AIR One of the lengthiest and most contentious meetings of the ICAO Dangerous Goods Panel ended last November in agreement on some far-reaching provisions. Those who ship dangerous goods by air should be aware that there are some significant changes coming, some as soon as next year
The International Civil Aviation Organisation's (ICAO) Dangerous Goods Panel (DGP) held its 21st meeting in Montreal, Canada this past November 5-16 to discuss and adopt proposals for amendments to the Technical Instructions for the Safe Transport of Dangerous Goods by Air (TIs) that will appear in the 2009/2010 edition.
Geoff Leach from the UK Civil Aviation Authority (CAA) was elected chairman for the meeting. Much of the discussions centred on the alignment of the TIs with the 15th edition of the UN Recommendations on the Transport of Dangerous Goods, aka the model regulations, which were adopted by the UN Committee of Experts in December 2006 and which will need to be implemented by the modal authorities as from 2009. A lot of the ground work had already been done by working groups ahead of the DGP meeting but that did not mean that their conclusions went unchallenged.
One of the most substantial amendments deriving from the model regulations was the adoption of the new 'Excepted Quantity' provisions. These were based closely on the existing requirements in the ICAO TIs, although some changes were made by the UN experts to quantity limits for the sake of consistency. Adoption of the new system will mean that the TIs will be fully harmonised with ADR/RID as regards Excepted Quantities, although for the sea mode the International Maritime Organisation (IMO) has adhered to its usual practice by requiring such shipments to be accompanied by documentation, one of the areas where the air and land modes offer relief.
The Panel adopted the provisions for environmentally hazardous substances (EHS) and have aligned with the UN model regulations. In this instance the ADR/RID experts in Europe chose to follow the approach of the International Maritime Dangerous Goods (IMDG) Code, so full modal harmonisation remains unattainable.
The revisions to the requirements for radioactive substances of Class 7 to make them more user-friendly were adopted, as they had been in the case of all the other modes.
The provisions for fuel cells were generally adopted in line with UN decisions but series of new packing instructions in the new style (see below) have been developed to deal with:
(a) fuel cells;
(b) fuel cells in equipment; and
(c) fuel cells with equipment.
These have generally been aligned to the UN provisions.
The great battery debate
The provisions regarding lithium batteries are a different story and took up a great deal of time. The consideration for lithium batteries focussed on three main issues:
(a) the carriage of lithium metal batteries under the provisions of Special Provision A45 (UN SP 188);
(b) the carriage of lithium metal batteries on passenger aircraft; and
(c) the carriage of lithium ion batteries under the provisions of Special Provision A45.
Notwithstanding the enhanced packaging and identification requirements flowing from the amendments to SP 188 in the 15th revised edition of the UN Model regulations, a working group that met a few weeks prior to the November session determined that the current per package mass of 30 kg for lithium ion batteries meeting the requirements of Special Provision A45 is excessive given the 5 kg gross mass limit that applies for packages containing fully regulated batteries when transported on a passenger aircraft.
Therefore, based on representation from the battery industry and on the amendments to SP A45 coming from UN SP 188, a 10 kg gross mass per package limit was adopted for lithium ion batteries meeting SP A45.
There was agreement that the wording of A45 has become so detailed as to create confusion for shippers. It was therefore determined that the applicable provisions in A45 relating to batteries should be transferred to a packing instruction to more clearly detail the requirements. A similar approach will also be taken for batteries shipped under A45 and packed with or contained in equipment. Separate packing instructions were created for lithium metal batteries and lithium ion batteries to reflect the differences in the two chemistries and the separation of the UN numbers.
The final decision by DGP was that fully regulated lithium metal batteries will remain permitted on passenger aircraft with a maximum gross mass per package of 2.5 kg with a metal intermediate or metal outer packaging. The addition of a metal intermediate packaging provides an additional level of protection in the event of fire and therefore it would be acceptable to permit these packages on passenger aircraft. For small lithium metal batteries that meet the provisions of A45, the same 2.5 kg gross mass per package limit will apply, although the metal packaging was not deemed necessary.
To alert all persons in the transport chain that a package contains lithium metal or lithium ion batteries, as applicable, it was agreed to require a new red-hatched marking on packages. The red-hatched marking will contain the ISO 'wineglass' symbol to identify that the packages are to be handled with care, a 'flame' symbol to indicate that if the packages are damaged a fire risk is present, and then indication that the packages contain lithium metal or lithium ion batteries and the telephone number for use in an emergency.
The UN model regulations use a numbering system for Special Provisions that runs from 1 to 330; this same numbering system is used in RID/ADR and the IMDG Code but, while the air mode has adopted UN special provisions, a completely different numbering system is used; e.g. SP188 in the UN is A45 for air transport. There had been discussions at the earlier working group to see if a change to the UN system would be acceptable but in the event the Panel decided that they wished to retain the 'A' numbering system. However, where a provision is the same as the equivalent in the UN model regulations the equivalent UN special provision number would be shown in the list of dangerous goods in the TIs.
Some very hard work undertaken by a few individuals had resulted in proposals for a completely restructured set of packing instructions. However, the restructured instructions came in for some severe criticism from industry and those involved in the original drafting had to go back and revisit the proposal. These were brought back to the Panel and, with a number of (mainly editorial) amendments proposed by the European Chemical Industry Council (Cefic) and the Dangerous Goods Advisory Council (DGAC), were adopted.
The new packing instructions will come into force January 1, 2011. Packages prepared for transport before December 31, 2010 will be permitted to move until March 31, 2011. To ensure as much publicity as possible for this major change to the instructions, it is the intention to take a number of actions:
The texts of the new packing instructions will be put on to the ICAO website in electronic files, hopefully by early March after their approval by the Air Navigation Committee (ANC). A table of correspondence will be available to show how the old numbers equate to the new system, by UN number and packing group. Some additional guidance material will be added to address:
(b) interpretation of the new secondary closures text; and
(c) the revisions to the inner packaging specifications (the old IP numbers disappear as agreed in 2001 and some packaging types have been combined).
The 2009/2010 edition of the TIs will include the new packing instructions for information to allow users to check them. Comments identifying errors or inconsistencies will be welcome. Users will also thereby have the opportunity and time to change their systems and begin training staff
An example of the newly formatted instructions is shown in Figure 1 on page 12.
Cargo aircraft only
The 'cargo aircraft only' (CAO) label has been under discussion for the last two years. After failed attempts to come up with a new label that would do away with the need for text on the label, it was proposed that the current wording, which says "DANGER", should be replaced by "CARGO AIRCRAFT ONLY"; furthermore, "DO NOT LOAD IN PASSENGER AIRCRAFT" will read "FORBIDDEN IN PASSENGER AIRCRAFT". A transitional period to allow the use of old stock of labels will apply until December 31, 2010.
Emergency phone numbers
Some years ago the US made it a requirement for most dangerous goods shipments into or through the US that there had to be a mandatory telephone number for emergencies shown on the documentation. This number has to be manned at all times while the goods are in transport. Subsequently a number of other countries and airlines imposed a similar requirement.
At the DGP meeting Cefic proposed that this should be introduced as a mandatory requirement for all air shipments. There was a long debate about this and many countries were sympathetic to the Cefic proposal, although it was recognised that there would have to be exemptions similar to those in the US Hazardous Materials Regulations.
However, after much debate, Canada and other countries that require such information said that the proposal was of very limited value unless it applied to all modes of transport and this was supported by some others. After a vote the proposal was not adopted.
With thanks to Martin Castle of VCA for his help in preparation of this report.
[post_title] => The Montreal deal [post_excerpt] =>
One of the lengthiest and most contentious meetings of the ICAO Dangerous Goods Panel ended last November in agreement on some far-reaching provisions. Those who ship dangerous goods by air should be aware that there are some significant changes coming, some as soon as next year
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