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Security Advisors

The R.D.A., also known as the European Agreement concerning the International Carriage of Dangerous Goods by Road, is an international agreement that regulates the transport of dangerous goods by road in Europe. This agreement establishes specific rules and requirements for the packaging, labeling, documentation and transport of substances and materials that pose a risk to health, safety or the environment.

The A.D.R. classifies dangerous goods into different classes according to their nature and the type of risk they represent. In addition, it establishes detailed requirements for the transport of each class of dangerous goods, including packaging conditions, information to be provided in the transport documentation and safety measures to be taken during transport.

This agreement is of great importance to ensure safety in the transport of dangerous goods by road in Europe and to facilitate international trade by establishing a common regulatory framework.

The ADR classifies dangerous goods into several classes according to their nature and the risks they represent. These classes are:

  1. Explosives (Class 1): Includes explosive substances and articles, such as solid explosives, liquids, gases, pyrotechnic articles, etc.

  2. Gases (Class 2): Refers to compressed, liquefied or dissolved gases under pressure, such as butane gas, propane, oxygen, etc.

  3. Flammable liquids (Class 3): Covers flammable liquids, such as gasoline, alcohol, oils, paints, etc.

  4. Flammable solids, self-reactive substances and solids that emit flammable gases on contact with water (Class 4): Includes flammable solids, self-reactive substances and substances that emit flammable gases on contact with water.

  5. Oxidizing substances and organic peroxides (Class 5): Covers oxidizing substances, organic peroxides and chemicals that react violently with other substances.

  6. Toxic (Class 6): Refers to toxic, poisonous or infectious substances, such as pesticides, hazardous chemicals, infectious biological materials, etc.

  7. Radioactive materials (Class 7): Includes radioactive materials, such as uranium, plutonium, etc.

  8. Corrosives (Class 8): Covers corrosive substances that can damage living materials and tissues when in contact with them, such as acids, bases, etc.

  9. Miscellaneous (Class 9): Refers to hazardous substances and objects that do not fit into the other classes, but still present risks during transport, such as environmentally polluting goods, substances presenting various hazards, etc.

It is important to note that these classes have subdivisions and that the transport of dangerous goods is subject to specific regulations regarding packaging, labeling, documentation and transport, as established by the ADR.

Companies that need a Dangerous Goods Safety Advisor are those that carry out activities related to the transport of dangerous goods by road and meet the following criteria:

  1. Perform operations of loading, unloading, packing, filling or unloading of dangerous goods.
  2. Are responsible for the preparation of documentation related to the transport of dangerous goods.
  3. Be responsible for the loading of transport vehicles.
  4. Are responsible for the operation of vehicles transporting dangerous goods.

In summary, any company that engages in activities related to the transport of dangerous goods and meets the above criteria must appoint a Dangerous Goods Safety Advisor. This advisor is responsible for advising the company on issues related to dangerous goods transportation safety and ensuring compliance with applicable regulations.

Royal Decree 97/2014, which regulates the transport of dangerous goods by road in Spain, establishes various functions for the Dangerous Goods Safety Advisor. These functions are crucially important to ensure safety in the transport of hazardous substances. Some of the main functions of the Safety Advisor according to this decree are:

  1. Advice and supervision: The Safety Advisor must advise and supervise all activities related to the transport of dangerous goods to ensure compliance with safety regulations.
  2. Report preparation: You must prepare periodic reports on the company’s compliance with dangerous goods transport regulations.
  3. Education and training: You must provide adequate education and training to personnel involved in the transport of dangerous goods, including drivers, loading and unloading personnel, and other related workers.

  4. Packaging and labeling supervision: You must supervise that dangerous goods are properly packaged, labeled and documented in accordance with applicable regulations.

  5. Internal audit: Conduct periodic internal audits to assess compliance with safety regulations and propose improvements in procedures if necessary.

  6. Coordination with competent authorities: Collaborate with relevant transport and safety authorities to ensure compliance with regulations and facilitate inspections and controls.

These functions are essential to ensure that the transportation of dangerous goods is carried out safely and in compliance with all applicable regulations. The Safety Advisor plays a key role in preventing accidents and protecting the environment and public health.

The ADR, which stands for the European Agreement concerning the Transport of Dangerous Goods by Road, applies mainly to the international transport of dangerous goods by road. This agreement is reviewed every two years by the WP-15 working group, attached to the Inland Transport Committee of the Economic Commission for Europe (UNECE), and covers more than 45 European countries, plus some additional countries such as Morocco, Tunisia, Turkey, Kazakhstan and Azerbaijan.

Safety Data Sheets SDS

Safety data sheets, also known as safety data sheets (SDS), are required for any substance or product that is considered hazardous according to the relevant regulations. This includes chemicals, hazardous materials, flammable products, toxic products, corrosives, explosives, among others.

In general terms, safety data sheets are required by:

  1. Manufacturers: Manufacturers of chemicals and other hazardous materials are responsible for providing safety data sheets for their products.

  2. Distributors and vendors: Distributors and vendors who handle or sell chemicals and hazardous materials should also have access to MSDSs to adequately inform their customers about the risks associated with such products.
  3. Employers: Employers who use or store chemicals or hazardous materials in the workplace are required to have safety data sheets available for their employees as part of their occupational safety program.
  4. Carriers: Companies transporting dangerous goods by road, rail, air, air, sea or inland waterways must also have access to the relevant safety data sheets to ensure safe handling and transport of the products.

MSDSs provide detailed information on chemical properties, health and safety hazards, precautionary measures and safe handling instructions for hazardous products. They are intended to provide clear and accurate guidance for the safe handling, storage, transport and disposal of these substances to protect human health and the environment.

The review and update of safety data sheets are not predetermined, there is no requirement that data sheets must be reviewed annually, every two years or every five years.

The review is necessary in all cases where new information on the product becomes available. The safety data sheet must be revised without delay in accordance with Article 31 of REACH if:

  • There is new information that may affect risk management measures.
  • There is new hazard information, e.g. new classification according to CLP.
  • An authorization is granted or denied (listed in Annex XIV of REACH as a substance subject to authorization).
  • A restriction is imposed on the substance (Annex XVII).

The SDS must be provided in the official language(s) of the country where the product is marketed.

Notifications to Poison Centres. ECHA

Article 45 of the CLP Regulation defines importers and downstream users who place dangerous mixtures on the market as responsible parties. In all cases, the obligation always lies with the EU as a legal entity, which means that a supplier of the mixture who is not domiciled in the EU cannot replace the responsible party who is domiciled in the European Union. It is also important to note that compliance with the notification obligation is a precondition for placing the mixture on the market; this may be of importance in cases where the placing on the market of the product is not done by the importer or downstream user.

The obligation applies to marketed mixtures classified in relation to human health or physical hazards.

Please note that biocides and plant protection products are within the scope of this obligation and that the reporting requirements apply in addition to other obligations under the Biocides Regulation and the Plant Protection Products Regulation.

You may benefit from a transitional period for all products that you have previously notified and that are already on the market. These notifications will remain valid until January 1, 2025 or until changes are made to the product (e.g. changes in the composition of the mixture, toxicological properties or product identifiers).

  • If the product requires an update of the presentation as a result of a change, this must be done in the new harmonized format; note that the different application dates according to the type of use are still valid.
  • mixtures subject to customs supervision.
  • However, if your product remains unchanged until January 1, 2025, you will need to submit a new application in the harmonized format, as no data migration is foreseen.
  • If your product is no longer manufactured before the end of the transition period, you will not have to file a new application. medical devices and food and food products.

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