There are some major issues being discussed by the UN experts in the current biennium, as the agenda for their first meeting clearly demonstrated
The UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) held its 47th session, the first of the 2015-2016 biennium, this past 22 to 26 June in Geneva. This was quite a short meeting and set the tone for the deliberations to come in the next three sessions before the Experts finalise the changes that will appear in the 20th revised edition of the UN Model Regulations.
The first two parts of this report on the June meeting (HCB Monthly December 2015, page 56; January 2016, page 55) covered discussions of Class 1 matters by the Working Group on Explosives and of a wide range of other classification matters by the plenary session. This final part of the report wraps up the remaining discussions. Readers should bear in mind that there is plenty of time for decisions made at the June meeting to be revised or overturned before they are adopted by the parent Committee at its December meeting at the end of this year.
DANGEROUS GOODS IN MACHINERY
The UK followed up on discussions at the previous session on the classification and transport of various dangerous goods contained within machinery, apparatus or articles that are not already included within the Dangerous Goods List. An informal paper summarised those discussions and reported on a proposal that the UK had circulated since that session. It had received a number of constructive comments, which were also summarised.
The UK’s thinking was that new UN numbers should be adopted for each class and division of dangerous goods (other than Classes 1 and 7), for dangerous goods in machinery, apparatus or articles, with a new special provision applicable to all of them to explain their scope. The proposed text includes the clarification that these entries should not be used for machinery, apparatus or articles for which a proper shipping name already exists in the Dangerous Goods List, and that machinery, apparatus or articles containing dangerous goods where all the dangerous goods contained are within the permitted limited quantity amounts, shall be assigned to UN 3363.
There would also be a new packing instruction and a substantial number of consequential amendments.
The UK chaired an informal working group to discuss the proposals and again received a considerable amount of feedback. The UK agreed to return to the December 2015 session with a formal proposal.
MARKING AND LABELLING
Having succeeded in getting agreement for a new label/placard to highlight the hazards posed by batteries assigned to Class 9, the UK had proposed doing something similar for elevated temperature substances and environmentally hazardous substances, i.e. placing the relevant symbol in the lower half of the Class 9 label/placard.
However, most delegations were of the opinion that the move was not necessary. In particular, the criteria for environmentally hazardous substances are not harmonised across the modes and this would cause confusion. The proposal was not adopted and the UK said it would not pursue the matter further.
The Russian Federation proposed a revision of 18.104.22.168.2, on the basis that it contains a lot of repetitive information and it would clarify the provisions if the information were presented in a tabular form. Some experts felt there was no need for change and others were of the opinion that a table would make a useful guidance document.
Russia was asked to draw up an official proposal for the next session, taking into account the comments made.
Canada had spotted what it felt was an error in the French version of 22.214.171.124(d) relating to the rounding of the pressure value in kPa. The English version invites the value to be rounded down to the nearest 10 kPa, whereas in French it merely asked for the value to be rounded to the nearest 10 kPa. The experts agreed this was an error and the French version will be amended; it was also felt that the other language versions should be investigated.
In an official document, Germany sought the amendment of 126.96.36.199.4 and 188.8.131.52.2 to specify a minimum temperature for the temperature at which hydraulic pressure tests of plastics packagings should be undertaken. At present no temperature is indicated but the Federal Institute for Materials Research and Testing (BAM) has found that failure rates differ markedly depending on the temperature of the packaging and the testing medium. Norway supported the proposal but provided a slightly revised text to allow for the use of a correction factor when the test is carried out at a temperature higher than Germany’s suggested 12˚C.
The Sub-committee agreed that the subject should be considered at the next session on the basis of a new proposal that would address the issues raised, such as justification for the choice of the minimum temperature of 12°C, how to measure the temperature, extension to composite packagings/IBCs, grandfather clause for existing design type approvals, etc.
Norway also reported on a problem it had experienced during the recent outbreak of Ebola in West Africa. It had initiated a process of having larger packagings for Division 6.2 category A substances approved and had found problems in determining exactly how the testing should be carried out. Test requirements are described in Chapter 6.3, but some additional requirements are given in the packing instructions. These, though, do not specify the time period for which the primary receptacle or the secondary packaging is required to withstand the internal pressure. The International Civil Aviation Organisation (ICAO) does give further guidance in the Technical Instructions.
Norway’s paper posed a number of questions but the experts were broadly of a mind that the provisions as they stand in the Model Regulations are correct. It is, though, instructive that ICAO has felt it necessary to provide more information and it might be useful for other modes to do the same.
Switzerland invited the Sub-committee to extend the provisions of 184.108.40.206 to lamps containing mercury, as well as those containing other dangerous goods. Special provision 366 in Chapter 3.3 exempts all manufactured instruments and articles containing not more than 1 kg of mercury (land and sea transport) or 15 g of mercury (air transport). In the light of this provision, 220.127.116.11 is not applicable to lamps containing levels of mercury below those limits.
Switzerland’s argument failed to convince, with the Sub-committee finding that the provisions are clear enough.
The International Air Transport Association (IATA) queried the wording of some of the provisions adopted into the 18th revised edition of the Model Regulations, particularly the term “accepted for transport” in 2.2.4, 2.3.5, 18.104.22.168 and 2.8.3. This phrase, IATA argued, implies that there is some duty on the part of the carrier to validate a consignment before it is loaded.
The Sub-committee felt that IATA was reading too much into the phrasing, although it was accepted that there are inconsistencies of this nature throughout the Model Regulations and this is an issue that would warrant some attention. IATA was invited to submit an official document could bring more consistency in the terminology used.
In an informal document, Romania proposed tidying up the Model Regulations slightly by moving the definition of “reference steel”, which currently appears in 22.214.171.124, 126.96.36.199 and 188.8.131.52, to sit with the other definitions in 1.2.1. There was no opposition to the idea, and Romania was invited to put this in an official document for the next session, having first checked that the definition in Chapter 6.7 would also be valid when used in other chapters.
France reported on discussions at the International Maritime Organisation (IMO) on the maritime and intermodal transport of cobalt powder, which until recently had been consigned as UN 3089 metal powder, flammable, nos, Division 4.1. New tests on ultra-fine cobalt powder, undertaken in light of the European regulation on the classification, labelling and packaging (CLP) of substances and mixtures, had revealed an acute inhalation toxicity hazard.
This suggests that cobalt powder could also be consigned as UN 3179 flammable solid, toxic, inorganic, nos, Division 6.1. However, special provision 915, which is specific to the maritime mode, does not allow UN 3179 to be used for metal powders. There is a proposal to delete SP 915 from the next edition of the International Maritime Dangerous Goods (IMDG) Code, but to clear up the problem France offered a proposal to create two new UN entries for metal powder, toxic, flammable, nos.
The Sub-committee was generally in agreement with France and invited it to submit a formal proposal at the next session, although some wanted more time to check the available toxicity data for such powders.
ICAO’s Dangerous Goods Panel Working Group had met at the end of April to review the proposed amendments to the Technical Instructions stemming from the 19th revised edition of the Model Regulations. It presented an informal paper with some observations about a number of the revised provisions.
In general, the Sub-committee felt that any issues ICAO had reflected the fact that the Model Regulations aim to lay down proper conditions of transport under which dangerous goods may be safely transported, and are not intended to define the respective responsibilities of consignors and carriers nor to act as a legal document. The experts did agree that there was merit in ICAO’s proposal to add a Note to clarify the method of determining the transport index for radioactive materials, but felt that this proposal should come from the International Atomic Energy Agency (IAEA).
A similar paper was provided by IMO’s Editorial and Technical (E&T) Group, relating to the preparation of the next amendment to the IMDG Code and its Supplement. Once more, many of the observations made reflected the differing nature of the Code and the Model Regulations, but this time the Sub-committee did accept the need for some amendments. In 184.108.40.206.1, “chromium/chromium-oxide coated steel” should read “chromium/chromium oxide-coated steel” and in 220.127.116.11, “or” is deleted after “3530 MACHINERY, INTERNAL COMBUSTION”.
Other observations made by the E&T Group should, the Sub-committee felt, be put forward in official documents. These included the idea to require an indication of the emergency and control temperatures in the transport document when polymerising substances are transported under temperature control, and clarification of the special provisions relating to the transport of lithium batteries.
IAEA also provided some information on the outcome of the Transport Safety Standards Committee’s (TRANSSC) session in June 2015, of which the Sub-committee took note.
The Secretariat offered its proposals for updating the Guiding Principles to take account of the 19th revised edition of the Model Regulations. The Sub-committee was invited to check the revised text and provide feedback to the Secretariat before the end of the meeting. After that, the updated version would be posted on the UN ECE website.
France reported on progress being made in the round robin testing programme, with work on Test O.2 for oxidising liquid now having started. This was noted by the Sub-committee.
The Sub-Committee also took note of the progress made by the Joint TDG/GHS informal working group on the categorisation for flammable gases, and noted that a new session of the group was scheduled for September 2015 in Brussels.
More discussion was devoted to a paper from Canada with proposals to revise Chapter 2.8 of the Model Regulations so as to finalise the long-running debate over the adoption of the GHS criteria for corrosivity into the Model Regulations. The paper from Canada, along with informal documents from Spain and the European Chemical Industry Council (Cefic) together with the International Association for Soaps, Detergents and Maintenance Products (AISE), posed yet more questions for both the TDG and GHS Sub-committees, some of which were left to a lunchtime working group to discuss and decide on the way forward.
Following those discussions, the Sub-committee determined that the GHS corrosivity criteria as written in table 3.2.1 of the GHS have been adequately transposed into the Model Regulations. The Sub-Committee is in favour of the use of alternative methods to avoid testing but the current methods in the GHS are not sufficiently precise to adequately assign substances and mixtures to GHS sub-categories 1A, 1B, 1C or to the appropriate transport packing groups. It is essential to find a solution to this and, as the packing groups are specific to transport, it was felt that the work should be performed by the TDG Sub-committee.
The Canadian paper also went to the GHS Sub-committee and a revised proposal will be made at the next sessions of both Sub-committees.
The Secretariat reported on work being carried out to make the Manual of Tests and Criteria usable in the context of GHS. A new consolidated edition is also being developed.
The Sub-committee also agreed that the joint TDG/GHS working group should continue its work so as to enhance cooperation between the two bodies.
The Dangerous Goods Advisory Council (DGAC) returned again to the problem of GHS pictograms being applied outside of the GHS label and in the same size as transport labels and placards, causing confusion and violating transport regulations. The GHS Sub-committee had previously adopted a new section to prohibit the practice but DGAC felt that action was needed by the TDG Sub-committee and proposed new text for the Model Regulations.
Several experts expressed support for the DGAC proposal, at least in principle, although there were difficulties in terms of the overlapping provisions. Also, it seems clear there is a failure in enforcement. Perhaps some guidance on the placarding of cargo transport units should be included in GHS.
The 48th session of the UN Sub-committee of Experts on the transport of dangerous goods took place in Geneva from 30 November to 9 December 2015. A full report on that meeting will appear in a forthcoming issue of HCB Monthly.[post_title] => Deep thought [post_excerpt] =>
There are some major issues being discussed by the UN experts in the current biennium, as the agenda for their first meeting clearly demonstrated
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