In this article written by our Lab Manager Livia Fioravanti we look at why it is quite common for clients have uncertainties regarding what is a hazardous substance and what are dangerous goods for transport, e.g. why is my product a dangerous good, without being classified as hazardous substance?
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What are Hazardous Substances?
A hazardous substance is any substance that may be explosive, flammable, able to oxidise, corrosive, toxic or ecotoxic (environmentally hazardous) as described and regulated by Hazardous Substances and New Organisms Act 1996 (HSNO) and Health and Safety at Work (Hazardous Substances) Regulations 2017. They exclude some substances and products like asbestos, manufactured articles, food, medicine, radioactive material and drugs as they are regulated by their own specific acts or regulations.
Depending on the hazardous classification, a hazardous substance is automatically considered a Dangerous Good, e.g.:
- Flammable liquids categories 1, 2 and 3 are also dangerous goods (Class 3), while flammable liquids category 4 (low hazard flammable liquids that are classified as combustible liquids) are not flammable liquids for transport.
- Skin corrosion categories 1A, 1B and 1C are also dangerous goods (Class 8), while substances classified only as skin irritation category 2 are not corrosive for transport.
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What are dangerous goods?
Dangerous goods are substances or material that can pose a significant risk to health, safety, property, or the environment during transport and they shall be transported following specific rules, e.g., Land Transport Rule: Dangerous Goods 2005.
Dangerous goods for transport are a subset of hazardous substances as defined in the HSNO, for explosive, flammable, oxidiser, toxic, corrosive and ecotoxic properties (as mentioned above). In addition, dangerous goods for transport include other materials such as, radioactive material and infectious substances and other hazardous material that are not regulated by HSNO.
Some common examples of this are:
Drinks with high alcohol content are not considered hazardous substances, as they are regulated by the Food Act 2014, but are considered dangerous goods for transport due to its flammability:
UN 3065, Class 3, ALCOHOLIC BEVERAGES, with more than 70% alcohol by volume or ALCOHOLIC BEVERAGES, with more than 24% but not more than 70% alcohol by volume.
Lithium batteries are not classified as hazardous substances under the HSNO. While batteries may contain hazardous substances, they are designed and manufactured with a specific purpose and do not involve the intentional release of those substances during their normal operation. However, they pose significant hazards during transport due to their potential for fire, explosion, and the release of hazardous materials, therefore, they are considered dangerous goods for transport, e.g.:
UN 2794, Class 8, BATTERIES, WET, FILELD WITH ACID
UN 3090, Class 9, LITHIUM METAL BATTERIES (including lithium alloy batteries)
Asbestos, excluded from the HSNO hazardous substance definition, but with its own regulations (Health and Safety at Work (Asbestos) regulations 2016)
UN 2590, Class 9, ASBESTOS, CHRYSOTILE
UN 2212, Class 9, ASBESTOS, AMPHIBOLE
Note that under the transport classification, class 9 can be environmental hazard OR miscellaneous dangerous goods.
Also, dangerous goods can include substances that, on normal conditions, do not represent a health risk, e.g.:
Carbon dioxide (CO2), abundantly present in the air we breathe, but when stored and transported in cylinders (compressed gas) can be hazardous due to its potential to displace oxygen and cause asphyxiation, especially in confined spaces, therefore is classified as a dangerous good (UN 1013, Class 2, Division 2.2).