Dangerous (software) errors in IMDG Code 39-18 and ADR 2019?

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 (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, 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, 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 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?

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I wish you a pleasant vacation season.

Mr. Safety