[ID] => 7458
[post_author] => 34
[post_date] => 2017-01-05 12:44:19
[post_date_gmt] => 2017-01-05 12:44:19
[post_content] => The UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) held its 49th session this past 26 June to 6 July in Geneva under the chairmanship of Duane Pfund (US), with Claude Pfauvadel (France) as vice-chair. This was the third of the four planned meetings of the Sub-committee for the 2015-16 biennium, at the end of which it was due to adopt the amendments that will appear in the 20th revised edition of the UN Recommendations on the Transport of Dangerous Goods – otherwise known as the Model Regulations or the ‘Orange Book’ – and will take effect in international modal regulations as from the start of 2019.
The meeting was attended by experts from 24 countries, observers from Luxembourg, New Zealand and Romania, and representatives of the European Union (EU), the Intergovernmental Organisation for International Carriage by Rail (OTIF), the Food and Agriculture Organisation (FAO), the International Civil Aviation Organisation (ICAO), the International Maritime Organisation (IMO), the UN Institute for Training and Research (Unitar), the World Health Organisation (WHO) and 31 non-governmental organisations.
The first part of this two-part report (HCB January 2017, page 58) covered matters relating to the transport of explosives and to listing and classification. This second part looks at the rest of the agenda.
ELECTRIC STORAGE SYSTEMS
Innovation in battery technology is keeping the Sub-committee on its toes and there are also ongoing issues concerning lithium batteries to discuss. Indeed, the first item on the agenda was a report from the third meeting of the informal working group on lithium batteries, presented by France, the Portable Rechargeable Battery Association (PRBA), the European Association for Advanced Rechargeable Batteries (Recharge) and the Council on Safe Transportation of Hazardous Articles (COSTHA).
The report contained a number of proposals based on consensus reached at the meeting, which took place at the end of March in Bordeaux. The Sub-committee adopted a proposal to amend the definition of ‘Disassembly’ in 22.214.171.124 of the Manual of Tests and Criteria; a new Table 38.3.2 summarising the applicable tests for primary cells and batteries; and a new sentence at the end of 126.96.36.199:
A cell or battery that is an integral part of the equipment it is intended to power that is transported only when installed in the equipment, may be tested in accordance with the applicable tests when installed in the equipment.
A number of other discussion items from the report were dealt with elsewhere in the agenda. An editorial change to 2.9.4(f) was agreed. The proposal to reduce the number of cycles from 50 to 25 in the tests required under 38.3.3(c), (d) and (e) was queried by the Sub-committee but, after an explanation from Recharge, was accepted.
PRBA and Recharge also suggested that it would be useful for the Manual of Tests and Criteria to have flowcharts to facilitate the understanding of testing procedures. The two associations were invited to submit a formal proposal at the next session.
PRBA and Recharge also returned with a proposal to insert a new UN number for lithium metal polymer (RLMP) batteries, which are expected to become more widely used in the next few years. Opinion was divided: some experts urged the acceptance of the proposal whereas others felt that RLMP batteries should fall under the same entry as lithium metal batteries. Again, the two associations offered to return with a new document at the next session.
A paper from ICAO summarised the changes it had recently made to the Technical Instructions, in particular the ban on the transport of lithium ion batteries as cargo on passenger aircraft. That decision led to a lengthy discussion, where it was noted that it is difficult to predict the behaviour of lithium batteries in a fire purely on the basis of their lithium content or energy rating. In fact, that behaviour appears to depend primarily on battery and packaging design. That suggests that perhaps an approach to classification akin to that used for explosives might be appropriate. France promised to present the results of a study at the next meeting.
PRBA proposed a new set of UN entries for lithium batteries used for medical devices but this failed to gain much support, the experts being of the opinion that there is no way to determine during transport what the end use of a battery is to be. The proposal was withdrawn.
PRBA had more success with a paper highlighting the different marking requirements between the ICAO Technical Instructions on the one hand and the UN Model Regulations and other modal rulebooks on the other. The matter was solved by the addition of a second Note to special provision 188(f):
Packages containing lithium batteries packed in conformity with the provisions of Part 4, Chapter 11, Packing Instructions 965 or 968, Section IB of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air that bear the mark as shown in 188.8.131.52 (lithium battery mark) and the label shown in 184.108.40.206.2, Model No.9A shall be deemed to meet the provisions of this special provision.
Yet another paper from PRBA proposed revised wording for SP376 on the packaging of damaged or defective lithium batteries and a new special provision for the return of damaged or defective lithium batteries by consumers to the vendor. Both received some support but there was no agreement on the wording; PRBA promised revised versions for the next meeting.
The Sub-committee was less welcoming of PRBA’s suggestion to add a new UN entry for lithium metal button cells and batteries, not least since the conditions of carriage suggested would be identical to those applicable to UN 3090. Some experts were, though, in favour of a method by which to differentiate the hazards posed by different formats of cell and battery.
The International Organisation of Motor Vehicle Manufacturers (OICA) and Recharge appealed for the urgent agreement of a temporary system for the transport of damaged or defective batteries for automobiles and electric bicycles; the market for such equipment is growing rapidly and it is becoming impossible to seek competent authority approval each time a damaged/defective battery needs to be transported. There was a great deal of sympathy for the suggestion and experts were invited to submit comments in detail so that a formal proposal could be presented at the next session.
At the previous session PRBA had raised the issue of transportable lithium battery power systems, which generally consist of banks of lithium ion or lithium metal batteries, electrically connected and with the necessary battery management systems, which are secured to racks, cabinets, or similar structures that, in turn, are securely attached to the interior structure of closed cargo transport units (typically either freight containers or freight vehicles). PRBA now returned with some alternative proposals in a formal paper.
After some discussion, the experts decided to adopt a new UN 3536 for lithium batteries installed in cargo transport units, Class 9, along with a new SP 389 to specify the entry’s applicability and conditions of carriage.
Germany came with two informal documents dealing with large packagings of lithium batteries of small production runs or prototypes, and with container transport units (CTUs) equipped with container tracking devices containing lithium batteries. After comments from the experts, Germany said it will return with formal proposals at the next session.
The last paper under the topic of energy storage systems was a lengthy paper from France summarising discussions over the previous two years on the special provisions concerning the carriage of vehicles. The paper contained three proposals, two of which came with alternative solutions.
The Sub-committee favoured the idea of deleting special provisions 240, 312, 380 and 385 and replacing them with a new SP 388, applicable to UN 3166 and 3171. In addition, a new introductory sentence is added to SP 363:
This entry may only be used when the conditions of this special provision are met. No other requirements of these regulations apply.
The last sentence of SP 363(f) is replaced by:
However, lithium batteries shall meet the provisions of 2.9.4, except that 2.9.4 (a) does not apply when pre-production prototype batteries or batteries of a small production run, consisting of not more than 100 batteries, are installed in machinery or engines.
Where a lithium battery installed in a machinery or an engine is damaged or defective, the machinery or engine shall be transported as defined by the competent authority.
The Sub-Committee emphasised that the reference to the competent authority for determining conditions of transport means that it is for the competent authority to establish such conditions of transport for domestic traffic. In international transport, the Contracting Parties to the applicable legal instruments may decide to set such conditions in the relevant modal regulations (ADR, RID, IMDG Code, etc).
TRANSPORT OF GASES
The issue of gas tanks for motor vehicles had been raised at the previous two sessions and Germany returned to the subject with a formal proposal involving a new special provision. Most delegates were in favour of the idea, at least in principle, but no agreement was reached. A new paper will be prepared for the next session.
The International Standardisation Organisation (ISO) arrived with a list of newly agreed standards for inclusion in 6.2.2. These were adopted:
ISO 4706:2008 Gas cylinders – Refillable welded steel cylinders – Test pressure 60 bar and below
ISO 18172-1:2007 Gas cylinders – Refillable welded stainless steel cylinders – Part 1: Test pressure 6 MPa and below
ISO 17871:2015 Gas cylinders – Quick-release cylinders valves – Specification and type testing
ISO 11623:2015 Gas cylinders – Composite construction – Periodic inspection and testing.
Following the adoption of ISO 21172-1:2015 at a previous meeting, concern had been expressed that this effectively prohibits the longstanding practice of transporting corrosive gases in pressure drums (also known as ton tanks, ton containers, or multi-unit tank car tanks) with dished ends convex to pressure.
The solution to this problem was to add a Note after the title of the newly adopted standard in 220.127.116.11.8:
Irrespective section 18.104.22.168 of this standard, welded steel gas pressure drums with dished ends convex to pressure may be used for the transport of corrosive substances provided all applicable requirements of these Regulations are met.
The UK followed up on changes provisionally agreed at the previous session for packing instruction P200(3)(e) involving the rationalisation of the terms “liquid phase”, “liquefied gas” and “liquid component” with a proposal to make similar changes in P206(3). These too were provisionally adopted, subject to confirmation at the following meeting.
MACHINERY AND ARTICLES
The UK continued with its ongoing project to rationalise the provisions regarding the transport of dangerous goods in machinery, apparatus and articles. It came with an extensive proposal to add a number of new entries in the Dangerous Goods List, a new section for Chapter 2.0 and a flowchart for the classification of articles containing dangerous goods.
This was all remitted to a lunchtime working group for discussion but no consensus was reached. Work was to continue by correspondence with the hope that decisions could be reached in time for a revised proposal to be drawn up for the December 2016 meeting; if not, the matter would need to be held over to the 2017/18 biennium.
Switzerland raised a looming problem with the application of special provision 363 in 2017, namely the impossibility of knowing how much liquid fuel is contained in engines or machinery during transport. SP363 requires labels or placards if “…the engine or machinery contains more than 60 l of liquid fuel…”. It proposed changing this so that the provision refers simply to the capacity of the engine or machinery concerned.
Some experts concurred with Switzerland’s position but others said that the wording had been specifically included so as to ensure that the consignor checks the volume of fuel contained. There was also opposition to the idea of changing a provision that had not yet entered into force. The Swiss delegate said he would discuss the issue further with his domestic enforcement agencies and return with a revised proposal.
MARKING AND LABELLING
After the adoption of new provisions on the use of flexible bulk containers, there had been discussion at the previous meeting on how the placarding and labeling provisions should be applied to such containers. It was decided that they should be subject to the provisions of Chapter 5.3 and the US now offered a formal proposal to add suitable text, which proved acceptable to the Sub-committee.
The changes involve the addition of “and bulk containers” or “or bulk containers” after “cargo transport units” in the title of Chapter 5.3, the introductory paragraph of 22.214.171.124.2, and in 126.96.36.199.1 and 188.8.131.52.2.
The International Air Transport Association (IATA) noticed that, when the new lithium battery label was adopted, the wording did not exactly match that of other label descriptions. The Sub-committee agreed and added “or suitable contrasting background” after “black on white” in the last paragraph of 184.108.40.206.2. This change is a correction to the 19th revised edition of the Model Regulations.
Spain queried the provisions for design type tests for intermediate bulk containers (IBCs), particularly an apparent contradiction in the number of IBCs that may be used for the drop test. It suggested some changes to clarify the issue.
The Sub-committee felt that the wording of 220.127.116.11.5(e) is clear but agreed that it might be best to amend the last paragraph of 18.104.22.168.3 to read:
The same IBC or a different IBC of the same design may be used for each drop.
Germany persisted with its position that a minimum water temperature should be specified for hydraulic pressure tests involving plastics packaging. Several delegations still had reservations about the idea but a compromise was reached on the basis of an informal document from the International Confederation of Intermediate Bulk Container Associations (ICIBCA) and the International Confederation of Plastics Packaging Manufacturers (ICPP), which will require the temperature of the water used to be shown on the test report. This involves an additional sentence under item 8 of 22.214.171.124 and a similar addition to item 8 of 126.96.36.199.1.
Russia arrived with a formal proposal to amend the wording in certain special provisions and packing instructions with regard to electrical insulation in battery packaging. This was an issue that had been identified by the joint RID/ADR/ADN meeting.
Some of the changes proved acceptable but one was rejected and another was remitted to IAEA for discussion. Those that were adopted involve:
- replacing “protection against contact with conductive materials” by “protection against contact with electrically conductive material” in SP188(d), and
- replacing ““non-conductive” by “electrically non-conductive” in P801, P908, P909, P910 and LP904.
A lengthy and reasoned paper from IATA contended that the UN Model Regulations use “risk” and “hazard” interchangeably, whereas the two words have different meanings; that difference is clearly stated in the Globally Harmonised System of classification and labelling of chemicals (GHS). “Hazard” is the intrinsic property of the substance concerned, whereas “risk” involves a factor of likelihood and/or consequence.
IATA produced a long list of examples in the Model Regulations where, it believed, “risk” should be replaced by “hazard”. Most of these were accepted. The Sub-committee also suggested that it would be worth examining the French language edition and possibly others to see how the two terms had been translated.
The International Dangerous Goods and Containers Association (IDGCA), with supporting information from the Responsible Packaging Management Association of Southern Africa (RPMASA), queried the use of flexible tanks for the carriage of liquid fuels, in particular diesel classified under UN 1202. It appears that in certain countries such transport is permitted under competent authority approval but there had been several instances where the flexible tank had leaked.
The Sub-committee confirmed that it did not regard flexitanks and similar flexible containers as “large and robust articles” within the meaning of 188.8.131.52. Even though some competent authorities have authorised their use to carry liquid fuels, this should not be seen as generally acceptable, although it might be justified in exceptional circumstances. The Sub-committee did not feel it appropriate to make any change to the Model Regulations.
Germany followed up on the adoption of provisions on the emergency and control temperature for polymerising substances with a proposal to add wording in section 7.1.5 on temperature control during transport. The proposal had, though, not been submitted in time for delegates to consider it in detail and while it was broadly supported it would need to be put forward as an official document for the December meeting before any decision could be taken.
COSTHA offered a proposal to amend the wording of P902 to make it clear that the relief offered for manufacturers moving unpackaged articles (specifically, UN 3268 safety devices, electrically initiated) from the point of manufacture to an assembly plant applies equally to movements involving an intermediate handling location. There was some support for the idea and COSTHA will return with a formal proposal.
The Secretariat had spotted some inconsistencies in the French text of the Model Regulations in relation to the translation of the term “distinguishing sign for motor vehicles in international traffic” and the related reference to the 1968 Convention on Road Traffic in several places. Having done so, it also noted that the English text is not entirely accurate and offered some amendments, which were duly accepted.
The Secretariat had also identified inconsistencies in the proper shipping names listed in the Spanish version of the Model Regulations and those listed in the IMDG Code, the ICAO Technical Instructions, RID, ADR and national regulations of various Spanish-speaking countries. The experts felt that this was not a matter for the Sub-committee as Spanish is not one of its working languages, but it is an official UN language and urged the use of the UN translation service.
Romania returned with another proposal to insert definitions for “reference steel” and “mild steel” in 1.2.1. The Working Group on Explosives confirmed that the proposed changes would have no impact on the performance of tests but some experts feared that there could be other unforeseen problems for metal IBCs and radioactive material packagings. The Romanian observer offered to return again with a clearer proposal.
The Sub-Committee noted that the IMO Maritime Safety Committee had adopted Amendment 38-16 of the IMDG Code and that this will become mandatory as from 1 January 2018. IMO had also issued MSC.1/Circ.1520 (Guidelines on consolidated IMO provisions for the safe carriage of dangerous goods in packaged form by sea); MSC.1/Circ.1521 (Amendments to the inspection programmes for cargo transport units carrying dangerous goods); and MSC.1/Circ.1522 (Amendments to the Emergency Procedures for ships carrying Dangerous Goods (EmS) Guide).
The Secretariat provided a report on the spring 2016 joint RID/ADR/ADN meeting. A number of proposals to amend the Model Regulations arising from that meeting will be discussed at the next session of the Sub-committee.
The Sub-committee also noted the outcome of the 32nd session of IAEA’s Transport Safety Standards Committee (TRANSSC), held in June 2016.
The informal working group on classification criteria for flammable gases had been hard at work looking into how best to align the transport rules with the GHS building blocks for low flammability gases. A paper from Belgium and Japan, reporting on the group’s work, proposed substantial revisions to Chapter 2.2 of the GHS along with consequential amendments. A more extensive proposal was put forward by Germany, Cefic and the European Industrial Gases Association (EIGA) included some amendments to Chapter 2.2 of the Model Regulations as well.
The Sub-committee accepted the need for a new sub-category for low flammability gases (which will affect refrigerant gases in particular) but felt it premature to agree changes to the Model Regulations when the matter is still under discussion by the GHS Sub-committee. However, it did support a two-stage approach to the matter, with the informal working group’s proposals to be put first to the GHS Sub-committee and only after that to establish if any changes are needed in the Model Regulations.
This was among a number of matters to be passed on to the joint session of the TDG and GHS Sub-committees that was held immediately after the TDG Sub-committee’s meeting, where it was agreed to proceed along the lines suggested. The work will aim to provide a coherent system for the classification of all flammable gases, including pyrophoric and chemically unstable gases.
The joint session discussed a number of other topics, including France’s search for a suitable fuel material for the O.2 and O.3 tests for oxidising liquids and solids. The experts were invited to review the results of round robin testing and be prepared to discuss the matter further at the next session.
Work is also continuing on the revision of Chapter 2.1 of GHS. As part of this, it has been observed that additional guidance is needed as regards the applicability of the GHS to some stages of the life cycle of explosives. Cefic observed that the same may be true of physical hazards in general.
The working group on explosives also reported that its work on the use of the Manual of Tests and Criteria within the context of GHS should be finished during the 2015/16 biennium.
An informal paper from the International Council on Mining and Metals (ICMM) noted that, according to Annex 4 of GHS, section 14.7 of the safety data sheet (SDS) should give information on dangerous goods carried in bulk by sea. However, this only references the IMO instruments relating to liquid cargoes; there are many solid bulk and gaseous cargoes that are also carried in bulk by sea and this should be reflected in the provisions, ICMM argued. There was general support for the proposal but the experts did not like the wording offered; a revised proposal will be put before the next meeting.
The 50th session of the TDG Sub-committee took place in Geneva from 28 November to 6 December 2016. This was followed by a meeting of the GHS Sub-committee and then by the biennial meeting of the parent Committee; it was only then that the changes to the Model Regulations that will appear in the 20th revised edition were formally adopted. Those amendments will then be transposed by the various modal and national authorities into regulations that will apply as from 2019.
A report on the meetings of those two bodies will appear in HCB Monthly as soon as possible.
[post_title] => UN: Over the hump
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The work of the UN TDG experts gets ever more technical and granular but they are well on the way to agreeing the next edition of the Orange Book