Recap of the ECOSOC Sub-Committee of Experts on the Transport of Dangerous Goods

A New Biennium

With the retirement of Mr. Hart of the UK, a new UN Sub-committee of experts on the transport of dangerous goods biennium began on 22nd June under the chairmanship of  Mr. Pfund from the US.  Mr. Pfund follows in the footsteps of such luminaries from the US DOT as Mr. Al Roberts and Labelmaster’s own, Mr. Bob Richard.  Despite the burden of having to work in a foreign language, British English…  Mr. Pfund guided the amazingly diverse group to a successful mid Friday afternoon conclusion.  Almost 200 dangerous goods experts from around the globe representing some 27 States and a like number of international organizations, participated.  Yours truly was privileged once again to attend, facilitating the work of the Dangerous Goods Advisory Council as they brought some key issues before the Sub-committee.

Being the first of four meetings, as expected, discussions were mostly of a general nature and few concrete decisions were taken.  Indeed, any decisions can be revisited with further proposals in subsequent meetings.

Some of the highlights:

Seed cake (WP2015/7) – While in principle, this proper shipping seems to be a historical anomaly dating back to the early days of the Regulations, the proposal to change to a less specific but descriptive term was met with some concern.  Both regulators and industry identified the very real likelihood that this would regulate materials from a broad range of agricultural sources which would never otherwise be considered as dangerous goods in transport.

Environmentally Hazardous Articles (WP2015/8) – Are articles containing substances which are designated environmentally hazardous themselves environmentally hazardous?  That was the question posed by this paper.  The answer seemed to be, no, that’s not what was intended, but the text needed looking at.  In consequence, we can expect to see further discussion on this topic next December.

Infectious waste (WP2015/18) – The recent outbreak of Ebola had global implications for the dangerous goods industry.  The problem of transporting and disposing of large quantities of potentially contaminated waste materials is not easily addressed under the current regulations.  Interestingly, many countries had experienced similar difficulties to the sponsor of the paper, Switzerland.  More discussion and research will be needed in order develop a framework to address the problem.

GHS Pictograms as Placards – A paper sponsored by DGAC demonstrated the bizarre use of GHS style pictograms as placards on ISO containers.  This highlighted the growing problems that industry is seeing worldwide with respect to the application of GHS marking requirements.  These are of course workplace communication standards and were never intended to be used in transport.  However, more and more cases are appearing.  The solution to the matter as far as the sub-committee was concerned, was to pass it along to the GHS sub-committee…   That group met the following week and concluded that there was merit in adding explanatory text to the GHS document and invited DGAC to return with an updated proposal.

Corrosivity criteria (WP2015/21) – This subject has a long history.  In a nutshell, assigning packing groups to corrosive mixtures under the GHS criteria is impractical.  It is not simply a matter of using pH values.  Transport conditions are such that sometimes very low/high pH values are in fact not hazardous and sometimes the opposite is true.  After much discussion, the problem was passed on the GHS group, which promptly passed it back to the Transport group.  The dangerous goods equivalent of Wimbledon…

The discussions will be revisited in December.  May I say that this observer is happy to observe although I know this subject is of great concern to many Labelmaster partners.

Hazard communication (WP2015/16) – A novel approach was suggested which was intended to improve hazard communication for elevated temperature and environmentally hazardous materials.  This involved changing the design of the class 9 label.  I often receive comments to the effect that Labelmaster must be pleased to see new labels being proposed.  Not in the slightest, a label is a label, regardless of the picture printed on it.  And in this case, there was little interest from the sub-committee in pursuing the concept.

Label presentation (WP2015/Inf 19) – As the Author of Labelmaster’s AIR Shipper publication, I particularly enjoyed hearing this proposal which suggested that the label illustrations in the model regulations be presented in a tabular form.  Of course, this is how they are shown in AIR Shipper and users do indeed find them to be more user friendly.  INF papers are simply discussion starters and we can expect to see a formal proposal in December.

Chemical and First Aid kits (WP2015/Inf 11) – At the ICAO 2015 working group meeting, it had been noted that the quantities ICAO permitted in chemical and first aid kits were at odds with those identified in the Model Regulations.  It had been suggested that the ICAO TI be aligned with the model regulations.  It was industry intervention that suggested perhaps it was the UN which was unnecessarily restrictive and a more rational approach might be applied.  IATA’s Inf 11 asked this question and the answer was that  the sub-committee would like to see a formal proposal.  This is a topic with considerable impact on industry.

Lithium batteries (WP2015/20) – Any UN meeting on dangerous goods transportation must include a discussion on lithium batteries and this meeting was no exception.  A highly technical subject, the UN has an informal working group which considers revisions to the tests which are so essential to the safety of these ubiquitous items.  Discussions are ongoing with the next meeting scheduled for 26-28 August  in Washington.  Of particular note however, was the fact that it was agreed that the working group could extend its work program to include damaged and defective batteries.  There appears to be considerable confusion as to what is meant by damaged and/or defective with consequent problems in determining the transport conditions for the shipment of these items.  This is an important topic for many of Labelmaster’s partners and Mr. Richard of our LMS division will be on hand in Washington to provide impact assessment and other expertise.

Of course, there was much more going on in Geneva.  You may be interested in items which I haven’t touched on.  If so, I recommend reviewing the formal reports of the meeting, and indeed the papers themselves which can be found at:

http://www.unece.org/trans/main/dgdb/dgsubc3/c3rep.html

http://www.unece.org/trans/main/dgdb/dgsubc4/c4rep.html

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