In my classes, and in all good instructors’ classes, the goal is to have students understand the regulations, not just blindly attempt to comply without comprehension. To that end I sometimes talk about animal bites. With a picture of a tiger and of a chihuahua on the screen at the same time, I ask if anyone wants to be bitten by an animal. No one does. I then ask, if you absolutely, positively had to be bitten by an animal, would you prefer the tiger or the chihuahua? A tiger could snap your spine with one bite, killing you, while the chihuahua…, well the chihuahua would run back under the sofa/couch before you could kick it in retaliation. Some animal bites are worse than others. Then, I ask who wants to be accidentally exposed to Dangerous Goods (HazMat)? No one does. Later, we can talk about intentional exposures to aerosol deodorants, medicines, flammable perfumes and Alcoholic Beverages. But, for now, I compare animal bites to unintentional HazMat exposures. Some are worse than others; there are differing degrees of danger. A tiger bite is PG I, gasoline/petrol is PG II, while the chihuahua and hand sanitizer are PG III.
The degree of danger is important, as the degree of danger often dictates the performance of the packaging. Obviously, this is a serious concept. And this is where the DG regulations begin to diverge. Some regulations refer to major, medium, and minor dangers, a scale I prefer if only for the alliteration, while other regs use high, medium, and low danger. I’ll concede this is an insignificant difference, but will also provide you another example to ponder. What is the PG of 85% Cumyl hydroperoxide? Assuming the proper diluent, the Organic Peroxide Tables give us UN3109, which is Organic Peroxide, liquid, Type F, 5.2. But in the DG (HazMat) regs the HazMatTable (DG Lists) don’t show a PG. Really? The organic peroxide packing instructions (and references such as IATA Special Provision A802) say that organic peroxides must be in packaging that meets the PG II performance level. As the famous tennis player John McEnroe said, “You cannot be serious!”. The packaging must be PG II, but we can’t be bothered to call the material itself PG II? How does that make sense?
And it gets worse. There are other isolated examples of this problem, such as the U.S. D.O.T. (Department of Transportation) and Class 9 Chemical Kits. But it’s not just a small accumulation of occurrences, over the years we’ve done this for quite a many articles, from batteries to fuel cells, from engines to vehicles, from safety devices to life-saving appliances, and more. We’ve agreed, or perhaps I should say the regulators have agreed, because I don’t agree, that whenever an article requires packaging that must meet some particular performance level, PG I or II or III, we will consciously, intentionally, omit that PG from the Table/List of Dangerous Goods. Really?
How does one explain to a classroom full of novice students, who are desperately trying to find and understand the underlying principles and concepts of the DG transport regulations, so that they can more effectively apply them in real life, that both chemicals and their packages both get PGs, but that for articles, we don’t allow them to have PGs even when their packaging requires it? It defies common sense.
Eh, who cares about the problems of a few hundreds of DG trainers? We’re paid to make the regulations comprehensible, or at least point out the inconsistencies (absurdities?) while saying “it may not make sense, but just do it because the regs say to”.
But how about DG acceptance agents? Whether road, rail, air, or water, wouldn’t it be great to have a compliance check, even a rudimentary one, on packaging before the package gets moved? For chemicals, we have that. An acceptance agent or driver (it’s usually going by road before it gets to an airport, seaport, or rail hub), compares the PG on the paperwork to the X, Y, or Z on the drum, box, bag, or jerrican. Then they compare, at least for solids and for combination packagings, the listed weight on the shipping papers to (against) the maximum gross weight in the UN-specification mark. But for articles, the absence of a PG on the paperwork prevents an acceptance agent from knowing whether UN-specification packaging is required, and if required, whether it’s capable, both from a PG and weight standpoint.
“Don’t complain without offering a potential solution!” Yes, I’ve heard that before. Perhaps, as we now list multiple PGs in the DG Lists for some classifications, e.g., Alcohols, n.o.s. as PG I or PG II or PG III, we could list multiple PG choices for articles? Perhaps as PSN Article… n.os., PG none or PG II, and then require the shipping document match the appropriate entry? In the meantime, requiring a PG for a packaging but refusing to list it in a HazMat Table or on a shipping document is at best inconsistent, and, at least in my ponderings from my porch swing, at worst and quite likely, unsafe.
Really? Yes, really. Don’t say I can’t be serious John McEnroe and DG regulators, because, I am serious.