[ID] => 8084
[post_author] => 34
[post_date] => 2017-05-09 13:10:22
[post_date_gmt] => 2017-05-09 12:10:22
[post_content] => The UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) held its 50th session in Geneva from 28 November to 6 December 2016. As regular readers will be aware, this was the last of four in the 2015/16 regulatory biennium and the final chance to agree the amendments that will appear this year in the 20th revised edition of the UN Model Regulations. Those amendments will appear in the international modal and regional/national regulations as from 2019.
The meeting was chaired by Duane Pfund (US) with Claude Pfauvadel (France) as vice-chairman. It was attended by experts from 22 countries and observers from Qatar and Slovakia. Also at the meeting were 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 35 non-governmental organisations.
The first part of this report in last month’s issue of HCB covered discussions on the transport of explosives, and numerous matters related to listing, classification and packaging. This second and final part looks at the remaining papers.
ELECTRIC STORAGE SYSTEMS
No regulatory meeting these days gets away with ignoring new technologies in batteries and the TDG Sub-committee was no exception.
Germany recalled that, when provisions had been agreed during the previous biennium relating to small production runs or prototype lithium batteries contained in equipment, an option to include provisions specific to large packagings had not been taken up. It now returned with alternative ways to plug this gap, the first of which – with some amendment – was deemed appropriate.
As a result, a new LP905 was adopted, along with consequential amendments to LP903.
The Sub-committee also remarked that, where packing instructions contain no limit on the maximum mass of unpackaged articles or equipment, it would be useful to reflect that interpretation more clearly in the text. That may be a task for the 2017/18 biennium.
CTUs with tracking devices
Another paper from Germany proposed inserting a new section in Chapter 5.5 relating to cargo transport units (CTUs) fitted with tracking devices containing lithium batteries. The experts felt that any such provisions should be specific to the tracking devices themselves, as the CTUs in question may contain other dangerous goods. Some felt that Chapter 5.5 was not the ideal place for the mooted provisions. The proposal was withdrawn but may reappear during the coming biennium.
Damaged/defective lithium batteries
Papers from the International Organisation of Motor Vehicle Manufacturers (OICA) and the European Association for Advanced Rechargeable Batteries (Recharge) proposed a general packaging performance standard for the transport of damaged or defective lithium batteries, in light of experience with the existing requirements to seek competent authority approval. So far, that course of action has resulted in a number of different transport solutions and the organisations felt it would be helpful to come up with a consistent provision.
The proposal led to a lengthy discussion that recognised the rapid development in the design of electric vehicles and the need to define the transport of the batteries involved more closely. Some experts felt there needed to be a better definition of the concept of ‘damage’; it was also regretted that the proposal still required action by the competent authority in cases where the batteries were liable to react dangerously. On the basis of those discussions, a revised proposal was drawn up and, after some editorial amendments, was adopted by a large majority.
As a result, the text after the third paragraph of special provision 376 is amended to read:
Cells and batteries shall be packed in accordance with packing instructions P908 of 188.8.131.52 or LP904 of 184.108.40.206, as applicable.
Cells and batteries identified as damaged or defective and liable to rapidly disassemble, dangerously react, produce a flame or a dangerous evolution of heat or a dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport shall be packed and transported in accordance with packing instruction P911 of 220.127.116.11 or LP906 of 18.104.22.168, as applicable. Alternative packing and/or transport conditions may be authorized by the competent authority.
Packages shall be marked “DAMAGED/DEFECTIVE” in addition to the proper shipping name, as stated in 5.2.1.
The transport document shall include the following statement “Transport in accordance with special provision 376”.
If applicable, a copy of the competent authority approval shall accompany the transport.
New packing instruction P911 and large packing instruction LP906 give more details.
Recharge also provided information on the types of hazards that may result from lithium batteries and the envisaged levels of severity that would make it possible, in a second stage of work, to provide for appropriate packaging for damaged or defective batteries.
In a separate paper, the Rechargeable Battery Association (PRBA) sought to simplify SP 376 and align it with the ICAO Technical Instructions. However, some experts thought that, as there had already been a lengthy discussion on the topic and that PRBA’s informal document had been submitted late, they were no minded to make further amendments. PRBA will raise the matter again during the 2017/18 biennium.
Lithium metal polymer batteries
PRBA and Recharge raised the subject of rechargeable lithium metal polymer batteries and proposed that they should be dealt with in the same way as lithium ion batteries. Most experts felt that the current provisions for lithium metal batteries applied, although many recognised industry’s efforts to develop less dangerous cells and batteries. On the whole they were not in favour of adding new entries to the list of dangerous goods whenever new technologies emerged. As a result the proposal was withdrawn but the comments indicate that perhaps it will be necessary to take a step back and reconsider the approach taken in the Model Regulations relating to batteries of all chemistries.
Special provision 389
In an informal document, Switzerland urged clarification of the new entry UN 3536 – Lithium batteries installed in cargo transport unit, along with its corresponding SP 389. Reference to that new UN number was included in 2.9.2 under the heading ‘Lithium batteries’ but, on the whole, the Sub-committee felt that the proposals in the paper had been presented too late to allow time for proper consideration. An official proposal will be prepared for the 2017/18 biennium.
Lithium batteries by air
A paper from ICAO explained its decision to prohibit the carriage of UN 3480 lithium ion batteries as cargo on passenger aircraft and summarised subsequent work on the risks posed by the carriage of lithium batteries by air. While acknowledging the difficulties presented by varying risks posed by different batteries, ICAO was clear about the problems it faces:
“While regulators have been asked to improve oversight activities to address non-compliance, the complexity of the regulatory framework makes an effective oversight system for lithium batteries difficult to achieve. The enormous quantities being shipped and the expectation that oversight is required for excepted lithium batteries not subject to full regulation further complicates matters.”
The Sub-committee agreed to follow up on ICAO’s comments and include a specific item in its programme of work. The first stage will be to develop a new system of criteria based on the intrinsic hazards posed by various types of cells and batteries and the Sub-committee welcomed work already done by France in this regard. Once those criteria are established, it will be possible to begin the determination of corresponding conditions of transport.
Sodium ion batteries
The UK presented further information on sodium ion batteries, including their working principles, applications and safety issues. It was agreed that the Sub-committee will look at the issue during the 2017/18 biennium.
France had noticed that the report of the informal working group on lithium batteries at the previous session included an error in the text of 38.3.3(c)(iii) and (iv) of the Manual of Tests and Criteria. At the end of each sub-paragraph, “in fully charged states” should read “at 50% of the design rated capacity”. The Sub-committee accepted this correction.
Germany noted that the example in the introductory text in 3.3.1, “Damaged Lithium Batteries”, is not correct. It was agreed to change this to “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES”.
PRBA and Recharge came with a proposal to specify in 38.3.5 of the Manual of tests and Criteria the information that should be included in the lithium battery test report. Another proposal from France included a new paragraph for 2.9.4 in the Model Regulations, and it was this that the experts found more persuasive, though they agreed that details should be included in the Manual.
After work by a drafting group, the following two sub-paragraphs were adopted for 2.9.4:
(f) Lithium batteries, containing both primary lithium metal cells and rechargeable lithium ion cells, that are not designed to be externally charged (see special provision 387 of Chapter 3.3) shall meet the following conditions:
(i) The rechargeable lithium ion cells can only be charged from the primary lithium metal cells;
(ii) Overcharge of the rechargeable lithium ion cells is precluded by design;
(iii) The battery has been tested as a lithium primary battery;
(iv) Component cells of the battery shall be of a type proved to meet the respective testing requirements of the Manual of Tests and Criteria, part III, sub-section 38.3.
(g) Manufacturers and subsequent distributors of cells or batteries shall make available the test summary as specified in the Manual of Tests and Criteria, Part III, sub-section 38.3, paragraph 38.3.5.
T.2 thermal test
PRBA and Recharge reiterated their proposal to decrease the temperature at which the T.2 test is carried out from 72˚C to 65˚C. Although some experts agreed that there might be some procedural problems due to the activation of safety protective components when testing cells or batteries equipped which such components, most did not support the proposal. This may come back again in the next biennium.
Gas tanks for motor vehicles
Germany sought to finalise discussions on the inclusion of provisions for the transport of fuel gas containment systems containing gas. This was neatly packaged into a proposal for a new special provision, which after some editorial amendment proved acceptable to the Sub-committee. This new SP 394 lists the standards and ECE Regulations applicable to fuel tanks for vehicles powered by LPG, CNG and hydrogen under pressure.
Germany had been working on a proposal to improve the wording of 7.1.5 and 7.1.6 in light of the new provisions covering polymerising substances. The experts appeared grateful for the work that had been done and accepted the proposal, leading to a complete re-write of 7.1.5 and the deletion of 7.1.6. This necessitated a number of amendments to references elsewhere in the text.
An informal document from the UK supporting the German proposal offered some further clarifications but, as it had been submitted late, it was left to the UK to come back with a formal proposal in the 2017/18 biennium.
Spain was concerned at the differences between the entries for UN 1386 seed cake in the Model Regulations and the International Maritime Dangerous Goods (IMDG) Code. The IMO representative said that the issue was already under discussion, although it is complicated by the use of UN 1386 (and UN 2217) both for carriage in packaged form in the IMDG Code and in bulk form in the International Maritime Solid Bulk Cargoes (IMSBC) Code. A correspondence group is considering the question.
The Sub-committee invited IMO to keep it informed, especially if IMO feels that the current description in the Model Regulations needs to be amended.
The US noted that, while the Guiding Principles identify the appropriate E-Code assignments for dangerous goods in excepted quantities, they do not identify a rationale for that assignment. Its paper offered an amendment to the table in Chapter 3.5 of the Guiding Principles, which was deemed acceptable.
Cooperation with IAEA
The International Atomic Energy Agency (IAEA) had identified a number of editorial errors in the Model Regulations in the provisions relating to the transport of Class 7 materials and the Secretariat prepared a list of necessary changes, mostly relating to the assignment of special provisions. These were accepted by the Sub-committee as corrections to the 19th revised edition of the Model Regulations.
Despite this being the last session of the biennium, some delegations brought forward new proposals, some of which were accepted.
PRBA and Recharge were at it again, proposing the deletion of a number of redundant or overlapping provisions in 2.9.4 of the Model Regulations and 38.3 of the Manual of Tests and Criteria. While many delegations liked the idea of removing redundant provisions, overall it was felt necessary to keep the essential requirements for classification. PRBA withdrew the proposal but may come back with a revised version in the 2017/18 biennium.
6HH1 composite packagings
The International Confederation of Plastics Packaging Manufacturers (ICPP) noted what it felt was a long-standing error in packing instruction P001. This places a maximum capacity limit for packing group I materials in a plastics drum with a plastics inner receptacle (6HH1) of 120 litres, rather than the 250 litres allowed for 1H1 plastics drums.
The experts agreed with ICPP’s reasoning and made the necessary changes in P001.
A paper from the US referred to the annual testing requirement for the lead lining of portable tanks used for the transport of UN 1744 bromine or bromine solution. It sought an amendment to portable tank special provision TP10 to allow such tanks, once emptied but before cleaning, to be transported to the next test or inspection within a period of three months after expiry of the last lining inspection. This also proved acceptable to the experts and the change was made.
Another paper from the US addressed the classification of mixtures of environmentally hazardous substances (EHS). The current text of 22.214.171.124.6.5.1 includes a statement drawn from GHS that is not relevant to transport and it was felt that this could safely be deleted. The experts once more agreed and deleted “… x percent of the mixture consists of ingredient(s) of unknown hazards to the aquatic environment.”
Large salvage packagings
An informal document from Germany proposed amendments to 126.96.36.199 and 188.8.131.52.3 to clarify that their provisions refer to large salvage packagings as well as salvage packagings. This was also agreed.
Another informal document from Germany sought to include an exemption for non-toxic, non-flammable gases of Division 2.2 from the provisions for adsorbed gases. However, in this case the experts felt that more time was needed to discuss the issue and it will return during the next biennium.
Oxidising liquids and solids
France presented the results of the round robin testing of Test O.2 for oxidising liquids and Test O.3 for oxidising solids. Its paper proposed amendments to the cellulose specifications for conducting these tests, which proved acceptable, as well as proposals for further work. This topic will continue on the programme of work for the 2017/18 biennium.
Belgium and Japan reported on the work that had been undertaken during the previous year with regard to new classification criteria for flammable gases, in particular the division of current Category 1 into 1A and 1B so as to recognise those gases (typically refrigerants and foam expanders) developed to replace other gases that have been identified as contributors to global warming.
The outcome of the work was four specific proposals for amendments to the Globally Harmonised System of classification and labelling of chemicals (GHS). The TDG Sub-committee recommended that the GHS Sub-committee adopt these proposed amendments, affecting classification criteria and hazard communication elements.
The Sub-committee noted that work to review Chapter 2.1 of GHS would continue during the 2017/18 biennium and felt it would be highly desirable for the Working Group on Explosives to have experts involved from sectors other than transport.
The Sub-committee decided on a majority vote to grant consultative status to the Medical Device Battery Transport Council, which will be invited to take part in the development of a comprehensive hazard-based system to classify lithium batteries and cells for transport.
The Sub-committee recognised Patrick van Lancker, who had served as observer and then expert from Belgium since 1989 and who was attending for the last time. Van Lancker has also represented Belgium at IMO meetings and was for some years chair of the Editorial and Technical Group. The Sub-committed thanked him warmly for his outstanding contribution to the safe transport of dangerous goods and wished him a long and happy retirement.
On a sadder note, the Sub-committee learned of the death of John Monteith, former expert from Canada and vice-chair of the Sub-committee from 1988 to 1996.
Duane Pfund and Claude Pfauvadel were re-elected as chair and vice-chair, respectively, for the 2017/18 biennium.
The full list of amendments that will appear in the 20th revised edition of the UN Model Regulations can be found on the UN ECE website.
[post_title] => UN: Race to the finish
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[post_modified] => 2017-05-09 13:10:22
[post_modified_gmt] => 2017-05-09 12:10:22
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