From Nov. 28 to Dec. 7, 2011, the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (the “Sub-Committee”) met in Geneva, Switzerland, to continue its work on the development of the 18th revised edition of the Recommendations on the Transport of Dangerous Goods – Model Regulations (the “Model Regulations”).
The Sub-Committee agenda addressed 26 formal proposals in five general topic areas, as well as more than 40 informal papers. The general topics discussed were:
- Listing, classification and packing
- Electric storage systems
- Miscellaneous proposals of amendments to the Model Regulations
- Cooperation with the International Atomic Energy Agency (IAEA)
- Global harmonization of transport of dangerous goods regulations
The following is a summary of the papers discussed and their outcomes:
Listing and Packing Provisions: Asbestos
(ST/SG/AC.10/C.3/2011/44 – Australia) – Australia proposed substantive amendments to the Model Regulations as they currently apply to asbestos (UN 1212 and 2590). Australia stated that the current Model Regulations requirements introduce inconsistencies and possible confusion as to how the current provisions apply to the international intermodal shipment of asbestos and asbestos-containing materials. Currently asbestos is assigned to Class 9 dangerous goods as “a substance which on inhalation as fine dust may endanger health.” Asbestos has been declared a proven human carcinogen by the International Agency for Research on Cancer of the World Health Organization. However, there was generally limited support for the proposed amendments and a number of experts (e.g. Canada, Russian Federation, China, Brazil and Spain) indicated that they could not support the proposed amendments, suggesting that Australia’s paper did not provide sufficient justification and they were not appropriate. Australia withdrew their paper and indicated that they would submit a revised paper for the next session.
Outcome of the Joint Meeting of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods on its Autumn 2011 Session
(ST/SG/AC.10/C.3/2011/47 – Secretariat) – This paper summarized discussions by the participants of the Joint ADR/RID meeting in relation to the adoption of recently agreed decisions by the Sub-Committee. The ECE secretariat frequently provides feedback relative to discussions and decisions taken during the Joint Meeting to the Sub-Committee in order to promote international harmonization. On the basis of this paper the Sub-Committee agreed to maintain the 450 L exception for viscous flammable liquids in Packing Group III. The Joint Meeting noted the request by the Sub-Committee for opinions on amendments to 220.127.116.11, 18.104.22.168 and 22.214.171.124 of the Model Regulations. The Joint Meeting noted that the limit of 450 L per package in 126.96.36.199 was also applicable to RID/ADR and that it should not be reduced to 30 mL.
Dried Blood Spots and Faecal Occult Blood Screening Tests
(ST/SG/AC.10/C.3/2011/27 – WHO) – The World Health Organization proposed to clarify the requirements applicable to the exceptions for dried blood spots samples and faecal occult blood screening samples. The proposal was simply intended to clarify the existing exceptions for the transport of these samples that are transported for patient diagnosis. Germany proposed alternative text in INF.34. A small drafting group was convened and developed text documented in INF.41 that was subsequently adopted by the Sub-Committee.
Amendments to the Classification Flow Chart/Decision Logic for Self-Reactive Substances and Organic Peroxides
(ST/SG/AC.10/C.3/2011/29 – ICCA) – The International Confederation of Chemical Associations (ICCA) proposed amendments to the classification flow chart/decision logic for self-reactive substances and organic substances on the basis of discussions amongst international experts that are members of the International Group of Experts on Explosion Risks of Unstable Substances Working Group of Energetic and Oxidising Substances (IGUS-EOS). Apart from a minor change that was introduced in the second part of both flowcharts in the ninth edition of the Recommendations (1995), these flow charts have remained unchanged since their first introduction more than 25 years ago. At the time of introduction of the flow chart, nearly all substances were transported and handled in packagings. However, over time the transport and handling in intermediate bulk containers (IBCs) and tanks became more and more common practice. It was felt in the discussion in IGUS-EOS that this should have some consequences for the classification flow chart. A number of experts including the United States expressed concern that the flowchart changes proposed by ICCA over simplified the classification process. ICCA agreed to submit a revised paper for the 41st session of the Sub-Committee.
Classification under UN 2211 and UN 3314
(ST/SG/AC.10/C.3/2011/30 – ICCA) – This paper from ICCA addressed requirements for polymeric beads, expandable and plastics moulding compounds, evolving flammable vapours. Currently these materials are assigned to Class 9, with UN numbers 2211 and 3314. Historically the proper shipping name for UN2211 was Polystyrene beads expandable, but along with the development of new products the Proper Shipping Name was changed to Polymeric beads expandable. Under these UN numbers 2211 and 3314, there is no distinction between those materials that evolve a lot of flammable vapour and those that evolve almost no or few flammable vapours. The risk for formation of an explosive atmosphere is very much depending on the product properties. ICCA explained that n new products that do not or hardly evolve flammable vapours are now being produced and that these products will never result in a Lower Explosive Limit (LEL) being achieved in a closed transport container or cargo hold. ICCA proposed to change SP207 for UN 2211 and 3314:
“Substances, where no risk of formation of a flammable (explosive) atmosphere in a container at storage temperature up to 50° C exists, are not subject to these Regulations. The test to confirm this absence of risk consists in storing the substance at 50° C for two weeks in a serum bottle with the same weight/volume relation as is to be expected in a container: the concentration of the flammable vapours shall not exceed 50% of the Lower Explosive Limit (LEL) of the flammable vapour evolved.”
A number of experts expressed concern that the test method used by the ICCA did not reflect actual transport conditions (particularly the 50° C upper test temperature) and on the basis of these comments the proposal was not adopted.
Proposal on Transporting Waste Lithium Cells and Batteries
(ST/SG/AC.10/C.3/2011/39 – PRBA – RECHARGE) – This paper requested feedback from the Sub-Committee on how to classify mixtures or solutions composed of a single predominant substance identified by a proper shipping name in the Dangerous Goods List and one or more substances not subject to the Regulations and/or traces of one or more substances identified by name in the Dangerous Goods List which was addressed at the 39th session. ICCA requested clarification from the Sub-Committee on how to deal with mixtures or solutions containing a listed predominant constituent and a small or trace amount of an environmentally hazardous constituent. ICCA explained that the issue is further complicated because environmentally hazardous substances need to be named on the transport document according to the IMDG-Code (i.e. “Marine Pollutant”) and for ADR/RID/ADN (i.e. “environmentally hazardous”). In order to avoid substances being assigned to different UN numbers for different transport modes, ICCA is looking for clarification from the Sub-Committee. In order to illustrate the issue ICCA provided the following example:
- A predominant component listed specifically by name in the Dangerous Goods List (e.g. 70 % Acetone)
- An environmental hazardous component (e.g. 25 % Triphenyl phosphate)
- One or more non dangerous components (e.g. 5 % water)
ICCA pointed out that by taking into account the text recently adopted in 188.8.131.52, the classification of the mixture/solution above can be made in two alternative ways:
Alternative I: Classification under the Most Appropriate Collective Entry
- The environmentally hazardous component is a second dangerous substance besides a predominant component subject to the Model Regulations and therefore the requirement, that the mixture/solution includes only one dangerous component is not fulfilled.
- The second component does not meet the description of “trace” as it causes the solution/mixture to be classified as environmentally hazardous.
- Sea transport requires different emergency actions for environmentally hazardous substances regarding stowage position, priority for salvage actions and notification to authorities in case of an incident.
The solution/mixture can therefore not be assigned to the specific entry of the predominant component and has to be classified under the most appropriate collective entry, “UN 1993 FLAMMABLE LIQUID, N.O.S. (Acetone, Triphenyl phosphate), 3, II.”
Alternative II: Classification under the Entry of the Predominant Substance
- None of the conditions of 184.108.40.206 (a) to (d) for not assigning the specific entry of the predominant substance are met.
The solution/mixture has therefore to be assigned to the specific entry of the predominant component, “UN 1090 ACETONE SOLUTION, 3, II.”
The discussion was quite interesting and pointed out the various views of the competent authorities attending the Sub-Committee meeting and on that basis the ICCA paper was very appropriate and welcomed. The Sub-Committee generally agreed that the current text needs clarification and welcomed ICCA’s efforts to clarify the existing text and to submit a proposal for the 41st session.
Special Provision 335: Exemption for Small Quantities of Environmentally Hazardous Substances
(ST/SG/AC.10/C.3/2011/42 – ICCA) – This paper proposed to amend SP 335 to address environmentally hazardous substances with no additional hazards which are often transported in very small quantities. SP 335 exempts these very small quantities when solids less than 10 g or liquids fully absorbed in a non hazardous solid and contained in sealed packets and articles. ICCA requested that the exemption for very small amounts of environmentally hazardous liquids to Special Provision 335. A number of experts expressed concern that the packaging should not be used as a means of absorbing any leaking liquids. A revised proposal will be developed for the 41st session.
Request for Consultative Status by the Dangerous Goods Trainers Association, Inc. (DGTA)
(UN/SCETDG/40/INF.4) – This paper requested consultative status for the Dangerous Goods Trainers Association. The application was unanimously approved. A number of experts indicated that they welcomed the perspectives of trainers to the Sub-Committee’s work.
IBC Packing Instruction Requirements for Solids That May Become Liquid
(ST/SG/AC.10/C.3/2011/45 – DGAC) – In this paper DGAC proposed to authorize certain IBCs intended for the transport of liquids to be used for the transport of certain solid materials (e.g. powdery substances, solids which may become liquid in transport or those that need to be heated for unloading). DGAC pointed out that in the 15th revised edition of the Model Regulations, a number of IBCs were removed from packing instructions IBC 04 to IBC 08. These include IBCs designed to contain liquids. DGAC is proposing that many of these IBCs may be more robust than IBCs designed for solids. The U.K. disagreed with the premise of the proposal and Belgium felt additional testing would be necessary to address the fact that the liquid IBCs would not be drop tested with a solid. For instance the U.S. expert expressed concern that a shipper would not easily be able to determine the maximum loading weight. DGAC decided to meet with the U.K. to determine if additional modifications could be made to the document. DGAC indicated that they would attempt to revise their proposal. Further discussions will continue later in the week. DGAC staff attempted to work out a compromise with experts that expressed concern with the proposal during the margins of the meeting but was not able to reach a consensus. As a result, DGAC requested a formal vote on their proposal and it was narrowly adopted by a vote of 8-7.
“Torch” Cigarette Lighters Containing Lithium Metal Batteries
(ST/SG/AC.10/C.3/2011/43 – United Kingdom) – The U.K. informed the Sub-Committee of a new type of cigarette lighter that is commercially available which contains not only a liquefied flammable gas but also a number of lithium metal batteries to power a torch (flashlight). The articles do not appear to fit readily under the existing classification for either UN1057 “Lighters containing flammable gas” or UN3091 “Lithium metal batteries contained in equipment.” The U.K. paper provided photographs of these items and explained that they can be quite large but most likely do not exceed the 10 g limit of liquefied petroleum gas specified in Special Provision 201. A number of experts expressed concern that the lighters could pose a significant risk in transportation particularly in air transport and in the case of passengers carrying them in their checked or carry-on luggage. There were also differing views on how the devices should be described and consigned. The U.K. indicated that they would submit a formal proposal addressing how these devices should be shipped for the 41st session of the Sub-Committee.
Proposal on Transporting Waste Lithium Cells and Batteries
(ST/SG/AC.10/C.3/2011/39 – PRBA – RECHARGE) – This paper was jointly submitted by the Portable Rechargeable Battery Association (PRBA) and the International Association for the Promotion and Management of Portable Rechargeable Batteries (RECHARGE). The proposal included a new Special Provision XXX and Packing Instructions P903a and P903b to take into consideration changes in international battery collection and recycling activities as well as changes in lithium ion technologies for consumer applications. There were numerous comments from various experts. It was agreed that a lunchtime working group would be convened to work through the many comments and differing opinions on how to develop appropriate requirements for transporting lithium batteries for recycling or disposal. Three working groups were convened where a number of issues were resolved and significant progress was made. PRBA and RECHARGE plan to take the text developed and to prepare a revised paper for discussion at the next session and they welcomed inter-sessional comments from experts.
Proposal on Transporting Damaged or Defective Lithium Cells and Batteries
(ST/SG/AC.10/C.3/2011/40 – PRBA – RECHARGE) – In their paper PRBA and RECHARGE explained that there are no provisions in the Model Regulations for transporting damaged or defective lithium cells and batteries. This issue was discussed at length during the 39th session of the Sub-Committee. Two key issues that the proposal addressed were defining a damaged or defective lithium cell or battery and establishing the necessary packaging and hazard communication for transporting them. PRBA and RECHARGE proposed to add a Special Provision and two new Packing Instructions for incorporation into the Model Regulations for transporting damaged or defective lithium cells and batteries. A number of experts expressed the need to develop appropriate requirements because damaged batteries are frequently shipped in transport and without the appropriate regulatory requirements being applied these shipments pose significant risk to the public. The U.S. expert explained the approvals they have issued for transporting damaged batteries and the need to ensure the packaging used is able to contain and reaction, evolution of heat or fire that may occur. Others highlighted the difficulty in requiring such packaging for large format batteries such as those used for electric vehicles. The Sub-Committee recognized that further work was needed to address the transport of damaged or defective batteries and it was agreed that this would be considered by the working group tasked with addressing waste batteries. While a working group was convened there wasn’t sufficient time to address the many differing views. PRBA and RECHARGE will develop a revised proposal for the next session.
Large Packagings for Lithium Batteries
(ST/SG/AC.10/C.3/2011/41 – PRBA – RECHARGE) – During discussions on lithium batteries at the 39th session, it was noted that a Large Packing Instruction was needed for lithium ion and lithium metal batteries to accommodate batteries whose net mass exceeds 400 kg or for lithium battery packaging with a capacity exceeding 450 L. Large format lithium ion batteries are becoming more common in the marketplace and the limitations of Packing Instruction 903 of the Model Regulations do not provide for these larger lithium ion batteries. In this paper PRBA and RECHARGE have the addition of a Large Packing Instruction LP903 for lithium batteries. A number of experts supported the proposal in principle but offered various suggestions for substantive and editorial changes to the proposed large packing instruction LP903. PRBA and RECHARGE developed a revised proposal and submitted it as INF.45. The revised proposal received significant comments due to confusion by some related to the last paragraph that addressed batteries with impact resistant outer cases. On this basis the 12 kg value was removed from paragraph 4 and the 400 kg limit in the introductory sentence. The paper was not adopted because experts could not agree on a few minor details based on suggested verbal edits. PRBA was requested to submit a revised proposal.
Lithium Battery Mark
(ST/SG/AC.10/C.3/2011/35 – United States of America) – At the 38th session, the Sub-Committee considered a document from France (ST/SG/AC.10/C.3/2010/80) in relation to a quality management program for the manufacture of lithium cells and batteries. In response to this proposal, the United States submitted an informal document INF.21 supporting France’s proposal and in addition proposing: (1) requiring retention of test documentation verifying battery designs have successfully passed the required design-type tests, and (2) requiring application of a mark on the battery to indicate that the battery design has successfully passed the applicable design-type tests. The SC adopted a requirement to retain test documentation and agreed to further consider a mark during the present biennium. At previous sessions some experts voiced concern regarding the appropriateness of the “UN” marking as the authorized mark to indicate battery design has successfully passed the required design type tests in the required manner. Specifically, there was some concern that the marking “UN” may imply that the batteries were tested under the auspices of the competent authority, while the testing is actually performed under the responsibility of the manufacturer. However, others indicated that use of the UN symbol may be preferable as there is widespread recognition of the symbol and its relationship to the Model Regulations, and its meaning for lithium batteries could be specifically identified in the Regulations to be the manufacturer’s certification. The expert from the U.S. requested that the SC take a decision in principle that a mark indicating that the battery design has successfully passed the required design type tests in a readily recognizable manner is considered beneficial and to discuss whether the “UN” marking is appropriate or whether another mark employing the letters “UT” would be more appropriate.
The paper recognized that a mark may not be appropriate for all lithium batteries – for example those not required to conform to a tested design type and those of such a small size that a marking is not feasible. To address this issue, an exception for batteries not required to conform to a tested design type and for certain small lithium batteries was suggested. With respect to implementation, the paper proposed that the mark apply to batteries manufactured after Jan. 1, 2016 – one year following modal implementation of the provisions of the 18th revised edition of the Model Regulations.
The experts from France, Germany, Austria, Norway and some others supported a certification mark but expressed concern about how the person applying the mark could be held accountable. The representative from COSTHA supported the U.S. proposal but questioned what specific size battery would not be required to be marked.
The experts from Belgium, Sweden, Switzerland, Netherlands, and Canada expressed doubt that the mark proposed by the U.S. would be effective in enhancing compliance and were not in favor of using the UN symbol as a certification mark. Canada expressed concern with using the “UT” mark because it can also mean “ultrasonic testing.”
China indicated that it would be more appropriate for a recognized independent certification authority to authorize the mark.
The Chairman summarized that there was a small majority in favor of a lithium battery certification mark and therefore asked the expert from the U.S. to submit a revised proposal for the 41st session of the Sub-Committee.
Large Salvage Packagings
(ST/SG/AC.10/C.3/2011/24 – Belgium, Germany) – This paper proposed to include requirements for large salvage packagings in the Model Regulations based on the definition of a large packaging and the test regime for currently defined salvage packagings including definitions, marking requirements, and testing requirements. With a number of editorial amendments from various experts the proposal was adopted.
References to ISO Standards – Section 6.2.2
(ST/SG/AC.10/C.3/2011/25 – ISO) – In this paper ISO proposed to add four new industry standards to the Model Regulations related to the design and construction of pressure receptacles and bundles of cylinders. The ISO representative withdrew one of the standards and proposed that the following be added with appropriate transitional provisions:
- ISO 9809-1:2010 Gas cylinders – Refillable seamless steel gas cylinders – Design, construction and testing – Part 1: Quenched and tempered steel cylinders with tensile strength less than 1 100 MPa;
- ISO 9809-2:2010 Gas cylinders – Refillable seamless steel gas cylinders – Design, construction and testing – Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1 100 MPa; and
- ISO 9809-3:2010 Gas cylinders – Refillable seamless steel gas cylinders – Design, construction and testing – Part 3: Normalized steel cylinders.
The representative from the Compressed Gas Association expressed concerns regarding several technical details related to the standards. After a long discussion the ISO representative withdrew the proposal.
Definitions – Section 1.2.1
(ST/SG/AC.10/C.3/2011/26 – ISO) – This paper proposed to amend two definitions in section 1.2.1 consistent with ISO 10286. A number of experts were not in agreement with the proposed change to the definitions for tubes so ISO withdrew the proposed change. The Sub-Committee agreed with the editorial amendment of the definition for “Multiple-element gas containers” (MEGCs). The Sub-Committee provided general support for the paper; however several members noted consequential amendments may be necessary. This concern was particularly directed at the inclusion of “composite construction” in the proposed definition for “tube.” The Sub-Committee stated they were reluctant to adopt the amendment to the definition of tubes. As a result, the definition for “Multiple-element gas container” was modified, but the definition change for “tube” was not.
Packagings with a Capacity Exceeding 450 Litres – 220.127.116.11 (D)
(ST/SG/AC.10/C.3/2011/34 – Germany) – In this paper Germany proposed to amend 18.104.22.168(d) of the Model Regulations to authorize packaging intended for solids that have a volume larger than 450 L. There are packagings, especially for articles, which are not designed for mechanical handling (1.2.1 Definitions) and have a capacity of more than 450 L (e.g. fibreboard boxes used for air-bags with a special shape, gross mass about 25 to 30 kg, box dimensions app. 2,300 mm x 800 mm x 300 mm = capacity 552 L). The majority of experts supported the proposal and it was adopted.
Sample Pressure Receptacles
(ST/SG/AC.10/C.3/2011/33 – Germany) – The Expert from Germany pointed out that competent authorities provide approvals of non-UN specification pressure receptacles on a case by case basis, but based on certain criteria. Since these cylinders would require multiple approvals from competent authorities, Germany proposed a method for reviewing and approving such approvals, and suggested posting approvals on competent authority websites and/or the UN website so that other competent authorities may review approvals from other states. Several experts generally supported Germany’s suggestion noting caution should be taken as the process moves forward. However others, in particular Canada, the UK, and the Netherlands were concerned that the proposed system would create a dangerous precedent. Ultimately, the Sub-Committee noted the issue was valid and needed some resolution. Germany agreed to consider the comments made during discussions and indicated that they would come back with a revised proposal at the next session.
Internal Inspection of Portable Tanks Used for the Transport of Water-Reactive Organometallic Substances
(ST/SG/AC.10/C.3/2011/28 – ICCA) – ICCA proposed that the Model Regulations be amended to waive the 2.5 year internal inspection for portable tanks used for the transport of liquid and solid organometallic substances provided that the portable tank remains in the dedicated service of transporting organometallic substances. Due to the water-reactive nature of organometallic substances, cleaning of tanks to permit an internal inspection creates additional safety risks. Therefore, ICCA proposed to eliminate the two-and-a-half year internal inspection requirement for organometallic substances through a new Tank Provision (TP) Code. France felt a competent authority should be necessary. China and Belgium were strongly opposed on the grounds that it fundamentally changed the inspection process. After extensive discussion, ICCA decided to prepare additional language for submission in INF.44. France and Belgium continued their objection and instead offered language modifications to 22.214.171.124.5. DGAC and others indicated that a requirement for a competent authority would be unnecessary and overly burdensome. After a vote of 8 to 4, the French language modification was adopted.
Marking of the Date of Manufacture with Packagings of Types 1H and 3H
(ST/SG/AC.10/C.3/2011/36) – ICPP submitted this proposal to align the current practice with the Model Regulations regarding the marking of the production date for packaging types 1H and 3H. This proposal was previously supported by the Sub-Committee; however several editorial suggestions were made to improve the text in 126.96.36.199(e) which includes packaging marking examples with the year of manufacture as a two digit number in the middle of the “clock.” Canada suggested an additional figure would not be necessary and instead language could be placed immediately after the existing “clock” in 188.8.131.52(e) and by placing an asterisk in the existing clock. The ICPP proposal with this modification was adopted by the Sub-Committee.
Fumigation Warning Mark and Coolant/Conditioning Unit Warning Mark
(ST/SG/AC.10/C.3/2011/31 – United Kingdom) – This paper proposed to deal with the fumigation warning mark and the coolant/conditioning unit warning mark recognizing several inconsistencies from previous documents on the Fumigant Warning and Coolant/Conditioning mark. Sweden also submitted INF.19 proposing additional changes to the fumigation mark. A number of experts commented on the size of the lettering within the marks while others indicated that the minimum size of 25 mm was sufficient. Significant questions were raised about the fact that the lettering should not be reduced. The Chairman requested industry to provide comments on how these practices are being implemented. Both papers were therefore withdrawn. The U.K. and Sweden agree to take the comments made into account and come back with revised proposals.
Revised Proposals for the Descriptions of Labels, Placards, Symbols, Markings and Marks
(ST/SG/AC.10/C.3/2011/32 – United Kingdom) – Following previous documents discussed at earlier sessions, the U.K. proposed amendments to clarify and improve the specifications for marks and label in the Model Regulations. Proposed amendments included reducing the limited quantity mark to 90 mm x 90 mm, allowing a boarder. COSTHA provided support for the document and further suggested the minimum size on the UN 3373 mark to be 45 mm x 45 mm. ICAO noted that they would be likely to retain the 100 mm x 100 mm size for the limited quantity mark. DGAC indicated that the illustrations should be stipulated as approximately proportional, not exact. Belgium, Austria, and the Netherlands were reluctant to reduce the minimum size on the LQ and EHS marks. The U.K. decided to withdraw the paper for additional review and input from Sub-Committee members.
Transitional Periods for UN Portable Tanks Intended for the Transport of Liquids
(ST/SG/AC.10/C.3/2011/37 – United Kingdom) – Changes to tank codes in previous sessions have created confusion at times as to why the codes where changed. Therefore, the U.K. proposed to adopt language in the Guiding Principles to outline when changes to tank codes would be required and provide a concept of defined transitional periods. Also, the U.K. proposes to apply the proposed transitional period (either 15 or 10 years) for several tank codes modified during the last biennium. The Sub-Committee was generally concerned the proposal was too prescriptive as to when tank codes could be changed. Further, the transitional periods were deemed too rigid. Germany pointed out today transitional periods are often set based on input from industry. The U.S. was more supportive of the document commenting that guidance is needed. The U.K. decided to withdraw the document for additional modification. However the proposals for extending a number of specific tank code transitions was rejected.
Provisions for Uranium Hexafluoride with Less Than 0.1 Kg per Package
(ST/SG/AC.10/C.3/2011/46 – IAEA) – IAEA proposed a new UN number for “Radioactive material, excepted package” for uranium hexafluoride (UF6) with less than 0.1 kg per package as approved by the IAEA Transport Safety Standards Committee at its 22nd session (TRANSSC 22) (June 2011). At the 39th session of the Sub-Committee (20 to 24 June 2011) (ST/SG/AC.10/C.3/78, para 86), it was recalled that the issue had been discussed at the 38th session of the Sub-Committee but the decision had been postponed at the request of IAEA since the transport conditions had not yet been approved by IAEA. The IAEA was therefore invited to submit a proposal for the fortieth session covering transport conditions in the light of the comments made by the Sub-Committee at the 38th session. The current logic of the IAEA Regulations for the Safe Transport of Radioactive Material (TS-R-I) and of the Model Regulations, is that uranium hexafluoride (UF6) shall always be transported as a Class 7 material under UN Nos. 2977 or 2978, as appropriate (see 184.108.40.206.5 of the Model Regulations). Nevertheless, this has led to divergent interpretations when this material is transported in packagings meeting the requirements for excepted packages, notably because this material is highly corrosive. Most experts agreed that the primary hazard should be Class 7 but were divided on whether a 6.1, 8 or both subsidiary hazards were appropriate. IAEA only proposed a Class 8 subsidiary risk. A lunchtime working group was convened. The working group presented its outcome in INF.48. There was a long discussion of more than 1 hour. While INF.48 addressed the majority of concerns there was still some concern related to how the labelling and marking should appear on packages and there was still debate on whether a toxic sub-risk is needed. The Sub-Committee agreed to adopt a new PSN and UN number, but agreed to defer the unsettled matters to the 41st session.
TRANSSC Review of Proposed Changes to the UN Model Regulations
(UN/SCETDG/40/INF.6 – Secretariat) – The Secretariat provided a document describing the review process for IAEA and UN bodies. The U.K. and Germany positively commented on the document but pointed out the document does not provide guidance on how to more closely cooperate with the IAEA verses simply reporting on progress in sessions. However, the Secretariat argued that without concrete proposals, there is little expectation that any formal cooperative discussions would be fruitful. IAEA pointed out that previous discussions were welcomed by the TRANSSC and would expect additional participation at the UNSCOE TDG in the future.
Special Provision 172
(UN/SCETDG/40/INF.27 – IATA) – In the document IATA indicated that Special Provision 172 is assigned against the entries for radioactive materials other than the entries for radioactive materials excepted package and the two entries for radioactive material, uranium hexafluoride. The special provision addresses radioactive materials with a subsidiary risk and identifies that additional hazard labels, placards must be applied and also that additional information relating to the subsidiary risk must be provided on the dangerous goods transport document. IATA explained that the wording of Special Provision 172 with respect to the additional information required on the document and the placement of this information creates confusion for shippers and carriers as the placement of the information is not consistent with that normally required for the sequence of the dangerous goods description set out in 220.127.116.11.1(a) to (d). The Sub-Committee is invited to consider if the wording of Special Provision 172 should be revised to make the provision of the information relating to the subsidiary risk class or division and packing group, when applicable, consistent with the basic sequence of the dangerous goods description set out in 18.104.22.168.1(a) to (d). IATA asked the Sub-Committee to consider if the name of the constituents which contribute to the subsidiary risk should be required to be associated with the proper shipping name of the radioactive material as would apply to a technical name where Special Provision 274 is assigned. Placement of the additional information associated with the subsidiary risk could then be included as part of the marking of the proper shipping name on the package, which may help to assist with hazard communication in the event of an incident. Since this was a late paper it was agreed to defer it to the next session.
Electronic Data Identification
(UN/SCETDG/40/INF.13 – United Kingdom) – The Sub-Committee has been kept up to date on the work being undertaken by the International Air Transport Association (IATA) on a pilot project for e-freight for dangerous goods transport (see UN/SCETDG/39/INF.34 for the latest update). At the same time, in the context of the European RID/ADR/ADN Joint Meeting, a Working Group has been established to look at the possible application of transport telematics for the safe and secure transport of dangerous goods by road, rail and inland waterways (see INF.7 submitted to the September 2011 Joint Meeting). In both cases, the work is some way off reaching a conclusion. One of the things that both work streams have in common is how to identify electronically specific information related to the transport of dangerous goods. The U.K. suggested using a five-digit electronic “short-hand” code. This code would be assigned to each each row in the Dangerous Goods List (DGL). There were mixed opinions on whether such an effort would be beneficial. DGAC indicated that it would not be a useful exercise and that such efforts should be left to commercial software developers. The expert from the U.S. was of the same opinion.
Information on Decisions Taken by the ICAO Dangerous Goods Panel (DGP)
(UN/SCETDG/40/INF.40 – ICAO) – The ICAO Secretariat brought a few issues to the attention of the Sub-Committee and indicated that she would be bringing formal proposals for the 41st session on the basis of comments. The following is a summary of the issues:
- The ICAO DGP agreed that there was no need for limited quantity provisions for 1.4S explosives.
- The DGP identified several instances where the excepted quantity provisions are not harmonized appropriately because some dangerous goods are not authorized for transport aboard passenger aircraft but are authorized as excepted quantities in the Model Regulations.
- The DGP expressed concern with respect to the note that was added to 22.214.171.124.3.3, “Medical equipment which has been drained of free liquid and meets the requirements of this paragraph is not subject to the regulations.” The DGP did not adopt the note in the ICAO TI. The concern was that in the absence of a definition which specifies their size, there was concern that the exceptions could be applied to smaller-sized equipment with Category B infectious substances present.
- The DGP ICAO felt that the De Minimis Quantities provisions did not belong in the excepted quantity provisions section of the ICAO TI. The DGP decided to keep the provisions in a similar location and adopt the provisions as suggested.
- The ICAO secretariat explained that in adopting the exception for orientation arrows for hermetically sealed inner packagings the DGP added additional text defining hermetically sealed as “an air and vapour tight closure.” The DGP decided to indicate such a hermetically sealed inner package must be “pierced or punctured”, and provided the examples of tubes, bags, or vials which are opened by breaking or puncturing.
- For classification of viscous flammable liquids in Packing Group III, the DGP adopted a limit of 30 L for passenger aircraft and 100 L for cargo aircraft.
Meeting of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods on its Autumn 2010 Session
(ST/SG/AC.10/C.3/2011/23 – Secretariat) – The ECE Secretariat identified a number of points related to harmonizing the ADR/RID regulations with the Model Regulations. These are summarized as follows:
- Paragraph 27 – This paragraph questions whether it is acceptable if IBC samples used for vibration tests were not subjected to preliminary storage in order to verify chemical compatibility (six month storage with the chemical in question before vibration test). Belgium points out that in the ADRs there is an alternate three week accelerated compatibility test. However in using the accelerated process, the requirement for the vibration test is omitted. The Model Regulations do not prevent this from occurring under 126.96.36.199.4. Drawing on authority provided in the rules of order at the Sub-Committee, Belgium reinstated INF20 which had been previously withdrawn. INF20 by ICPP described round robin tests which would be conducted on plastic IBCs including a six month preliminary storage period on several test samples. Belgium felt this was vital to determining whether the applicability of the six month storage period was actually beneficial in identifying poor construction of IBCs. The Sub-Committee was concerned that the information could lead to the conclusion that a vibration test would not be needed. Members were split as to whether the test was beneficial or not, and whether the compatibility testing was independent of the vibration testing. The Chairman suggested persons interested in the debate submit formal proposals on the issue. No decision was taken.
- Paragraph 33 – This paragraph addresses the inclusion of the letters “UN” preceding the UN number on a label as permitted 188.8.131.52.1.5. The Sub-Committee noted that there is allowance in the Model Regulations to include the UN numbers on labels although it may not be a common practice. Sweden suggested if the numbers are preceded by the letters “UN”, then it would not be necessary to repeat the UN number marking on the package (not on the label). Belgium agreed but was concerned that would not be permitted by existing text. IVODGA asked whether, given the new minimum size requirements for markings, whether “UNxxxx” would fit on a minimum size label. France, Belgium, and Switzerland all felt if the marking on the label will be used to meet the UN marking requirement in 184.108.40.206, then the UN number MUST be preceded by the letters “UN.” The rest of the Sub-Committee generally agreed. Given this discussion resulted from a report from another meeting, no formal text was proposed. The U.S. volunteered to prepare a formal paper for the June session.
Harmonization of the IMDG Code with the 17th Revised Edition of the UN Recommendations on the Transport of Dangerous Goods, Model Regulations
(UN/SCETDG/40/INF.15 – Secretariat) – This INF paper described the decisions made by IMO to changes for the 36th Edition of the IMDG Code in order to address issues that needed further consideration by the Sub-Committee to ensure harmonization between the Model Regulations and IMDG Code. There are a number of items which drew the attention of the Sub-Committee.
- Paragraph 3.6 – The references in 220.127.116.11 to 6.3.2 is not the correct reference and should be replaced by 6.3.5. The proposal was adopted.
- Paragraph 3.9 – In P200, there are a number of notes following Tables 1, 2 and 3 yet it appears the note relating to maximum working pressure do not apply to gases listed in Tables 2 and 3. CGA noted that while there is no applicability in the UN or in international texts. However these notes do have applicability in North America. CGA did not object to removing the note but commented that it is a more complicated issue. The decision was that the UN was correct and any changes to align with the UN text should be taken up by IMO.
- Paragraph 3.12 – IMO questions whether Refrigerant Gas R 1113 should be added to UN1082 as an alternate proper shipping name. The Secretariat will review historical discussions and report back to the Sub-Committee.
- Paragraph 3.16 – IMO adopted the provisions for flexible bulk containers (BK3) but noted additional packing provisions were adopted in 4.3.2. There is currently no direct connection between the dangerous goods list and section 4.3.2. Therefore IMO suggested developing special provisions to link the two areas. The Sub-Committee noted that the column heading for column 10 indicated they would review formal proposals on this topic in the future.
- Paragraph 3.19 – Since SP318 also requires the proper shipping name be supplemented with a technical name, IMO suggests 18.104.22.168.3(a) be modified by adding “or 318” after “274.” The Sub-Committee agreed and adopted the provision.
- Paragraph 3.21 – IMO suggested the use of the word “above” in the certification statement in 22.214.171.124.1 does not make sense if the certification statement is located at the top of a shipping paper. It was further pointed out the form in 5.4.1 used the word “below.” COSTHA requested a transition period be adopted if any changes are agreed. The Sub-Committee felt this change should not be a point of enforcement so decided against any transition period. The text was modified to state “above or below.”
- Paragraph 3.22 and 3.23 – IMO noted the language for the container packing certificate does not note the new conditions including marking contained within 5.5.3. The Secretariat will take the item for review.
- Paragraph 3.24 – Section 126.96.36.199.7 does not reference from where the country code originates. Other sections of the Model Regulations make reference to the distinguishing sign of motor vehicles in international traffic. The Sub-Committee decided it was an omission from previous changes adopted. Therefore they accepted the change.
- Paragraph 3.27 – IMO notes the reference to marking durability in 6.7 is not consistent. The question was raised as to whether this was intended or not. ITCO and CGA noted general support for including the word “durable” and noted a limited impact to industry as the marks are already being applied durably. The Sub-Committee agreed to amend the text where applicable to include the word “durable.” This edit will apply to all other locations where this is necessary.
- Paragraph 3.29 – The text within 188.8.131.52 requires documentation to include a statement indicating “Bulk Container BK(x) approved by the competent authority of…” while not fully indicating what (x) means. IMO suggested adding a note indicating that “x” should be replaced by either a “1” or “2” as applicable. The Sub-Committee agreed.
- Paragraph 3.36 – In all modes but air, the marking of the proper shipping name is not required on limited quantity shipments. However, Special provision 274 notes a requirement to append the proper shipping name with the technical name. There was some ambiguity as to whether the technical name was therefore required to be marked even when the proper shipping name was excepted. The indication from IMO was no, however it begged the question as to whether this needed to be made clearer. They proposed to add the words “when required” to SP274 to make this point clear. The Sub-Committee determined the introductory language in 3.4 was clear by referring to the “relevant requirements” and therefore decided not to adopt the proposal.
- Paragraph 3.42 – IMO questioned the inconsistent use of lower case or upper case letters in Appendix B. The understanding is that uppercase should be used for recognized proper shipping names. The Secretariat agreed and noted it is done this way in the ADR. The Secretariat will prepare a paper for the next session to correct the apparent mistake.
- Paragraph 4.2 and 4.3 – At IMO, China noted SP145 excepted shipments of ALCOHOLIC BEVERAGES up to 250 L by the sea mode. However, much smaller quantities are regulated by the air mode. The concern was whether a quantity limit should be listed that is inconsistent with other modes. No decision was made at IMO but the issue was referred to the Sub-Committee. The Sub-Committee acknowledged the problem but decided not to take any action on the issue.
Request for Consultative Status by the European Lamp Companies Federation (ELC)
(UN/SCETDG/40/INF.35 – Secretariat) – The Global Lighting Forum, represented by the European Lamp Companies Federation, requested UN Observer status to bring data and information from the lighting industry. The Sub-Committee agreed to their consultative status. This was timely in relation to INF.12 from the UK.
Light Bulbs Containing Small Quantities of Dangerous Goods
(UN/SCETDG/40/INF.12 – United Kingdom) – The U.K. recognized there are currently provisions in the Model Regulations to except light bulbs containing Div 2.2 gases. However they note there are a number of products on the market which include mercury, sodium, and radioactive isotopes. The U.K. believes these bulbs are not adequately addressed in the regulations and classification of these articles may in fact overestimate the actual risk in transport. GLF gave a short presentation on the technologies currently being utilized in the lighting industry. Of interest, GLF pointed out that 90% of lamps have less than 0.03 g of mercury, 9% contain up to 0.03 g, and only 1% contain more than 0.03 g up to a possible maximum of 100 g of mercury. For other than mercury or radioactive materials, the only appropriate entry might be for the pure substance. The UN entries covering these lamps is currently UN3363, UN2911, UN2809, and UNxxxx for pure substances. Restrictions see to limit the transport of such materials. The IAEA noted they have been working on consumer products containing radioactive materials but light bulbs fall under this area. They are also reviewing the much broader problem of what radioactive materials are allowed in consumer products. The IAEA is willing to consider a move toward excepted quantities and will bring a formal proposal to address in the future. The IAEA is against using a general entry for light bulbs as the provisions would be voluminous and could overwhelm the current provisions. The U.S. was very interested in seeing more from industry as to different types of materials and technologies involved, as were the Netherlands and Australia. The U.K. thanked the Sub-Committee for the comments and will prepare a more comprehensive proposal for future sessions.
Classification of Desensitized Explosives for the Purposes of Supply and Use
(UN/SCETDG/40/INF.7 – Germany) – This paper updates actions taken by the TDG and GHS Subcommittees on desensitized explosives classified as Class 3 or Division 4.1 but may become explosive over time. While several working groups were held, several delegations opposed the general principles under which the working group was formed. Therefore, Germany is proposing a new direction. This document proposed to create a new informal working group charged with reviewing desensitized explosives separately from the Explosives Working Group. Germany suggested participants should include members of the explosives working group as well as GHS and experts familiar with desensitized explosives. The Netherlands, U.S., and France felt the way forward was still through the Explosives Working Group. Germany will resubmit the issue for review by the Explosives Working Group in June, perhaps specifying half-day session to be set aside for this subject.
Substances and Mixtures with Explosive Properties Which Are Exempted From Classification as Explosives
(UN/SCETDG/40/INF.17 – Germany, United States of America and Canada) – During the last meeting the proposal to introduce a note in the GHS for substances with explosive properties which are exempted from classification as explosives was discussed (see UN/SCEGHS/21/INF.11). There was general agreement on the need to address the issue raised in the informal paper and on the fact that the note in the informal paper, with some additional amendments, could provide a short-term solution to the problem. However, some experts felt that given that this is the beginning of its biennium of work, the Sub-Committee still had time to work on a long-term solution before adopting a final solution. There was also discussion on whether this issue belonged with the Sub-Committee, as the focal point for all physical hazards. To further the discussion, this paper was sent to both the TDG and GHS sub-committees for their consideration. The document contained background information and the corresponding formal proposal for a short-term solution, taking into account the feedback for improvement of the note. The Sub-Committee agreed to the adoption of the note as an interim measure. France offered a slight amendment to also take into account the properties of the material in addition to the packaging and this was subsequently adopted.
Invitation to Participate in an International Videoconference Regarding Fireworks Classification, Approval and Transport
(UN/SCETDG/40/INF.39 – United States of America) – The U.S. invited the Sub-Committee to participate in a video conference in early 2012 regarding fireworks classification, approval, and transport. Topics discussed will include the testing of fireworks, use of the UN default fireworks classification table, and the safe transport of fireworks. The document included a list of questions and there were some brief response in particular from the Netherlands but nothing substantive.
Adsorbed Toxic Gases
(UN/SCETDG/40/INF.42 – COSTHA) – In this information paper COSTHA questioned whether adsorbed gas technology was adequately addressed in the Model Regulations through this INF paper. Specifically, COSTHA requested comments from the Sub-Committee as to whether adsorbed gases should be considered gases or whether they more resemble solids. While time was short, Canada and Austria provided specific comments that adsorbed gases are not adequately addressed, and individual entries for such gases may be necessary to adequately address. However both Canada and Austria were adamant that the material was in fact a gas and should, at least at this stage, remain classified as a toxic gas. These comments were in alignment with comments received earlier in the week from CGA and EIGA. The Chairman noted additional comments would be welcome in the margins of the meeting or following the session via email.
Transport of Uncleaned Waste Packaging Having Contained Dangerous Goods
(UN/SCETDG/40/INF.24 – United Kingdom) – This paper addressed the transport of uncleaned waste packaging having contained dangerous goods. At the ADR/RID Joint Meeting France made certain proposals regarding the carriage of packaging wastes, empty, un-cleaned consigned for the purpose of recycling the material from which the packaging was constructed or for disposal. Those discussions have yet to be completed but the view of the Joint Meeting was that a rapid solution to the perceived problem was needed as the disposal of such waste posed a regulatory problem at the EU level. The U.K. stated that the issue which will also be pertinent in other regions of the world and which may also involve journeys consisting of both land and sea transport legs (i.e. short sea ferry crossings) and therefore the issue should be discussed in the context of the Model Regulations where they are currently not appropriately addressed. While the transport of empty packaging is addressed in 184.108.40.206 of the Model Regulations which states:
“220.127.116.11 – Empty packagings, including IBCs and large packagings, that have contained a dangerous substance shall be treated in the same manner as is required by these Regulations for a filled packaging, unless adequate measures have been taken to nullify any hazard.”
The packaging only becomes “waste” when the consignor either decides that is no longer viable for future use as it is no longer fit for purpose, or it is more economical to send it for recycling or, more likely, when the user of the product contained in the packaging has no interest in the future of the discarded packaging and simply wishes to rid themselves of it. In these circumstances the “waste” packagings are often collected en mass and placed in a bin, box or bulk container for transport to a sorting, recycling or disposal point. In this case it is likely that the empty packagings come from a number of sources and have had a range of different classes of dangerous goods in them. The U.K. asked the Sub-Committee to consider how such consignments should be transported and what marks, labels, documentation etc. and whether the experts agreed that the transport of packaging wastes, empty, un-cleaned was currently adequately covered by the Model Regulations and if this is an issue for the Sub-Committee to resolve. The U.K. also suggested a new Class 9 entry for “PACKAGING WASTES, EMPTY, UN-CLEANED FOR DISPOSAL.”
A number of experts (Netherlands, France, Austria) agreed in principle to include requirements for waste packagings with DG residue but were not in favour of the approach suggested. Some felt that a Class 9 entry would not adequately address all hazards (toxic, explosive, etc.). Several industry associations (ICPP, ICCR, ICIBCA, ICDM and EMPAC) indicated that the implications of the U.K. proposal could be significant on industry and that the current practices vary from continent to continent and how wastes are handled. Furthermore they stated that currently emptied un-cleaned packagings containing residues of dangerous goods are moved safely all over the world for reconditioning and reuse under agreed procedures in individual national legislation. In its present form, the U.K. proposal could disrupt this important transport activity and impose significant new costs on industry with no apparent safety improvement. The expert from the United States expressed concern that the U.K. approach would complicate the current U.S. requirements for dealing with waste packaging. He also expressed concern with establishing a new Class 9 entry. He agreed to share information with the U.K. on how used or wasted packagings are addressed in the U.S. This being a late INF paper no decision was taken. The U.K. indicated that they will resubmit a revised proposal on the basis of the comments received.
Work of the Joint Correspondence Group on Corrosivity Criteria: Agenda for the Meeting and Additional Information
(UN/SCETDG/40/INF.33 – United Kingdom) – This information paper was submitted by the expert from the United Kingdom on behalf of the joint correspondence group on corrosivity criteria. It was submitted in preparation for the meeting of the joint correspondence group on corrosivity criteria on Dec. 6. The joint informal correspondence group was initiated at the 20th session of the GHS Sub-Committee, with the aim of considering further the harmonisation of corrosivity criteria in the transport Model Regulations and the GHS. The agreed terms of reference were as follows:
- Verify the definition of “skin destruction” as mentioned in the Model Regulation on the transport of dangerous goods complemented with reference to the Organisation for Economic Co-operation and development (OECD) test guidelines. If the definition is not aligned with paragraph 18.104.22.168.1 in Chapter 3.2 of the GHS, propose appropriate improvements.
- Identify and analyse the discrepancies between assignment to subcategories 1A, 1B and 1C, based on in vitro and in vivo testing and alternative approaches (bridging principles, mixtures calculations, pH…)
- Identify differences in assignment to categories in lists provided by different regulations and guidance documents for a few representative common substances. Analyse the underlying data and origin of these differences and use these results for the work under paragraphs a, b and d.
- Check the way OECD guidelines are referenced and their relevance.
- Report findings and make recommendations that meet the need of all sectors with the aim of achieving consistent classification outcomes for skin corrosivity.
A proposed agenda for the joint TDG/GHS informal working group was provided in UN/SCETDG/40/INF.33/Add.1.
Harmonization of Classification Criteria for Transport with the Classification Criteria of the GHS for Substances and Mixtures Corrosive to Skin
(UN/SCETDG/40/INF.9 – ICCA) – This document identifies typical differences in skin corrosion classifications listed in the Annex VI to European Regulation 1272/2008 in relation to the dangerous goods list of the Model Regulations. Taking into consideration the different scope of GHS and TDG the document provides a combined GHS/TDG-substance list. ICCA indicated that the harmonization of the classification criteria for transport and for supply and use needs to be pushed forward to avoid confusion during the transport, based on contradicting classifications and label information for substances and mixtures. They also stated that in order to avoid confusion, dissenting classifications (not only for corrosive substances, as this applies also to other classes) should be declared in a combined GHS/TDG-substance list. The expert from the United States stated that he was opposed to developing a global list for a number of reasons including the fact that various test methods are authorized, that GHS and TDG are established on differing basis (GHS intrinsic properties and TDG risk based approach). The GHS and TDG approaches in some cases lead to differing results. The UN Secretary indicated that if a list were to be developed on the basis of the Model Regulations. He also noted that such an effort could involve extensive resources and work that could span decades. Other experts (e.g. Belgium and France) were not as adverse to the idea of establishing a global list of chemicals.
Harmonization of Classification Criteria for Transport with the Classification Criteria of the GHS for Substances and Mixtures Corrosive to Skin
(UN/SCETDG/40/INF.10 – ICCA) – In this information paper ICCA addresses the classification of corrosive mixtures and proposes the adoption of the current GHS additivity approach to transport regulations and the implementation of a modified non-additivity approach, taking into account that the current classifications currently required in the GHS are not reasonable for transport purposes. The paper proposes to adopt parts of GHS Table 3.2.3 regarding category 1 and the note to table 3.2.3 in the transport regulations. It also proposes a new non-additivity approach for the classification of mixtures based on the classification of the ingredient (non additivity approach). ICCA stated that according to the GHS criteria, the additivity approach cannot always be applied and particular care must be taken when classifying chemicals such as acids and bases, inorganic salts, aldehydes, phenols, and surfactants. For these cases the additivity approach cannot always be applied. ICCA noted that the application or non-application of the additivity approach is still under discussion in the relevant GHS correspondence group but that the result has to be implemented in the transport regulations as well. The expert from the United States explained while it may be a noble goal to work on establishing an agreed global list of corrosive substances it will be a huge difficult task. The expert from Belgium was not as pessimistic. He also stated that an extreme ph assessment is “just a crude precursory procedure for evaluating corrosive properties but not a valid or precise classification method.”
Harmonization of Classification Criteria for Transport with the Classification Criteria of the GHS for Substances and Mixtures Corrosive to Skin
(UN/SCETDG/40/INF.9 – ICCA) – In this paper ICCP warned the Sub-Committee that if as a result of changes to the corrosivity criteria in the TDG many products may move to Packing Group I in which case there would be consequences specifically that Packing Group I liquids are not authorized in IBCs. A number of experts stated that while it is not their intent to invoke inefficiencies in transport but that the development or modification of corrosivity criteria must be based on safety and risk considerations. The Sub-Committee thanked ICCP for explaining the potential implications of any changes to the criteria.