be treated as non-hazardous.
When dangerous goods are being transported, the driver of the vehicle is required to carry certain documents, these include:
- Instructions in Writing for the dangerous goods
- Their Vocational Training Certificate (specific to the Class of dangerous goods being carried).
All personnel involved in the carriage of dangerous goods require training and instruction, including drivers and vehicle attendants. Additionally, certain drivers of road vehicles carrying dangerous goods may need to hold a vocational training certificate (VTC, or "ADR certificate"). In the UK the VTC is obtained after a driver has attended a training course and successfully completed an examination, approved by the DfT. The examination has to be appropriate to the class or classes of goods which are to be carried on the vehicle. http://www.dft.gov.uk/topics/freight/dangerous-goods/training/dangerous-goods-driver-training/
DGSA. Businesses that handle (including the transport related activities of loading and unloading), process or transport dangerous goods need to appoint a dangerous goods safety adviser(s) (DGSA). DGSAs need to have obtained a vocational training certificate (VTC) after undergoing training and successfully completing a written examination approved by the DfT. DGSA VTCs are valid for 5 years.
The role and duties of a DGSA are laid out in ADR, Chapter 1.8. As part of these duties the DGSA is required to produce an Annual Report. EIGA provide a template for an annual report for Class 2 dangerous goods (gases), refer to EIGA Document 156. Further
information on the roles and activities of DGSA's is available through the
British Association of Dangerous Goods Professionals (BADGP).
Within the UK the following agencies assist in regulating transport, vehicles and drivers:
There are specific requirements for vehicles driving through tunnels, further information is available from:
- The Road Tunnel Operator Association
- Mersey Tunnel
- Dartford Tunnel
- Blackwall Tunnel (London Traffic)
- UK Road Tunnels Map
Vehicles used for freight transportation have to meet certain standards. Useful information can be found at:
- Construction and use regulations - as amended
- Euro 5 / Euro 6 engine emission standards
- AdBlue vehicle emissions
BCGA provides a number of publications which are useful when transporting gases or gas equipment. These include:
- BCGA CP 16 - The movement of static storage tanks for non-flammable non-toxic gases by road.
- BCGA CP 27 - Transportable vacuum insulated containers of not more than 1000 litres volume.
- BCGA CP 29 - The design and operation of cylinder and tube trailers for the safe transport of compressed gases by road.
- BCGA CP 31 - The safe storage and use of cylinders in mobile workshops and service vehicles.
- BCGA GN 27 - Guidance for the carriage of gas cylinders on vehicles
- BCGA L 1 - The carriage of small quantities of gas cylinders on vehicles.
- BCGA L 13 - Medical oxygen in a vehicle.
- BCGA TIS 26 - Model risk assessment for the transport of gas cylinders.