'TOO MANY PLACARDS ?'

摘要

The philosophic basis for regulating Dangerous Goods can broadly be stated as: 'Many chemicals andsubstances can be dangerous under certain conditions and in certain quantities if not handled ortreated properly' This then leads to the prescribing of a list of dangerous chemicals or substancescalled 'Dangerous Goods', and the setting of regulations pertaining to (amongst other things) theirtransport, as set out in the UN Orange Book. For Radioactive Material, the basic philosophyunderlying their regulation can broadly be set out as 'All Radioactive Materials are dangerous andsubject to regulation, unless specifically exempt' . This then leads to the prescribing of a list of exemptquantities of radioactive material or products containing radioactive material. The IAEA ModelRegulations for the Safe Transport of Radioactive Material (TS-R-1) sets the requirements for the safetransport of all radioactive material, based on this philosophy.Radioactive Material is a subset of Dangerous Goods (Class 7) and to overcome this philosophicaldifference the UN Orange Book has to date referenced TS-R-1when referring to the transport of Class7 material. While this is a convenient quick fix for the policy makers, at the operational level it causesdifficulties. A case study of the consequences of the placarding requirements for shippers ofDangerous Goods compared to the placarding requirements for shippers of Radioactive Material,demonstrate the poor fit of these two philosophies. The resulting confusion at the operational levelfrom these different philosophic bases could help explain the increase in the 'Denial of Shipment'reports being received concerning the transport of radioactive material.