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11th October 2010. Issue 134 in the series
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Welcome to TT Talk Edition 134
Contents:
1. Forthcoming amendments to ADR and RID
2. European Union 24-hour Security Rule (Electronic Entry and Exit Summary Declarations)
3. The Importance of Regular Structural Examinations of Quay Cranes
4. Conclusion
1. Forthcoming amendments to ADR and RID
The FIATA Advisory Body Dangerous Goods (ABDG) has provided an advice concerning the proposed amendments of the ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road) and the RID (Regulation concerning the carriage of Dangerous Goods by rail) that are due to enter into force on 1 January 2011. There are general transitional measures until 30 June 2011 with the possibility to apply for longer transitional measures for specific technical issues.
The amendments touch on the following subjects:
- New definition and obligations for "unlades"
- Complete reformatting of LQ (Limited Quantities) provisions
- Transport document: Change of sequence of entries for dangerous waste
- Transport document: New entry (“environmentally hazardous substances”)
- Retention of dangerous goods transport information
- Change of Instructions in Writing
- ADR driver training – change of system and certificate
The full details of these changes can be downloaded from the following link:
Forthcoming amendments to ADR and RID
For further information on the ADR/RID Regulations, you may refer to FIATA Advisory Body Dangerous Goods (ABDG) or your usual Club contact.
2. European Union 24-hour Security Rule (Electronic Entry and Exit Summary Declarations)
Dr Risto Talas, Research Fellow at University of Hull Logistics Institute, writes:
‘Exporters to and from the European Union should be aware that the 18-month transitional period for the introduction of electronic entry and exit summary declarations (as provided under Commission Regulation (EC) No 273/2009 of 2 April 2009) expires on 31 December 2010. The 18-month period of grace was initially provided in recognition of the complexity of processing electronic entry and exit data and the investments required in automatic data transmission systems.
The primary purpose of the new regulation is to ensure that an entry summary declaration (ENS) is submitted electronically to the first customs office of entry of the goods to the European Union within the time limits specified in the regulation. The time limit is typically 24 hours before any containerised cargo is loaded onto the vessel in the non-EU port, as is the case in the US 24-hour rule, to allow for Customs Authorities to carry out a security risk analysis and to have sufficient time to issue a ‘Do Not Load’ message, if required.
The rules for breakbulk cargo, short sea shipping, air transport, rail, inland waterway and road transport differ in the time limits for the submission of the ENS. For example, for short sea shipments, the ENS transmission must be carried out no later than two hours before arrival of the vessel at the first port of entry in the EU. For maritime breakbulk cargo not on short sea shipping routes the time limit is four hours. For short haul flights of less than four hours, the ENS must be submitted at least by the actual takeoff time of the aircraft. For long haul flights of more than four hours’ duration, the ENS must be submitted at least four hours before arrival at the first airport in the EU. For rail and inland waterways, the ENS must be submitted at least two hours before arrival at the customs office of entry to the EU and the corresponding time limit for road traffic is one hour.
The regulation states that if a vessel leaves an EU port and calls at a non-EU port before returning to an EU port with the same cargo on board, a ENS must be submitted for that cargo prior to each call at an EU port. The regulation also specifies who can file ENS declarations, the procedures for obtaining Economic Operator Registration and Information numbers, the ENS data requirements and rules governing amending ENS declarations and shipment diversions. The data required in the ENS can be found in tables 1 to 5 in the following annex to the Security Amendment here:
ENS data requirements
A comprehensive guide to Frequently Asked Questions on the ENS can be found here:
ENS FAQ
More information about the EU Security Amendment advanced manifest rule is available at:
EU Security Amendment
This information is profiled in the Club handbook to which Dr. Talas contributed, ‘Supply Chain Security- Management, initiatives & technologies’. This was published in June 2010. If you would like a copy please email us.
Readers may also wish to look at the WSC website:
3. The Importance of Regular Structural Examinations of Quay Cranes
Based on an analysis revealing a number of major structural failures in port equipment in recent years, Laurence Jones, TT Club's Global Risk Assessment Director, stresses how essential it is for operators of ports and cargo handling facilities to establish a regular sequence of maintenance and thorough examination of all the lifting appliances it utilises. “Provisions for such examinations are specified in ILO Convention 152 and its accompanying Code of Practice, and represent the international standard for the port industry. The purpose of a thorough examination is to make sure a crane can continue working safely and effectively, and a crucial element of this with regard to a quay crane is the safety of its structure,” Jones emphasised.
The Club recommends that independent examinations are always performed when procuring any type of crane. The ILO Convention requires that before being brought into commission for the first time, lifting appliances are tested and a thorough examination carried out. The Club also recommends that appropriate mechanical and electrical inspections are carried out during installation and commissioning to check for quality and conformance to standards and specification – beyond the ILO Convention requirement. Once commissioned, a crane should also be examined regularly during its operational life, regardless of how good its manufacture. Damage resulting from relatively minor impacts, regular heavy-lifts close to, or equal to the safe working load limits, intensive use or simply general wear and tear can affect the integrity of the crane’s structure. Often such operational issues can occur without anybody being aware, so regular examinations need to be conducted. Any known incident should clearly result in a check on the structural integrity of the crane at that time. This advice applies equally to fixed and mobile cranes of any type.
The ILO standard calls for a competent person to carry out the testing and thorough examinations. It is common practice to utilise third party inspection companies to check for quality and design conformance during manufacture. Laurence Jones recommends that only specialist inspection companies should be used, such as Bureau Veritas, Lloyd's Register, Liftech Consultants and World Crane Services. These companies provide examinations globally during and after manufacture, although it is clear that there are other equally competent and locally based service providers. Thorough examinations during the life of the crane should fall within a strict maintenance policy that is seeking to maximise its useful life and minimise unplanned downtime.
The Club’s analysis indicates that the actual structure of a crane, because of its size and complexity, may not always be examined as often as it should. The standard calls for such examinations to be conducted at least once every twelve months. Generally, as a crane gets older the examination frequency should increase. Furthermore, the regularity of examinations should increase based on the degree of use and if this is at or close to the crane’s safe working load limits.
4. Conclusion
We hope that you will have found the above items interesting. If you would like to have further information about any of them, or have any comments you would like to make, please email us. We look forward to hearing from you.
Ian Lush
Marketing Director
TT Club
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