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Have you ever been confronted with the problem that you have supposed dangerous goods in your company and there is no categorization according to chapter 3.2 ADR/ RID/ IMDG-Code? In the following I will explain to you how to classify a UN number from the substance properties and how to determine the correct technical name!

Here are the individual steps briefly and succinctly:

1. determine the properties of the substance

2. look at the table in subsection 2.1.3.10 ADR/ RID or 2.0.3.6 IMDG Code

3. explosive substance? Yes --> Glossary Annex B --> 4.

4. explosive? No --> 5.

5. annex A

6. classification

7. list of dangerous goods

8. transport according to ADR or/ and RID? Yes --> 9. No --> 11.

9. compliance with parts 1 - 7 ADR/ RID

10. responsibilities according to RL Binnenland, GGBefG, GGVSEB, RSEB, GGAV, ODV observed

11. transport according to IMDG Code? Yes --> 12., No --> 13.

12. observe responsibilities according to GGBefG, MoU Baltic Sea, GGVSee, RL GGVSee

13. you have reached the destination!

Treatment according to other laws (ChemG) or regulations (CLP-VO) is disregarded!

The description of the individual steps

1. determine properties of the substance

The specialist for occupational safety, dangerous goods officer or the dangerous goods officer can now determine the properties of the substance.

Supposed hazardous substances/dangerous goods are also known as H-phrases due to the reference to the hazard statements. Since this is a solid substance, I can make the following restrictions. The severe eye irritation can be caused by corrosive substances, which must be declared with the danger label pattern, No. 8 for dangerous goods. Since this substance was, or still is, present in skin creams, I assume that the fertility damage is caused by toxic substances (No. 6.1). I exclude infectious substances (No. 6.2) and environmentally hazardous substances as well as radioactive substances.

2. view table in 2.1.3.10 ADR/ RID or 2.0.3.6 IMDG Code

According to ADR/ RID, the predominant hazard by merging 6.1 II (DERMAL) and 8 I according to table 2.1.3.10 for a solid substance and mixtures (SOL) is 6.1 II.

Justification for classification:

H319 with the description "severe eye irritation" suggests, under the presumption of the song closure reflex and the required rinsing with water, that the effect on the sensory organ is immediate. I hereby assign VG I as the maximum hazard.

H360 in combination with the word "may" makes me classify the substance in packing group II (medium hazard), because although damage does not occur immediately, the effects in relation to unborn life or fertility may have immense side effects.

GHS08 and the signal word "Caution" have not caused any further findings in addition to the H-phrases.

3. explosive? Yes Glossary Appendix B 4.

According to my research and opinion, sodium tetraborate (trade name: borax) is not an explosive.

4. explosive? No --> 5.

Go to Annex A

5. appendix A

In the list of "proper technical names" of "generic entries" and "N.A.G. entries", under Class 6.1 and additional hazard 8, the following entry is most appropriate:

6. classification

Described here as "TOXIC ANORGANIC SOLID, CORROSIVE, N.O.S." with UN number 3290.

7. dangerous goods list

In the dangerous goods list of the ADR/ RID as well as the IMDG code this substance has the packing group I, the limited quantity here is 0. According to the ADR/ RID SV 274 with reference to the subsection 3.1.2.8 apply here, which is only permitted for transport by road and rail as follows: UN 3290 TOXIC ANORGANIC SOLID, CORROSIVE, N.O.S. (sodium tetraborate decahydrate). In the IMDG Code, reference is made to SV 274 in subsection 3.1.2.8.1.

8. transport according to ADR or/ and RID? Yes --> 9. No --> 11.

Yes, the hazardous substance has been transported by land afterwards

9. compliance with parts 1 - 7 ADR/ RID

Must be observed here in detail!

10. responsibilities according to RL Binnenland, GGBefG, GGVSEB, RSEB, GGAV, ODV must be observed!

Assume responsibility according to 10.

11. transport according to IMDG Code? Yes --> 12., No --> 13.

Assume, because the country of origin is Turkey and the article was available as a 1kg container on Ebay with shipping from Poland for less than €11. Thus I exclude here the air transport (DGR).

12. responsibilities among other things according to GGBefG, MoU Baltic Sea, GGVSee, RL GGVSee note!

Assume responsibility according to 11.

13. you have reached the goal!

Relaxation flows through your body, if not don't draw €2.000 and go back to start (1. Determine properties of the substance!)

If you have already self-declared a hazardous substance, I would be interested in your approach. Did my approach help you further, or do you have any hints/suggestions for changes? I would be very pleased to exchange ideas.

Thank you for your attention

Mr. Safety

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Errors can creep in during database systems, software and the transfer of data records up to the production of a print medium, which affect the subsequent elements of the effective chain with all its branches. Years can often pass before software defects are discovered. In the event of damage, this can then result in not inconsiderable financial losses and, in particular, damage to the company's image. Sometimes the system suppliers are affected by this, since the effects only become visible at the end of a supply chain, namely in the application, since often insufficient testing and checking has been carried out. Therefore, a good quality management including a security management is also necessary. How errors can occur, I would like to show with some examples of the ADR 2019 and the IMDG Code 39-18.

Within the ADR 2019 edition, there were subsequent editorial changes. Such known errors are also referred to as safe errors in ISO 26262, as they are controllable in the damage effect:

In 1.1.3.6.3 (column 2) of the table for transport category 0, under Class 9, change "equipment" to "articles". In column 2 of the table for transport category 0, under Class 9, replace "articles" with "mixtures".

In 1.8.3.1, replace "Safety adviser, hereinafter referred to as "dangerous goods safety adviser", for the carriage of dangerous goods" with "Safety adviser for the carriage of dangerous goods, hereinafter referred to as "dangerous goods safety adviser".

In 1.8.3.13, in the fifth indent, replace "aviation fuel assigned to UN 1268 or 1863" with: "Aviation fuel assigned to UN number 1268 or 1863".

I categorize the previously described errors as form errors.

The following errors of IMDG Code-39-18 in contrast to ADR 2019 and UN Model Regulations have come to my attention. I would categorize these errors as dangerous errors in the sense of ISO 26262, since the extent of damage caused by technical errors can often be devastating if they are not detected or detected too late.

For UN 2763 Packing Group III (column 5), the German translation of the IMDG Code includes the tank instruction T1 (column 13) since 2014. The English one reads T3 since 2014. Here, the English IMDG code is probably wrong. The entry should read "T1".

UN number 1056 (column 16a) only has stowage category A, but the English has Category A SW1. SW1 was first included in 38-16 Amdt. / Circular letter 3598, but not in Draft Amendments according to CCC3/6. This is probably an error in the German IMDG code. The entry should read "A SW1".

For UN 3028, packing group III (column 15) is entered in the IMDG code. Since it is an object, the packing group is probably wrong. The entry should therefore read "-".

I have noticed differences between the IMDG Code and ADR regarding the limited quantities for the following UN numbers:

UN-number IMDG-Code-39-18 ADR 2019

UN 1286 II 1 L 5 L

UN 1743 III 500 ml 1 L

UN 2802 III 500 g 5 kg

UN 2956 III 0 5 L

UN 3028 III 5 kg 2 kg

UN 3094 II 500 ml 1 L

UN 3242 II 500 g 1 kg

Tabel 1 Overview of limited quantities in IMDG Code 39-18 versus ADR 2019.

The entries are different from the UN model regulations. My guess is that this is an error in the IMDG code. The values in the column "ADR 2019" should also be valid for the "IMDG-Code-39-18".

But what does this mean in practice now?

Since all the listed UN numbers of the incorrectly indicated "limited quantities" in the IMDG Code, with the exception of UN number 3028 Packing Group III, are lower than those of the ADR, the permissible limited quantity is undercut in maritime transport and thus no error is made. Even if transport by road subsequently takes place, this is to be classified as harmless.

For "UN 3028, BATTERIES (ACCUMULATORS), DRY, CALIMHYDROXIDE, SOLID, CONTAINING, ELECTRICAL COLLECTOR" the "limited quantity" is exceeded on the road, with its incorrectly assumed 5 kg in maritime transport, with the exception of a transport according to subsection 1.1.4.2 ADR in the on-carriage. Also permissible is a transport according to the special regulation 598, which means that for new batteries a transport that is not subject to the regulations of the ADR can take place. New batteries must be secured against sliding, falling over and damage, e.g. on pallets and additionally against short circuit. In addition, no contamination of dangerous traces of alkalis or acids must be visible. Likewise, identification marks must be removed from any pallet or rigid packaging.

For the user, the additional question might be which (new) errors in the ADR 2021 and the IMDG Code 2021 have already been eliminated, or when will they finally be eliminated?

If you want to learn more about which methods you can use to keep a bug-free software very lean, please choose from a total of 12 different trainings at https://www.elektrobit.com/trainings/ on the topic "Agile & lean" with different training durations of ½, 1 or 2 days.

I wish you a pleasant vacation season.

Mr. Safety