All those who are involved with the transportation and handling of hazardous products are expected to be aware of all the applicable statutory requirements.
As far as HOCL products are concerned, the following statutes are important.
Central Motor Vehicle Rules 1993
The above descriptions are only brief and the customer and transporter shall go through the statutory requirements in detail and understand their responsibilities.
Petroleum Act 1934
A.Which of the goods produced by HOCL come under the classification “Petroleum” under the Petroleum Act ?
(i) Cumene (ii) Phenol (iii) Acetone
B.What is Petroleum under the Petroleum Act ?
Under the Petroleum act “Petroleum” means any liquid hydrocarbon or mixture of hydrocarbons and any inflammable mixture (liquid, viscous or solid) containing any liquid hydrocarbons.
C. How are goods classified under the Petroleum Act ?
There are 3 classes of petroleum as under –
i)Petroleum Class ‘A’ - means petroleum having a flash point below 23 Deg C . Acetone (with flash point (–) 20 deg C) comes under Class A.
ii)Petroleum Class ‘B’ - means petroleum having a flash point of 23 deg C. and above but below 65 deg C. Cumene (with flash point 46 deg C) comes under Class B.
iii)Petroleum Class ‘C’ - means petroleum having a flash point of 65 deg C and above but below 93 deg C. Phenol (with flash point 85 deg C) comes under Class C.
D.What is flash point ?
“ Flash point” of any petroleum means the lowest temperature at which it yields a vapour which will give a momentary flash when ignited, determined in accordance with the provisions of chapter 2 of the Petroleum Act.
E. Is a license required always for the transport or storage of petroleum ?
A license is required for the transport or storage of petroleum except in the following cases :-
i)Petroleum Class ‘B’ (Non Bulk) in quantity not exceeding 2500 ltrs. and in receptacle not exceeding 1000 ltrs.
ii) Petroleum Class ‘C’ (In Bulk) in quantity not exceeding 45,000 ltr.
F. Differentiate between Non-bulk and Bulk storage according to Petroleum Act ?
iii)a) ‘Non-bulk storage’ means storage of petroleum in receptacle /container/tank of water capacity not exceeding 1,000 ltrs.
iv)‘Bulk storage’ means storage of petroleum in container/tank of capacity exceeding 1,000 ltr
v)Which are the products manufactured by HOCL that requires license for transport ?
G. Transportation of HOCL is both in Bulk and Non-Bulk forms.
Acetone being a Class A petroleum product, it needs a license for transport.
Cumene being a Class B petroleum product it needs a license for transport.
Phenol being Class C, it does not require a license for transport in loads of Net weight below 45 MT.
Public Liability Insurance Act 1991
During transportation, the products of HOCL are under the custody of the transporter. As per the Public Liability Insurance Act 1991, the transporter shall be responsible for public liability during transportation. If an accident results in spillage of Phenol, it may have dangerous consequences and may cause loss to public. If the transporter does not have public liability insurance, since the sales in on exfactory basis, customer shall be the next responsible party. To protect the customers interest, HOCL ensures that the transporter has public liability insurance.
However, this is not a legal responsibility of HOCL. Whoever has control over the hazardous material at the time of accident is the ‘owner’ as per Public Liability Act and the owner is expected to take the insurance as per the law. It is important that the public liability insurance policy clearly mentions that the hazardous product (Phenol, Acetone, Hydrogen peroxide as applicable) is covered under the policy. Customers may insist that the Public liability policy of the transporter engaged by them is always valid and covers the hazards applicable in the transportation. Customers may continuously ensure that the transporter engaged by them has always a valid public liability insurance covering all the risks applicable in transportation. Otherwise customers shall be liable to bear the expenses by law in case of any public liability due to accident of the transport vehicle carrying their product..
Hindustan Organic Chemicals LimitedOffice No. 1003-1004, 10th Floor,
Post Bag: No: 18,
Ambalamugal P. O.,
Kerala - 682 302, India
PH : 91 484 2720911– 13, 2720844 – 45
E-mail : firstname.lastname@example.org