The Australian Dangerous Goods Code is being updated to align with the United National model regulations. The changes apply to new and used batteries and mostly affect lead acid and lithium batteries.
We will be preparing a submission in line with the information provided below, and would very much like your input to identify any other issues or opportunities with the changes.
As we communicated in the last newsletter, the deadline is December 31st, so this is your last chance to include input in the ABRI. Please send us any suggestions by lunchtime this Thursday.
ABRI’s submission will include high levels recommendations for:
- harmonisation of transport regulations internationally and requests that this pursuit also be applied to inter-jurisdictional implementation within Australia.
- a single point reporting for all ADG related transport
- standardisation of language as interpreted by the states
On the lithium side a quick review indicates that there have been extensive updates to multiple parts of the ADG with regards to lithium batteries. We are hoping that some of our more lithium focused members can provide us with feedback on the changes. Specifically Special Provisions 390 & 389 also Packaging Instructions P911 LP905 and LP906.
On the lead acid battery side, Ben and the Ramcar team have reviewed the draft changes in relation to packaging and transport of lead acid batteries under UN numbers 2794 and 2800.
General Placarding Requirements
- The general placarding requirements have been changed with lead acid batteries new and used.
- UN number 2794 falls under Table 5.3.e
- UN number 2800 falls under Table 5.3.f
Special Provision AU08, relevant to UN No:2794
- The amendment to this special provision will allow larger loads on lead acid batteries to be transported without placarding.
- Up to 2,000 L of corrosive liquid can be carried without placarding.
- An assumed 25% of gross weight of a lead acid battery is assumed to be corrosive liquid if precise volume is not known.
The positive result to industry is that as a rule of thumb 8,000kg of lead acid batteries wet or sealed or a mixture of both can be transported without placarding. Where the specifics of the acid quantities are known a larger weight may be possible. This is ultimately a doubling of capacity when compared to ADG 7.6.
UN No: 2794
- Special Provisions
- 295 – Unchanged
- AU08 – Changed to industry advantage
- Packaging Instruction
- P801 – Changed – No significant change to industry
UN No: 2800
- Special Provisions
- 238 – Unchanged
- Packaging Instructions
- P003 – Unchanged
- Special Packing Provisions
- PP16 – Changed – with minimum expected impact on industry. Zero impact on Ramcar.
P801 Packing Instructions
Both ABRI and ABIA have worked together extensively on P801 this year. The version as proposed into ADG 7.7 is a direct import of the UN 21 P801 with no local adjustments as previously discussed. Taking the Government positions on the matter into consideration, we can see no reason to object to the proposed update to the generic UN 21 P801 standard.
Ben has kindly extracted the relevant pages from the 1300+ document as a starting point for delving into this rather challenging document.
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