The Health & Safety Authority is seeking industry consultation on the requirement to extend the provisions of M256 for the transport of Ammonia Solution , UN2672, in IBCs.
ADR 4.1.1.10 states that IBCs intended for the carriage of liquids shall not be used to carry liquids having a vapour pressure of more than 110KPa (1.1bar) at 50°C or 130KPa (1.3 bar) at 55°C. Ammonia solutions at a concentration of greater than 19% have vapour pressures exceeding the ADR limits, and thus cannot be carried in IBCs without a derogation.
M256 was drawn up by the Department for Transport in the UK in January 2013 and, following consultation with the Irish pharmaceutical industry and the chemical distribution industry, it was determined by the Authority that there was a need for this derogation in Ireland, and Ireland thus countersigned the agreement.
M256 is due to expire on 01 Feb 2018.
If it is determined that the pharmaceutical and chemical distribution sectors in Ireland require the continued use of rigid and composite IBCs for the carriage of Ammonia Solution (UN 2672) at concentrations of up to 35%, it will provide justification for an application to the UN Economic Commission for Europe to initiate a new MLA which will be valid for three years, until January 2021.*
*Please note that in the UK new packaging (a new metal IBC), which will be capable of withstanding vapour pressures of 550 kPa, is at an advanced stage of development, having already undergone in house testing and is currently undergoing testing at an approved test facility in the UK. This package testing is the second step in multi-step process of progressing the task of ensuring the continued capability of the pharmaceutical and chemical industries to carry ammonia solutions in concentrations ranging from 19 to 35%.
The Health and Safety Authority thus requests that relevant parties consider the needs of their business or that they consult with their stakeholders, as appropriate, and confirm in writing to the Authority if there is a continuing need to transport ammonia solutions under the terms of M256, thus in concentrations of ammonia of up to but not more than 35%. We would also welcome justification for this need if possible.
Interested parties should respond by Monday, 18th December 2017.
