United Nations makes surprise changes

By John V. Currie -- Logistics Management, 8/1/2000

As the 18th Session of the United Nations (U.N.) Subcommittee of Experts on the Transportation of Dangerous Goods (UNSCOE) wound down in Geneva on July 13, many observers came away from the meeting stunned by two decisions that will increase shippers' expenses significantly.

The first was the overwhelming subcommittee vote in favor of a Belgian proposal to change the sequence in which the description of dangerous goods is entered on shipping papers. When that ruling takes effect, shippers will be required to enter the U.N. identification number before the proper shipping name-just the opposite of what is required today. Some predict that the financial impact on companies that use computer-generated documentation will be staggering, not to mention the cost of retraining employees.

The second blow came when it became clear that shippers would have a hard time keeping the current exceptions from documentation, marking, and labeling requirements for "limited quantity" packaging or consumer goods.

This is not the first time that this issue has been raised. At UNSCOE's 17th Session in December 1999, Australia submitted a proposal to do away with the current exceptions for placarding, marking, and labeling limited quantities. In a proposal at the 18th Session, the Australian delegation suggested an exemption to the previously proposed placarding requirements for consignments of 2,000 kg or 2,000 liters or less. Germany and Sweden, while indicating support for the Australian proposal, jointly suggested that placards for limited quantities over that threshold might be impractical and instead recommended that retro-reflective orange panels with U.N. numbers be used.

At this meeting, Australia rallied support for its proposal and overcame opposition from the United States, Canada, and the United Kingdom. The subcommittee voted in favor of placarding limited quantities above an unspecified threshold limit and instructed the Australians to prepare a detailed proposal for the next meeting.

Both sides of this contentious issue have put forth convincing arguments. Chemical distributors cite the safety history of excepted consignments, saying that these consumer commodities present a very limited hazard. They argue that these same products are found under your kitchen sink or in your garage. Others say that distribution systems have changed since the consumer commodity exceptions were first granted; often, full containerloads of these small packages are offered for international ocean carriage, so that the total quantities go well over the "limited quantity" threshold.

Some wonder if the proposed threshold quantities that trigger placards, markings, or documentation could pose problems for freight forwarders or consolidators that stuff containers with excepted limited-quantity shipments from multiple consignors. How would this affect supply houses that distribute previously excepted consignments that collectively exceed the threshold in the delivery vehicle?

The official position of the U.S. delegation is that current regulatory exceptions provide an adequate level of protection and more stringent controls are not warranted. However, it appears that their opposition to the proposal will require additional support from hard data and that the argument "We've been doing it this way for years without a problem" will not prevail.

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.