Safe Transport of Dangerous Goods
South Africa is well known for a rich history in mining and the export of mineral resources.
With the 10th largest road network in the world and a heavy reliance on road freight transport, it is to be expected that motorists often share the roads with the transporters of dangerous goods.
Are we aware of the risks presented by the transport of dangerous goods and what can we expect from the operators in this industry?
Do we know how to share the roads with dangerous goods vehicles and how to react when arriving at the scene of a road crash of a dangerous goods vehicle?
To answer these questions and to gain further insights into the transport of dangerous goods we approached some of the experts in the industry.
What are the most important pieces of Legislation governing the transport of Dangerous Goods/ Hazardous Goods?
The National Road Traffic Act, 93 of 1996 (NRTA) and the SANS specifications referred to in the NRT Regulations – reg 273A.
Up until around August 2000 the responsibility of the transportation and handling of Dangerous Goods was with the Department of Health under Hazardous Chemicals Regulation of the Occupational Health and Safety Act and regulations as prescribed within the Hazardous Substance Act (15 of 1973). This system was difficult to police and enforce as the regulations were fragmented, encompassing several different legislations and included the Hazardous Substance Act, Explosive Act, Mining Act, Fire Brigade Services Act and the Farm Feeds Agricultural and Stock Remedies Act (36 of 1947).
The regulations had specific limitations and only affected substances transported by road tanker in quantities in excess of 500 litres. This responsibility has now been transferred to the Department of Transport and was implemented in stages between August 2000 and October 2001 and replaced by new legislation prescribed within the National Road Traffic (93 of 1996) and a wide selection of the South African National Standards (SANS) codes of practice (formerly known as SABS or South African Bureau of Standards).
South African National Standards (SANS)
The following SANS codes are applicable to Dangerous Goods:
SANS 10228: Identifies and classifies each of the listed dangerous goods and substances and set out information including the United Nations Number, the correct shipping name, hazard class assigned and other information pertinent to the substance.
SANS 10229: Contains information on acceptable packaging for dangerous goods and substances and include requirements for the testing of packaging and the correct marking and labelling of packages.
SANS 10230: Includes statutory vehicle inspection requirements for all vehicles conveying dangerous goods. This code stipulates the safety aspects of both the vehicle and the goods containment area. Minimum inspection requirements by both in-house and outside agencies are listed.
SANS 10231: This code of practice prescribed the operation rules and procedures for transporting Dangerous Goods and Hazardous Materials. It also includes the prescribed responsibilities of the owner/operator of the dangerous goods vehicle. It outlines the information required and who will have to supply information for the safe conveyance of dangerous goods. The requirements for the drafting and formulating of an operational agreement are also specified. This code also requires the owner/operator or vehicle to be registered as dangerous goods carrier. It is also prescribed that the owner-operator has available adequate insurance cover for civil liability as well as pollution and environmental rehabilitation cover in the event of an incident.
SANS 10232-1: 2007: This code includes details of new placarding requirements for vehicles transporting dangerous goods and the individual or substance exempt quantities and the compatibility requirements of mixed loads. Part 3 of this code contains information on the Emergency Response Guides to be used in case of an incident or accident.
What are the major requirements in terms of permits and licensing to transport Dangerous Goods?
The major requirements of the transportation of dangerous goods are, amongst others: duties of the operator, consignor, consignee and the driver; classification and certification of dangerous goods, training of drivers, relevant documents to be carried by the driver, dangerous good inspectors, powers and duties of traffic officers in respect of dangerous good regulation and dealing with incidents and crashes involving dangerous goods transportation.
Without getting into specialized dangerous goods that require special permits (Cyanide), all vehicles need to be certified to carry Dangerous Goods and this must be displayed on the Operator Card for each vehicle and trailer.
All drivers of these vehicles must be over the age of 25 and have a PrDP (D) which must be renewed every 2 years. [D classification]
The renewal of this permit is dependent on the presentation of a Dangerous Goods certificate (Renewable every year) issued by a DOT approved provider and a valid medical certificate (renewable every 2 years).
Instances vehicles require fire permits to be issued and displayed on the vehicle, but it varies from metropole to metropole.
Are there specific Categories of Hazards/Dangerous Goods?
Dangerous Goods are classified in 9 classes listed in SANS 10228.
Some of the categories are further subdivided based on their properties or risks that they present.
Each category is clearly defined by different risk hazard diamonds for easy visual recognition and some products may also present more than one risk.
Classification of dangerous goods according to the type of dangerous materials or items present:
Miscellaneous Dangerous Goods
What would be the Dangerous Goods posing the greatest threat/danger and what would be the ones posing the least significant threat?
Any dangerous substance, if handled incorrectly can pose a serious threat -These would be any items that are flammable, explosive, corrosive or infectious. All types of fuel, chemical and flammable gases would be dangerous.
Dangerous Goods have different levels that have different hazards. For example, explosives do not have any exempt quantities. Many other products have exempt quantities and others do not.
This is not easy to pinpoint and would often depend on where an incident took place i.e. near waterways, communities, built-up areas or where other risks could be triggered by such an incident.
Flammable products obviously present serious risks while poisonous gases present extreme danger because they are very difficult to contain and given the right trigger, explosives can cause extreme damage so, with 3468 classified products, it is difficult to pinpoint the most/least dangerous.
Do you believe motorists are aware of the dangerous goods warning signs on trucks and do we need to create more awareness about these signs and the threats they alert us to?
Knowledge among road users about dangerous goods is very limited.
Most road users would be aware that there are “those orange signs with some numbers on,” but they refer to a list of instructions contained in resources like the Emergency Response Guidebook of Southern Africa.
This is a rather detailed work that would normally be in the hands of emergency responders, firefighters, spill control companies and law enforcement. The book lists all the hazardous goods and the response protocols, control, evacuation and other procedures that should be followed. There are literally hundreds of codes, classifications and guidelines that would not normally be within the survey of the general road user. Having access to this manual, however, can save lives.
There are more than 3 500 substances with UN numbers [Dangerous goods identification numbers].
Ordinary motorists are not expected or tested to interpret the placards on a vehicle carrying dangerous goods, so unless they read the “Danger”, “Explosive” or “Inflammable” signage, they would be oblivious to the dangerous load that a vehicle is carrying.
Most motorists understand that the warning signs signify some risk, but their lack of understanding is clearly displayed in their driving behaviour around vehicles that are transporting dangerous goods.
In order to create more awareness around Dangerous Goods vehicles, we need to make these vehicles more visible/identifiable. Very few people know what the meaning is of the orange diamond on the front of Dangerous Goods vehicles. They also have no clue of the meaning of the UN numbers on the Dangerous Goods signage.
More education and awareness around the dangers of the various classes needs to be disseminated to the driving public.
Awareness about Dangerous Goods could be created by handing out reading material in the form of pamphlets at toll gates or at service stations on all major routes.
Are you aware of limitations on the transport of Dangerous Goods in terms of area and time of travel?
Yes, every municipality must determine dangerous goods routes for their area in terms of the National Land Transport Act (NLTA).
Certain goods – like explosives – can only be transported at certain times or under certain conditions.
Others only along certain approved roads, subject to permits, etc. The TRH 11 Guidelines and Regulations contain most of the parameters and procedures for the transport of all dangerous or abnormal goods and should be consulted by all transporters.
The relevant section of the Act provides full details on what substances can be carried, how they must be carried and what international standards must be followed in respect of any incident involving a dangerous good vehicle. Operators, consignors, consignees and drivers are therefore required to be completely familiar with these requirements.
Most operators conduct route risk assessments for their vehicles that are transporting dangerous goods and inform local authorities of their routes and nature of risk for their respective loads, but this seems to have become a best practice rather than a definite that is carried out.
Are there specific requirements in terms of confinement and securing the load during transport of hazardous goods?
Yes, there is a specification dealing with this - SANS 10187-8: Load securement for Dangerous Goods.
Also, refer to the Conveyance of Abnormal Loads (TRH11).
Each product is expected to follow a certain minimum packaging requirement and load securement will follow dependent on the packing requirement. SANS codes do play a significant role in this area which is product specific.
This is the primary responsibility of the driver first, then, of course, the dangerous goods inspectorate who will conduct inspections to ensure that the relevant prescripts in respect of storing and confinement are being adhered to.
Does the Law require specialised training for those transporting Hazardous Goods?
Yes. The PRDP for DG requires training before a PRDP is issued and annually between PRDP applications.
The training is regulated in terms of Chapter VIII.
All drivers must undergo annual Dangerous Goods training by an approved DOT training provider.
Only accredited trainers can provide Dangerous Goods training. The companies are gazetted.
Drivers also need to undergo specialized training where loading/off-loading requires specific procedures to be followed i.e. Bulk fuel.
Drivers cannot be younger than 25 years of age.
There must be a clear differentiation between “Goods”, “Passenger” and “Dangerous” goods drivers.
Some believe rollover prevention training must become one of the minimum requirements as rollovers involving DG vehicles pose the biggest risk on our roads. From my own experience, our rollover incident rates at Afrox improved drastically since we implemented mandatory rollover avoidance training in our bulk operations.
What would you recommend in terms of health checks and driver well-being of those drivers transporting hazardous goods?
The NRTA requires a medical check every 2 years before a PRDP is issued.
Some believe the medical test that is accepted by all license centres across the country is adequate.
Although Dangerous Goods driver medical certification is quite strict, some believe the issue around fatigue is not adequately addressed throughout the industry. Many accidents occur as a result of fatigue.
In Afrox much focus is placed on fatigue monitoring and the results speak for themselves.
The conditions under which truck drivers work lend themselves to unhealthy practices, which can escalate to chronic illness over time. By the very nature of their work, truck drivers spend long hours sitting, with little physical exercise and poor sleep cycles.
They also tend to eat unhealthy convenience food, snacks and drinks containing high levels of salt or sugar. Over time, these factors increase their risk of weight gain, high blood pressure and Type 2 diabetes, among other conditions. This has an impact of a poorly managed health condition for truck drivers and places other road users at risk.
Driver health is a crucial, but often overlooked factor in overall road safety. Health Initiatives such as Your Truck, Your Gym, an exercise programme for truck drivers developed with the help of the University of Stellenbosch, enable drivers to get fit by using their trucks as their gyms while waiting at borders or parked at truck stops.
Fleet managers can also create a culture that presents regular health workshops at the workplace, introduce free HIV, TB, Blood pressure testing and regular counselling for drivers requiring more information about their health condition.
It is a good idea for operators to conduct regular, in-house driver wellness programmes, rather than rely on generic health examinations which may come too late.
What are the requirements placed on the operator in terms of recovery and cleaning of spillage in the event of a road crash/ rollover etc?
Operators must carry insurance to cover all possible spills and the cost of clearing as part of incident management.
The consignor is responsible at all times but too often this process ends up in dispute and is a constantly moving target.
The cleaning-up of an accident scene or spillage is the responsibility of the transporter/s.
Each transporter MUST have a service provider specializing in the field of chemical spillage cleaning.
Do operators mostly sub-contract these functions?
There are only a few companies that offer clean-up of Dangerous Goods sites.
These spill responders assist with response units across the country.
Some of the bigger fleets may also have in-house people doing clean-up.
What are the most important bits of advice for other road users to adhere to when sharing the roads with dangerous goods vehicles?
Do not approach a vehicle with UN placarding in the event of an accident. Many of the substances are combustible, others affect your health and respiratory system etc.
Be especially careful of driving near such vehicles. Obey all road traffic rules, do not drive too close to them, do not tail-gate or cut-in in front of them. If you have one that is bearing down on you, slow down, signal and allow it to pass.
Most Dangerous Goods vehicles are larger than the average light motor vehicle so apply simple logic and respect the larger vehicle together with its increased levels of skill needed to operate it safely.
Understand that the product that such vehicles are carrying, pose risks that could negatively impact on you or the environment, so stay well clear.
Awareness creation is very important, (Speed restrictions on goods vehicles), yellow line restrictions and associated risks and lastly the fact that if you as a motor vehicle driver don’t see the truck tractor’s mirror/s, the truck driver cannot see you. Few people really know and understand this.
Any advice you would offer to other road users first arriving at the scene of a crash involving a Dangerous Goods Vehicle?
Since Dangerous (or Hazardous) goods could include chemicals that are described as heavier-than-air (they can flow along the ground like soup, but not be visible at all), road users should attempt to steer clear of hazardous vehicles, by several hundred meters, as far as possible.
Certain chemicals are invisible and odour free but can displace oxygen (on account of weight) and cause either dangerous levels of noxious gasses, a partial or total absence of oxygen, which can lead to rapid loss of consciousness or fire or explosion hazards.
Any such scene should be avoided at all costs and even staying away over long distances – of up to 100 meters – may not be enough, depending on the chemicals involved. When encountering a rolled-over or damaged vehicle transporting dangerous goods, ALWAYS:
Evacuate immediately – preferably 250m or more from the vehicle.
Attempt to SEE or PHOTOGRAPH the Hazardous Goods Warning Plate (from a distance, for the numbers) to provide this to emergency services.
Call 10117 (the Fire Department) first, then Ambulances for any casualties and then police to report the accident or spill.
Attempt to prevent traffic and pedestrians from entering the area.
Normal operation should not pose any specific risk to MOVING traffic, but when roll-overs and collisions occur with ANY vehicle bearing ANY Hazardous goods warnings, people should NEVER:
Approach, drive or walk towards the vehicle.
Remain in the area (move away immediately).
Attempt to “see if they can help” by approaching the driver or the vehicle.
Think that “being a distance away” is enough.
Park their vehicles too close to the damaged vehicle.
Use flashlights (torches), cell phones or radios to call for help, in the vicinity (sparks can cause a fire).
Try to smell if they smell anything – some gasses can cause immediate incapacitation.
Try to approach to help anyone who has already collapsed, unless they are properly equipped and trained to do so.
Safe Driving near the Dangerous Goods Crash
Accident scenes are hard to ignore and are in many cases a distraction to passing motorists. Many accident scenes have taken place near other accident scenes, solely because motorists were not paying attention to the road ahead and only focused on the emergency personnel and accident scene. Passing motorists adhere to the following guidelines:
Observe changes in the traffic pattern around a given accident scene.
Look for emergency personnel directing traffic.
When directed to stop, do so immediately.
Proceed through the scene slowly.
Look for signs indicating what you should do.
Be vigilant of personnel walking on the scene.
Be vigilant of emergency vehicles arriving and exiting the accident scene.
Do not disregard the instructions of emergency personnel.
Remain calm and avoid stepping out of your vehicle.
Keep doors and windows closed, to avoid inhaling in the fumes.
Avoid smoking or attempting to light a cigarette or disposing of flammable goods (deodorant, acetone, paint, methanol, etc).
Looting of goods vehicles after road crashes have become a significant problem - what are the most important knowledge we need to share about the dangers in terms of Dangerous Goods?
It is very dangerous to expose Dangerous Goods without proper unloading procedures.
Dangerous Goods can explode, contaminate water or fields, cause breathing problems, etc.
Communities have sadly been decimated trying to recover fuel from overturned tankers - even while understanding the risks associated with fuel.
A method suggested has been to provide each driver with a megaphone that he can use [if able] to address the looters and explain what lethal substances he is transporting and the imminent danger to them should they attempt to loot his vehicle.
Once clean-up crews have attended to the scene of a hazardous goods vehicle crash, who ultimately has the power to decide on when a road may be re-opened?
This will normally be a decision made at the Joint Operational Command (JOC) level.
This is a multi-disciplinary decision that involves Traffic Authorities (from a traffic flow and Traffic Risk Perspective), the South African Police Services (from a Crime Scene Perspective), the Fire Department (from a Hazardous Goods or Fire Risk Perspective) and/or Medical Services (from a Patient Extrication Perspective).
Roads should or cannot be opened until SAFETY and LEGAL considerations have been exhausted.
Any important information about the transportation of dangerous goods not covered by the above that we need to create more awareness of?
Every Transport Operator that can, does, would or could transport dangerous or hazardous goods, should be in possession of the Emergency Response Guidebook, the TRH-11 and the appropriate Acts.
Every Driver should be trained and equipped to detect, manage, handle and respond to a dangerous goods spill, from an involved party perspective.
Every actual and near-miss or possible Dangerous or Hazardous Goods Collison should be properly, completely and professionally analysed – even where there is no major loss or fatalities.
The knowledge and intelligence gained from near-misses can provide key learnings for the prevention of actual losses. By attaining a full and proper understanding of all the dynamics associated with Hazardous Goods Incident, the intelligence can be used to avoid future losses and/or to better manage them, when they do occur.
Dangerous Goods legislation is very voluminous and quite intricate. It will be difficult to do more than create awareness with a summarised document.
Critical is to provide ordinary motorists with a number (0861 400 800 – National Traffic Call Centre at RTMC) or educate motorists to contact the operator number at the rear of the truck should the driver be driving negligently or recklessly.
A word of appreciation to the following for their Assistance:
Alta Swanepoel, Alta Swanepoel & Associates
Stan Bezuidenhout, Crash Guys