Provisional Translation
| OTO No. | 491 | Classification | MHA-14 |
|---|---|---|---|
| Date of Acceptance | December 11, 1992 | Ministry/Agency Receiving Complaint | Economic Planning Agency |
| Responsible Ministries | Ministry of Home Affairs | Related Laws | Fire Service Law |
| Complainant | Domestic firm | Exporting Countries | Germany |
| Subject | Clarification of reason for regulations concerning containers for overland transport of liquid chemicals (alkyl lithium) and relaxation of regulations | ||
| Details of Measures | Description of Complaint: 1. The Fire Service Law does not allow overland transport of chemicals in liquid form in containers with a capacity of 250-450 liters, and containers which can be used for maritime transport or in other countries cannot be used for overland transport as is when unloaded from ports. 2. The complainant wishes to have the rationale for the Fire Services Law regulations clarified and to have regulations relaxed to allow transport in 450 liter containers. The ministry replied as follows: 1. The 450 liter (400 kg) limit set by the International Maritime Dangerous Goods (IMDG Code) is the general maximum capacity for the container. This maximum capacity is limited according to the type of substance contained. For alkyl lithium, the allowable maximum capacity when stored in metal drums is 125 kg. However, if the relevant authorities of the said country give approval, this limit may be exceeded. 2. Under the Fire Services Law, the maximum capacity for overland transport of liquid hazardous substances in metal drums is 250 liters, but the maximum capacity for alkyl lithium is 110 liters (equivalent to 125 kg), which is compatible with the IMDG Code. This limit was set to ensure safety during overland transport in light of the dangers posed by alkyl lithium. 3. Regarding the overland transport of containers of alkyl lithium that exceed 110 liters, a detailed study on the safety of these containers is being carried out. A decision on the feasibility of using these containers will be made based on the findings of the study. Based on the chairman's summary at the 9th Grievance Processing Committee, the ministry undertook a study of conditions in Germany, the U.K. and the United States, and the ministerial ordinances and notices concerning regulations on hazardous materials were amended March 30, 1999, raising the maximum capacity of containers for alkyl lithium to 450 liters. As a result of this change, it is now possible to use these containers for overland transport (implemented April 1, 1999). |
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| Classification of Processing | A | Directions | I-a I-b |
| Remarks | Improvement measures were taken on April 1, 1999. | ||