The 41st session of the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (the Sub-Committee) convened earlier this week. The following is a summary of papers discussed so far. We will provide periodic updates throughout the course of the meetings. For more background on this meeting, please view our overview of the 41st Session.
Explosives and Related Matters
Each paper was briefly introduced and then remitted to consideration by an explosives working group led by Mr. Ed DeJong from the Netherlands, who has served as the chairman of the UN explosives working group for many years.
Special Provisions Requiring Reconsideration
The Dangerous Goods Advisory Council’s (DGAC) paper addressed the various special provisions that are assigned in the dangerous goods list to indicate when a substance or article may be excepted form the requirements of the UN Model Regulations (the Model Regulations). The main issue that DGAC was asked to address was to consider the introduction of criteria for environmentally hazardous substances. Specifically, DGAC was asked to provide a document identifying other substances that may be similarly affected by the introduction of Environmentally Hazardous Substance (EHS) criteria. The Dangerous Goods Trainers Association (DGTA) suggested that Chapter 2.0 of the Model Regulations be amended to make it absolutely clear that any substance which does not meet the criteria for Class 1-9 is not subject to the Model Regulations. The Sub-Committee welcomed DGTA’s verbal proposal and encouraged DGTA to submit a formal proposal.
Heat Transfer Pipes
Spain proposed a new entry in the Model Regulations to facilitate the transport of heat pipes. Spain indicated that 2.1, 2.2 and 2.3 gases may be contained within the heat pipes. However, they proposed that the entry be included as a Class 9 dangerous good. Some experts expressed concern with the Class 9 designation and preferred assigning a Class 2 designation. A number of experts and observers, including the US, UK, Sweden and Netherlands, indicated that additional work needed to be undertaken to ensure that appropriate specifications, hazard communication and quantity limitations were addressed. Spain indicated they would continue to consult with other participants in an effort to revise the proposal for the 42nd session in December.
Excepted Quantity Provisions for Fuel Cells
This paper proposed that fuel cells be authorized for transport under the excepted quantity provisions. Since articles are currently not authorized to be transported as excepted quantities, the proposal had significant implications and could have led to other articles being authorized as such. An extensive discussion of the proposal resulted, but there was generally insufficient support for the proposal.
T6 Tests for Lithium Cells
This paper proposed to amend section 38.3 of the Manual of Tests and Criteria as it relates to tests for lithium batteries and cells. In particular, the paper proposed changes to the applicability of the impact and crush tests. Both tests simulate the mechanical abuse that may result in the internal short circuit to cells. The impact test currently applies to cylindrical cells not less than 20mm in diameter, and the crush test applies to the cells not more than 20mm in diameter. China proposed to amend the diameter limits as follows:
- 18.104.22.168.2 Test procedure – Impact (applicable to cylindrical cells not less than 18.0mm in diameter)
- 22.214.171.124.3 Test procedure – Crush (applicable to prismatic, pouch, coin/ button cells and the cylindrical cells less than 18.0mm in diameter)
The data provided by China supported the need for the changes from a safety perspective. Previously, the lithium battery working group had decided that conducting the impact test on small batteries was difficult to implement in practice. However, China reasoned that the impact test was more likely to result in a short circuit. The paper was adopted on the basis of an 8-4 vote.
New Proper Shipping Name for Asymmetric Capacitors
An asymmetric capacitor is an electrochemical capacitor with positive and negative electrodes comprised of different active materials. In such a device, the charge and discharge are accomplished through different electrochemical processes. Japan explained that a new entry for asymmetric capacitors was necessary because of the fact that they are different from the current entry, “UN 3499, Capacitor, electric double layer (with an energy storage capacity greater than 0.3 Wh)” for electric double layer capacitors (ELDCs). The main difference is that unlike EDLCs, the asymmetric capacitors can’t be completely drained and are always charged, to some extent. There was general support for the proposal, although a number of experts had editorial comments that Japan agreed to take incorporate. Once the revised proposal is completed, it is likely that it will be adopted.
Packing Groups for UN 3316 Chemical Kits
Germany proposed adding two entries in the Dangerous Goods List (DGL) for chemical kits. The DGL does not provide any information on the packing group of “UN 3316, Chemical Kit or First Aid Kit”. This is due to the fact that the packing group has to be determined according to the most stringent packing group assigned to any individual substance in the kit (see special provision 251 of Chapter 3.3). Germany indicated that many users are not aware of the necessity to determine the packing group, as column 5 of the dangerous goods list does not contain any information.
Germany also explained that the information “0” and “E0” in columns 7a and 7b is often misinterpreted in a way that there is no possibility to consign these articles as limited or excepted quantities. There was broad support for the German proposal and it was adopted.
Alignment of Excepted Quantity Codes in the ICAO TI and UN Model Regulations
At the 40th session of the Sub-Committee, the International Civil Aviation Organization (ICAO) submitted an informal document addressing differences between the excepted quantity codes in the ICAO Technical Instructions (ICAO TI) and the Model Regulations. This included an indication that a number of substances which are forbidden on passenger aircraft are permitted in excepted quantities within the Model Regulations.
When excepted quantities were incorporated into the Model Regulations, it was done largely on the basis of a rationalized approach and the values provided in the ICAO TI. ICAO proposed that the EQ code for a number of entries be changed to EO (not allowed). A number of experts questioned the basis for the fact that some substances identified by ICAO were forbidden on passenger aircraft when other similar substances were allowed. Others suggested aligning on the basis of the ICAO proposal and then asking ICAO to revisit the basis for the substances not allowed on passenger aircraft. The chairman suggested that the Sub-Committee defer a decision until ICAO meets in October and verifies the entries that were questioned are considered. The ICAO Secretariat agreed to this approach.
Clarification of Packing Instruction 903
The Rechargeable Battery Association (PRBA) pointed out during editing of packing instruction P903a from the 16th to the 17th revised edition of the Model Regulations, the resulting wording suggests strong outer packagings must be provided in protective enclosures, instead of strong outer packagings OR in protective enclosures. DGTA suggested the options be detailed as “a)”, “b)”, and “c)”. The Subcommittee supported the paper with the DGTA suggestion.
Large Packagings for Lithium Ion Batteries
This paper proposed to add large packagings for lithium batteries. Sweden felt clarification of what comprised a battery assembly was needed, but Germany suggested removing the term, as a battery assembly is also considered a battery. The proposal was adopted as amended (i.e. removal of the reference to battery assembly).
New Entry for Ammonia Cartridges
The expert from France proposed a new entry for cartridges used by the automobile industry for the prevention of nitrous oxide emissions based on the generation of anhydrous ammonia. The cartridges are installed in vehicle exhaust systems. The cartridge is activated by an increase in temperature and ammonia is released into the exhaust system, thereby reducing nitrous oxide emissions. A number of experts expressed concern about adding numerous new entries to the DGL. A number of experts raised technical questions, so the expert from France agreed to work with them intersessionally and to submit a revised proposal for the 42nd session.
Assignment of Packing Groups to Articles
In this paper, the International Air Transport Association (IATA) pointed out the inconsistent application of packing groups to articles and indicated that this creates problems for dangerous goods trainers in explaining the rationale to students trying to understand the regulatory structure. IATA also stated that it creates problems that result in the rejection of shipping papers. IATA proposed removing the packing group in the DGL for a number of articles and revising paragraph 126.96.36.199 by adding the following statement:
“Articles assigned to Classes 3, 4, 8 and 9 and Divisions 5.1 and 6.1 are not assigned packing groups. For packing purposes any requirement for a specific packaging performance level is set out in the applicable packing instruction.”
There was broad support for the proposal, but some experts asked IATA to ensure they had addressed all of the applicable articles. For instance, DGTA suggested the packing group assigned to mercury contained in manufactured articles be removed. IATA will resubmit their proposal for the 42nd session after conducting a thorough review of all the applicable article entries.
Proposal for Classification Criteria and Packing Requirements for Gases Adsorbed on Solids
This paper proposed six new entries, a packing instruction and applicable requirements in the Model Regulations to address gases adsorbed onto solid porous materials. There was general support for the proposal, but a number of experts had specific editorial recommendations (e.g. the test period should be five years, only UN cylinders should be allowed, etc.). The Council on Safe Transportation of Hazardous Articles (COSTHA) agreed to modify their proposal consistent with comments provided and to submit a revised paper for the 42nd session.
Requirements for Asbestos
This paper proposed to modify the entries for asbestos into two groups: chrysotile and amphibole. There was general support for revising the proper shipping names but, based on a comment from DGTA, the word “Asbestos” would be listed first to ease searching alphabetically. Thus, the new shipping names would be “Asbestos, Amphibole and Asbestos, Chrysotile or Asbestos, Chrysotile, Fibre.” The proposal was adopted with the amendment suggested by DGTA.
Assignment of IBC Packing Instructions to UN 3089
There are two entries for “UN 3089, Metal powder, flammable, n.o.s.” Packing instruction IBC 08 is assigned to UN 3089, packing group II, while IBC 06 is assigned to UN 3089, packing group III. Consequently, fibreboard, wooden and flexible IBCs are allowed for the packing group II substance, but are forbidden for the less dangerous packing group III substance. The assignment is also not aligned with the guiding principles. The proposal was adopted.
Lithium Batteries Working Group
A lunch time working group met on Tuesday (6/26) and Wednesday (6/27) to discuss lithium battery requirements consistent with proposals 2012/37 and 2012/38 from PRBA. While some progress was made on developing requirements for defective or damaged batteries, the working group could not reach a conclusion. PRBA will take all of the comments provided and develop a revised proposal for the 42nd session based on intersessional discussions. The working group will meet again on Thursday (6/28) to continue discussion on waste battery requirements.
Special Provision 335, Exception for Small Quantities of Environmentally Hazardous Substances
There was broad support for adopting the proposed amendment to SP 335 that would except quantities not more than 10 ml or 10 grams of environmentally hazardous substances from the Model Regulations. DGTA, DGAC and COSTHA provided explanations explaining why these exceptions were so important to their members particularly with respect to the pending Globally Harmonized System of Classification and Labelling of Chemicals (GHS) implementation dates. There was general support for providing exceptions and it was recognized that small quantities of environmentally hazardous substances pose virtually no risk in transport. However, the other proposals in 2012/27 (excepted quantity provisions) received mixed views and many experts indicated that they were not ready to address the excepted quantity provisions on the basis of the proposed text. It was decided that an intersessional correspondence working group be established to address additional exceptions for environmentally hazardous substances. The expert from the United States agreed to lead the work. The amendment to SP 335 was placed in square brackets pending the outcome of the intersessional working group:
[Inner packagings containing not more than 10 ml of an environmentally hazardous liquid packed in a combination packaging not exceeding 30 kg total gross mass conforming to general packing provisions 188.8.131.52, 184.108.40.206, 220.127.116.11, and 18.104.22.168 and meeting the construction requirements of 6.1.4 are not subject to these Regulations, if the packaging is designed to prevent the release of the liquid content by using an intermediate packaging (plastic bag, blister or similar) or by adding absorbing material in a part of the packaging (outer or intermediate packaging).]