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Feature reprint from SampleRite Challenging Illegal Chemical Sampling

SAMPLERITE

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SampleRite UK is a specialist inproviding a global sample

management service to the chemicalsindustry. The company has beenpreparing and dispatching bothhazardous and non-hazardoussamples from a site at Elland, UK,since 1994. It recently set up a facilityat Qingdao in Shandong province,China. Based on its work in both the UK

and China, SampleRite hasdiscovered that, whilst on the face of itregulations concerning air freight (theInternational Air Transport Association(IATA) Dangerous Goods Regulations)and sea freight (the InternationalMaritime Dangerous Goods (IMDG)Code) are being adhered to by manychemicals companies shippinghazardous chemical productworldwide, the perception is far fromthe reality.Small samples of hazardous

chemicals are knowingly beingdispatched by many Asian chemicalcompanies, re-labelled and packed asnon-hazardous in order to avoid theadditional costs incurred by correctpackaging, training and paperwork,as required to comply with the IATAand IMDG regulations. Health andsafety regulations are knowinglybeing flouted to save money and theconsequences could be fatal.These practices are putting many

personnel within the supply chain –and sometimes the general public - atrisk. Anyone opening a package that

they believe contains non-hazardouschemicals could be exposed todangerous liquids, powders or fumes.Workers are unlikely to have takenadequate precautions or to bewearing the correct personalprotective equipment in such cases. The problem is getting worse with

the shift in chemical manufacturingfrom its traditional base in Europe tosites in Asia, particularly China. Today,many of the world’s major chemicalscompanies source from China, haveoperations in the region or outsourceproduction to Chinesemanufacturers so that theycan compete in anincreasingly price-sensitiveand commoditised market. This means that more and

more samples are now beingsent overseas in order to drivesales. Unfortunately, too manysamples dispatched out ofChina are being shippedunder false pretences. To say this, incidentally, is

not to blacken China’s name.On the contrary, the problemis far more acute in Chinaitself and, as usual with thesescandals, the vast majority ofthe victims are Chinese.Consider, for example, one

poor man in China who diedin November 2013 as a resultof a leak in transit of methylfluoroacetate, a commonlyused pharmaceutical

intermediate which can causeconvulsions or respiratory problems ifinhaled or ingested incorrectly. Hewas not in any way involved in thechemical supply chain; he hadordered some shoes for his daughteronline and that package came intocontact with the leak. The productionmanager at the firm in Hubei that sentthe chemical out was later arrested.Anecdotally, at least, it appears that

such incidents are not uncommon.Many cases of chemical poisoninghave been reported by Chinese

Bruce Percy, managing director of SampleRite UK, looks atthe dangers and possible repercussions of the mis-declaration of hazardous samples

Turning a blind eye to illegalchemical sampling

Percy – Chemical companies must takeresponsibility themselves

WHERE TO BUY CHEMICALS Directory 2015 www.w2bchemicals.com 3

express delivery firms who do nothave a licence to deliver or transportchemicals. So why is this happening?It is largely the unintendedconsequence of a booming market,where vast numbers of firms tradesmall amounts of chemicals, comingup against stricter regulation andbureaucracy.In 2011, China began to implement

new basic rules on chemicals. These,ironically, had just come into place bythe time of the aforementioned fatalincident. They stipulate that allcompanies transporting hazardouschemicals must use appropriatevehicles, train workers adequatelyand keep hazardous and non-hazardous goods apart in transportand in depots. Every link in the chain is subject to

licensing and all chemical productsmust have an identification certificatebefore being accepted by airlines, inconjunction with the standardhazardous paperwork. Certificatesare issued for each individual product

by testing bodies, such as DGM or theShanghai Research Institute, toconfirm its identity. One effect of all this is to make the

added cost shipping of hazardouschemicals even more expensive,relative to non-hazardous ones, thanbefore. At the same time, however,only major chemicals companies andtransportation companies, many ofwhich are still state-owned, areallowed to deliver chemicals. In the main, these companies think

in tonnes when quoting prices and arenot interested in delivering gramquantities – or, if they do, they chargevery high prices and/or have very longlead times. The government remainsreluctant to open this market up toprivate firms.The net result of all this is that many

chemists and lab scientists deliversamples themselves, if the distance isdrivable. Where it is not, they usuallyresort to using regular courier firms,who are not licensed or equipped tohandle hazardous chemicals.

In some cases, companies haveobtained a certificate for a non-hazardous product and use this toship the hazardous product - on theface of it legally and at a considerablecost saving. Competition in this field iscut-throat, with extremely low margins,making courier firms reluctant to turnany order down, even in the unlikelyevent that they are able to know whatthe consignment actually contains.The problem inevitably extends

internationally and could threaten thelives of airline passengers and groundpersonnel. In 2007, for instance, 11ground personnel at Taiwan Taoyuaninternational airport in Taipei wereinjured and two hospitalised as aresult of leakage from an undeclaredClass 8 DG corrosive on a flight fromHong Kong. This was part of aconsignment from Shanghai that wasclaimed to be general and which wasaccompanied by a laboratorycertificate and a Safety Data Sheet.(Not, incidentally, that the problem

is unique to China. Back in 1998, an

SampleRite processes thousands of chemicals in packages of all shapes and sizes

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SAMPLERITE

American Airlines flight from Dallas-Fort Worth to Nashville experiencedan outbreak of fire in the cargocompartment because of “undeclaredand improperly packaged hazardousmaterials” in a fibre drum, includinghydrogen peroxide and sodiumorthosilicate-based material. Otherincidents have involved chemicaloxygen generators, nitric acid andflammable liquids in lab machines.)SampleRite knows that practices

like these are widespread because wehave received supplies of clients’products that are incorrectly labelledand packaged, which have beensourced and manufactured in China.We get situations relatively frequentlywhere the outer box indicates oneproduct (non-hazardous) but withinthe box the product and paperworkare completely different (hazardous).This effectively means the actualpackaging type (bottle and box) mayalso be illegal. If a delivery has not been labelled

or packaged properly, we immediatelycontact our clients to make them

aware of the situation. Our clients areusually taken aback by therevelations. The question here is, doEuropean companies want to dealwith and source material fromChinese companies who blatantlybreak the law?The issue is creating enormous

confusion and compromising safety,so it is important to flag it up. The factthat sample management is not acore function for most chemicalmanufacturers and distributors isclearly exacerbating the problem. Allproducts have to be sent away forcertification before being decanted incontrolled conditions, packagedcorrectly, labelled in line with currentlegislation and shipped via approvedtransport companies. All this takestime and money.Given the costs involved, when

companies try to do this themselves,many cut corners to save on shippingfees. The difference between sendinghazardous samples legally andillegally between China and, say,mainland Europe can be as much as

500%. Unfortunately there is no wayround the financial implications unlesslaws are broken. Our industry should stop turning a

blind eye to these dubious practices.Many companies know that thesepractises occur, but too little is beingdone to prevent it. It is not the couriers,freight forwarders or airlines who areat fault, it is the chemical companiesthemselves who should demand thatbest practices are followed at alltimes, as should the customer whoreceives the sample. If a European chemicals company

has outsourced its manufacturing toChina, it needs to ensure that thesamples dispatched in its name aresent legally. If an incident occursbecause labelling has been falsifiedor if a sample is stopped at customsduring a routine check-up, themanufacturer or distributor concernedcould face prosecution and severefinancial penalties (see box storyopposite). The European chemical company

that asked this manufacturer or

Sampling is a complex, multi-stageprocess

Key regulationsThe IMDG Code was developed as auniform international code for thetransport of dangerous goods by seacovering such matters as packing,container traffic and stowage, withparticular reference to thesegregation of incompatiblesubstances.You need to complete a

dangerous goods notification(www.gov.uk/government/publications/dangerous-goods-declaration-noteis the standard one in the UK) for anydangerous goods you want to sendby sea. You can be fined for breakingthe regulations on transportingdangerous goods. You can beprosecuted and face a large fine anda prison sentence for seriousbreaches, for example transportinganimal by-products in an unsafe way. The internationally agreed rules

for transporting dangerous goods byair are covered by IATA’sInternational Dangerous GoodsRegulations (www.iata.org/publications/dgr/ pages/index.aspx).

You can be given an unlimited fine orsentenced to two years in prison orboth if your cargo fails an inspectionor causes a safety incident in the UK.Anyone packing dangerous

goods for air transport must bespecially trained (see, for examplewww.caa.co.uk/ default.aspx?catid=1464&pagetype= 90&pageid=8298).You and your staff must havedangerous goods training if you areusing your own aircraft to transportthe goods. For the UK, Civil AviationAuthority-approved dangerousgoods training organisations isavailable on the web (www.caa.co.uksee ‘Dangerous Goods’ sub-sectionof ‘Operations & Safety’ section).The internationally agreed rules

for transporting dangerous goods byroad are covered by the EuropeanAgreement concerning theInternational Carriage of DangerousGoods by Road, or ADR of 2103(www.unece.org/trans/danger/publi/adr/adr2013/13ContentsE.html). There isa range of fixed penalty fines if yourcargo fails a spot check.

WHERE TO BUY CHEMICALS Directory 2015 www.w2bchemicals.com 5

Case studiesOn 17 August 2012, at Isleworth CrownCourt, Angel Case & Packing pleadedguilty to ‘Causing to be delivered forloading onto an aircraft dangerousgoods which it knew or ought to haveknown or suspected to be goodscapable of posing a significant risk tohealth, safety or property when carriedby air, when the packaging did notcomply with the technical instructionsand the packing was not in a fitcondition for carriage by air’ underRegulation 5(1) of the UK’s AirNavigation (Dangerous Goods)Regulations of 2002. It was fined£25,000.The defendant, a specialist packing

company, had collected 51 chemicaloxygen generators from an aircraftspares company in August 2011, whichwere to be transported on a cargoflight to Italy. It packed them in threeboxes and handed them over to afreight forwarding company. Here, adangerous goods specialist wasconcerned about the consignment,although it was appropriately markedand labelled. When the consignment was opened

and inspected it was found that: (a) theUN certificate for the boxes hadexpired more than ten years previouslyand was not valid for chemical oxygengenerators in any event; (b) each boxhad one loose generator on top,contrary to the requirement for tightpacking; (c) polystyrene chips hadbeen used as packing material when

they should not have been and thechips had penetrated the chemicaloxygen generator box vent holes; and,(d) a document pouch had beenplaced inside one of the boxes whichshould not have been. In another case heard at

Chelmsford Magistrates Court on 12June 2012, Atom Scientific pleadedguilty to five offences under differentparts of the Air Navigation (DangerousGoods) Regulations and was fined£1,000 for each of them:

1. Causing to be delivered for carriagein an aircraft dangerous goodswhich it knew, or ought to haveknown or suspected to be, goodscapable of posing a risk to health,safety, property or the environmentwhen carried by air when thetechnical instructions had not beencomplied with (Regulation 5(1))

2. Consigning dangerous goods forcarriage by air without ensuring thatthe goods were packed accordingto the technical instructions(Regulation 11(d))

3. Consigning dangerous goods forcarriage by air without ensuring thatthe package in which they werecontained was marked and labelledas specified in the technicalinstructions (Regulation 11(e))

4. Consigning dangerous goods forcarriage by air without ensuring thatthe operator of the aircraft had beenfurnished with the dangerous goodstransport document (Regulation 11(i))

5. Not ensuring that all personsinvolved in the preparation ofdangerous goods had receivedspecified training (Regulation 13(1))

This case related to two cylindricalpackages that arrived at the FedExpremises at London Stansted airporton 5 May 2011, shipped by AtomScientific and to be loaded on a cargoaircraft flight to Paris Charles deGaulle. The contents of theconsignment were recorded on the airwaybill as ‘Distilled Water’. One of the cylinders was found to

be leaking its contents as it was beingloaded onto a conveyor belt. Thebottom of the cylinder haddisintegrated. Seven FedExemployees experienced tingling andburning sensations to their skin andtheir skin turned white. The burnswere treated on site with salinesolution and burn gel. Atom Scientific later informed FedEx

that the contents were hydrogenperoxide. Hydrogen peroxide solutionsact as oxidising agents and arecorrosive. Hydrogen peroxide is not

flammable but can cause spontaneouscombustion of flammable materials(i.e. if it comes into sustained contactwith cotton, wool, wood, paper, textiles,dirt, oil or dust it can cause a fire). Itcan evaporate and the concentratedmaterial can react violently with manychemicals, either explosively orcausing a fire.

distributor to dispatch samples on itsbehalf could suffer irreparabledamage to its reputation in the market.Clearly, then, companies involved withthe transport of chemicals need to beaware of the various internationaltransportation regulations and thespecific training that employees arerequired to take (see box story opposite). To send any hazardous sample

overseas requires that the product isfirst identified with a four-digit UNnumber. Over 3,000 UN numbers arelisted and published as part of theRecommendations on the Transport ofDangerous Goods, which is alsoknown as the Orange Book.IATA’s Dangerous Goods

regulations are constantly changing

and that impacts how samples mustbe classified and packaged.Companies and individuals that fail tocomply fully with the current rules aresubject to severe and unprecedentedenforcement actions. It is now morecritical than ever that anyone involvedin shipping samples is fully trainedand up-to-speed on the latest laws andstandards.So chemical companies that

regularly send out hazardous samplesfrom China by overseas carriage havethree options if they are to ensure allsamples are dispatched with thecorrect paperwork.Firstly, they could set up and train a

team in-house to handle samplerequests, which is costly and time-

consuming. Secondly, they can enlistthe help of one of the major couriercompanies to complete the relevantpaperwork on their behalf, which istypically very expensive. Or they couldlook to outsource the process to acompany that offers a dedicatedsample management service, which isoften the most cost-effective option.Providing samples is an involved

process. The chemicals have to bestored correctly prior to decanting,technicians must be trained to handlethese substances safely; the right typeof packaging must be used dependingon the sample; an up-to-date healthand safety data sheet must beincluded; all labelling must meet thelegal requirements; and finally,

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SAMPLERITE

accompanying paperwork must befilled in correctly by trained personnelbefore the courier company will agreeto deliver the package.For many companies it is simpler

and more cost-effective to outsourcethe process rather than invest in therecruitment and training of staff, not tomention temperature-controlledstorage areas, cleanrooms andlaboratory facilities for handling thechemicals and extra space to keep asupply of packaging materials. Onmany levels an outsourced samplemanagement service can be muchmore efficient than handling it in-house.

SampleRite has a web-basedpassword protected 24/7 orderingfacility that allows clients to log samplerequests from their customers. Subjectto stock availability it can then sendsamples out within 24 or 48 hours. Atthe end of each month managementreports are prepared so our clientscan see exactly where their producthas been sent.SampleRite currently dispatches

over 50,000 samples each year onbehalf of its clients, who benefit fromthe high volume discounts on freightcosts that the company has negotiatedwith the major courier companies. Thecompany can handle a variety of

hazardous and non-hazardouschemicals, including dyes, corrosive,toxic and flammable products, foodand pharmaceutical grade. Thisallows clients to focus on their coremanufacturing and distributionactivities.

Contact:Bruce Percy Managing Director SampleRite UK Ltd.Tel:+44 1422 327369 E: bpercy@samplerite.com Web: www.samplerite.com

6 www.w2bchemicals.com WHERE TO BUY CHEMICALS Directory 2015

Sampling at SampleRite’s UK laboratories