Interpretation on the Transport of Hazardous Chemicals in China

Recently, the transport of hazardous chemicals has become more frequent. As a result, the public, especially those in the chemical and logistics industry, are paying significant attention to the safety of the transport of hazardous chemicals. Hazardous chemicals are frequently mentioned in chemical regulations in China. So what is the difference between hazardous chemicals and dangerous goods; is there any exemptions for dangerous goods during transport; and what are the differences between hazardous chemicals and dangerous goods with regard to packages and relative documents. CIRS will explain above questions for you as follows:

1. Difference between Hazardous Chemicals and Dangerous Goods

Definition and judgment of hazardous chemicals and dangerous goods are different.

Hazardous chemicals: In accordance with Article 3 of Regulations on Safe Management of Hazardous Chemicals (State Council Decree 591), hazardous chemicals refer to highly toxic substances and other chemicals which are toxic, corrosive, explosive, flammable or are combustion-supporting and can do harm to the people, facilities and the environment.

To be specific, hazardous chemicals are those included in the Catalog of Hazardous Chemicals (2015 version, 2828 entries included) as well as those fulfill the identification criteria. Among all the 95 classification categories of 28 hazard classifications, 81 classification categories have been selected as the hazardous chemical identification criteria; while other 14 classifications categories, which are less hazardous (including 8 physical hazards classifications, 4 health hazards classifications and 2 environmental hazards classifications), are managed as hazardous chemicals. Details are as follows:

Dangerous Goods: In accordance with Classification and Code of Dangerous Goods (GB6944-2012), dangerous goods refer to substances and articles requiring specific protection that have such hazardous characteristics as explosivity, inflammability, toxicity, infectivity, corrosivity and radioactivity and may cause personal injury, property damage and environmental pollution during transport, storage, production, sales, usage and disposal.

Dangerous goods can be classified into 9 classes based on their hazards and the most predominant hazards. They are:

Class 1 Explosives;

Class 2 Gases;

Class 3 Flammable Liquids;

Class 4 Flammable Solid, substances liable to spontaneous combustion and substances emitting flammable gases when wet;

Class 5 Oxidizing substances and organic peroxides;

Class 6 Toxic and infectious substances;

Class 7 Radioactive substances;

Class 8 Corrosive substances; and

Class 9 Miscellaneous dangerous substances and articles, including environmentally hazardous substances.

Based on the definitions of dangerous goods and hazardous chemicals, some chemicals, such as flammable liquids and flammable solid, can be classified as hazardous chemicals and dangerous goods as well. On the other hand, some chemicals can only be classified as hazardous chemicals but cannot be classified as dangerous goods. As a result, these chemical products can be transported as general goods. The reasons why the classification criterion of hazardous chemicals and dangerous goods are different are:

(1) Many non-acute hazards classifications for hazardous chemicals, such as respiratory & skin sensitization, carcinogenicity, reproductive toxicity, specific target organ toxicity (repeated exposure/ single exposure), serious eye damage/ eye irritation, aspiration hazard and germ cell mutagenicity, are not adopted by the classification standards for dangerous goods; and

(2) Some products shall not be classified as hazardous chemicals, but they are dangerous goods, for instance, infectious substances, radioactive substances as well as products like lead-acid battery and lithium battery.

2. Packing Symbols and Labeling of Dangerous Goods

Packages of dangerous goods must satisfy the UN packing specifications. That is to say, the packages of dangerous goods must meet the basic requirements as follows:

• Material and type of the containers and packages should be suitable for the property of the dangerous goods;
• Packages and containers for the dangerous goods should be strong enough to withstand shocks, jolting, extruding and friction normally encountered during transport;
• The packages should have suitable pad and absorbing materials;
• Weight, specification and
• Package marks and labels should be labeled as required on the outside of the package

(1) UN Pac kage Marks

All numbers and letters in the package marks have specific meanings, for instance:

(2) Shipping Marks

Shipping marks should be displayed on package during transport of dangerous goods. Besides, in practical shipment, labels should also be displayed at times depending on the packaging forms of the dangerous goods.

Combination packaging: Labels should be displayed on the inner package while shipping marks should be displayed on the outer packages. For instance:

Single packaging: Both shipping marks and labels should be displayed, either on the same side or on different sides.

3. Transport of Dangerous Goods

Under current circumstances, if one hazardous chemical is required to transport by vehicles with specific qualifications, then this hazardous chemical should be classified as dangerous goods, otherwise it is only general goods. Before shipment, the dangerous goods need to be classified, appropriately packaged and labeled with shipping marks and labels. Besides, enterprises should check qualifications of the transport units, making sure that the transport unit is qualified for the transport of the dangerous goods and that the transport vehicle also fulfills relevant requirements.

4. Limited Quantities and Excepted Quantities

Above are the requirements of packages, marks, labels and transport qualifications for general dangerous goods. However, is it possible to effectively reduce the cost of transport?

The UN Recommendations on the Transport of Dangerous Goods – Model Regulations (Abbreviated as Model Regulations hereinafter) introduced two special transport methods. They are: limited quantities and excepted quantities. Some kinds of dangerous goods, when packaged in small quantities with strong and durable packing materials, are less dangerous than those in large quantities during transport. As a result, limited quantity is introduced and parts of the restrictive requirements for the transport of dangerous goods may be exempted. Some kinds of dangerous goods (articles excluded), when packaged with strong, durable and qualified packages in small quantities and the quantities of which in each inner package and each overpack are limited, are far less dangerous than those packaged in large quantities during transport. As a result, limited quantities are available. But enterprises should also abide by requirements on training, classification and packages, etc specified in the Model Regulations.

The Standardization Administration of the People’s Republic of China formally began to compile standards on dangerous goods in limited quantities and in excepted quantities in 2009. After 3 years of work, Excepted Quantities and Packing Quantities of Dangerous Goods (GB 26844.1-2012) and Limited Quantities and Packing Requirements of Dangerous Goods (GB 26844.2-2012) was released to public and went into force on 1 Dec. 2012.

Limited Quantity (LQ) GB28644.2-2012, Limited Quantities and Packing Requirements of Dangerous Goods

(1) Documentation

When transported by air or sea, the words limited quantity or LTD QTY shall be filled in the description of dangerous goods packed in limited quantities. Except for air and sea transport, the documentation provisions of Model Regulations 5.4.1 need not apply to dangerous goods packed in limited quantities.

(2) Markings

Except for air transport, packages containing dangerous goods in limited quantities need not be labeled nor marked with the normal shipping name or UN number of the contents, but should bear the marking shown in Figure 3 below. Packaged in limited quantities of dangerous goods consigned for air transport should bear the marking shown in Figure 4 below.

When packages containing dangerous goods in limited quantities are placed in an overpack, the overpack shall be marked with the word 外包装 or OVERPACK, unless the markings representative of all dangerous goods in the overpack are visible

(3) Exemptions

• Packaging containing dangerous goods bearing the marking shown in Figure 4 shall be deemed to meet the provisions of chapter 6 and need not bear the marking shown in Figure 3;
• Any segregation provisions for dangerous goods packed in limited quantities need not apply within a vehicle or freight container.
• The provisions of Chapter 1.4 and security provisions concerning transport by road, railway and inland waterway of section 7.2.4 in Model Regulations do not apply to the transport of dangerous goods packed in limited quantities.

Excepted Quantity (EQ) GB28644.1-2012, Excepted Quantities and Packing Requirements of Dangerous Goods

Dangerous goods applicable for transport in excepted quantities will be expressed by E1 to E5, the meaning of which are shown in the table 2 below.

Table 2 Meaning of Excepted Quantities Code E1 – E5

Code	Maximum net quantity per inner packaging (in grams for solids and ml for liquids and gases)	Maximum net quantity per outer packing (in grams for solids and ml for liquids and gases, or sum of grams and ml in the case of mixed packing )
E 1	30.	1000.
E 2	30.	500.
E 3	30.	300.
E 4	1.	500.
E 5	1.	300.

Where dangerous goods in excepted quantities for which different codes are assigned are packaged together, the total quantity per outer packaging shall be limited to that corresponding to the most restrictive code. The number of packages in any freight vehicle, railway freight wagon or multimodal freight container shall not exceed 1000.

Packages should also finish 1.8m drop test and 24h stacking test. If the inner packages do not rupture or leak after the test, it means that the packages can withstand the above two tests. That is to say, the packages are available for transport.

(1) Markings

Packages containing excepted quantities of dangerous goods should be durably and legibly marked (shown in Figure 5). The primary hazard class or, when assigned, the division of each of the dangerous goods contained in the package should be shown in the mark. Where the name of the consignor or consignee is not shown elsewhere on the package, this information shall be included within the mark.

An overpack containing dangerous goods in excepted quantities shall display the markings required by Figure 5, unless such markings on packages within the overpack are clearly visible.

NOTE 1: Hatching and symbol of the same color, black or red, on white or suitable contrasting background

NOTE2: * The Class or, when assigned, the Division number(s) shall be shown in this location.

NOTE3: ** The name of the consignor or of the consignee shall be shown in this location if not shown elsewhere on the package.

(2) Documentation

If a document accompanies dangerous goods in excepted quantities, it shall include the statement Dangerous Goods in Excepted Quantities and indicate the number of packages.

(3) Exemptions

Dangerous goods carried as excepted quantities, meeting the provisions of this Standard are not subject to any other provisions of these Regulations except for:

a) The training requirements for personnel involving the transport of dangerous goods;

b) The classifications, classification procedures and packing group criteria of dangerous goods.

5. Summary

For the transport of hazardous chemicals, enterprises should at first judge whether the hazardous chemicals are dangerous goods by inquiring the List of Dangerous Goods (GB 12268-2012); then enterprises should judge whether the dangerous goods can be transported in limited quantities or excepted quantities based on the quantities of dangerous goods for transport as well as the Excepted Quantities and Packing Quantities of Dangerous Goods (GB 26844.1-2012) and Limited Quantities and Packing Requirements of Dangerous Goods (GB 26844.2-2012); based on the judgment, enterprises should select suitable packing materials for package, for instance, whether the dangerous need to be packaged in UN specification packages, whether the dangerous goods are appropriately marked and labeled or whether the dangerous goods can be packaged in excepted quantities and limited quantities for transport; at last, enterprises should choose a transport unit with relevant transport qualifications for their dangerous goods.

It is worth mentioning that requirements on dangerous goods in limited quantities and excepted quantities are only given in national standards. Although the Rules on the Road Transport of Dangerous Goods mentioned the limited quantity and excepted quantity, it was only an draft for public comments and the official version has not be published yet. However, the draft ruled that the gross weight of the dangerous goods packaged in limited quantities should be limited to 8 ton while the number of packages in excepted quantities should be limited to 1000 per vehicle. Besides, according to the Postal Law in China, hazardous chemicals are not allowed to send by post; Air transport and sea transport normally follow internationally accepted transport method. Limited quantities and excepted quantities may also be applied when relevant requirements are satisfied.

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Further Information

Dangerous goods regulations dowload

How to classify dangerous goods