[ID] => 10427
[post_author] => 34
[post_date] => 2018-12-28 11:14:05
[post_date_gmt] => 2018-12-28 11:14:05
[post_content] => The UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) held its 53rd session in Geneva from 25 June to 4 July 2018. The meeting was chaired by Duane Pfund (US) with Claude Pfauvadel (France) as vice-chair. It was attended by experts from 20 countries, observers from three others, and representatives of the EU, the Intergovernmental Organisation for International Carriage by Rail (OTIF), the UN Food and Agriculture Organisation (FAO), the International Atomic Energy Agency (IAEA), the International Civil Aviation Organisation (ICAO), the International Maritime Organisation (IMO), the World Health Organisation (WHO) and 32 non-governmental organisations.
Attendees were faced with a heavy agenda as the Sub-committee sought to clear up most of the outstanding issues before it ahead of the final meeting of the biennium, which was to begin on 26 November. As usual, matters relating to explosives were remitted to a specialist working group; its discussions, along with those in plenary relating to listing, classification and packaging, were covered in the first part of this two-part report on the meeting in last month’s issue (HCB December 2018, page 52).
ELECTRIC STORAGE SYSTEMS
No regulatory meeting goes by without some reference to lithium batteries but, as the Sub-committee’s recent discussions show, new battery technologies are coming along that will need to be examined closely in order to ensure safety during transport. That was not to say that there are still not matters relating to lithium batteries to be concluded.
The Rechargeable Battery Association (PRBA) and the European Association for Advanced Rechargeable Batteries (Recharge) proposed that, on the basis of experience, to remove fully discharged batteries from the list of tests required in 38.3.3(a) and (c).
There was no support for the proposal. Most experts felt it premature to make such a move without further test result data, while the expert from China reported that, in some cases, fully discharged primary batteries had resulted in fires and explosion when undergoing testing.
France and Recharge reported on the ongoing work of an informal working group looking at the development of a hazard-based system for classifying lithium batteries, work that might also point towards ways of classifying other battery technologies. Discussions will also move on to the role of packagings in mitigating hazards. A further meeting of the group was scheduled to take place at the International Air Transport Association’s (IATA) Geneva office in early December.
Proper shipping names
PRBA and Recharge returned with a formal proposal to simplify the use of proper shipping names for lithium ion and metal batteries packed with equipment. Currently, there is disharmony between the provisions of the UN Model Regulations and those contained in the International Civil Aviation Organisation’s (ICAO) Technical Instructions, which can cause problems for shippers of equipment such as power tools, which are often contained in a box with spare batteries.
With some amendments, the proposal was deemed to be a suitable way to get around the problem, which had been discussed at previous meetings. The Sub-committee adopted a new paragraph (5) for packing instruction P903:
For packaging containing both cells or batteries packed with equipment and contained in equipment:
(a) For cells and batteries, packagings that completely enclose the cells or batteries, then placed with equipment in a packaging conforming to the requirements in paragraph (1) of this packing instruction; or
(b) Packagings conforming to the requirements in paragraph (1) of this packing instruction, then placed with the equipment in a strong outer packaging constructed of suitable material, and of adequate strength and design in relation to the packaging capacity and its intended use. The outer packaging shall be constructed in such a manner as to prevent accidental operation during transport and need not meet the requirements of 188.8.131.52.
The equipment shall be secured against movement within the outer packaging.
Devices such as radio frequency identification (RFID) tags, watches and temperature loggers, which are not capable of generating a dangerous evolution of heat, may be transported when intentionally active in strong outer packagings. When active, these devices shall meet defined standards for electromagnetic radiation to ensure that the operation of the devices does not interfere with aircraft systems.
There is also a new special provision 390, assigned to UN 3091 and 3481:
When a package contains a combination of lithium batteries contained in equipment and lithium batteries packed with equipment, the following requirements apply for the purposes of package marking and documentation:
(a) the package shall be marked “UN 3091 Lithium metal batteries packed with equipment”, or “UN 3481 Lithium ion batteries packed with equipment”, as appropriate. If a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package shall be marked as required for both battery types. However, button cell batteries installed in equipment (including circuit boards) need not be considered.
(b) the transport document shall indicate “UN 3091 Lithium metal batteries packed with equipment” or “UN 3481 Lithium ion batteries packed with equipment”, as appropriate. If a package contains both lithium metal batteries and lithium ion batteries packed with and contained in equipment, then the transport document shall indicate both “UN 3091 Lithium metal batteries packed with equipment” and “UN 3481 Lithium ion batteries packed with equipment.
Damaged or defective batteries
A further paper from PRBA and Recharge, this time with the participation of the Medical Device Battery Trade Council (MDBTC), addressed issues surrounding the requirements for damaged or defective lithium cells and batteries in special provision 376, particularly in light of decisions made by the ICAO Dangerous Goods Panel (DGP) in October 2017. The joint paper argued that special provision 376 does not currently cover all scenarios in which it might apply, leading to confusion among shippers and carriers, and offered some textual revisions to help clarify matters.
The Sub-committee concurred with the idea but took a red pen to the proposed changes. In the end, it was agreed to amend the Note to special provision 376 to read:
NOTE: In assessing a cell or battery as damaged or defective, an assessment or evaluation should be performed based on safety criteria from the cell, battery or product manufacturer or by a technical expert with knowledge of the cell’s or battery’s safety features. An assessment or evaluation may include, but is not limited to, the following criteria:
- Acute hazard, such as gas, fire, or electrolyte leaking;
- The use or misuse of the cell or battery;
- Signs of physical damage, such as deformation to cell or battery casing, or colours on the casing;
- External and internal short circuit protection, such as voltage or isolation measures;
- The condition of the cell or battery safety features; or
- Damage to any internal safety components, such as the battery management system.
Sodium ion batteries
The UK followed up on an earlier thought-starter document with a proposal for a new special provision to provide an exemption for sodium ion cells and batteries and a list of issues for further work.
There was support in principle for the proposals but most experts felt that more information was needed; it was also pointed out that sodium ion batteries cannot be compared to other energy storage systems and would require a fresh approach. The proposal was withdrawn but will appear again in a new form that would take account of the comments made.
Lithium battery mark
In an informal document, PRBA and Recharge tested the waters for a proposal to allow the use of smaller versions of the lithium battery mark on packagings that are not large enough to carry the full-size version. It was pointed out that 184.108.40.206 already allows the use of smaller marks in such cases but, noting the difficulties being experienced in the field, it was agreed that the wording of that provision might benefit from amendment. A further proposal would be made at the next session.
ICAO reported that the issue would be brought to the attention of the DGP at its October 2018 and a report on the outcome of discussions at that meeting would be provided to the Sub-committee at its next session.
Sodium nickel chloride batteries
A very extensive informal document from Switzerland proposed that cells and batteries containing sodium tetrachloroaluminate should be exempted from the provisions of the Model Regulations when in a ‘cold’ state. Such cells and batteries only work at high temperatures and the cathode, anode and electrolyte are effectively ‘off’ at temperatures below 98˚C.
Although the expert from Switzerland stressed that no incidents involving such batteries have been reported for many years, most experts were reluctant to provide a blanket exemption. They noted, for instance, that a certain amount of sodium remains in the battery even in the discharged state, and that this hazard cannot be ignored; others considered that these cells and batteries fall most easily under UN 3292 and that specific transport or packing provisions could be developed.
The exert from Switzerland was invited to consider the comments made and to submit an official proposal for the next session.
TRANSPORT OF GASES
Canada proposed that the shell requirements in 220.127.116.11.3 for UN acetylene cylinders be revised to better align with the specification in the ISO 3807:2013 standard. On the basis of informal documents from the International Standardisation Organisation (ISO) and Germany, the experts agreed to amend the heading of the second table in 18.104.22.168.3 to read: “For the acetylene cylinder including the porous material”. In the table, under “For the cylinder shell”, reference is now made to two additional standards: ISO 4706:2008 and ISO 7866:2012+Cor 1:2014.
ISO returned with text to clarify the marking provisions for UN pressure receptacles, after raising the topic a year earlier. ISO noted that similar text has already been adopted for RID and ADR in Europe but elsewhere there is still the possibility that the wrong decision is made. The experts agreed with ISO’s proposal to add a Note to 22.214.171.124.2(c), although it was reworded before being accepted:
For the purpose of this mark the country of approval means the country of the competent authority that authorized the initial inspection and test of the individual receptacle at the time of manufacture.
The experts also noticed that the same Note should also be added to 126.96.36.199.2(c).
ISO brought along its usual list of new and revised standards relevant to the transport of gases. The experts agreed most of them, which involves the following changes:
- Replacing ISO 10156:2010 with ISO 10156:2017 in 188.8.131.52 and 2.2.3
- Adding a new row to the end of table in 184.108.40.206.1 for ISO 11119-4:2016 Gas cylinders – Refillable composite gas cylinders – Design, construction and testing – Part 4: Fully wrapped fibre reinforced composite gas cylinders up to 150 l with load-sharing welded metallic liners
- Adding a new row to the table in 220.127.116.11 for ISO 14246:2014+Amd 1:2017, with applicability of the existing reference to ISO 142464:2014 limited to 31 December 2024
- Adding a new row at the end of the first table in 18.104.22.168 for ISO 20475:2018 Gas cylinders – Cylinder bundles – Periodic inspection and testing
- Deleting the row for ISO 10462:2005 in 22.214.171.124, as this is no longer applicable after the end of 2018.
A proposal to add a reference to ISO 17879:2017 Gas cylinders – Self-closing cylinder valves – Specification and type testing was not adopted. The experts noted that it would imply a significant increase in the pressure value for the burst test, a change that had not been reached by consensus at ISO. The ISO representative withdrew this item but said that work would continue with industry bodies to try and reach an agreement.
The Sub-committee noted that there might be other standards that are referenced in Chapter 6.2 that might have been superseded; the ISO representative offered to check them and return with a proposal for the necessary updates at the next session.
Another paper from ISO proposed updating the LC50
values referenced in packing instruction P200, to harmonise with those given in ISO 10298:2010. Several experts felt that more information supporting the changes was needed before a decision could be taken. ISO offered to work with industry bodies to compile the required data.
Waste gas cartridges
At a recent session of the Working Party on the Transport of Dangerous Goods (WP15), Ireland had opened discussion on the development of provisions for the transport by road of waste gas cartridges (UN 2037) similar to those already in place for waste aerosols (UN 1950). As this was thought to be a multimodal issue, Ireland was asked to bring the proposal to the UN. Ireland’s proposal included textual changes to special provision 327 and LP200 and a new special packing provision for P003.
There was support in principle for the proposal but it was felt that the text that was offered needed work. A revised proposal would be made to the next session.
ISO reported that Denmark had experienced a number of incidents involving composite cylinders without liners, manufactured form two parts joined together with an adhesive, constructed according to EN 12245 and in LPG service. The European Committee for Standardisation (CEN) has initiated a revision of EN 12245; meanwhile, a recent Joint Meeting of RID/ADR/ADN decided to forbid the manufacture of such cylinders.
The Model Regulations refer to ISO 11119-3, which is very similar to EN 12245 and ISO suggested a similar action should be taken by means of new Notes to 126.96.36.199 and 188.8.131.52. Its proposed texts were adopted in square brackets, pending confirmation at the next session.
Gas-based suppression systems
The European Chemical Industry Council (Cefic) observed that chemicals under pressure, without subsidiary hazard, and widely used in gas-based fire suppression systems are now assigned to UN 3500; this entry includes a maximum periodic inspection interval of five years. However, other gas-based suppression systems assigned to UN 1956 have a ten-year inspection interval. Cefic proposed aligning these two provisions by means of the amendment of packing instruction P206.
There was support in principle for the change but no consensus on how to achieve it. Cefic was invited to take account of the discussion and come back with a revised proposal at the next session.
LABELLING AND PLACARDING
Special provision 363
Germany felt that the placarding requirements for engines and machinery of UN 3528, 3529 and 3531 are misleading, particularly the statement that placarding shall be “in accordance with 184.108.40.206.2”. ADR/RID refer instead to 220.127.116.11, which is the equivalent of 18.104.22.168.1 in the Model Regulations, but this is not clear either. Germany offered some amendments to the texts in the last paragraphs of SP 363(j) and (k).
The Sub-Committee agreed that the proposed amendments would improve the understanding of placarding provisions. In the last paragraph of both SP 363(j) and (k), “in accordance with 22.214.171.124.2” is deleted and the following sentence added at the end: “Placards shall correspond to the class indicated in Column 3 of the Dangerous Goods List of Chapter 3.2 and shall conform to the specifications given in 126.96.36.199.1.”
Russia felt that 188.8.131.52.1.3 and 184.108.40.206.1.5 were confusing, in terms of their treatment of the recently adopted label model 9A, which is specific to lithium batteries, and offered some textual changes to help clarify the requirements. The Sub-committee disagreed, feeling that the proposed changes did not help. The Russian expert maintained that further alignment with the description in the table in 220.127.116.11.2 could be possible and a revised proposal may be forthcoming.
Russia had also been wrestling with inconsistencies in the translation of the term ‘placard’ in other languages, not least Russian, where it is expressed as ‘information board’. In comparing the ways in which other languages deal with ‘placards’, Russia preferred the German version – ‘grosse Zettel’ or ‘big label’. The Sub-committee took note of Russia’s paper and asked the Secretariat to see that the proper terms are used in the next revised edition of the Model Regulations.
Stacking load of IBCs
Following up on its informal document from the previous session, the International Confederation of Plastics Packaging Manufacturers (ICPP) proposed a revision of 18.104.22.168.2 to clarify the role of the stacking symbol for intermediate bulk containers (IBCs). ICPP’s simple solution was to delete “when the IBC is in use” from the first sentence of 22.214.171.124.2, which the Sub-committee agreed to adopt. The Sub-committee spotted that the same change should be made to 126.96.36.199, which relates to large packagings.
A proposal from Cefic to introduce a new definition of ‘carriage’ specifically for use in the context of 188.8.131.52.2 did not receive support, as the definition offered was significantly different from that already used in legal instruments relating to land transport.
Maintenance of IBCs
Belgium followed up on its informal document that had been discussed at the previous session, relating to the marking of IBCs to identify the party performing routine maintenance. The proposal contended that there is no value in knowing the identity of the party performing routine maintenance when that is done on behalf of the owner (not least as the definition of ‘routine maintenance’ includes cleaning).
The Sub-committee did not agree with Belgium’s argument, pointing out that similar situations can be found elsewhere in the Model Regulations relating to other means of containment. To introduce an additional clarification for IBCs only would be misleading, it was felt.
Marking of composite IBCs
Another paper from Belgium queried the intent of 184.108.40.206.4, which requires that the marks that are placed on the inner receptacle of a composite IBC shall be “placed in a location so as to be readily visible when the inner receptacle is placed in the outer casing”. Belgium noted that most composite IBCs have a rigid inner plastics receptacle housed in an open cage and that in such cases the marks on the inner receptacle remain visible. However, other types of composite IBC exist that have full external walls (either metal or plastics), which are designed for specific applications. In these IBCs, the mark of the inner receptacle is not readily visible once the IBC has been assembled.
The Sub-committee confirmed that the aim of 220.127.116.11.4 is that the marks should remain visible throughout the life of the IBC and not just during assembly. Belgium withdrew its proposal, although the problem of how to meet the requirements in an IBC with full external walls persists.
Italy felt that the current text in various paragraphs in 6.1.4 relating to the compatibility of the packaging material and the material to be carried is inadequate, particularly given the potential corrosion issues with some common substances that might be carried in aluminium drums.
There was a difference of opinion within the Sub-committee. Some experts felt that Italy had hit on an important point but that it had more general applicability and it would therefore be more appropriate to insert a general requirement in Chapter 6.1; others, conversely, felt that there was no need for an amendment as the issue is already adequately covered in the general requirements in 18.104.22.168.
After some discussion, the Sub-committee adopted a new paragraph 22.214.171.124.6:
If materials used for body, heads, closures and fittings are not in themselves compatible with the contents to be transported, suitable internal protective coatings or treatments shall be applied. These coatings or treatments shall retain their protective properties under normal conditions of transport.
The existing 126.96.36.199.6 and 188.8.131.52.7 are renumbered to take account of this addition. The Sub-committee also invited experts to review Chapter 6.1 and see if there are other places where a similar text should be inserted.
An informal document from the UK noted that the 53rd session of the Sub-committee had been presented with six papers dealing with Chapter 6.5, noting that the text of Chapter 6.5 has not been subjected to review for around 20 years. In that period, the number and types of IBCs in transport have proliferated. The UK felt it would be an opportune time to conduct a broader review of the whole of Chapter 6.5 and offered to organise an intersessional working group.
Most of the experts who expressed an opinion felt that there was no need for such a review on the basis of safety, as IBCs have a generally good safety record. The UK expert explained that the proposed review could help harmonise the approaches taken in Chapter 6.1 and 6.5 and better align with 6.6 and 6.7. However, taking into account the comments made, the UK may return with a list of specific items to be addressed.
Cefic and the Dangerous Goods Advisory Council (DGAC) returned to the topic of the multiple marking of packagings, including IBCs and large packagings, indicating conformity with more than one successfully tested design type. The issues raised had been acknowledged and there was a general consensus that mention should be made in the Model Regulations of the possibility that packagings could conform to more than one design type. Cefic and DGAC offered some concrete proposals for amendment of the existing text.
The Sub-committee agreed with some of those proposals and, after some further amendments, adopted a number of changes. A new sub-paragraph 184.108.40.206.1 reads:
Packagings, including IBCs and large packagings, may conform to one or more than one successfully tested design type and may bear more than one mark.
Interim text adopted at the previous session was further amended and adopted:
220.127.116.11 Where a packaging conforms to one or more than one tested packaging design type, including one or more than one tested IBC or large packaging design type, the packaging may bear more than one mark to indicate the relevant performance test requirements that have been met. Where more than one mark appears on a packaging, the marks must appear in close proximity to one another and each mark must appear in its entirety.
The new 18.104.22.168.3 contains much the same text but is specific to IBCs, and a similar 22.214.171.124 is specific to large packagings.
Minimum wall thickness
The Stainless Steel Container Association (SSCA) returned with data to support its earlier proposal made in 2013 to remove the requirement that metal IBCs should have a minimum wall thickness of 1.5 mm. SSCA believes this requirement is a vestige from earlier provisions when metal IBCs were seen as small tank containers; its paper noted that there are no similar minimum wall thickness requirements for other types of IBC.
The Sub-committee could not agree on a position, with some experts considering that the minimum wall thickness guarantees a minimum level of safety and others feeling that concerns are related more to the expected lifetime of a metal IBC than the thickness of the wall. Several experts asked for more time to consult stakeholders so the Sub-committee invited SSCA to submit an official document for the next session.
Date of manufacture
Belgium raised the issue of the ‘clock’ marking on the inner receptacles of composite IBCs; this mark shows the month and year of manufacture. Industry has queried why the date of manufacture is still required within the UN mark, especially if the clock is positioned adjacent to the UN mark.
The Sub-committee agreed with Belgium’s argument and adopted a new text for the note explaining the asterisk after the clock image in 126.96.36.199(e). The second sentence is replaced by:
In such a case and when the clock is placed adjacent to the UN design type mark, the indication of the year in the mark may be waived. However, when the clock is not placed adjacent to the UN design type mark, the two digits of the year in the mark and in the clock shall be identical.
In the second paragraph of 188.8.131.52.4, the second sentence is amended to read:
In such a case, the date may be waived from the remainder of the marks.
The pressure-relief devices of portable tanks used for Class 8 substances must be inspected annually, according to 184.108.40.206.1. However, Canada said, the text does not specify how they are to be inspected, which results in different approaches being taken. Its paper suggested referring to 220.127.116.11.8(e).
There was support for clarification of 18.104.22.168.1 but not in the way that Canada proposed. The proposal was therefore withdrawn but may reappear in a different form at the next session.
Belgium proposed that the Model Regulations should adopt the requirement introduced in the 2017 version of RID/ADR/ADN that, for tank wagons and tank containers carrying refrigerated liquefied gases, the consignor must enter in the transport document the date at which the actual holding time ends, in a specified format.
The Sub-committee agreed this would be useful and adopted two new paragraphs:
22.214.171.124.3 The date at which the actual holding time ends shall be entered in the transport document (see 126.96.36.199.13).
188.8.131.52.13 Actual holding time
In the case of portable tanks carrying refrigerated liquefied gases the consignor shall enter in the transport document the date at which the actual holding time ends, in the following format:
“END OF HOLDING TIME: ………….. (DD/MM/YYYY)”
Special provision TP19
Belgium returned to another topic it had raised earlier, namely the intent of portable tank special provision TP19, which requires that the calculated shell thickness of a portable tank must be increased by 3 mm when used for the transport of UN 1017 chlorine or UN 1079 sulphur oxide. Does this additional 3 mm apply at the point of construction or should it be there during the life of the tank?
The Sub-committee agreed that clarification would be useful and adopted a new text for TP19 in 184.108.40.206:
At the time of construction, the calculated shell thickness shall be increased by 3 mm as a corrosion allowance. Shell thickness shall be verified ultrasonically at intervals midway between periodic hydraulic tests and shall never be lower than the calculated shell thickness.
Expired inspection dates
In an informal document, the UK said it had recently become aware of situations relating to the use of portable tanks that are not covered by the text in Chapter 6.7. The UK sought the opinions of the experts on two cases:
- The conditions that should be applied to portable tanks that have gone past their required inspection date but are intended to continue to be used for the transport of dangerous goods, and
- Portable tanks that intend to switch from general cargo to dangerous goods, which may have originally been inspected and certified for dangerous goods but have not been in such use and may have missed one or more inspections.
Several experts felt that, in the second case, portable tanks should be subject to the five-year inspection and test before being put into dangerous goods service. Others, however, pointed out that they had not had time to consider the issue before the session. The UK expert was invited to take those comments into account and to submit an official document for the next session.
A similar fate befell an informal document from Russia seeking to amend 220.127.116.11(b)(ii) dealing with the design pressure calculation, its belief being that the current text is not applicable to portable tanks. There was some support in principle and the Russian expert was invited to submit an official document at the next session.
Russia noted the wide support given by the Sub-committee to its proposals for a new Chapter 6.9, giving provisions for the design, construction, inspection and testing of portable tanks with shells made of fibre-reinforced plastics (FRP) intended for the transport of substances of Classes 3, 5.1, 6.1, 6.2, 8 and 9. It now came with a further proposal for a parallel Chapter 6.10 covering FRP portable tanks for the transport of Class 2 non-refrigerated liquefied gases.
The meeting of the working group on FRP portable tanks took note of Russia’s proposal but intends to focus on Chapter 6.9 first. The working group also looked at the logistics involved in bringing experts together and said it would look to hold a two-day session concurrent with the 54th session of the TDG Sub-committee.
The IMO representative welcomed the work on FRP tanks, noting that related discussions by IMO’s Maritime Safety Committee was held in abeyance pending a decision by the Sub-committee. IMO is keen to see this completed in time to allow provisions to be included in the IMDG Code for mandatory application from 1 January 2024.
Minimum shell thickness
At the previous session, Belgium proposed insertion of a reference to 18.104.22.168 in 22.214.171.124.1 on the minimum shell thickness of portable tanks used for the transport of non-refrigerated liquefied gases. Most experts supported the proposal and had asked for a formal proposal, which was now forthcoming. However, the Sub-committee, while agreeing that the current text would benefit from clarification, could not reach a consensus on the Belgian proposals. Belgium will revisit its proposal at the next session.
Germany had spotted two errors, which the Sub-committee acknowledged and adopted as corrections to the 20th revised edition of the Model Regulations. In LP 905, “cells and batteries” is replaced by “cells or batteries” twice. Special provision 323 contains an expired transitional provision and was deleted; reference to SP 323 from Column (6) in the Dangerous Goods List against UN Nos 3101 to 3120.
Portable tank instructions
Germany also noted that portable tank instructions TP35 and TP37 contained expired transitional provisions and that transitional provisions in TP38 and TP39 were due to expire on 31 December 2018. All could therefore safely be deleted in the 21st revised edition of the Model Regulations. Again, this was agreed by the Sub-committee.
France had been looking at the use of French and English in the definition of the term ‘U’ in 126.96.36.199.2.1 and 188.8.131.52.1.1; the English text refers to ‘thermal conductance’ and the French to ‘conductivité thermique’. In France’s opinion, neither of these is accurate. The Sub-committee agreed to amend the English term “thermal conductance” to “heat transfer coefficient”, while the French text remains under review.
Germany and Cefic noted that 184.108.40.206 includes a definition for ‘structurally serviceable’ for cargo transport units used for the transport of explosives; this is the case in the IMDG Code but RID/ADR the corresponding requirements have been implemented for all classes of dangerous goods. Germany and Cefic aligned themselves with the RID/ADR position but had other questions on the extent and applicability of the requirements.
Several experts noted that the concept of ‘structurally serviceable’ in 220.127.116.11(b) had originally been introduced to address the transport of explosives in bulk and expressed concern about the impact of extending its scope to dangerous goods of all classes. It was suggested that the Working Group of Explosives should be asked to review the issue. Some experts felt it would be more appropriate to replace the current specific criteria with a more general requirement. The German expert said she would continue to work on the issue and invited other interested delegations to help in generating a revised proposal.
Definition of flash point
Russia queried why the Model Regulations have no definition of ‘flash point’, especially as the term is used more than 200 times in the Model Regulations. There is a list of international and national standards used for the determination of flash point in 2.3.3 but nothing in 1.2.1. RID/ADR/ADN does include a definition but, according to the Russian paper, it is not wholly acceptable.
The Sub-committee did not support the proposal, with some experts concerned at the potential unintended consequences of adopting a definition that could conflict with the standards listed in 2.3.3.
The European Industrial Gases Association (EIGA) proposed that the Model Regulations should adopt the exemption provided by special provision 653 in RID/ADR/ADN for small cylinders of carbon dioxide, argon, helium and nitrogen. All are inert gases that present little risk in transport.
Most of the experts who expressed an opinion felt that, while the exemption could be justified in land transport, it would be unwise to extend it to other modes. Others felt it would be dangerous to ignore filling provisions and training requirements. The EIGA representative said he would take account of these comments and submit a revised proposal for the next session.
Training in Canada
Following the implementation of competency-based training standards by ICAO and similar initiatives by the Dangerous Goods Trainers Association (DGTA), Transport Canada is reviewing it domestic training provisions and provided an update on work to the Sub-committee. One concrete proposal is that, in collaboration with the Canadian General Standards Board, a dangerous goods training standard is currently being developed that may be incorporated by reference into Canada’s domestic TDG regulations.
The experts from Brazil reported that similar discussions had begun at national level. Meanwhile, ICAO said that the guidance material on competency-based training published in 2017 had been revised to take account of feedback received. The Sub-committee urged those countries looking at this topic to continue to provide it with information.
An informal document from DGTA suggested establishing an informal working group on the subject but the overall feeling of the Sub-committee was that this would be premature.
In implementing the new section 7.1.5, adopted by the Sub-committee in December 2016 and applicable to self-reactive substances, organic peroxides and other substances stabilised by temperature control, WP 15 had determined that the measures in 18.104.22.168.5(c), (d) and (e) were meaningless without some mention of thermal insulation and had added additional text to those sections in ADR. The Netherlands now came to the Sub-committee to suggest similar adjustments for the Model Regulations.
Opinions were divided within the Sub-committee; some were in favour of the changes while others felt they were unnecessary. There was certainly a feeling that stakeholders at national level should be consulted before agreeing any changes. As such, the amendments were placed in square brackets pending confirmation at the next session.
The International Atomic Energy Agency (IAEA) presented a list of proposed amendments to the Model Regulations to align with the 2018 edition of the IAEA Regulations for the Safe Transport of Radioactive Material (SSR-6, Rev 1). The IAEA representative expressed some concern about the potential consequences of the revised wording for 22.214.171.124 on emergency preparedness for consignors and carriers and the Sub-committee agreed; it was decided to defer a decision on 126.96.36.199 and 188.8.131.52 to the next session to allow time for experts to consult with stakeholders.
A large number of other amendments were adopted; many of them are editorial in nature, but there are many very technical and detailed changes. Those involved in the transport of radioactive materials are advised to consult SSR-6, Rev 1 for full details.
France reported on continuing work on the testing of oxidising substances, focusing on consequential amendments to Tests O.1 to O.3 after the replacement of cellulose as the reference material and taking into account the needs of the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). France’s paper offered proposals for changes to the texts relating to those tests in the Manual of Tests and Criteria; various opinions on these proposals were expressed and the proposals will now be revised in light of the comments made.
TDG AND GHS
The TDG and GHS Sub-committees held their third joint session to discuss matters relevant to both regulations.
Sweden reported on progress with the revision of Chapter 2.1 of GHS, which contains the classification and labelling provisions for explosives. The GHS experts originally based this chapter on the classification system used in the Model Regulations, which relies on explosives being packaged or configured for transport. Their packaging often has an important role in their classification. However, GHS needs to recognise explosives that are not packaged for transport and discussions have been going on for three years as to how best to achieve this.
Sweden’s paper included a tentative system of classification of explosives for GHS purposes; it was pointed out that the suggested system would not require additional testing and would ensure consistency with the transport regulations. There were a number of observations on particular aspects of the proposals during the joint session, which will help inform ongoing work. A further paper was planned for the next session.
EIGA reported on the update to standard ISO 10156:2010 Gas cylinders – Gases and gas mixtures – Determination of fire potential and oxidising ability for the selection of cylinder valve outlets. The 2017 edition includes a new test method to determine the flammability limits of gases and gas mixtures in air and a new calculation method to determine the lower flammability limits of gas mixtures. EIGA asked if it would be appropriate to update the reference to the standard in Chapter 2.2 of the Model Regulations and Chapter 2.2 of GHS.
The TDG Sub-committee agreed to the change, with some additional consequential amendments elsewhere in Chapter 2.2; amendments concerning GHS were held over for endorsement at the subsequent meeting of the GHS Sub-committee.
Cefic and EIGA offered proposals to classify chemicals under pressure within Chapter 2.3 of the GHS, analogous to the provisions adopted by the TDG Sub-committee for the new UN numbers 3500 to 3505. Their reasoning was that chemicals under pressure used for spray applications present hazards that are similar to aerosol dispensers. Due to the similarities in hazards, aerosols and chemicals under pressure can be combined in the same chapter of the GHS using similar classification criteria for the hazard of flammability.
There was a lengthy discussion of the issues raised, which will be taken into account in a revised proposal at a future session. One item that was raised is that there may have to be an amendment to special provision 362 in the Model Regulations.
In an informal document, Germany continued its discussion of ways to handle the classification of physical hazards according to the GHS, in particular to identify the possible and impossible combinations of physical hazards. Germany offered to lead a correspondence group to continue with the work.
There was general support for the programme of work outlined by Germany and a number of comments were made. In particular, there is a difference between GHS and the Model Regulations insofar as the transport provisions recognise a precedence of hazards. There was, however, no decision on the establishment of an intersessional working group.
Use of the MTC
The chairman of the Working Group on Explosives submitted a document with a proposed list of amendments to Sections 1 and 10 of the Manual of Tests and Criteria to take account of its use in the context of GHS. The joint session noted the progress made and that work on other sections of the Manual was expected to be completed before the end of the biennium.
The fourth and final session of the TDG Sub-committee of the 2017/18 biennium was held from 26 November to 4 December and was followed by the ninth session of the Committee of Experts on TDG and GHS, which adopted the amendments that will appear in the 21st revised edition of the Model Regulations. A report on those meetings will appear in a forthcoming issue or issues of HCB.
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