When people move, material does follow. Because of globalisation, innovative technology and ever-changing lifestyle of people, the need to transport hazardous material (also known as dangerous goods) is increasing beyond one’s imagination.

By definition, dangerous goods are substances or articles that are capable of posing a risk to life, property and environment when transported. However, transportation of such goods cannot be avoided since mankind needs such dangerous goods like acids and flammable liquids for their daily use.

Realising the need to transport hazardous goods, the United Nations developed Model Regulations for all modes of transportation. Though India has adopted it, its effective implementation is still vague.

Air

Adopting the UN Model Regulations, International Civil Aviation Organization (ICAO) under Annex 18, developed Technical Instructions for Safe Transportation of Dangerous Goods by Air through Aircraft Act, 1934 (to be replaced by Aircraft Bill, 2023) and Aircraft Rules, 1937.

Aircraft (Carriage of dangerous goods) Rules, 2003 ensures high safety standards through classification, packing, handling, training, surveillance audits, incidents and accidents reporting, investigation and penalties for violations.

The effective implementation of the provisions by the Directorate General of Civil Aviation is reflected in the country’s track record of not reporting any accident due to dangerous goods though few isolated incidents with insignificant impact have been reported.

Sea

India adopted the International Maritime Dangerous Goods (IMDG) Codes that have been developed by the International Maritime Organization based on UN Model Regulations. But, IMDG Code is considered more often for classification of dangerous goods whereas other requirements associated with the handling of hazardous cargo take a back seat because of the lack of appropriate national regulations.

In 2020, after a large amount of ammonium nitrate stored at the Port of Beirut, Lebanon, exploded, causing at least 218 deaths, 7,000 injuries, loss of property and leaving an estimated 3,00,000 people homeless, the Indian government ordered for a surgical audit of all cargo facilities. Almost 700 tonne of ammonium nitrate were found lying in a Chennai sea cargo facility for years. This talks about the lack of implementation and oversight to confirm safety standards.

Mere adoption of IMDG Codes will do no good. Effective national regulations that cover all processes and requirements in all areas of cargo handling such as seaport, CFS and ICDs as is done in air transportation is required to bring in high safety standards in transportation of hazardous goods by sea.

Rail

Currently Indian Railways is the regulator as well as the operator and hence the implementation of rules governing transportation of hazardous material tiled as ‘The Red Tariff’ solely rests with Indian Railways.

Road

The transportation of hazardous cargo by road continues to be a matter of serious concern. In many countries, The European Agreement Concerning the International Carriage of Dangerous Goods by Road and/or USDOT 49 CFR are the basis for their national regulations. Though references are made in Central Motor Vehicles Rules 1989 for certain requirements, it misses an inclusive framework thus paving way for wild interpretations, poor standards and unsafe transportation.

Now, the Bureau of Indian Standards has come up with IS 18149:2023—Guidelines for Transportation of Dangerous Goods which appears to be more of a cut and paste from other sources. Guidelines don’t gain legal status and support enforcement.

There is an urgent need to develop comprehensive national regulations/rules for transportation of hazardous cargo by road that considers all processes from the preparation of shipments, loading, securing, unloading or discharging, conditions and limitations related to road, tunnels and vehicles, hazard communication, training, emergency responses with defined authorities or agencies for audits, investigation and penalties for violations. Until that happens, transportation of dangerous goods by road will continue to be countered with confusions, challenges, accidents leading to loss of life, property and affecting the environment.

B Govindarajan

B Govindarajan

(The writer is Founder of Tirwin Management Services, and Member of DGCA’s Aviation Advisory Panel - Dangerous Goods.)

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