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Letters to the editor
One of the great strengths of HCB’s reporting is its attention to detail. It is with regret, therefore, that I must point out a serious factual error in your October report of the recent VCA Update Seminar (‘The gang’s all here’).
You mention the presentation on security issues given by Martin Castle, adding the soubriquet “recently retired from VCA”.
May I point out that Mr Castle has not retired from VCA but has merely moved to part-time working for VCA. He continues to provide valuable support to the UK Department for Transport. All talk of ‘retirement’ by Mr Castle is premature – I know this to be true as there has been no retirement party as yet.
Head, Dangerous Goods Division
UK Dept for Transport
It is now six years since I “fell on my pen” and ceased to work in the world of dangerous goods. I have kept my eye on events, spoken with old colleagues and failed to write my memoirs. I have followed my other interests and gained additional family duties that have made me wonder how on earth I ever had the time to work! But I do enjoy reading HCB and the September Issue and your editorial did give me pause for thought.
When I left work within the UK civil service, Tony Blair was still Prime Minister, George W Bush was in the White House and the Euro was top of the currencies. In fact everything in the garden looked fine and the UK had “abolished boom and bust”. By 2007 things were looking somewhat different and now they look completely and utterly different.
What I find interesting is the world of dangerous goods. The UN umbrella continues to preside over two-year reviews of the dangerous goods regulations for road, rail, sea, inland waterways and air. These revisions then need to be accommodated into the various modal rules and to be quite frank I see no sign of the constant changes stopping or even slowing down. In Europe, the EU as your article Effective Directives shows, refuses to give up its role of re-considering the international scene.
In the UK, the Government wants the size of the civil service cut. The UK financial deficit has to be reduced and the “reductions” in the UK transport budget and civil servants will be either 20%, 30% or 40%. But, if this is to happen how will the various parts of the international rule changes be incorporated into national legislation? The EU bureaucracy seems to be acting in a strange world that faces no cuts. Is it not the time for a sane government to suggest in the international various forums that there is not a requirement or need to review, refine, tinker and play around with what is a good system other than a lack of modal harmony? Would the world of dangerous goods transport be less safe with changes every four years? Such a time-scale would reflect the current economic reality and allow the “poor old infantry” – the users - to get a grip on the situation without having to face a rethink, retrain, reassessment etc every two years.
Why is this not happening? I will be cynical and suggest that the “national and international experts” enjoy their endless meetings in Geneva, London, Brussels and their other meetings some in more exotic locations. The training organisations see an ongoing need for training in order to take account of the changes. The nongovernmental experts seem to have no wish to see any change in the system as they prize their great expertise and understanding and they too are stakeholders in the continuation of constant round of change. With respect, even HCB thrives on the changes as the reports of the changes fill its pages. As a famous saint may have once said – “Lord save me from sin; but not in my lifetime!”
The West drives the various forums. I am quite sure that the emerging economies, although willing to attend and pay lip service to the endless rule changes, know that their chances of economic growth will best be achieved by letting the West get on with it all. They know that the manufacturing task will come their way as the West is priced out of business by endless new rules, be they safety or the modern great gods of security and environmental protection.
I have little doubt that unless the European governments wake up and cease the endless round of change and tinkering, the bulk of the manufacturing base will have fled to China and other emerging economic powers. Directives such as REACH will not matter a single jot as there will be no chemical industry in Europe to micro-manage.
Look at other industries - shipbuilding has long gone east, car production is going and the Airbus Group now seems willing to start manufacture of their more profitable aircraft in China and India. Unemployment in the UK is rising as it is in Spain, Germany and France. Once again the Irish are migrating. Do the European governments think that they can have full employment on the basis of us all opening doors for each other? Spain and Portugal have not yet succeeded in achieving that aim even with a large tourist sector. The idea seems more and more unlikely to me. To staff its National Health Service the UK has “robbed” the third world of its doctors, nurses and care workers; the constant rise in the numbers employed in health care have not reduced the numbers of unemployed in the UK.
If I am a lone voice then so be it, but I long to see a conference report in HCB reporting that both governmental and national experts think that there is no need for a bi-annual review of dangerous goods safety legislation. I do not expect to see this but I would just ask the last person in the chemical manufacturing sector to please turn out the light when the factory closes.
A J Slatter
IBCs - a clarification
In a prior issue of Hazardous Cargo Bulletin, we published remarks from an IBC manufacturer that could have been interpreted as unfairly characterising IBCs imported from China. That was not our intention. Indeed, there are IBCs imported from China and used throughout the industry that are manufactured from high quality materials in accordance with strict UN/DOT specifications. We have every reason to believe that these IBCs are 100% safe and effective for their intended uses.