JUST OFF the printer is the SA Revenue Service (Sars) external policy on the administration of consignments classified as dangerous goods (DG) in terms of the SA National Standards and the National Road Traffic (RT) Act – but there is some industry doubt about the tax authority's involvement in the issue. According to information released to FTW by trade and customs consultants Deloitte, the Sars publication laid down the six conditions for the transport of dangerous goods and substances. “This is a confirmation by Sars of already existing legislation,” said Eddie Crane, CEO of dangerous goods legislation consultants, EC Logistics. “All the conditions published fall under Section 8 of the RT Act.” Indeed, looking at the airfreight side of things, Johannes Cilliers, operations training manager of TNT Express, questioned what the policy was aimed at. “I’m not sure what Sars involvement with the import and export of dangerous goods is all about,” he told FTW. “I can only speculate that it needs the information to ensure that it collects the necessary VAT and duties. “Anyway, dangerous goods have to be lodged at the airlines on their own master air waybill (MAWB).” In air transport, the conditions for importers or exporters of dangerous goods are clearly defined. “Legislation lies with the International Air Transport Association (Iata) and is enforced by the local Civil Aviation Authority (CAA).” But these conditions, which are repeated in the Sars publication, are applicable to all the modes of import/ export transport – road, rail, air and sea. “Experience in all the modes shows that dangerous goods can be transported safely provided these principles are strictly followed,” said Cilliers. An importer or exporter of dangerous goods (DG) must comply with the following: • Identification and classification of dangerous goods and substances: “Basically means that the shipper must identify that they are shipping DG, and what type of DG.” • They must classify them into one of the nine classes laid down. “These relate to the type of hazard of the dangerous goods.” • Placarding and labelling: “These are the markings that appear on the outside of the package indicating that the contents are DG and also indicate the type – i.e. corrosive material, gases etc.” • Packaging and storage requirements: “Depending on the type of DG, the packaging has to comply with UN specification packaging.” • Storage of DG: “Packages which might react dangerously with each other must not be stowed next to each other or in a position that would allow interaction between them in the event of leakage. Segregation requirements are shown in table 9.3.A in the latest version of the DG manual. These storage requirements are also applicable to DG shipments in transit within the warehouse.” • Dangerous goods product compatibility and compatibility chart: “As per storage explanation above.” • Emergency response information: “This is basically the contact details of relevant emergency services in case of leakage and/or accidents of the DG shipment.”
Sars lays down conditions for transport of dangerous goods
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