GHS Situation and Gap Analysis

1
GHS Situation and Gap Analysis Transport Sector

• May 2006
• Office of the Permanent Secretary, Ministry of
  Transport
• Study conducted by
• Mahidol University
• and
• Pongnarin Petchu

2
Overview of the Study
B
A
C
DB(A)-C
Transport of DG
Situation
Gap
Classification Hazard Communications Trainings

• List of dangerous goods most commonly carried and
  their identification and Classification
• Consignment procedures Labelling, Marking and
  Transport Documents
• Standards for packagings, test procedures and
  approval
• Standards for multimodal tank-containers, test
  procedures and certification
• Training of persons involved in transport

• Classification
• - Physical hazards
• - Health hazards
• - Environmental hazard
• Hazard Communications
• - Labelling
• - Safety Data Sheet
• (SDS)
• Trainings of target audiences

• National Background Information
• Legal/regulatory Infrastructure
• National Institution/Adminitrative Infrastructure
• Programs conducted by Industry,
  Labor/Public/Environmental Interrest Groups and
  Research Institutes
• Programs conducted with support of international
  organizations
• Summary of Situation Analysis
• Summary of Gap Analysis

3
A. Globally Harmonized System for Classification
and Labelling of Chemicals (GHS)
4
Overview of the GHS
5
Overview of the GHS
Part General Classification Classification Classification Hazard Communication Hazard Communication Training
Part General Physical Health Envi. Labelling SDS Training
1 1.1 1.3 1.3 1.3 1.4 1.5 1.4
1 1.2 1.3 1.3 1.3 1.4 1.5 1.4
2 2.1-2.16
3 3.1-3.10
4 4.1
Annexes 1
Annexes 2 2 2 2
Annexes 3
Annexes 4
Annexes 5
Annexes 6 6 6
Annexes 7
Annexes 8 8 8
Annexes 9
Annexes 10
6
GHS Classification
PHYSICAL HAZARDS 1 Explosives 2 Flammable gases
3 Flammable aerosols 4 Oxidizing gases 5 Gases
under pressure 6 Flammable liquids 7 Flammable
solids 8 Self-reactive substances and mixtures 9
Pyrophoric liquids 10 Pyrophoric solids 11
Self-heating substances and mixtures 12
Substances and mixtures which, in contact with
water, emit flammable gases 13 Oxidizing
liquids 14 Oxidizing solids 15 Organic
peroxides 16 Corrosive to metals
HEALTH HAZARDS 1 Acute toxicity 2 Skin
corrosion/irritation 3 Serious eye damage/eye
irritation 4 Respiratory or skin sensitization 5
Germ cell mutagenicity 6 Carcinogenicity 7
Reproductive toxicity 8 Specific target organ
systemic toxicity Single exposure 9
Specific target organ systemic toxicity
Repeated exposure 10 Aspiration
hazard ENVIRONMENTAL HAZARDS 1 Hazardous to the
aquatic environment
7
GHS Classification Physical
Physical Hazard Classes Hazard Category Hazard Category Hazard Category Hazard Category Hazard Category Hazard Category Hazard Category
Explosives Unstable Explosives Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6
Flammable Gasses 1 2
Flammable Aerosols 1 2
Oxidizing Gases 1
Pressurized Gasses
Compressed Gasses 1
Liquefied Gasses 1
Refrigerated Gasses 1
Dissolved Gasses 1
Flammable Liquids 1 2 3 4
Flammable Solids 1 2
Self-Reactive Substances Type A Type B Type C Type D Type E Type F Type G
Pyrophoric Liquids 1
Pyrophoric Solids 1
Self-Heating Substances 1 2
Water Reactive ? Flammable Gases 1 2 3
Oxidizing Liquids 1 2 3
Oxidizing Solids 1 2 3
Organic Peroxides Type A Type B Type C Type D Type E Type F Type G
Corrosive to Metals 1
8
GHS Classification Health Envi
Health Hazard Classes Hazard Category Hazard Category Hazard Category Hazard Category Hazard Category
Acute Toxicity, Oral 1 2 3 4 5
Acute Toxicity, Dermal 1 2 3 4 5
Acute Toxicity, Inhalation 1 2 3 4 5
Skin Corrosion/Irritation 1 1A/B/C 2 3
Eye Damage/Irritation 1 2 2A/B
Respiratory Sensitization 1
Skin Sensitization 1
Germ Cell Mutagenicity 1 1A/B/C 2
Carcinogenicity 1 1A/B/C 2
Reproductive Toxicity 1 1A/B/C 2 Lactation
Target Organ ST Single Dose 1 2 3
Target Organ ST Single Dose 1 2
Aspiration Hazard 1 2
9
GHS Hazard Communications
Labelling
Safety Data Sheet
Pictograms
from Cradle to Grave
Workplace including pesticides and pharmaceuticals Labels and Safety Data Sheets
Consumers Labels
Transport Labels, Placards, Transport Documents
Emergency responders Labels, Placards
10
GHS Training
11
B. International Regulations for Transport of
Dangerous Goods
12
The UN System
13
International Regulations Structure
UN Recommendations on the Transport of Dangerous
Goods (Model Regulations or Orange Book)
14
International Regulations for Dangerous Goods
Transport System
System of Linkage
http//www.unece.org/trans/danger/danger.htm
15
International Regulations for Dangerous Goods
Transport System

• Multi-modal Transport UN Recommendations on the
  Transport of Dangerous Goods a so-called UN
  Model Regulations or Orange Book
• Road The Restructured ADR of UNECE in Geneva,
• Rail The Restructured RID of OTIF in Bern,
• Inland Waterways The Restructured ADN of UNECE
  in Geneva,
• Sea IMDG Code of IMO in London,
• Air IATA-DGR of ICAO-TI of ICAO Montreal

http//www.unece.org/trans/danger/danger.htm
16
European and German Rules Regulation of DG
Transport History/Road Map
17
Development of the Classification System of
Chemicals

• Workplace aspect
• Risk Phrases
• Acute and long-term effects
• Storage classes
• Segregation and separation of dangerous goods and
  dangerous substances

• Transport aspect
• Transport classes
• Acute effects
• (Closed packagings,
• Contact only in case of incident)

Past
Present

• Globally Harmonised System (GHS)
• Harmonisation of classification and labelling
  systems
• Same criteria but different limit values for
  handling and for transport

Future
18
Workplace aspect Risk (R) - Phrases
Physicochemical Properties
Toxicological properties
Property Risk phrase
Explosives R2 R3
Oxidising R7 R8 R9
Flammability R12 R11 R15 R17 R10 R30
Explosive reactions R1 R4 R5 R6 R16 R18 R19 R44
Fire R7
Water reactive R14
Property Risk phrase
Toxic effects R28 R27 R26 R39 R25 R24 R23 R39 R48 R22 R21 R20 R65 R68 R48
Corrosive effects and other effects on skin R35 R34 R38 R36 R41 R37
Sensitation R42 R43
Liberation of toxic gases R29 R31 R32
Other effects R33 R64 R66 R67
Specific effects on human health
Specific effects on environment
Property Risk phrase
Carcinogenic substances R45 R49 R40
Mutagenic substances R46 R68
Substances toxic to reproduction R60 R61 R62
Property Risk phrase
Toxic or harmful effects on the aquatic environment R50 R51 R52 R53
Toxic flora, fauna, soil organisms and bees R54 R55 R56 R57
May cause long-term adverse effects in the environment R58
Dangerous for the ozone layer R59
19
Workplace aspect Storage classes
Storage class Description
1 Explosive substances
2A Compressed, liquefied and dissolved gases
2B Pressurized small gas containers (aerosol cans/aerosol containers)
3A Flammable liquids
3B Flammable liquids
4.1A Flammable solids
4.1B Flammable solids
4.2 Spontaneously combustible substances
4.3 Substances that emit flammable gases in contact with water
5.1A Oxidising substances
5.1B Oxidising substances
5.1C Oxidising substances
Storage class Description
5.2 Organic peroxides
6.2 Infectious substances
7 Radioactive substances
8A combustible corrosive substances
8B Non- combustible corrosive substances
9 (not used)
10 Combustible liquids unless classified in storage class 3 A or 3 B
11 Combustible Storage
12 Non- combustible liquids
13 Non- combustible solids
20
Transport Aspect Transport classes
Class Description Packing Group (PG) Packing Group (PG) Packing Group (PG) Packing Group (PG) Packing Group (PG) Packing Group (PG)
1 Explosives 1.1 1.2 1.3 1.4 1.5 1.6
2 Gases Flammable gases Gas under pressure Toxic gases
3 Flammable liquids I II III
4 Flammable solids Spontaneous combustible substances Dangerous when wet I II III
5 Oxidizing agents Organic peroxides I II III
6 Toxic substances Infectious substances I II III
7 Radioactive material
8 Corrosive substances I II III
9 Miscellaneous
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Comparison of GHS vs. Transport
Explosives Class 1
Flammable Gasses Class 2 (2.1)
Flammable Aerosols Class 2 (2.1)
Oxidizing Gases Class 5.1
Pressurized Gasses Class 2 (2.2)
Compressed Gasses Class 2 (2.2)
Liquefied Gasses Class 2 (2.2)
Refrigerated Gasses Class 2 (2.2)
Dissolved Gasses Class 2 (2.2)
Flammable Liquids Class 3
Flammable Solids Class 4.1
Self-Reactive Substances Class 4.3 Class 1 (for category 1)
Pyrophoric Liquids Class 4.2
Pyrophoric Solids Class 4.2
Self-Heating Substances Class 4.2
Water Reactive ? Flammable Gases Class 4.3
Oxidizing Liquids Class 5.1
Oxidizing Solids Class 5.1
Organic Peroxides Class 5.2
Corrosive to Metals Class 8
Acute Toxicity, Oral Class 6.1
Acute Toxicity, Dermal Class 6.1
Acute Toxicity, Inhalation Class 6.1
Skin Corrosion/Irritation Class 8
Eye Damage/Irritation
Respiratory Sensitization
Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Target Organ ST Single Dose
Target Organ ST Single Dose
Aspiration Hazard
Acute Toxicity, Oral Class 9
Acute Toxicity, Dermal Class 9
22
Hazard Communications
23
Example of existing Danger Labels of Workplace
and Transport
24
Example of Pictograms and Labels of GHS
25
Example of transport labels (still the same
except Class 5.2)
26
Documents for Transport (1)
The following documents shall be carried on the
transport unit (truck)

• transport documents

• container packing certificate if appropriate

• instructions in writing

• drivers training certificate

• certificate of approval for tank vehicles and
  vehicles transporting tank containers

27
Documents for Transport (2)
Transport documents must bear the following
information

• Name and address of consignor

• Name and address of consignee

• UN-number

• Proper Shipping Name

• Class (number of label model for primary and
  secondary property)

• Packing group

• Number and description of packagings

• Total quantity

• Declaration concerning special agreement

28
Documents for Transport (3)
Instructions in writing (tremcards transport
emergency cards)

• for each substance, if the limits of 1.1.3.6 are
  exceeded

• information for driver and emergency services
  (fire brigade)

• language of the driver

• language of country of departure

• language of country of destination

• languages of transit countries

• certain information

29
Documents for Transport (4)
Contents of instructions in writing

• name of the substance or group of goods (load)

• nature of danger

• personal protection

• general actions to be taken by the driver

• additional and/or special actions to be taken by
  the driver

• fire

• first aid

• additional information

30
Training of Persons involved in the Carriage of
Dangerous Goods
Persons employed by the participants referred to
in Chapter 1.4, whose duties concern the carriage
of dangerous goods, shall receive training in the
requirements governing the carriage of such goods
appropriate to their responsibilities and duties.
The trainings undertaken should be documented and
supplemented with refresher training.

1. General Awareness training to be familiar with
   the general requirements of the provisions for
   the carriage of dangerous goods
2. Function specific training to receive detailed
   training according to their duties and
   responsibilities
3. Safety training to receive training covering the
   hazards and dangers presented by dangerous goods
   (aiming to make personnel aware of the safe
   handling and emergency response procedures)
4. Training for class 7 receive appropriate
   training concerning the radiation hazards
   involved and the precautions to be observed in
   order to ensure restriction of their exposure

31
Transport GHS Training
Chemicals life cycle
Production
Import
Transport
Storage
Storage
Transport
End users
Consignor
Consignee
Transport of Dangerous Goods
Packer/Loader/ Filler
Driver
Carrier
32
Safety obligations of the participants of the
transportation process
After transport
During transport
Prior to transport

• Consignee (1.4.2.3)

• Carrier (1.4.2.2)
• Driver (Chapter 8.2)

• Consignor (1.4.2.1)
• Loader (1.4.3.1)
• Packer/Filler (1.4.3.2) 1.4.3.3)
• Tank-container / portable tank operator (1.4.3.4)

• Take appropriate measures to reduce or minimize
  the risk from transport
• Receive training in the requirements governing
  the carriage of such goods appropriate to their
  responsibilities and duties (Chapter 1.3)

33
Situation Gap Analysis

• A) Legal/Regulatory Infrastructure
• B) National Institution/Administrative
  Infrastructure
• C) Programs Conducted by Industry, Labor /
  Public / Environmental Interest Groups and
  Research Institutes
• D) Programs Conducted with Support of
  International Organizations

34
Statistical Model for Transport of Dangerous
Goods by Modes of Transport and Classes
35
Overview of Problems from exposures to chemicals

• Acute effect ? most concern for transport sector
• Packagings/containment system will get UN Marks
  to certify that they passed the required tests
  and can take for transport

36
Disaster from Dangerous Goods Incidents in
Thailand
37
Disaster from Dangerous Goods Incidents in
Thailand
Substance involved Liquefied Petroleum Gas
LPG) UN 1075
Incident Place Petchburi Road, Bangkok Date 24
Sep 1990 Time around 2200 hrs.
54 Death with 97 injury
Cause Careless driving, too fast driving and
incomplete equipment (low standard)
38
Disaster from Dangerous Goods Incidents in
Thailand
Substance involved Explosive Substances of Class
1
Incident Place Phang-Nga Province (South) Date
15 Feb 1991 Time around 1500 hrs.
171 Death with 99 injury
Cause Careless driving, too fast driving and
incomplete equipment (low standard)
39
Disaster from Dangerous Goods Incidents in
Thailand
Substance involved Acrylonitrile (UN1093)
Incident Place 2ND stage Express Way,
Bangkok Date 4 Sep 2001 Time around 0500 hrs.
Cause Careless driving
40
Legal/Regulatory Infrastructure existing
regulations

• Hazardous Substance Act B.E. 2535 for control of
  production, import, export, and possession of
  hazardous substances
• Land Transport Act B.E. 2522 control
  transportation of man, animals and substances by
  land (by carriers of designated and undesignated
  routes) for the safety purposes to public
• Land Traffics Act B.E. 2522 concerns about safe
  transport on land traffic (enforced by the
  National Police Office)
• Navigation in Thai Water Act B.E.2456 and amended
  B.E.2535 controls all navigation in Thai waters
• Air Traffics Act B.E.2497 controls air traffics
  according to the international agreement on civil
  aeronautics, which Thailand is a member
  (Chicago/December 1944 to facilitate air
  transport accidents and qualifications of
  personnel)
• The Railway Act of Thailand B.E.2494 and Fifth
  Amendment BE. 2530 concerns all activities of
  train transport including all relevant
  regulations
• Other regulations concerning transportation of
  hazardous substances as announced by other
  agencies

41
National Institutional / Administrative
Infrastructure

• DIW chemicals hotline 1564 and www.diwsafety.org
• Pollution control Department (PCD) hotline 1650
  and www. http//www.pcd.go.th
• The Thai-FRID (Thai First Response Information
  Database) - a joint development program between
  the Information and Communication Technology
  Center, Office of the Permanent Secretary
  Ministry of Transport and GTZ developed during
  the Thai-German Dangerous Goods Project
  Implementation in 1998-2003

42
National Institutional / Administrative
Infrastructure
http//gis.mot.go.th/motcgtz/index.cfm
http//www.pcd.go.th/info_serv/er/defaultthai.cfm
43
Programs conducted by Industry
Responsible Care Management Committee of Thailand
(RCMCT) under the Federation of Thai Industries
(FTI)
44
Programs conducted by Industry
45
Programs conducted with Support of International
Organizations
Year Bi-lateral development cooperation Type of Program
1998-2000 GTZ Drafting of TP-I (NESDB) Train-the-trainer of driving license class 4 (DLT) Train-the-trainer of inspection of dangerous cargo vehicles (DLT) Training of Thai officials for packagings and tanks approval Train-the-trainer Hazmat Course 1
2000-2003 GTZ Drafting of TP-II (ADR) and TP-III (ADN) Training Classification of Dangerous Goods including GHS Train-the-trainer Hazmat Course 2
Thai GermanDangerous Goods Project
Thai GermanTechnical Cooperation
46
Achievements of the Project
Storage / Handling
Transport System
Emergency Response System

• HazMat Training Courses
• with Handbooks and Instructor Manuals as well as
  the coaching and supporting of train-the
  Trainer Courses to ensure the professional
  know-how transfer and the most appropriate
  qualification of First Response Teams
• Thai First Response Information Thai-FRID)
• a database for the preparedness, planning and
  response to the incident involving dangerous
  goods available at MoT and can be downloaded
  from the website www.mot.go.th

• Thai Provisions Volume I (TP-I)
• The Multi-modal Transport of Dangerous Goods
  based on UN Recommendations for Transport of
  Dangerous Goods or the Orange Book approved
  by the cabinet on May 23, 2000
• Thai Provisions Volume II (TP-II)
• The Transport of Dangerous Goods by Road based on
  the European Agreement Concerning the
  International Carriage of Dangerous Goods by Road
  (ADR2003) ready for seeking approval from the
  cabinet
• Thai Provisions Volume III (TP-III)
• The Transport of Dangerous Goods by Inland
  Waterways based on the European Agreement
  Concerning the International Carriage of
  Dangerous Goods by Inland Waterways (ADN2003)
  still on-going process by Marine Department
• Various trainings for core team of the government
  officials involved
• Driving License Class IV, Inspection of DG
  Cargoes vehicles, Transport of Dangerous Goods by
  Inland Waterways, Tanks Inspection and
  Certification, Approval of Packagings,
  Classification of DG DS

• Guideline for Safe Storage of Dangerous Goods and
  Dangerous Substances approved by the IEATs
  Governor in November 2002
• Various trainings for core team of the government
  officials involved
• How to Use the Guideline, How to Get Appropriate
  Information, Classification of DG DS, Using
  guideline for accident prevention

47
International Regulations for Dangerous Goods
Transport System adopted to Thai Provisions
48
Protocol 9 Agreement for transport of DG in
transit in ASEAN Countries
49
Summary of Situation and Gap Analysis

• Classification Already in line with the
  international transport regulations (UN
  Recommendations and ADR) but laboratories for
  testing of chemicals and consulting companies are
  still opened for establishment with facilitating
  of the government sector,
• Hazard Communication Already inline with the
  international transport regulations (UN
  Recommendations and ADR) but required a clear
  competent authority to supervise, control and
  check of the whole transport system with all
  modes of transport and training of persons
  involved in the transport life cycle is strongly
  required,
• Training system according to the TP-II (drivers
  and persons involved) is not fully in line with
  the international regulations and lack of
  information and support to SMEs as well as more
  awareness raising to relevant sectors and
  authorities,
• Enforcement is still needed to be tightening by
  training of responsible authorities and polices

50
Domestic Transport of Dangerous Goods Processes
and Persons Involved
During Transport Process
Start of Transport Process
End of Transport Process
Possible Transport Modes
Ports
Ports
Road
Factories (IE/IP)
Factories (IE/IP)
Rail
Warehouses
Possible Transport Destinations
Warehouses
Possible Transport Origins
Distribution Center
Inland waterways
Refineries
Distribution Center
Coastal shipping
Gas Stations
Refineries
Transport by pipelines
Trans-shipment
Trans-shipment
End users
Drivers
Custom officers
Custom officers
Vehicle crew
Port operators
Port operators
Transport associations
Consignors
Consignees
Transport operators / Carriers
Loaders / Fillers / Packers
Persons who unload / empty / unpack
Labor union
Persons involved
Persons involved
Transport operators
Transport operators
Chemical Industry
Chemical Industry
Chemical Industry
Emergency Responders
Transport associations
Transport associations
Municipalities
Polices / Highway polices
Labor union
Labor union
51
Training of persons involved in the transport
life cycle

• Persons involved in the transport process are
• Custom officers,
• port operators (if the dangerous goods are
  imported from abroad and unloaded at a ports),
• industrial provincial officers,
• industrial estate officers,
• loaders, fillers, packers,
• drivers,
• vehicle crew,
• master of vessel,
• others involved, like administrative staff of
  forwarding agent, carriers, etc.
• These people involved have to be trained in order
  to gain knowledge about
• classes of dangerous goods and the inherent
  hazard properties,
• pictogram of each class,
• labelling of the packages,
• placarding of the transport units,
• Safety Data Sheet (SDS),
• written instruction or Transport Emergency Card
  (TREM Card),

52
Next step and recommendations

• There is a need to make a clear cut about the
  competent authority and responsibilities of
  agencies involved,
• To establish a transport of dangerous goods
  committee to supervise and coordinate among the
  parties locally and internationally,
• The update and drafting of the relevant
  ministerial regulations and department
  notifications should be made,
• For a long run, drafting of a new Transport of
  Dangerous Goods Act is strongly recommended,
• The action of the government and responsible
  agencies on the facilitation of the service on
  classification and training of the target
  audiences in the transport related sector in
  regard to the GHS should be initiated to simplify
  the national implementation process of GHS,
• The incentive for encouraging private consulting
  to open up the markets in the training and
  consulting to SMEs should be considered,
• The stimulation of the awareness program and
  campaign made by the civil society and NGOs
  should be initiated and implemented to the whole
  life cycle of the transport because very often
  the civil society can be acting as magic eyes for
  the government and societies
• Some training curriculum should be introduced in
  the school or universities to ensure sustainable
  development