UNCOE pulls back on rules change

By John V. Currie -- Logistics Management, 1/1/2001

Initial reports from the 21st Session of the United Nations Committee of Experts on the Transport of Dangerous Goods (UNCOE) as it concludes in Geneva have allowed many international shippers to breathe a sigh of relief.

Last summer, an UNCOE subcommittee overwhelmingly voted in favor of a Belgian proposal that would change the sequence of the basic shipping description on dangerous goods documents by requiring that the U.N. identification number precede the proper shipping name. Because the proposal received strong support, many who opposed it thought that it was a done deal as the proposal went to the full UNCOE for approval.

But a few of the staunchest opponents set out to convince the committee that change merely for the sake of change and with no safety benefit was counterproductive to its mission. They submitted papers that cited economic factors, training burdens, incompatibility with existing computer programs, and other concerns.

One of the most convincing submissions came from U.S. expert Frits Wybenga. His paper documented the additional costs and resources that would burden the industry if the proposal were adopted. It also made reference to previous commitments the subcommittee had made regarding its responsibility as an international rule-setting body and suggested that adopting the proposed changes would contradict those commitments.

The U.S. paper emphasized those commitments by quoting statements other countries had previously submitted praising the committee's role in developing the U.N. Model Regulations. These model rules were described as a big step toward universally applicable regulations that would gain increased legal status after implementation by various rule-setting bodies. The paper also quoted statements that national regulators would rely on the committee to consider all implications of new amendments in order to "restrict the differences between the U.N. Model Regulations" and other codes. It also outlined the evolution of recommendations from a 1978 committee meeting on dangerous goods documentation, which have achieved near-universal adoption.

The paper used these quotes as the basis for arguing against the changes, saying that they would cause delays in the movement of goods, increase operational costs and danger to emergency responders, and negatively affect general safety considerations.

Those laborious efforts were successful, and those who had previously despaired were astounded when the UNCOE voted 14 to 4 not to adopt the proposed amendment. As a compromise, the sequence proposed by Belgium will be a permitted option in jurisdictions that choose to allow it. That will let the new European road and rail (ADR/RID) regulations require the U.N. number to be shown first while maintaining the current sequence in the U.N. Model Regulations.

Another proposal that had previously been approved by the subcommittee, which would have required special hazard communications for "limited quantity" consignments, also went down to defeat. Following arguments that additional study was required before a workable scheme could be adopted, the COE defeated the proposal by a narrow margin.

It appears that the fast-rolling wheels of change have been slowed in favor of more thoughtful consideration of international regulatory harmonization in tandem with quantifiable safety benefits, a development that all will welcome.

John V. Currie's firm, Currie Associates Inc., provides safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars on hazardous-materials transportation management and regulatory compliance. He may be contacted at 1118 Bay Road, Lake George, NY 12845. Phone: (518) 761-0668. E-mail: mail@currieassociates.com. Web site: www.currieassociates.com .