Working Party on the Transport	INF.21	E

of Dangerous Goods

(Sixty-seventh session,

8-12 November 1999)

Transmitted by the Government of the Netherlands

Chapters 1 - 7 of restructuring

In the refered fax UN ECE is asking the delegates to consider in more detail parts of the chapters 1 up to 7 of the restructured version and suggests to make time available in the agenda of the 67 th session.

PROPOSAL

The Netherlands underline the need that WP15 properly checks the texts of the joint meetings and in that respect we welcome the initiative of the secretariat. However we don't expect the

delegates will have ample time nor the appropriate documents to complete the job thoroughly.

Consolidated texts are not yet available. The editorial group of the joint meeting just started.

The chapters 1-7 have been prepared by a RID working group and the road specific matters haven not been discussed nor checked.

The Netherlands therefor are reluctant to make a final decision on the chapters 1-7 during this session. We prefer that the plenairy meeting agrees upon the way how to check the texts before the meeting of may 2000 and that WP 15 takes then their decision.

EXAMPLES

In the meantime we are studying the available documents and we can already identify the following subjects, which need detailed attention of the delegates:

Part 1 General Provisions

States how the carrier should act in case he cannot meet the required obligations.

The text of this article may be typically inspired by the CIM rules of the COTIF treaty. For road transport the text is uncomprehensible.

Other articles or definitions require attention by WP 15 delegates. At least we have to understand the meaning of this important new chapter in order to explain the consequences to our users. Without disturbing the joint effort it may be necessary to make some adjustments.

Part 3 Dangerous Goods List

The mode specific columns 14-16 of the table must be checked. Are the existing provisions of road transport completely incorporated in the cells? We have the opinion that the explanation how to use the table needs some extension for ADR. It must be clear that the table does not cover the requirements and that in addition the general requirements must be met. In the explanation of the columns it should be made clear where these general provisions can be found.

INF.21

page 2

Part 4 Packing and Tank provisions

Chapter 4.3 "Use of tanks, tankcontainers, swap bodies, battery vehicles" is partly ADR dedicated and WP 15 delegates should consider these texts.

Part 5 Consignment Procedures

Chapter 5.4 enables the carrier to use the required information in his transport unit in an electronic way. It means that instructions in a vehicle may be supplied by electronic data (EDI). This had been accepted by joint meeting of sept. 1999 on a proposal by CIT. Do we agree that a vehicle may drive without a written instruction?

Part 6 Requirements for construction

Chapter 6.8 and 6.9 are concerning tankvehicle construction. Special attention by WP 15 is required!

Part 7 Loading and unloading

This chapter has been discussed by the JM. However road specific subjects are dealt with, and should be checked.

RID uses only this chapter 7 for their railway specific matters while ADR is using also chapters 8. (and 9). Is there a need for chapter 7 for ADR or can we combine chapters 7 and 8?

These examples, which are not exhaustive, illustrate the importance of a thoroughly reading of the joint chapters.

____________