[ID] => 9380
[post_author] => 34
[post_date] => 2018-04-03 09:12:57
[post_date_gmt] => 2018-04-03 08:12:57
[post_content] => The UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) held its 52nd session in Geneva from 27 November to 6 December 2017. Duane Pfund (US) chaired the meeting, with Claude Pfauvadel (France) as vice-chairman.
Experts from 24 countries took part in the session, with observers from three more, along with representatives of the EU, the Intergovernmental Organisation for International Carriage by Rail (OTIF), the Food and Agriculture Organisation (FAO), the International Civil Aviation Organisation (ICAO), the International Maritime Organisation (IMO), the World Health Organisation (WHO) and 24 non-governmental organisations.
This second session of the 2017/18 biennium was, as is often the case, faced with a lengthy agenda that included a lot of new proposals. The Sub-committee will aim to complete its discussions on this new material in time for agreement at the fourth session of the biennium and adoption by the parent Committee in December 2018. Those amendments will appear in the 21st revised edition of the UN Model Regulations on the transport of dangerous goods, which will be reflected in the modal regulations due to enter into force during 2021.
Given the work that will be necessary to meet that schedule, the Sub-committee was concerned that Olivier Kervella, secretary to the Sub-committee and the parent Committee, was to retire on 30 November. The chair, vice-chair and several delegations had appealed for his retirement to be postponed, in line with UN General Assembly resolution 70/244, but had received no response. Further, appointment of a head of section had been postponed pending the arrival of Yuwei Li as the new director of the Sustainable Transport Division in February 2018. A further post in the section, which has been filled with a temporary appointment, was also due to fall vacant in February.
As is the normal process, papers relating to explosives were remitted to a Working Group chaired by Ed de Jong (Netherlands), which met during the first week of the session.
The Sporting Arms and Ammunition Manufacturers’ Institute (SAAMI) contended that the disruption criteria in test series 6(d) are too subjective; it urged that these should be deleted. There was some support for the problem identified by SAAMI but not for its solution. However, the Working Group felt that a review of the disruption as well as other acceptance criteria would be worthwhile; in particular, a definition of ‘hazardous effects’ might be beneficial. SAAMI is likely to return with a revised proposal at the next session.
Germany returned to the topic of the stabilisation of nitrocellulose. The Sub-committee had already accepted the need for additional tests and the Working Group had identified that the 3(c) thermal stability test in the Manual of Tests and Criteria is not suitable for nitrocellulose and its mixtures. It urged the inclusion of the Bergman Junk test and the Methyl Violet Paper test in the Manual. An intersessional working group led by the European Chemical Industry Council (Cefic) had generally agreed with Germany’s proposals, although it offered some amendments. Cefic and Germany will work on a formal proposal for the next session.
Work is also progressing on the classification of industrial nitrocellulose and desensitised explosives in supply and use situations, according to Chapter 2.17 of the Globally Harmonised System (GHS) of classification and labelling of chemicals. Cefic and SAAMI will prepare a formal proposal for the next session.
The UK also returned to a long-running proposal: the expansion of the list of high-consequence dangerous goods to include Division 1.6 explosives. The argument is that, while explosives assigned to this Division present a lower hazard during transport, they remain a risk should they fall into the wrong hands. The proposal had previously received general agreement and on the basis of a formal proposal it was accepted that Division 1.6 explosives should be added to Table 1.4.1.
At the moment, the only UN entry in this Division is UN 0486 articles, explosive, extremely insensitive, 1.6N. However, the way the change has been made leaves if free for further entries to be covered by the requirement, should new entries be added in the future.
The UK had also been looking at the packing instructions for explosives and identified what it felt was an unintentional error. Packing instruction P130 is assigned to 35 entries and the UK paper suggested that LP101 should be assigned to all of them as well. The US agreed, noting that its domestic regulations already do so. Conversely, Canada felt that LP102 is a better match. There was no consensus so the UK said it would consider the comments made and may submit a new proposal.
The Working Group on Explosives is also looking at how GHS addresses the topic; this is an important issue, since GHS deals exclusively with intrinsic hazards, whereas the Model Regulations recognise the hazard mitigation measures effected by means of specific packaging, particularly in Class 1. Sweden updated the Working Group on the outcome of an informal correspondence group, which had drawn up two alternative schemes for classifying explosives under GHS; the Sub-committee felt it would be appropriate for the TDG and GHS Sub-committees to take a closer look during their joint meeting in July 2018.
Germany had investigated the various fire test standards and confirmed that ISO 14451-2 represents an improvement on ISO 12097-3. A formal proposal will be made at the next session.
SAAMI had offered at the previous session a means of transporting small samples of explosives (25 grams or less) shipped under UN 0190. That proposal had been received favourably and it now returned with a formal paper illustrating how the topic is addressed, via a special permit, in the US. It suggested adoption of two new UN numbers, one for solids and one for liquids, a specification for the containers to be used, and a special provision. The Working Group offered some suggestions and alternatives and SAAMI promised to return with a formal proposal at the next session.
An informal document from Cefic addressed the transport of energetic samples for further testing, although it seemed to test the understanding of the experts. Comments were made as to how the proposal could be improved and Cefic will offer a revised version for intersessional discussion.
An informal paper from the Institute of Makers of Explosives (IME) queried the point of UN 0222, which at least in the US does not relate to any commercial material. If it were deemed obsolete, perhaps this entry could be removed. Other experts explained that it retains some usefulness in the classification of contaminated ammonium nitrate or for fertilisers that fail test series 2. It was agreed that UN 0222 should remain in the Dangerous Goods List.
Finland proposed a new UN number for mines with a bursting charge that meet the Division 1.6D criteria. The Working Group considered that, if such articles meet the test series 7 criteria they should be classified under UN 0486, Division 1.6N and that there is no need for a specific entry.
The Council on Safe Transportation of Hazardous Articles (COSTHA) asked for the Working Group’s opinion on the meaning of ‘safety devices’ in the proper shipping name of UN 3268. Specifically, it asked if micro gas generators, which performs the same function as a seat-belt pretensioner, fall under the description, as its members are finding variations in the interpretation on the part of different competent authorities. Some classify these articles under Class 9, others do not.
A range of views were expressed; some experts felt that, as micro gas generators can be used in other applications, they cannot be transported as UN 3268; others felt that this entry should be assigned purely on the characteristics of the article, not on its intended use. Some felt that the current entry covers micro gas generators. The one point of agreement was that the provisions for safety devices currently in the Model Regulations had been developed to address only those intended for use in vehicles, vessels or aircraft. The COSTHA representative said he would submit a further document at the next session to allow for more discussion before a decision is taken.
The US sought the extension of the default classification table for fireworks to include UN 0431 pyrotechnic articles. These are often similar in nature to consumer fireworks but designed for other purposes, such as for theatrical effects. The Working Group was sympathetic to the idea but felt that the proposal was too broad and could allow inappropriate classification. The US will likely return with a more specific proposal.
CLASSIFICATION AND PACKAGING
Germany proposed extending the scope of UN 2990 to include self-inflating recovery devices as well as life-saving devices. Most experts, though, felt that the current extent is appropriate. Germany may return with a revised proposal giving more justification for its idea.
Another paper from Germany proposed an additional entry for UN 1390 alkali metal amides of packing group I, in addition to that for material of packing group II already in the Dangerous Goods List. Recent testing on sodium amide has determined that it meets PG I criteria. The experts agreed and adopted the additional entry.
The US expert suggested it would also be useful to have an entry for PG III material and promised to submit a proposal. The expert from China said that a Class 8 subsidiary hazard should also be indicated; the Sub-committee could not make a decision without the relevant data but would be keen to see if that is the case.
Canada noted that, while 126.96.36.199 states that substances of Division 6.2 are not assigned to packing groups, the Dangerous Goods List has PG II in column (5) against UN 3291 clinical waste unspecified, nos. It felt that this was an error. The experts agreed to delete that reference, on the understanding that packaging should meet the performance requirements for PG II as shown in the relevant packing instructions.
A joint paper from Germany, Cefic and the Dangerous Goods Advisory Council (DGAC) sought to tidy up some errors in the assignment of polymerising substances. The paper said that UN 2522 2-dimethylaminoethyl methacrylate, Division 6.1, PG II has very similar properties to UN 3302 2-dimethylaminoethyl acrylate, which had earlier been identified as a polymerising substance. The experts agreed with the argument and added ‘stabilised’ to the end of the proper shipping name for UN 2522 and ‘386’ in column (6) of the Dangerous Goods List.
On the other hand, UN 2383 dipropylamine, which had been identified as a polymerising substance, does not in fact display such characteristics. Again, the experts concurred and deleted ‘386’ from column (6) for this substance. Both these changes have been placed in square brackets pending confirmation at the next session.
At the previous session there had been general support for the idea that large articles of UN 3164 could be carried unpackaged or in packagings not meeting the specifications of Chapter 6.1. Germany returned with a formal proposal, noting that there are some large articles subject to packing instruction P003 that have a mass exceeding 400 kg and which can, therefore, not be transported at all within the scope of the Model Regulations.
Germany offered two options and the Sub-committee opted for the simpler solution. In the Dangerous Goods List, “PP32” is added in column (9) against UN 3164, and PP32 itself is revised with the addition of the words “and robust articles consigned under UN 3164” after “3358”.
In a joint submission, DGAC and Cefic opened discussion on the issue of packagings that conform to more than one design type. Such packagings are in widespread use and offer industry a deal of flexibility without added costs. However, uncertainty among carriers and enforcement bodies can lead to the rejection of shipments using such packagings (which include intermediate bulk containers – IBCs – and larger packagings).
DGAC and Cefic proposed the addition of a new 188.8.131.52.1 to deal with the issue but, after discussion and input from other trade associations, a solution put forward by the International Confederation of IBC Associations (ICIBCA) was preferred. This will involve the addition of new paragraphs in Chapters 6.1, 6.5 and 6.6 to specifically allow packagings to bear more than one mark. Those new texts are currently in square brackets, pending a formal proposal for the next session that will also looking at the issue of multiple approvals.
The Compressed Gas Association (CGA) and European Industrial Gases Association (EIGA) felt that the hazards posed by pyrophoric gases during transport are not being properly communicated. They noted that GHS has recently adopted definitions for pyrophoric gases and proposed that similar criteria should be introduced into the Model Regulations along with new nos entries for pyrophoric mixtures and for those pure pyrophoric gases not already listed. There was general support for the idea and a lunchtime working group hammered out some details. CGA and EIGA will submit a revised proposal at the next session.
Canada proposed the revision of packing instruction P801 in an effort to improve compliance and the safe transport of batteries and, more specifically, to clarify the requirements for the transport of used batteries. Its paper identified a number of shortcomings in the provisions as they stand. The submission generated some differences of opinion, leading to the submission of a revised proposal. However, it was felt that this needed to be made by means of an official submission, which Canada may bring to the next session.
ELECTRIC STORAGE SYSTEMS
The Medical Device Battery Transport Council (MDBTC) submitted in an informal document urging discussion of what it called “specific challenges” in providing the lithium battery test summary document along the supply chain. The paper included a number of questions to prompt discussion, along with MDBTC’s opinion.
At the paper had been submitted rather late, the Sub-committee had not had time to consider it in detail but did provide some initial feedback. The Portable Rechargeable Battery Association (PRBA) will take up a point on the release of confidential business information in a paper for the next session.
Meanwhile, the International Air Transport Association (IATA) picked up on a similar issue, highlighting what it saw as an anomaly between the requirements of 2.9.4(g) introduced in the 20th revised edition of the Model Regulations, which requires “manufacturers and subsequent distributors” of cells or batteries to make the test summary available, and 38.3.5 of the Manual of Tests and Criteria, which extends a similar requirement to manufacturers of devices containing those cells or batteries. The Sub-committee pointed out that the Model Regulations apply only to dangerous goods and that some manufactured products containing cells or batteries may not meet that criterion. If they do, then the product manufacturer is a “subsequent distributor”.
France provided a report on the informal working group on data gathering for the hazard classification of lithium batteries, which had met in Paris in early November 2017. The aim of the work is to develop a rationalised system of classification, based on the hazards presented by particular cells and batteries. The parties involved have been collecting data on such factors as heat release rate, gas flow, toxicity, state of charge, response to external heating, and the potential release of hydrogen fluoride. The group will continue to collect and analyse data and develop an appropriate test scheme. Other experts were encouraged to contribute any relevant data they may have.
PRBA and the European Association for Advanced Rechargeable Batteries (Recharge) noted that the ICAO Technical Instructions have a special provision, A181, that allows packages containing lithium batteries that are both contained in and packed with equipment to be marked simply as “…packed with…”. This is useful in cases such as power tools, which often contain both. The Model Regulations have no such provision, which makes life difficult for shippers using a combination of transport modes. The associations proposed a similar provision at the end of special provision 230. The Sub-committee supported the idea in principle but felt that further work was needed on the proposed text; a revised proposal will be put to the next session.
PRBA and Recharge fared less well with another proposal, relating to the transport of damaged or defective lithium cells and batteries. Their paper stated that the current requirement in special provision 376 to ensure that such batteries “do not conform to the type tested” is redundant, as those handling batteries in return shipments do not have the equipment or training to make such a judgment. Most experts were of the view that SP 376 does not require re-testing but it was recognised that the Model Regulations should reflect that interpretation. The proposal was withdrawn but PRBA will submit a revised version, based on the comments received.
The UK made a presentation on sodium-ion batteries, an emerging technology that needs to be covered by the Model Regulations. It was suggested that a new UN number should be assigned and that consideration should be given to the transport of damaged and defective sodium-ion batteries, similar to that in place for lithium ion and lithium metal cells and batteries. The Sub-committee agreed that provisions should be developed but felt that more information was needed. A new document will be submitted at the net session.
TRANSPORT OF GASES
CGA and EIGA updated the Sub-committee on work to develop a common position on provisions for closures of pressure receptacles but said they had received only limited interest from other parties. They still feel a need for a solution and said they would initiate discussions in the first quarter of 2018 with the aim of drawing up a formal proposal.
Germany came with a proposal to extend the applicability of special provision 392, which relates to fuel gas containment systems containing flammable gases, to other gases. SP 392 is used by the automotive industry in the transport of such containment systems for disposal, recycling, repair, inspection or maintenance and, as such, they are often filled with others gases, some of which are listed dangerous goods (e.g UN 1956 compressed gas, nos) but are not flammable. The RID/ADR/ADN Joint Meeting had discussed this point and felt it warranted urgent attention but also that, for the sake of modal harmony, it should be put to the TDG Sub-committee as well.
The Sub-committee accepted the argument and agreed for now to add “392” in column (6) of the Dangerous Goods List against UN 1002, 1006, 1013, 1046, 1056, 1058, 1065, 1066, 1080, 1952, 1956, 2036, 3070, 3163, 3297, 3298 and 3299. This change is currently in square brackets, as the proposal was made in an informal document and requires a follow-up official proposal.
IATA contended that the text of 184.108.40.206, relating to the size of the marking of the UN number on packages, is unclear and confusing, particularly with regard to the marking of small packages. It offered two solutions to help clarify the situation but neither received approval. Most experts felt that the texts offered by IATA would not make the position any clearer, although it was agreed that the current text is not perfect. EIGA also felt that any change should make specific mention of gas cylinders. IATA withdrew the proposal.
Belgium had noted that, while there are specific provisions in Chapters 6.1, 6.3, 6.5 and 6.6 relating to the preparation of test samples for the drop test for plastics packagings, only one – 220.127.116.11.6.2 – specifies that the temperature of the test sample and its contents should be conditions for at least 24 hours. Its paper felt that this should be mirrored in the other relevant paragraphs, since as they stand they appear to allow test institutes to reduce the temperature of test samples to -18˚C and to leave them for only a short period before performing the test, thereby possibly carrying out the test on a packaging that has not cooled down entirely.
Some experts supported Belgium’s idea while others were not convinced. The expert from Belgium said this showed that test practices vary between countries, which could result in different safety levels. The matter will likely be raised again.
Another paper from Belgium addressed what it saw as a superfluous requirement in terms of the routine maintenance of IBCs. As the definitions in 1.2.1 currently read, cleaning is part of ‘routine maintenance’ and therefore, in accordance with 18.104.22.168, the IBC should be marked with the state in which the cleaning was carried out and the name of the party performing the cleaning. There is, Belgium’s paper said, no value in knowing this.
Several experts agreed but some did not and, as the paper was submitted late, an official proposal will be drawn up for the next session.
Germany sought to clarify 22.214.171.124.1 and 126.96.36.199.2 to highlight that the maximum permitted stacking load for IBCs only needs to be included in the pictogram. The Sub-committee agreed with the argument and, after discussion, opted to delete the last row in the table in 188.8.131.52.1 and the corresponding footnote b.
The US proposed allowing packagings that have been approved for the carriage of liquids to be used to carry solids. It reasoned that, as the testing of packagings for liquids is more strenuous than those for solids, there is in fact an additional safety benefit. Furthermore, the US Hazardous Materials Regulations have included an authorisation for the practice, with certain conditions, since 1991 and no incident attributable to this authorisation have been recorded.
The Sub-committee was not convinced by the argument, noting that packagings are already permitted to undergo testing both with liquids and solids and can bear both markings.
Germany addressed 184.108.40.206, which details additional provisions relating to the inspection of pressure relief devices on portable tanks intended for the transport of substances of Class 8, suggesting that it would be logical to extend the requirement to substances that have a Class 8 subsidiary hazard. EIGA pointed out that this is not necessarily justified in the case of gases. A revised proposal will be submitted taking account of the comments made.
Canada proposed a number of technical changes in Section 41 of the Manual of Tests and Criteria relating to the impact testing of portable tanks and multiple-element gas containers (MEGCs). These were agreed by the Sub-committee. Canada will also propose consequential amendments to the ISO 1496-3 standard.
An informal paper from Belgium addressed the minimum shell thickness of portable tanks used for the carriage of non-refrigerated liquefied gases, noting that portable tank instruction T50 does not specify any shell thickness while TP19 and TP21, which can also apply to tanks for non-refrigerated liquefied gases, do. It proposed a change to 220.127.116.11.1 to clarify the situation. The experts agreed in principle but asked Belgium to submit the proposal in an official document at the next session.
A similar outcome befell other informal papers from Belgium, the first on a similar topic aiming to clarify the shell thickness of tanks used for UN 1017 chlorine and UN 1079 sulphur dioxide in TP19. The second dealt with the provision of holding time information on the transport document.
Russia noted that RID and ADR have adopted provisions for tank-vehicles, demountable tanks, tank containers and tank swap bodies with tanks manufactured of fibre-reinforced plastics (FRP). Such provisions are thus far absent from the Model Regulations and the International Maritime Dangerous Goods (IMDG) Code and Russia proposed filling that gap, supporting its proposal with technical detail. Russia has also taken the proposal to IMO.
The Sub-committee supported the idea in principle but several experts considered that an intersessional informal working group should be set up to hammer out the details. A group of experts prepared draft terms of reference for the work. The US offered to lead a correspondence group.
Switzerland noted some errors in 18.104.22.168.2, specifically the omission of the required colour in three places. The Sub-committee agreed and adopted the changes as corrections to the 20th revised edition of the Model Regulations.
Russia and Austria proposed a number of amendments to section 5.5.3, which defines special provisions applicable to cargo transport units that present a risk of asphyxiation due to the presence of cooling or conditioning agents such as dry ice, refrigerated liquid or refrigerated argon. The paper noted the practice of using gaseous nitrogen during the loading of terephthalic acid in containers fitted with liner bags in order to reduce the risk of explosion and the formation of acidic dust. In such a scenario, the nitrogen is not used as a coolant or conditioner and is not in liquid form but it does nevertheless present a similar asphyxiation hazard for personnel carrying out the operation.
The Sub-committee agreed; “or nitrogen” was added after “(UN 1951)” in the text in parentheses at the end of 5.5.3 and a new Note was added:
In the context of this section the term “conditioning” may be used in a broader scope and includes protection.
There are further changes in 22.214.171.124.2.
ICAO presented information on some recent decisions made by its Dangerous Goods Panel (DGP) that have wider ramifications. Those included changes to the training provisions, which reinstate the high-level framework for general awareness, function-specific and safety training provided in the Model Regulations.
DGP adopted provisions for samples of energetic materials to be assigned to UN 3223 or 3224. It was noted that the Model Regulations do not indicate how to describe such substances so DGP added the word “sample” to the proper shipping name. This might have been an inadvertent omission on the part of the TDG Sub-committee.
DGP made some editorial revisions to the new special packing provisions PP94 and PP95, which were incorporated in packing instruction 459 in the Technical Instructions. These were offered for consideration by the Sub-committee.
DGP had also spotted some inconsistencies in the use of the term “material”, which might have different meanings depending on the context. The Sub-committee was invited to consider the use of the term in 126.96.36.199.1, 188.8.131.52(a) and SP 163 in the Model Regulations.
DGP assigned special provision A176, which aligns with SP 356 in the Model Regulations, to UN 3259 as well as UN 3528 and 3166. The Model Regulations only has it against UN 3166.
The Sub-committee noted ICAO’s comments and invited it to submit official proposals for the next session to enable the improvements to be adopted.
IMO reported on the work of its Sub-committee on Carriage of Cargoes and Containers (CCC) in the preparation of Amendment 39-18 to the IMDG Code. CCC decided against including ‘bulk containers’ in 184.108.40.206.2.2 as they are not used for Class 1 substances. In 220.127.116.11.1.1.2 it drew up some amendments to the provisions for labels, which might be adopted by other modes, and it re-worded part of LP903.
CCC also works on the International Maritime Solid Bulk Cargoes (IMSBC) Code and it had drawn up individual schedules for seed cake (UN 1386 and 2217). It is expected that Amendment 05-19 to the IMSBC Code would be prepared by the Editorial & Technical Group in April 2018.
The Sub-committee decided that two points in the IMO presentation warranted corrections to the 20th revised edition of the Model Regulations. It deleted “and bulk containers” from 18.104.22.168.2(b) and in the Glossary of Terms in Appendix B replaced “significant hazard” with “significant risk”.
Germany had identified a number of other places where corrections to the text of the 20th revised edition of the Model Regulations might help the modal authorities as they transpose the provisions for their respective regulations for entry into force in 2019. These were mostly deemed acceptable, although there was some debate about the proposed revision of SP 392. In the end it was decided to adopt an amended version, so the second sentence of SP 392(c) will read:
If only one valve exists or only one valve works, all openings with the exception of the opening of the pressure relief device shall be closed as to be gastight under normal conditions of transport;
In 22.214.171.124, “the grouping shall be based” is replaced by “the assignment shall be based”. In the second paragraph of P907, “filling density” is replaced by “filling ratio”. In TP10 in 126.96.36.199, “beyond the date of expiry of the last testing” is replaced by “beyond that date”. The proper shipping name for UN 3543 is amended to read:
ARTICLES CONTAINING A SUBSTANCE WHICH IN CONTACT WITH WATER EMITS FLAMMABLE GASES, NOS.
Another paper from Germany noted that UN 3363 now applies to articles for which a proper shipping name does not exist. Consequently, articles of UN 3537 to 3547 do not need to be reclassified as UN 3363 when transported empty and/or uncleaned. The Sub-committee confirmed that this is the case. Some experts felt that a note would be valuable to help consignors select the appropriate entry. The expert from Switzerland offered to submit a proposal for the next session.
There was much discussion about the need to amend the proper shipping name of UN 3363; on the basis of proposals drawn up by a lunchtime working group it was eventually agreed to:
- At the beginning of the description of UN 3363 in the Dangerous Goods List, add “DANGEROUS GOODS IN ARTICLES or”, and add the same entry to the Alphabetical Index
- Add “3363 DANGEROUS GOODS IN ARTICLES or” in 2.9.2 under “Other substances or articles presenting a danger during transport…”
- In the first sentence of SP 301, replace “machinery or apparatus” by “articles such as machinery, apparatus or devices”; in subsequent sentences, “machinery or apparatus” is replaced by “articles”; the same changes are made to P907.
These changes will apply to the 21st revised edition of the Model Regulations.
Note was taken of ongoing work relating to the GHS, including the testing of oxidising substances and the use of the Manual of Tests and Criteria in the context of the GHS. A formal submission for some amendments to the Manual will be submitted at the next session.
The Netherlands reported on intersessional work to clarify the scope of 188.8.131.52 and to what extent the Model Regulations should be applied to dangerous goods that are not themselves the goods being transported but are carried on the vehicle. This is becoming more urgent given the increasing use of lithium battery-powered sensors on vehicles. Work will continue.
The next, 53rd session of the UN Sub-committee of Experts on TDG will begin in Geneva on 25 June.
[post_title] => UN: Clear is the new Orange
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