ADN Safety Committee Urged to Reassess CMR Hazard Rules for Inland Waterway Transport

The request follows earlier discussions at the 46th session, where the Committee rejected exposure route as a criterion for classification, suggesting instead that a broader policy-level dialogue was needed across all transport modes. FuelsEurope, representing major European fuel producers, acknowledges this complexity but maintains that a targeted discussion within ADN remains both feasible and essential.

Calls for Practical Exposure Assessments Using Recognised Tools

FuelsEurope’s proposal centres on the Advanced REACH Tool (ART V.1.5), a widely accepted industry model developed with support from institutions such as TNO and Germany’s Federal Institute for Occupational Safety and Health (BAuA). The tool calculates the Risk Characterisation Ratio (RCR) for specific industrial tasks, comparing estimated exposure to acceptable limits.

In one example, the process of coupling or decoupling loading arms and hoses—coded as PROC8b in ECHA guidance—is assessed for a substance soon to be classified as H360fd (Toxic for Reproduction, Category 1B). The RCR value was found to be less than one, indicating an acceptable risk level and suggesting that mandatory vapour recovery systems may not be required for such tasks.

Relevance Beyond Fuel Operators

While originating from the fuel sector, the implications of FuelsEurope’s proposal could extend across the chemicals value chain. Current ADN rules focus on the intrinsic hazard (CMR classification) of substances, without factoring in real-world exposure risks. This disconnect, FuelsEurope argues, could lead to overly conservative transport requirements that impose unnecessary costs and technical burdens without measurable safety benefits.

If adopted, exposure-based considerations could affect not just manufacturers but also logistics providers, port operators, and regulators who must interpret and enforce ADN requirements.

Alignment with Sustainable Development Goals

FuelsEurope also links its proposal to the UN Sustainable Development Goals (SDGs), citing SDG 3 on good health and well-being, and SDG 11.2 on sustainable transport systems. By promoting evidence-based risk management, the industry group argues, ADN can better support safe, efficient, and proportionate chemical transport.