Special provision 188, exemptions in containerised transport

This document explains a significant safety gap in containerised transport of batteries, wherein multiple exempt batteries, each of which is individually exempt under special provision (SP) 188, are loaded within the same cargo transport unit (CTU). Due to the lack of hazard communication under SP 188, these shipments are treated as general cargo during transport despite the elevated hazard profile within the CTU. This safety gap has led to safety and fire incidents in transport, a typical example of which is shown in a formal investigation report cited within this document. The existing gap poses wider implications for the safety of transport, risk to life and environmental pollution. The current document presents an initial proposal for bridging this safety gap, and invites the Sub-Committee to consider this issue as a matter of urgency and take action as appropriate.

Read the full WSC submission here.