New people join the ranks of Dangerous Goods professionals every day—in many cases, with little or no preparation. Perhaps their first introduction is a well-thumbed copy of Labelmaster’s MasterRegs version of 49 CFR, along with the orange-colored volumes of the United Nations Model Regulations on the Transport of Dangerous Goods (UNMR).
The UNMR is the source for both modal and domestic Dangerous Goods regulations, developed and revised by the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCoE).
This group meets twice a year in Geneva. The cooperation during these meetings between government regulators, international organizations and industry representatives results in remarkable work that not only ensures safety in Dangerous Goods transport across the globe, but also contributes to efficient, effective and economically beneficial commerce.
Here are some highlights of July’s 51st Session of the UNSCoE. You can obtain copies of working documents, informal documents and the meeting agenda from the United Nations Transport Division’s website. Reports can be found here
Lithium battery regulations
No one involved in Dangerous Goods transport will be surprised that lithium batteries provided most of the session’s in-depth discussions. While we wait for the full report of the meeting to be published on the UNSCoE’s website, here is a brief summary of the preliminary decisions.
New hazard-based system to classify lithium batteries
The lithium battery working group of the Sub-Committee has been considering the hazards of lithium batteries from first principles. These vary considerably depending on a number of factors including chemistry, state of charge, etc.
The Sub-Committee agreed that the primary hazards that should be addressed under the new classification system are thermal, mechanical and chemical. Secondary hazards were identified as electrical and smoke/vapor.
A small team will meet in Paris in November to review available test data and literature, with a view to drafting a paper for the 52nd Session. In addition, the lithium battery working group will meet December 6–8, 2017, in Geneva after the UN Sub-Committee’s meeting.
The compliance date for the requirements of the lithium battery test summary was extended by one year to January 1, 2020. The Sub-Committee also agreed that the test summary will not be required for batteries manufactured prior to January 1, 2003.
The Sub-Committee also agreed to several amendments to the actual test summary, particularly to clarify its requirements for manufacturers and distributors of products powered by lithium batteries.
New lithium battery packaging
A late Informal Paper addressed UN packaging tests for certain Dangerous Goods that could “self-initiate or fail such that they evolve excessive heat, catch fire, or explode within the packaging.” Essentially, the paper proposed that the packaging standard should originate in the UN Model Regulations and be developed by the Sub-Committee.
There are number of implications to this work, since it may propose extending the packaging provisions from consideration of just the normal conditions of transport to accident conditions—a quantum change in packaging focus.
This paper appears to be in response to the ongoing work undertaken by ICAO, which is developing a packaging standard for lithium batteries by air—the results of which will be available for consideration for the 52nd Session in December 2017.
Cargo tracking devices/data loggers powered by lithium batteries
The Sub-Committee agreed that battery-powered data loggers and cargo tracking devices attached to packages and freight containers should not be subject to the UN Model Regulations—provided the batteries have been tested in accordance with the UN Manual of Tests and Criteria and are designed to prevent damage under normal conditions of transport.
Hazard label specifications
A late paper addressed the 2 mm width requirement for the line inside the edge of hazard labels, introduced in the 19th edition of the Regulations. The 2 mm specification was causing unnecessary delays to many consignments, particularly those by air, which uniquely required a specific acceptance check by airline staff.
The Sub-Committee agreed to remove the 2 mm minimum requirement, as follows:
188.8.131.52.1.1.2 The label shall be in the form of a square set at an angle of 45 degrees (diamond-shaped). The minimum dimensions shall be 100 mm x 100 mm. There shall be a line inside the edge forming the diamond which shall be parallel and approximately 5 mm from the outside of that line to the edge of the label. Lithium Battery Mark and Size for UN Number
A proposal to require a minimum size for the UN numbers required on the lithium battery mark was not supported by the Sub-Committee, and the paper was withdrawn.
U.S. representatives bring expertise, leadership and energy
The ongoing success of the UNSCoE is due in no small measure to the expertise, leadership and energy of the United States representatives. Of the six chairmanships, the U.S. DOT through PHMSA has held the chair of the Sub-Committee three times, most notably in the person of the current chairman, Duane Pfund.
This U.S. leadership is not limited to the chair, however—the very layout and structure of the UN’s orange UNMR books, now in their 20th edition, owe their clarity and effectiveness to the work of the Washington-based Dangerous Goods Advisory Council. (There was a faint hope that this might carry over to 49 CFR… but that hasn’t happened yet.)
Olivier Kervella—who has been Secretary to the Sub-Committee since its inception—has reached “a certain age” and will be required to retire midway through the following session. While there is hope that this requirement might be waived, the continuity and experience provided by Duane Pfund will be critical in ensuring the Sub-Committee continues to deliver its safety and economic benefits for world commerce.
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