Vietnam Vietnam: Draft circular on detailed rules for dangerous goods transportation is disclosed

Vietnam Dangerous Goods Transport Draft Chemical Substances (Products) Chemical Products
30 September 2020  AOKI Kenji  AOKI Kenji (EnviX, Ltd.)
Vietnam: Draft circular on detailed rules for dangerous goods transportation is disclosed

In late September 2020, Vietnamese Ministry of Industry and Trade (MOIT) publicized the Draft Circular on Mandated Packaging of Dangerous Goods During Transportation on Roads, Railways, or Inland Waterways. This draft circular stipulates a list of dangerous goods that must be packaged during transportation using roads, railways, or inland waterways, as well as requirements for packaging, emergency responding measures, and training for transporters in terms of transportation of dangerous goods.  When this draft circular comes into effect, the existing circular no. 44/2012/TT-BCT will be repealed.

The draft circular can be downloaded at:
http://legal.moit.gov.vn/default.aspx?page=document_bill&do=detail&doc_id=1084&rand=637351747117123384

 

Scope and major requirements

This draft circular regulates Class 2 (gas) and Class 3 (flammable or explosive liquid) out of the dangerous goods that are controlled by MOIT as defined in Article 24, Paragraph 1 of the Decree No. 42/2020/ND-CP on Transportation of Dangerous Goods on Roads and Inland Waterways, and different gasolines, combustion gases, hazardous chemicals, toxic chemicals, etc. The regulated dangerous goods are 1360 substances as listed in Annex 1 of this draft circular.

Major requirements mandated by this draft circular are summarized as follows.

Danger sings and warning statement
  • The size, symbol, color, and warning statement of danger signs must be pursuant to Annex III of Decree 42/2020/ND-CP.
  • An emergency information board (see the figure below) must be prepared pursuant to Annex 4 of this circular.
  • Danger signs and warning statement must be displayed on containers and packaging of dangerous goods in accordance with this circular.
  • When a vehicle or train carries dangerous goods exceeding the weight specified in column 7 of the dangerous goods list (Annex 1 of this draft circular), emergency information boards must be displayed at the end of the transporting vehicle or train, in addition to the mandated danger signs and warning statement.
Packaging of dangerous goods
  • Dangerous goods other than those classified into the Class 3 (gas), namely solid or liquid dangerous goods, must be packaged pursuant to the levels stipulated in the column 6 of the list.   The levels of packaging are PG I (most dangerous), PG II (moderate danger), and PG III (least danger).
  • The packaging codes for dangerous goods are stipulated in column 8 of the list.
Testing and verification of containers
  • Newly manufactured or reused containers or packaging for dangerous goods must be verified before every use.
  • Any organization that manufactures or imports containers or packaging for dangerous goods must comply with the provisions of the Law on Product and Goods Quality. Furthermore, when packing dangerous goods, verified containers or packaging must be used.
  • Disposable containers or packaging must be disposed of as hazardous wastes after use if they do not meet the requirements for multiple uses.
Transportation
  • A companion is required for transporters who transport dangerous goods exceeding the weight specified in column 7 of the list of dangerous goods (Annex 1).
  • Drivers, companions, and loading and unloading workers handling dangerous goods must work pursuant to the provisions of this draft circular.
Content, format and time of training for transporters
  • Transporters must receive training on laws and regulations related to transportation of dangerous goods, hazards and danger associated with transportation of dangerous goods, requirements for danger signs, containers and packaging, loading and unloading methods, emergency response plans, etc.
  • There are three training types: initial training (at least 16 hours), regular training (every two years, at least 8 hours / time), and retraining (at least 12 hours).
Emergency responding measures
  • When transporting dangerous goods exceeding the weight specified in column 7 of the list of dangerous goods (Annex 1), emergency responding measures must be taken. Details are provided in Annex 5 of this draft circular.
  • When the above does not apply, a material safety data sheet (MSDS) that contains responding measures against accidents such as leakage, outflow, explosion and fire as specified in Circular No. 32/2017/ND-CP must be prepared.
  • When transporting dangerous goods, the transporter must carry documents describing emergency response measures.
  • Annual training must be conducted on the prescribed responding measures.

Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting

Background

MSc in Earth Science, The University of Tokyo

AOKI Kenji