The Tech's Files #9 - Flipping the switch - EVs and DGs

The heavy vehicle decarbonisation transition has sparked lots of questions. Some are simple, yet others are surprisingly complex. After some investigation, this one fell squarely into the latter category!

The question: Can a battery-electric truck be used to haul dangerous goods?

The answer depends on the interaction between two regulatory instruments that are presently being reviewed and will undergo formal changes in the coming years. So, while the question can be answered now, that answer is very likely to change soon.

The good news is the change is likely to deliver a clearer answer, which will be very positive for the dangerous goods (DG) sector and its decarbonisation efforts.

The author would like to acknowledge the contributions of Matt Arkell, Principal Policy Analyst at the National Transport Commission, and Anthony Germanchev, on behalf of the National Bulk Tanker Association. Much of the technical material discussed in this article was developed by Matt as part of the NTC’s project to re-draft the Australian Dangerous Goods (ADG) Code, which has been progressed throughout 2023 and 2024.

Defining Characteristics

The current edition of the ADG Code (Edition 7.9, 2024) explains that in a broad sense, DGs include goods and substances that are flammable, corrosive, explosive, toxic, oxidizing and water-reactive. They are hazardous products, substances and materials that can cause serious harm to people, property and the environment.

There are nine classes of dangerous goods that are currently covered by the ADG Code, which are presented below alongside some common examples.

Even though their contribution may not be obvious at first glance, Australia’s economy is heavily dependent on the movement of all types of DGs. Some fast facts from the NTC:

• The basic chemical and chemical product industry is Australia’s third-largest manufacturing industry by value added ($11.3 billion in FY23).
• In 2017-18, Australia imported $25.5 billion in chemical products, including basic organic chemical products, fertilisers, other petroleum and coal products.
• Australia is also the world’s largest exporter of liquefied natural gas (LNG), accounting for 20 per cent of global export trade. This means that the rules on which vehicles can transport DGs are of crucial importance. If we don’t get it right, a massive commodity sector could be left with limited access to decarbonisation opportunities.

According to the NBTA, a safe and sustainable DG supply chain is vital not only for protecting people and the environment but also for supporting the long-term viability of Australia’s economy and industries.

This is not just about updating regulations for new vehicle types; it’s about ensuring the sustainability of the DG supply chain in a way that builds trust and confidence into the safety of the system.

The Devil In The Detail

The answer lies in the regulations, and as always, the devil is in the detail. In this instance, the critical details are how the DGs themselves are contained for transport and what type of battery-electric drivetrain the vehicles use.

DGs can be contained and transported in a variety of different ways, including in drums, stillages, small and large tanks and containers, and packages. Why is this important? Because the current version of the ADG Code requires a tank vehicle (ie a vehicle/trailer fitted with a tank body) to comply with Part 1 of Australian Standard 2809 (AS 2809.1). And AS 2809.1 excludes vehicles that are not powered by an internal combustion engine.

Let’s unpack the AS 2809.1 definition. What is a vehicle that is not powered by an internal combustion engine? There are three basic types of heavy vehicles that could fall into that category, which are:

• ‘Dedicated’ battery-electric trucks (that feature no other motive power source);
• Hydrogen fuel cell trucks (that store the energy created by the fuel cell in a battery, that is used to power the electric motor); and
• Diesel-electric hybrids (that typically use a smaller battery and motor than both above types).

Because of the way that the ADG Code requires vehicles with tank bodies to comply with AS2809.1, this means that currently, the above three types of vehicles are excluded from hauling DGs, when those DGs are carried in a tank that is mounted to the body of the vehicle, or the body of a vehicle it tows.

These exclusions do not apply to DGs packed in other ways. So, any of the above vehicles could be used to transport DGs in drums, stillages, packages or any other types that are not a tank mounted to the body of the vehicle or trailer itself.

Surprised? That’s justified! It is a complex regulatory outcome that was not created intentionally. You might also recall having seen examples of battery-electric rigid trucks being used in local DG operations, and you’d be correct on that front as well.

In 2022, Exro Technologies (then SEA Electric) delivered an all-electric rigid tank truck capable of hauling 16,000 litres of jet fuel to Brisbane Airport. Why was this vehicle allowed, when others are prohibited by regulations? Another good question – because it doesn’t operate on public roads, and the requirements of the ADG Code don’t apply.

But the fact that it has been operating successfully for several years, in a highly safety-regulated environment, highlights that any potential safety issues or concerns can be readily mitigated.

The Future

The good news is that work undertaken by the NTC over the past two years aims to rectify this situation. Specifically, the provisions in the current version of its draft ADG code make the rules much clearer.

Going forward, the new draft ADG code proposes that the restrictions on vehicles not powered by internal combustion engines only applies to vehicles fitted with tank bodies that haul flammable liquids and flammable gases, rather than tank bodies containing any type of DG.

That change aligns the ADG code with the current equivalent international codes. The NTC is currently consulting on the new Code that will include these clearer requirements. The NTC’s current timeline proposes to formally publish the new Code in late 2025, with the new Code to come into use from October 1, 2026.

This is an issue that is subject to ongoing discussions internationally. So, in the coming years, it’s possible that the international codes may be revised again to remove that restriction entirely, meaning that vehicles not powered by internal combustion engines may be able to transport all DGs in tank bodies, including flammable liquids and gases, pending some additional safety requirements. If that occurs, the ADG code will again be revised to harmonise it with international regulations.

The NBTA notes that its members, particularly those in DG sector, have always been early adopters of technology, driven by their commitment to safety. Above all else, any advancements must be safe, and it is essential that the regulations support this. From its ongoing collaboration with the NTC and other regulatory bodies, the NBTA are confident that safety will remain the central focus.

Over the coming years and months, HVIA advises that anyone specifying vehicles for DG transport to carefully consult with their vehicle manufacturer and trailer body builder, to understand the requirements that apply to their specific commodity, container type, vehicle body type and vehicle propulsion technology.

Still hungry for more detail? A note on Class 1 explosives …

The explosives transport regulations tend to be quite a bit more cautious than for other dangerous goods. At present, Class 1 explosives (even when in packages) generally must only be transported in a vehicle using a compression ignition engine fuelled by a combustible liquid (that is, diesel). There are some exemptions for very small quantities and some lower risk explosives, but ‘diesel-only’ is a good rule of thumb in the world of explosives transport.

Again, this may change in the future, but the NTC expects that restriction to remain longer than the restrictions on tankers transporting flammable liquids.