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PRODUCT
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Farming
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PRODUCT
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EFMA PRODUCT STEWARDSHIP FOR FERTILIZERS
Version 1.5: 01-08-2009
3.1.6 PRODUCT TRANSPORT AND DELIVERY
INTRODUCTION |
The transport of fertilizers and their raw materials is regulated by UN and EU legislation. In order to reduce the risk of accidents to a minimum, the transport operator should follow best industry practices. EFMA's Product Stewardship program calls for selecting transport operators based on SHE performance and competence, adherence to best industry practices for loading/unloading operations, and the proper attention to security issues during transport.. |
LEGAL REQUIREMENTS |
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General Harmonized Classification and labelling Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Second revised edition 每 ISBN-13:978-92-1-116957-7
Road
Transportable Pressure Equipment (TPE) Commission Decision 2003/525/EC of 18 July 2003 deferring the date of implementation of Council Directive 1999/36/EC for certain transportable pressure equipment (notified under document number C(2003) 2591)
Inland waters There are no EU enforced regulations for transport of dangerous good by inland waterways. This ommitance is recognized by the Parliament
Sea Code of Safe Practice for Solid Bulk Cargo ,2004, IMO publication ID260E, ISBN-13: 978-92-801-4201-3
Dangerous Goods Safety Adviser
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EFMA REQUIREMENTS |
All risks during loading .unloading and transport should be assessed. The assessment includes SHE as well as security aspects. The Guidelines For Transporting Nitric Acid in Tanks (1998) Guidance for Transport of Ammonia by Rail English (2007).. Guidance for Transport of Ammonia by Rail German (2007). Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines
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EFMA IMPLEMENTATION |
GENERAL RECOMMENDATIONS FOR TRANSPORT There are no regulations for the transport of the major part of fertilizers. However, some fertilizers (e.g. ammonium nitrate) and their intermediates (e.g. ammonia, nitric acid and phosphoric acid) are classified as dangerous and transport is regulated by the Recommendations on the Transport of Dangerous Goods - Model Regulations Fifteenth revised edition (Vol. I & II) 每 ISBN-13:978-92-1-139120-6 . The test methods associated with these recommendations can be found in: Based on this classification transport by road, rail, inland waters and sea in Europe is regulated by the following agreements: |
ROAD European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR).
Annex A lists the dangerous goods according to their class that may be carried internationally and lays down the provisions for packaging and labeling and for describing the goods on the transport document. Compliance with these provisions is the consignor's responsibility. Annex B sets out the provisions for the vehicles and the transport operations, for which the carrier is responsible. There is no overall enforcing authority for ADR nor are there any penalties for non-compliance. However most signatory states carry out checks at the roadside and can take action for any non-compliance through their domestic legislation and the EU directive on uniform checks for road. To facilitate free trading and to establish uniform provisions between Member States of the European Union, the so-called ADR Framework Directive (Council Directive 94/55/ECon the approximation of the laws of Member States with regard to the transport of dangerous goods by road, as amended, requires that Annexes A and B of ADR should serve as the basis for domestic regulations. ADR includes an unofficial Introduction that summarizes the provisions of ADR to give general guidance. After a brief summary the Introduction goes into more detail on the most important provisions for working under ADR ADR is published in 2 volumes. Volume I contains Annex A and Volume II Annex B. Interpretation of ADR regulations and comparison with Seveso Interpretation of the ADR descriptions of various UN numbers relevant to AN and AN fertilizers is not always easy. For example: 1) The EU resistance to detonation is not specified in the UN system relating to ADR. 2) ADR regulations include special provisions 186, 306 and 307 for Class 5.1 products. 3) ADR regulations do not apply to compound fertilisers capable to self-sustaining decomposition, UN Class 9. EFMA has prepared a note "Comparison of Seveso, EFMA interpretation and ADR classification" to assist EFMA members as well as authorities in interpreting ADR (See also chapter 3.1.3.5.). Comparison of Seveso, EFMA interpretation and ADR classification, EFMA 2006
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RAIL |
Inlandwater There are no EU enforced regulations for transport of dangerous good by inland waterways. This ommitance is recognized by the Parliament |
SEA Code of Safe Practice for Solid Bulk Cargo ,2004, IMO publication ID260E, ISBN-13: 978-92-801-4201-3
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TRANSPORTABLE PRESSURE EQUIPMENT (TPED) In the context of its global goal of improving safety in transport, the European Union has issued in 1999 the Directive 1999/36/EC to enhance safety with regard to transportable pressure equipment approved for the inland transport of dangerous goods by road and by rail. The Directive aims simultaneously to ensure the free movement of such equipment within the Community, including the placing on the market and repeated putting into service and repeated use aspects. Directive 1999/36/EC is commonly referred to as TPED (Transportable Pressure Equipment Directive). In order to facilitate the use of the Directive, the Commission together with Member States' experts has elaborated TPED Guidelines, which may be found here. These will be completed as new Guidelines are adopted. DG Enterprise on its website "Harmonised standards" contains in a summary list a compilation of the references of standards (CEN, EN numbers) which have been published in the Official Journal of the European Union. Although the list is updated regularly, it may not be complete and it does not have any legal validity; only publication in the Official Journal produces legal affect. For more information on the Pressure Equipment Directive visit the DG Enterpirse website.
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3.1.6.1 CLASSIFY AND LABEL PRODUCTS FOR TRANSPORT.
Dangerous good must be classified before they are consigned. There is a difference between classification and labeling for supply and for transport. The first one is primarily aimed at protecting the workers and the consumer of the products. The second one aimed at identifying the properties of substances and preparations that may constitute a hazard during normal handling and transport. Classification for transport is an essential first step in deciding how to label, package and transport a product safely, and is a legal requirement. Classification of dangerous goods is done accordingly to Recommendations on the Transport of Dangerous Goods - Model Regulations Fifteenth revised edition (Vol. I & II) 每 ISBN-13:978-92-1-139120-6 Classification of ammonium nitrate based substances in the UN system is difficult. Guidance to EFMA members is given in the "Guidance for UN Classification of Ammonium Nitrate Based Substances".
Guidance for UN Classification of Ammonium Nitrate Based Substances". Guidance for UN Classification of Ammonium Nitrate Based Substances
The testmethods associated with these recommendations can be found in: Recommendations on the Transport of Dangerous Goods 每 Manual of Tests and Criteria . Fourth revised edition 每 ISBN 92-1-139087-7 ; Fourth revised edition 每 Amendment 1 每 ISBN 92-1-139109-1 ; Fourth revised edition 每 Amendment 2每 ISBN 978-92-1-139125-1 The marking and labeling is outlined in the same reference document in chapter 5.2. and in Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Second revised edition 每 ISBN-13:978-92-1-116957-7 Placarding and marking of transport units is outlined in chapter 5.3 of the same reference document.
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3.1.6.2 ESTABLISH GUIDANCE FOR TRANSPORT OF RAW MATERIALS.
All aspects as described in the chapter 3.1.6 Product Transport and Delivery apply also to the transport of raw materials such as:
GUIDANCE FOR INSPECTION OF AND LEAK DETECTION IN LIQUID AMMONIA PIPELINES One of the major raw materials in the production of nitrogen fertilizers is liquid pipelines. It is transported in liquid ammonia pipelines.EFMA has produced a Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines with tThe underlying intention is to maximise the operational safety and reliability of these pipelines and to reduce environmental and health risks.
Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines
This document produced by EFMA provides guidance for the inspection of and leak
detection in liquid ammonia pipelines.
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3.1.6.3 RISK ASSESSMENT FOR DISTRIBUTION ACTIVITIES.
Risk assessment for distribution activities should not only include a general assessment of transportation methods (by what means, route, quantity, customers ) taken account of HSE aspects and security aspect, but also more specifically assessment of the transporter operator, loading and discharge, transport documents and emergency preparedness.
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3.1.6.4 TRANSPORT OPERATOR ASSESSMENT AND SELECTION (DANGEROUS GOODS).
INTRODUCTION Selection of external transport operators should include an assessment of the operator's SHE performance. Instruction to the transport operator should specify requirements for:
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SQAS Road The majority of the Fertilizer producers have contracted out the road haulage of their fertilizers and raw materials and the transport of products by rail is often done by third parties. Though there is no legal requirement regarding to assessment and selection of hauliers, it is good Product Stewardship practice that suppliers assess the HSE operations (including an effective management system), of all their hauliers, regardless of whether or not the products concerned are hazardous. CEFIC has developed a comprehensive system: SQAS (Road) is widely used in Europe and nearly 900 European hauliers have been assessed to it by independent certification bodies in the period of 14-12-1999 to 01-02-2005. The big advantage of SQAS (Road) is that it is no longer necessary for a supplier to carry out its own haulier audits or assessments.
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SQAS Rail Similar to SQAS (Road), CEFIC also has developed a SQAS Rail . In the period 05-06-2000 to13-12-2004, some 10 Railway companies in 6 countries have been assessed by independent Auditors. A SQAS system for loading and unloading facilities is under development. For further information see also Guidelines for the transport of ammonia by rail.
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SQAS Bulk marine ships
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SQAS Barges
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3.1.6.5 DEVELOP INFORMATION FOR TRANSPORT ON TREMCARDS, DANGEROUS GOODS NOTES AND ADVICE TO DRIVERS
Product related SHE Information to be provided to hauliers and their drivers so that they can transport a product by road correctly, and so that they can take suitable action in the event of an emergency.
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TRANSPORT EMERGENCY CARDS (TREMCARDS) The European Agreement concerning the international carriage of dangerous goods by road (ADR) regulates the road transport of such goods. Marginal 5.4.3 specifies the content of Instructions in Writing for the driver, which must be carried on vehicles carrying dangerous goods. There follows an extract from the text of Marginal 5.4.3 , as it appears in the 2005 edition of ADR .
Note: The requirements of ADR will change from 1-1-2009 (with transitional period of 6 months). The current Tremcard, per substance or per group of substances with similar hazards, will disappear and will be replaced by a (mandatory) 4 page document, which will be incorporated in ADR and which applies to all products. The consignor will no longer be involved as it will be up to the transport company to provide the driver with a copy of this document in a language, which the driver can read and understand. See pages 104-108 on the list of amendments to ADR for 2009:
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DANGEROUS GOODS NOTES Any carriage of goods governed by the ADR, shall be accompanied by the documentation described in chapter 5.4 Documentation, as it appears in the 2002 edition of the IMDG code, the 2005 edition of the ADR and in the 2003 edition of the RID.
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3.1.6.6 ESTABLISH A DANGEROUS GOODS SAFETY ADVISER.
EC Directive (96/35/EC) requires any company or undertaking involved in the transport, loading or unloading of dangerous goods to appoint a Dangerous Goods Safety Adviser. This Directive covers road, rail and inland waterways. The minimum examination requirements are laid down in the Directive 2000/18/EC.The prime duty of the DGSA is to advise the company who employs him on health, safety and environmental matters in connection with the carriage of dangerous goods. Directive 2000/18/EC establishes a common minimum framework for the examination of safety advisers and the conditions for the examination bodies in order to guarantee a certain level of quality and to facilitate the mutual recognition of EC certificates of training for safety advisers.
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Persons whose duties concern the carriage of dangerous goods, shall receive training in the requirements governing the carriage of such good appropriate to their responsibilities and duties. The majority of chemical companies have contracted out the road haulage of their products. Under these circumstances, it will be the haulier who is responsible for training its drivers. Basic elements in the training are general awareness training, function-specific training and safety training. Details of all the training undertaken shall be kept by both the consignor as well as by the consignee and shall be verified upon commencing a new employment. The training shall be periodically supplemented with refresher training to take account of changes in regulations. For further information see ADR Chapter 1.3
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3.1.6.8. PRODUCT EMERGENCY RESPONSE.
Responsibilities for providing guidance on emergency handling during product loading, transport and discharge should be assigned. An emergency number for contacting the company in case of an emergency should be given to transporters and a procedure to respond to emergency calls should be in place.
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ICE
There are seventheen national schemes already existing in Europe. Other countries are being progressively added and the ultimate aim is to cover the whole of Europe. Participation in a National Emergency Scheme is voluntary but requires the commitment of a company to provide help in (land based) distribution incidents on request of the Competent Authorities. Taking into account the capabilities and resources of a company there are 3 levels of intervention:
Such a commitment is applied firstly to products manufactured by the company itself and this is normally incorporated into its own distribution emergency response scheme. The Emergency Services may also require advice or help if the product supplier is not known or cannot be contacted. In such cases, companies may offer assistance on the basis of a prior arrangement with the National ICE Scheme. However, safeguarding their own site facilities takes priority over Level 2 and Level 3 intervention. Safety Data Sheets (SDS's) is the main source of information. Therefore participating companies ensure that SDS's for their own products are accessible at all times at the locations, which have been indicated as company contacts in the National ICE Scheme. Those companies which may possibly be involved in giving assistance or advice with respect to products that are not produced by themselves, should notify their insurers specifically of this fact and obtain confirmation that their general public liability policy will provide cover for these activities. This should not lead to increases in premiums.
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ERICARDS
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3.1.6.9 ESTABLISH
SAFE LOADING FOR SHIPS
EFMA has established a Guidance Document relating to Sea Transport of Ammonium Nitrate Fertilizers. Which covers UN Classification of type Fertilizers, Safety and control procedures relating to loading, transportation and emergency actions. This document includes also a checklist to ensure that all safety precautions are in place and that correct procedures are followed.
EFMA's Guidance Relating to Sea Transport of AN based Fertilizers
Code of Safe Practice for Solid Bulk Cargo ,2004, IMO publication ID260E, ISBN-13: 978-92-801-4201-3
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3.1.6.10 ESTABLISH GUIDELINES FOR TRANSPORT
All risks during loading/.unloading and transport should be assessed. The assessment includes SHE as well as security aspects. Drivers have to identify themselves before access to Company sites is allowed. Companies should have a procedure in place for safe loading/discharge of fertilizers and chemicals and product related SHE information should be communicated with and given to the truck driver/ railway operator before departure. The following EFMA guidelines contain information on requirements regarding procedure for unloading and unloading and requirements regarding transport operators. The instructions to the transport operator should include:
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ROAD TRANSPORT The transport of nitric acid is subject to stringent national and international rules which must be complied with by all those involved. The Guidelines For Transporting Nitric Acid in Tanks (1998) have been drawn up by EFMA in order to ensure high safety standards in operations involving nitric acid transport. Though these Guidelines go beyond the strict application of the existing rules, no part of these guidelines should be applied or interpreted in such a way that is clashes with existing national and/or international laws. In all cases, legal regulations must always prevail over any part of these guidelines.  EFMA's Guidelines for Transporting Nitric Acid
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RAIL TRANSPORT The transport of Ammonia is subject to stringent national and international rules which must be complied with by all those involved. EFMA's Guidance for Ammonia Transport by Rail has been drawn up by EFMA in 2005 in order to ensure high safety standards in operations involving Ammonia rail transport. Though these Guidelines go beyond the strict application of the existing rules, no part of these guidelines should be applied or interpreted in such a way that is clashes with existing national and/or international laws. In all cases, legal regulations must always prevail over any part of these guidelines. The guidance has been revised in 2007 and is available in both the English as well as the German version.
EFMA's Guidelines for Transporting Ammonia by rail
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SEA TRANSPORT In 2003 EFMA issued the Guidance relating to sea transport of ammonium nitrate based fertilizers. The scope of the guidance is to instruct the captains of the ship carrying ammonium nitrate based fertilizers, this to prevent decoposition accidents in ships.
EFMA's Guidelines for Transporting Ammonium Nitrate based Fertilizers by Sea
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Legal Requirements Road transport At its September 2003 session, the RID/ADR/ADN Joint Meeting adopted new provisions for security of the carriage of dangerous goods. The secretariat reproduces the consolidated text of Chapter 1.10 as adopted. The new version of the ADR (applicable as from 1 January 2005) already contains a full chapter 1.10. This security plan includes special measures for high consequence dangerous goods as list in Table 1.10.5. In addition CEFIC has prepared Industry Guidelines for the Security of the Transport of Dangerous Goods by Road. These Guidelines have been designed by industry to provide as comprehensive a range of technical and operational options as possible , from which users can select their optimum mix of options to achieve compliance with the regulatory requirement of Chapter 1.10. Sea transport The security of not only for ships used in international shipping but also for port facilities which serve them should be enhanced in the face of threaths of intentional unlawful acts. On 31 March 2004 an EU regulation regarding this issue came into force. Measures are given. This regulation constitute only part of the measures necessary to achieve an adequate level of security throughout maritime linked transport chains. That regulation is limited in scope to security measures on board vessels and the immediate ship/port interface. Directive 2005/65/EC of the European Parliament and the Council of 26 October 2005 on enhancing port security OJ L310 of 25-11-2005 pages 28-33. has been put in place to achieve the fullest protection for maritime and port industries and port security measures should be introduced, covering each port in the MS. The main points covered by the Directive are:
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EFMA Requirements In response to the increased concern related to terrorism and misuse of fertilizers, EFMA recognises the need for addressing security in production, storage, transportation and sales of fertilizers. Hence, EFMA has updated its Product Stewardship program to cover this important topic in more depth and in accordance with recently expressed demands by the authorities. EFMA's recommendations for security measures are not made available in this description of EFMA's Product Stewardship program. It is available for EFMA members only and is part of the EFMA auditing system for evaluating the adherence to the recommendations amongst the members.
EFMA's recommendations for security measures. Members Only Click on logo to access
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