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Submissions for Australian Code for the Transport of Dangerous Goods by Road and Rail Edition 7.6 - Consultation draft (Dec 2017)

Dangerous Goods Transport NSW - Kevin Gaskell

29 Jan 2018


I would like the NTC to consider my suggestion for any Codes of Practices or Guides pertaining to the transport of dangerous goods by road.

I have specialist, small-quantity dangerous goods transport company. I have become quite familiar with the ADG, the UNECE info and information on the subject on NSW EPA website.

Some of the work we do is for NSW ports (cargo ships and cruise ships.)

Here is my suggestion:

The NSW ports have their own rules about vehicle warning lighting. When in some areas of a port a vehicle must display amber hazard lights. Vehicles not fitted with beacons or lightbars can only use their existing vehicle hazard lights.

I would like to offer for consideration a rule that all dangerous goods vehicles of any kind must be fitted with amber light bar or rotating beacon(s), as a mandatory requirement. This would include smaller vehicles light utes or 1 tonne or 2 tonne trucks.

In the current ADG Code it only mentions use of hazard lights or failing that the "parking brake light" during a breakdown. This is of the Code. There is no mention of hazard lights anywhere else in the Code. This omission is impractical and reduces the vehicle to that of an every day "car" or "motorbike."

Not just in the case of a breakdown but it would be reasonably practicable that a vehicle transporting dangerous goods should be fitted with a light bar or beacon to distinguish them from "cars" or "motorbikes" much the same as beacons are required on Construction and Utility vehicles. In terms of risk, those vehicles are much less of a risk to public safety than a vehicle transporting dangerous goods, and yet it is law for those vehicles to display an amber beacon or light bar. It should be mandatory for all dangerous goods vehicles. If you are delivering to the ports you need to have it anyway. Include DG vehicles in the law too.

I hope this has been helpful and may be considered for the next edition of the ADG Code.