The 41st session of the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (the Sub-Committee) concluded on Wednesday. The following summary is the second and final in our series highlighting papers discussed during the course of the session. For more background on this meeting, please view our overview of the 41st Session or the first installment of our UN meeting coverage.
Proposal for Changing Section 6.2.4 to Permit Alternatives to the Hot Water Bath Test for Small Receptacles Containing Gas and Fuel Cell Cartridges Containing Liquefied Flammable Gas
“UN 2037, small gas receptacles (gas cartridges),” and “UN 3478, fuel cell cartridges containing liquefied flammable gas,” are required to meet the provisions of Section 6.2.4 of the UN Model Regulations (the Model Regulations), which requires each item to be subjected to a hot water bath leak test. The European Cylinder Makers Association (ECMA) proposed to authorize alternative leak testing methods for gas cartridges and fuel cell cartridges similar to that currently authorized for aerosols. The paper proposed amending paragraph 6.2.4.1 to permit alternatives to the hot water bath test for gas cartridges and fuel cell cartridges. While there was general support for the proposal, experts identified a number of editorial issues and, as a result, ECMA agreed to submit a revised proposal for the 42nd session.
Amendment to the Classification Flow Chart for Self-Reactive Substances and Organic Peroxides
During the last meetings of the Sub-Committee and the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS Sub-Committee), a proposal to amend the classification flow chart for organic peroxides and self-reactive substances was discussed (ST/SG/AC.10/C.3/2011/29–ST/SG/AC.10/C.4/2011/5). This proposal took into account previous comments. The proposal received broad support and was adopted. It was also to be considered by the GHS Sub-Committee, which met earlier this week.
Requirements for Fire Extinguishers
Germany proposed amendments to the requirements for fire extinguishers. DGTA, UK, IATA and Canada provided recommendations for improving the proposal, including developing a specific packing instruction for fire extinguishers, increasing the limited quantity value, specifying the types of cylinders that can be used, etc. Germany agreed to work intersessionally with several participants and to develop a revised proposal for the 42nd session.
Classification of Self-Reactive Substances
The Dangerous Goods Advisory Council’s (DGAC) paper did not include a specific proposal but drew attention to inconsistencies in classification requirements regarding self-reactive substances (SRS) and apparent deviations from the classification system in the Model Regulations. In the interest of greater international uniformity, DGAC offered their paper as a basis for discussion. In particular, DGAC indicated that some monomers that have the potential to polymerize are being classified as self-reactive substances. DGAC indicated that based on comments from other experts, they would submit a formal proposal for the 42nd session. A number of experts agreed that the Model Regulations should be clarified as suggested by DGAC and encouraged DGAC to submit a formal proposal for the 42nd session.
We would like to acknowledge a special thanks to Tom Fergussen of COSTHA for his help with the following summaries.
Guiding Principles
United Kingdom 2012/42
The guiding principles establish the rationale and basis for how the transport regulations are established. These principles are intended to enhance consistency and harmonization. The revisions to the guiding principles primarily addressed packaging requirements. With minor amendments, the Subcommittee adopted the text as proposed.
United Kingdom 2012/43
This paper proposed revisions to the guiding principles for portable tank instructions and when transitional measures are applied. There was significant opposition to a number of issues (most notably the transitional measures) so the U.K. withdrew the paper.
Secretariat 2012/INF45
The Secretariat produced the most up-to-date version of the Guiding Principles consistent with the 17th edition of the Model Regulations. The Secretariat noted the Guiding Principles are behind in publication, and thus it would not be appropriate to update them for more recent decisions. The Sub-Committee adopted the text as presented.
Editorial Amendments
The Secretariat noted a number of editorial corrections to the 17th revised edition. No comments were received and the corrections were adopted as presented. The changes will be reflected in a corrigendum.
Light Bulbs (Lamps)
The U.K. addressed comments from both the lamp industry and Sub-Committee members regarding lamps containing dangerous goods. Two special provisions were proposed to exempt certain requirements for lamps and to address waste lamps. It was questioned whether LED/LCD lamps were included. Austria noted extensive discussions on radioactive lamps were held at a recent meeting of the International Atomic Energy Agency (IAEA) and that any decisions of exceptions on radioactive material must be handled at the IAEA. This issue may be addressed through a formal paper at the 42nd session.
Harmonization of Corrosivity Criteria between the Globally Harmonized System of Chemical Classification and Labelling and the UN Model Regulations
The U.K. summarized the current work being conducted in relation to the corrosivity discussion between the Sub-Committee and the GHS Sub-Committee. The Sub-Committee supported the effort and the continued discussion. In INF.53, the U.K. explained differences between assignments of packing groups in the Model Regulations versus subcategories in GHS. Paragraph 8 of the proposal suggested a detailed assignment of packing groups which is not simply “PG I = 1A, PG II = 1B, PG III = 1C.” DGAC supported the proposal from the U.K. in INF53. The U.S. felt the current provisions in 2.8 are adequately harmonized with GHS and additional work is not necessary. The U.S. was not supportive of the approach by either the INF53 or INF27. Germany disagreed with the U.S., stating that 2.8 does not adequately address assignment of the packing group to N.O.S entries since GHS permits reference to pH. Germany felt the work should be focused on closing the gaps. ICCA pointed out the assignment of GHS subcategories does not require labeling while assignment of packing groups does affect transport conditions. Therefore, ICCA supported the U.K. proposal. The U.K. indicated the paper was a thought-starter and will consider the discussion at a further session. The Netherlands asked industry to provide data to support the discussion. ICCA pointed out data on extreme pH was provided in INF27. The Chairman summarized the discussion by saying there is no consensus point on transport classification although some sympathy has been viewed for both approaches. The Sub-Committee can only communicate to the GHS Sub-Committee that these papers are for informational purposes but they do not define the TDG Sub-Committee position.
Corrosivity Criteria
The European Chemical Industry Council (CEFIC) paper provided a comparison list between TDG and GHS. The document was discussed within the dialogue on INF53. The proposals in the document were withdrawn but the paper was retained for informational purposes.
Problems with EHS Criteria
The International Paint, Printing Ink and Coatings Association (IPPIC) noted the adoption of the Environmentally Hazardous Substance (EHS) criteria has resulted in a significant amount of paint, adhesives, and resin solutions becoming regulated as EHS. IPPIC proposed to adopt entries for paint, adhesives, and resin solutions as Class 9 hazards. Additionally, special provisions and packing provisions were proposed. The U.S. supported the idea of assigning these entries as Class 9 hazards and for the industry to create less hazardous products. COSTHA clarified materials covered by this proposal do not currently meet the criteria of hazard classes 1-8, but instead only meet the definition of EHS. The U.S. also pointed out the EHS designation is maintained through application of a special provision. China supported the concept, noting the wide variety of products which are now being classified as EHS. Belgium also noted MARPOL conventions require certain information be provided and that this proposal may limit that requirement. IPPIC requested that additional comments be submitted in writing to the IPPIC representative.
Criteria for Oxidizing Substances
Germany presented ongoing work on oxidizing substances. A working group is developing an alternate test for oxidizing solids. Potassium bromate is a carcinogen and, therefore, it would be beneficial to replace it. Also, the burning rate of potassium bromate is variable, leading to inconsistent results. The new test method would utilize calcium peroxide as a substitute. It was noted that as test methods are changed, existing classifications will be affected. Ammonium nitrate was pointed out as an example. Norway was not in favor of removing ammonium nitrate from Class 5.1. Particle size appeared to be a common problem for both tests. Germany will prepare a formal document for the 42nd session but requested input as to recommended transitional periods.
Lithium Batteries
The International Civil Aviation Organization (ICAO) noted the significant impact of fires resulting from electric devices and, in particular, lithium batteries. ICAO requested the Sub-Committee organize a working group to discuss whether assignment to Class 9 adequately addresses the hazards associated with such materials and whether a Division 9.1/9.2 or Class 10 should be considered. The U.S. supported ICAO’s suggestion. Recognizing additional technologies are on the horizon, the U.S. supported that the issue be included as a work item for the next biennium to develop a comprehensive solution. Others also supported the initiative and agreed that the Class 9 label doesn’t address the hazards posed by lithium batteries or devices with electrical hazards. ICAO welcomed the positive comments and agreed to present a formal document at the 42nd session.
ICAO also presented the decisions made at the October 2011 ICAO DGP meeting regarding shipments of lithium batteries. In particular, ICAO pointed out the new provisions adopted for 2013-14 for PI965 and PI968, as well as the allowance for small lithium batteries contained in equipment in the post (mail). Australia suggested that the lithium battery handling label should be expanded for electrical storage devices. China explained that they are encountering practical problems with applying the new ICAO provisions, particularly considering the application of the Class 9 label on packaging that has already been constructed.
Inclusion of SP223 for Alane (Aluminum Hydride)
This paper requested comments from the Sub-Committee regarding the proper classification of alane given testing of the powder, pelletized and certain forms do not meet Class 4.3 or other defining criteria in Classes 1-9. France noted it is not customary to assign SP223 to a PG I material and that it would be more appropriate to add a substance specific special provision to note which forms would be excepted. Comments received will be used to draft a formal proposal at the 42nd session.
Definition of Battery Assembly
The Rechargeable Battery Association (PRBA) suggested that the definition of battery assembly needed to be revised. Specific comments were directed to PRBA and RECHARGE so that they may consider the points for the 42nd session if they chose to submit a formal document.
Marks, Labels and Placards
The U.K. presented the latest version of the standardization process for marks, labels, and placards. The U.K. removed the tolerances previously included as they felt these were a more complicated method of defining minimum dimensions. Additionally, the U.K. introduced the term “approximate” to reduce the risk of overly zealous enforcement. The authors felt these changes take in account previous comments from industry regarding print bleeds. The proposal was adopted with the following exceptions:
- The U.K. agreed to remove the 5 mm line thickness for placards other than Class 7.
- In relation to proposal 5, the Subcommittee decided to change the word “marking” to “symbol and other elements of the label”.
- In relation to transitional periods, the U.K. decided to bring a formal paper at the next session identifying relevant sections of the adopted text which need a transition period.
Special Provision 363
Switzerland identified a potential conflict between Special Provision 363 (SP363) and “Dangerous Goods in Machinery,” in particular whether dangerous goods loaded onto a vehicle are covered under SP363. Switzerland suggested it would not be permitted. Therefore, it was proposed to clearly remove the ability for dangerous goods to be loaded onto vehicles by removing the term “loaded” from the SP. The Subcommittee agreed to the proposed text in INF47.
CTU’s with Coolant
Germany explained that they have received a number of questions about the applicability of the newly-adopted provisions on cooling and conditioning substances, particularly as they relate to CTUs with or without packaged goods. Germany proposed changes to sections 5.5.3.1.4, 5.5.3.2.2 and 5.5.3.2.4 of the Model Regulations. The Chairman made a note that it was the U.K.’s intent that the provisions applied for both packaged and non-packaged coolants. France supported Germany’s proposal but made some minor amendments to the text. The Sub-Committee agreed to the proposals made in 2012/53 as amended.
Electronic Shipping Papers
United Kingdom 2012/47
The U.K. once again began a discussion as to whether a concerted effort was needed internationally to develop a coding system for use in electronic documentation and electronic data transmission. The U.S. opposed the effort, noting that industry can adjust to changes quicker than government. COSTHA opposed the proposal, noting a one size-fits-all approach will not work in all cases. Companies already have existing systems which, in fact, may require additional programming if a new scheme is developed. Industry also cannot wait for changes through the UN. ICCA agreed with the opposition, stating a number of industry systems have already been developed which solve this problem. Additionally, the code seems limited to UN numbers and descriptions, which already exists in relevant transport documents. Germany suggested that the effort is only to help identification in software systems. Belgium stated that as a governing body, it is the Sub-Committee’s responsibility to detail what pieces of information are necessary on an electronic shipping paper so that all necessary information is available at any time, but that it is not the Sub-Committee’s responsibility to drive this process forward. DGAC agreed with the opposition, stating industry has additional issues which must be reconciled internally. Regulators cannot create a system that will make that effort easier. France pointed out an email from DGM presented at a previous session where the effort was supported. France believed such a system would ultimately reduce costs. The U.S. clarified they are supportive of the general effort to facilitate electronic data transfer, but they do not want to get into the details. South Africa agreed with the comments from Belgium and the U.S. The U.K. acknowledged the lack of general support but noted the work will continue.
IATA 2012/55 and 2012/INF61
IATA presented experience in a proof of concept initiative aimed at facilitating the use of electronic shipping documents. Two shipments were used to test the system from Switzerland to Canada. While the material was indeed transferred, operational limitations including a limited ability to accept XML documents that caused some difficulties. Additional changes are being proposed to accommodate XML documentation, and the expectation is that the more the program is tested, the more carriers and shippers will want the system. IATA incorporated a number of data elements from other modes of transport in their XML scheme. Therefore the system can be used for multimodal shipments.
