24 Spray February 2015 Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation Transport of Dangerous Goods into and within Mexico There are many opportunities to export aerosols and other dangerous goods to Mexico, but it requires an understanding of the regulatory mandates for the storage, handling and transport of dangerous goods into and within Mexico. Standards The Mexican Secretaría de Comunicaciones y Transportes or Secretariat for Communications & Transport (SCT), roughly equivalent to the U.S. Dept. of Transportation (DOT) or Canada’s Transport Canada, is responsible for publishing and maintaining the Mexican Standards or Normas Oficiales Mexicanas (NOMs), which supplement the Reglamento para el Transporte Terrestre de Materiales y Residuos Peligrosos (Mexican Regulation for the Land Transport of Hazardous Materials & Wastes). In addition, there are other Mexican government agencies that have published standards relevant to the storage, handling and transport of chemicals and dangerous goods including Secretaría del Trabajo y Previsión Social (Secretariat of Labor & Social Welfare—the equivalent of U.S. Occupational Safety & Health Administration OSHA and Health Canada) and Procuraduría Federal de Protección al Ambiente (Mexican Federal Environmental Protection Agency—the equivalent of U.S. Environmental Protection Agency EPA and Environment Canada). The SCT’s NOMs for the transport of dangerous goods are fairly consistent with those of older versions of the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations). Since the U.S. Hazardous Materials Regulations are periodically harmonized with the UN Model Regulations, the requirements of the HMR and of the Mexican NOMs are also fairly consistent. However, there are some significant differences with respect to classification and hazard communication. These differences are being addressed by the Land Transportation Standards Hazardous Materials Working Group and through amendments and restructuring of the UN Recommendations. As a general rule, the requirements of the Mexican NOMs are four to ten years behind the latest version of the UN Recommendations. It is important to note, however, that there have been a number of recent updates to specific sections of several NOMs that make some of the Mexican rules current with contemporary standards of the U.S. DOT’s Hazardous Materials Regulations (HMR) and Canada’s Transport of Dangerous Goods (TDG) Regulations. For example, the SCT recognizes and authorizes the use of the Limited Quantity hollow diamond with black points mark for dangerous goods documents on a bill of lading as “Cantidad Limitada” or Limited Quantity. SCT also recognizes and authorizes the basic description sequence (e.g., ID number, shipping name, hazard class and division, and packing group if it applies), which is consistent with the HMR and TDG. The most significant differences between the HMR/TDG and the SCT’s NOMs appear to be in the List of Dangerous Goods. The latest version of NOM-002- SCT (Listado de las Substancias y Materiales Peligrosos más Usualmente Transportados) was published in 2011 and does not include any items having a UN ID number greater than 3,495. In addition, a number of special provisions are not consistent between the two sets of rules and the current marine pollutant marking and excepted quantities markings are not included. Key standards are shown in the table on the next page.
Spray Feb 2015
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