[ID] => 7355
[post_author] => 34
[post_date] => 2016-12-02 10:42:40
[post_date_gmt] => 2016-12-02 10:42:40
[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.
As is now normal practice, matters relating to Class 1 substances and articles were remitted to the Working Group on Explosives, which met in parallel with plenary for five days under the chairmanship of Ed de Jong (Netherlands).
The Working Group considered a number of changes to the criteria for US and HSL flash composition tests, as agreed at the previous session of the Sub-committee but which had been placed in square brackets pending confirmation. These it felt agreeable, except that the term “lifting charge” should be replaced by “propellant charge”.
The result of these discussions will be a new section 2 in Appendix 7 of the Manual of Tests and Criteria, setting out the procedure for carrying out the US flash composition test and the interpretation of its results, as well as amendments to what is now section 1 on HSL flash composition tests. There are also changes in Chapter 2.1 of the Model Regulations to reflect those amendments.
At the 47th session of the Sub-committee Germany had proposed changes to the Koenen Test, in particular allowing alternatives to the specified tube steel, which is hard to obtain. Since then tests in Germany have shown that changing the steel quality does not have an effect on the outcome of the Koenen test. As a result of those tests, Germany also proposed changing the steel tube bursting pressure criteria from 30 MPa ± 3 MPa to 28 MPa ± 4 MPa. Other experts preferred 29 MPa ± 4 MPa, which was included in revisions to sections 188.8.131.52.1(d), 184.108.40.206.1(d), 220.127.116.11.1(d) and 18.104.22.168.1(d) of the Manual of Tests and Criteria, which will all read:
The bursting pressure as determined by quasi-static load through an incompressible fluid shall be 29 MPa ± 4 MPa.
France had been leading a search for a replacement for dibutyl phthalate (DBP) in calibrating the heating rate in some Koenen Tests, since this is now forbidden for general use within the EU after being identified as a substance of very high concern under REACH. It has identified a synthetic silicone oil that it believes is a suitable alternative and will set up a series of round robin tests to verify this belief.
The Institute of Makers of Explosives (IME) and Germany continued work on another long-term issue, viz the lack of availability of detonators meeting the specifications of the standard detonator. As part of that work, IME had earlier suggested that it might be possible to simplify the specifications of the standard detonator and to replace the European and US versions with a single universal version, an idea that had found favour with the experts.
There are, though, a number of issues to be resolved and work will continue through the 2017-18 biennium, led by IME and Germany.
A number of work projects are under way looking at the minimum burning pressure (MBP) test and its application in the determination of ammonium nitrate emulsion (ANE) classification and as an alternative to the 8(c) Koenen test. An informal correspondence group will continue to consider whether the Koenen test might be a suitable 8(c) test for gels and suspensions and the MBP test suitable for emulsions.
Another informal document from IME was remitted back to plenary for discussion as it was felt to have broader implications. This continued debate about the growing need for a standardised system of issuing and applying security marks to consignments of explosives. Since it was first discussed, the issue has divided the experts, although in practice there are now systems in place around the world and it is beginning to become clear that there is a need to address the issue at the Sub-committee level.
IME’s paper ended with a proposal for the format of the harmonised mark, based primarily on the existing EU format. Although these marking requirements are not directly linked to transport safety or security, the Sub-Committee agreed that it was important to provide recognition of the potential presence of this mark and to encourage an internationally consistent format to facilitate international and multimodal transport.
The US and UK came up with an alternative wording, which was accepted by the experts. However, as this had come up as a result of a late paper, it was deemed necessary to leave it in square brackets for confirmation at the 50th meeting in December 2016. The amendment will consist of the addition of a Note at the end of 22.214.171.124.1:
In addition to the security provisions of these Regulations, competent authorities may implement further security provisions for reasons other than safety of dangerous goods during transport. In order to not impede international and multimodal transport by different explosives security markings, it is recommended that such markings be formatted consistent with an internationally harmonized standard (e.g. European Union Commission Directive 2008/43/EC).
Several papers addressed work being done on the review of Chapter 2.1 of the Globally Harmonised System (GHS) with particular regard to the labelling of explosives. It is in areas such as this that the fundamental differences between the Model Regulations and GHS are laid bare: the classification of explosives in transport is highly dependent on the type of packaging used, whereas as a matter of principle GHS regards substances has having immutably intrinsic properties.
It was the opinion of the Working Group that all explosive divisions other than 1.4 and the category currently termed “unstable explosives” should bear the exploding bomb pictogram, the signal word ‘Danger’ and the hazard statement ‘Explosive’. For Division 1.4, there was no consensus on the most appropriate labelling, but the idea of separating out from this Division those substances, mixtures and articles that also without (transport) packaging pose only a minor hazard was generally accepted.
These items were to be discussed by a dedicated meeting during the GHS Sub-committee’s session immediately following the TDG Sub-committee; work will continue, with the aim of having formal proposals in place in time for the December 2016 session.
When special provision 347 is applied against an explosives entry, it requires that the 6(d) test be passed before 1.4S can be assigned; currently this applies to only eight entries but at the previous session Canada had proposed adding a number of others. The Working Group did not entirely agree but did agree to recommend applying SP347 to UN 0349, 0367, 0384 and 0481, each of which is an nos entry. This was confirmed in plenary.
At the previous session IME had challenged some terminology in the Manual of Tests and Criteria, in particular references to a “testing authority” in Section 1.1.2. The Working Group agreed that this could be misleading and agreed to replace it with “testing body”. It was noted that the same term was used in Section 2.3 of Appendix 6 and this too was changed.
Following up, France suggested that the proposal recommending “competence” of testing bodies be amended to recommend “technical competence” of testing bodies. Again this proved acceptable to the Working Group, and to plenary, which adopted all of the proposed changes.
An ad hoc working group under the International Group of experts on the explosion risks of Unstable Substances (IGUS) has been working to clarify the provisions for classification of ammonium nitrate-based fertilisers, especially SP307. Sweden presented the results of that group’s deliberations and a proposal to add a new Section 39 to the Manual of Tests and Criteria. This would provide procedures and criteria for classifying AN-based fertilisers and a flow chart to assist in determining the correct classification.
A detailed discussion led to a general support for the proposal, although some experts urged that care should be taken not to introduce new requirements. Sweden will prepare a revised proposal for the December 2016 session.
Along the way it had been spotted that the current text of 38.2 in the Manual of Tests and Criteria includes a requirement on ammonium nitrate that originated from an old version of SP193 that should have been removed when SP193 was modified. It was agreed that this should be done for the 7th revised edition of the Manual.
The Sporting Arms and Ammunition Manufacturers’ Institute (SAAMI) sought to remove the requirement for specification packaging of ammunition (UN 0012, 0014 and 0055) to better align with the limited quantity system and to allow an alternative to the 6(d) test when ammunition is packaged according to a proven configuration.
Although opinion was divided, the Working Group eventually supported the possibility of developing a default classification system for ammunition that would preclude the dependence on specification packaging requirements and the 6(d) test for transport in limited quantities.
Plenary did, however, stress that a revised proposal from SAAMI, which has been promised, would be subjected to stringent examination of its scope and the kinds of articles concerned.
Germany proposed to reword SP364 to make it clear that tests are the basis for its application. This was supported by some experts but others, notably SAAMI and the US, demurred. The working group noted that work on the previous item regarding the 6(d) test could have an impact and agreed that this item should be deferred.
A paper from Germany reported on sensitivity tests carried out on pentaerythrite tetranitrate (PETN) – UN 0150, Division 1.1D – with different levels of water content. The UN entry specifies a range of less than 25 per cent but more than 9 per cent. Germany indicated that the water in wetted PETN is only loosely attached to the crystals and can easily be removed even at ambient temperature. In response, Spain said that it had been unable to reproduce those results and suggested a round robin test.
No changes will be made to the water desensitisation requirements for UN 0150 but the working group agreed that Spain’s offer to coordinate a series of round robin tests would be taken up.
The European Chemical Industry Council (Cefic) and Germany’s Federal Institute for Materials Research and Testing (BAM) have been looking at ways to package for transport very small quantities of samples that, while not designed to be explosives of Class 1, display explosive and/or self-reactive properties. After conducting tests, BAM concluded that it had found a safe package design, which was offered to the Working Group for discussion so that a formal proposal can be developed.
The Working Group supported the proposal in principle, although some experts wanted the scope of applicable substances to be more tightly defined. Cefic will prepare a formal proposal for the next session.
At the request of the Sub-committee the Working Group discussed Romania’s proposal to insert definitions for “reference steel” and “mild steel” in the Model Regulations. It was concluded that such proposals would have no impact on the performance tests described in the Manual of Tests and Criteria.
The Australian Explosives Industry Safety Group (AEISG) and SAAMI urged clarification of the classification criteria used for desensitised explosives in GHS, saying that 126.96.36.199(a) of GHS can be interpreted to mean that, although it is transported and stored in a desensitised state, the intention is that the desensitiser will be removed prior to use.
There was general support for the proposal although it was felt that the solution offered was too difficult to understand. A revised text did prove acceptable, which was forwarded to the GHS experts. New Zealand noticed that similar wording was used in 51.2.2 of the Manual of Tests and Criteria and it was agreed to change this too.
LISTING AND CLASSIFICATION
The introduction in the 19th revised edition of the Model Regulations of new entries for polymerising substances has – as might be expected – led to some questions and additional changes.
A proposal to add the word “STABILIZED” to the proper shipping name for UN 3302, 2-dimethylaminoethyl acrylate, was accepted, albeit some experts were not happy with the level of detail provided in the proposal.
Austria sought the deletion of 188.8.131.52.1(c), which says that polymerising substances under temperature control that do not meet the criteria for assignment to Classes 1 to 8 must be assigned to Division 4.1. Its paper suggested that this sub-paragraph may have been left in inadvertently, as the original suggestion had been to place polymerising substances in Class 9.
The Sub-committee did not agree but instead held on the issue raised for later discussion on emergency and control temperatures.
Cefic asked why there is no provision for exemptions in 184.108.40.206.1, as there is with the similar texts for self-reactive substances of Division 4.1 and organic peroxides of Division 5.2. The Council’s paper offered some basis for exemptions. There was widespread opposition to the idea, not least since Cefic’s proposal appeared to be package-specific and lacked test results.
The Cefic representative said he would look into the matter and may return with a revised proposal.
Germany reported on work done by BAM since the last session, when it proved impossible to agree on a revision to the packing provisions in order to overcome the problems encountered in practice with waste contaminated with infectious substances, for example in the recent context of the treatment of solid wastes generated in relation to the outbreak of the Ebola virus. That work had led Germany to draft proposed changes to packing instruction P620 and 220.127.116.11.1, 18.104.22.168 and 22.214.171.124.
Canada supported Germany’s submission but felt a different approach would be more effective and in an informal document offered two options based primarily on the addition of specific new packing instructions.
The matter was discussed by a lunchtime working group, which identified a need to treat the issue in such a way so as not to interfere with the existing transport of Category A infectious substances. The working group achieved a broad consensus on the packaging specification but felt more work needed to be done on testing provisions. Further proposals were promised for the next session.
Also on the subject of infectious substances, Canada proposed harmonising the three packing instructions for regulated medical waste, (bio) medical and clinical waste assigned to UN 3291. The proposal failed to convince many of the experts but the Canadian experts said a revised paper would be presented, taking their comments into account.
A joint paper from WHO and FAO followed up on an ICAO paper at the previous session, querying the new provisions for the transport of infected animals. There is clearly some misunderstanding, which is not helped by inconsistencies in the wording of various paragraphs in Chapter 2.6.
Several experts did not support the solutions offered and the WHO and FAO representatives met with interested delegations to draw up an alternative. That did receive some support but a number of experts asked for time to discuss the matter further at national level. A new proposal will be put forward at the next session.
Germany followed up on discussions at the last session on the need to clarify the provisions in 126.96.36.199.4.1 of the Manual of Tests and Criteria relating to the N.1 test for readily combustible solids with some specific proposals. After some explanation from the US, the experts agreed to adopt the proposed amendments, with some changes. These were placed in square brackets pending confirmation at the next session.
Canada proposed a modification of packing instruction LP902 to eliminate inconsistencies between P902 and LP902 for UN 3268 safety devices, electrically initiated. These inconsistencies were introduced when P902 was amended in 2010.
The experts agreed with Canada’s argument and adopted the changes. In packing instruction LP902 in 188.8.131.52, the line “Packagings conforming to the packing group III performance level.” is replaced by:
Rigid large packagings conforming to the packing group III performance level, made of:
metal other than steel or aluminium (50N)
rigid plastics (50H)
natural wood (50C)
reconstituted wood (50F)
rigid fibreboard (50G).
Another proposal from Canada noted that SP293 is applied to three of the four UN entries for matches and suggested that it should apply to all four. The experts agreed, adding “293” to column (6) of the Dangerous Goods List against UN 1945, matches, wax “vesta”. A small editorial amendment to SP293 was also made.
Yet another paper from Canada proposed the revision of P801 to define what is meant by "battery boxes" in the context of the packing requirements relating to used storage batteries (UN 2794, 2795 or 3028). The proposal drew a number of comments, which the Canadian expert will take into account in forming a revised paper for the next session.
Canada was also involved, along with Cefic and the International Association for Soaps, Detergents and Maintenance Products (AISE), in drafting proposals for the revision of Chapter 2.8 as part of the long-running project to bring the Model Regulations into line with the GHS provisions on the classification of corrosive substances.
It does now seem as though this particular saga may be nearing its conclusion, with many experts in favour of adopting the text for a revised Chapter 2.8 as proposed. Others still found points that needed clarification so a revised proposal was put together by a lunchtime working group. This was provisionally adopted, pending the outcome of deliberations at the GHS Sub-committee relating to the GHS definitions on corrosivity, which were also under discussion.
The International Fishmeal and Fish Oil Organisation (IFFO) proposed modifying SP308 along the lines of SP945 in the International Maritime Dangerous Goods (IMDG) Code, to allow antioxidants other than ethoxyquin to be used.
The Sub-committee felt such a move would be premature, as tests are ongoing on the use of other antioxidants. The representative of IFFO pointed out that new results would soon be available and that she would submit a new document at the next session.
The US raised the issue of proper shipping names for mixtures and solutions, particularly those that contain a single predominant substance, but where a proper shipping name other than the name for the predominant substance may be most appropriate. Such situations are dealt with in 184.108.40.206 and 220.127.116.11.
The Sub-committee recalled that many generic entries, such as resin solutions, glues, perfumery products and alcoholic beverages, are generally intended to include products containing just one dangerous substance, such as ethanol, and that it is perfectly acceptable to classify such substances under the appropriate generic entry.
On the other hand, some experts pointed out that consignors can choose to classify a substance as a solution of the dangerous component, especially if that if of greater use to emergency response personnel in the event of an incident.
It was decided not to adopt the proposal for now, although the US expert said a revised proposal may be put forward.
The Dangerous Goods Advisory Council (DGAC) proposed the creation of a new E code, E6, to authorise the use of the excepted quantity provisions for inner packagings not exceeding 1 g/1 ml outer packagings not exceeding 1,000 grams or ml. Such a move would give packaging manufacturers greater flexibility in providing packagings for the needs of various users.
Most experts opposed the creation of a new E code to apply to only a few products containing alcohol and considered Chapter 3.5 already allows for the necessary flexibility. The proposal was not adopted and the US expert said he would prepare a proposal of guiding principles for the assignment of E-codes.
A proposal from Austria addressed the meaning of 18.104.22.168, which deals with the situation where a single UN number has more than one proper shipping name. There was support for some clarification but not in the way Austria envisaged. Instead, on the basis of an informal document from Spain, the experts amended the first sentence of 22.214.171.124 to read:
When a combination of several distinct proper shipping names are listed under a single UN number, and these are separated by “and” or ”or” in lower case or are punctuated by commas, only the most appropriate shall be shown in the transport document or package marks.
The second sentence of 126.96.36.199 is deleted.
Canada felt it may be worthwhile adding a definition of ‘vapour pressure’ but several experts expressed doubts, noting that test laboratories ought to know what it means. Canada may return with a formal proposal.
Canada reported on a teleconference held to discuss the classification of crude oil. The two main topics were the determination of the initial boiling point and the use of ASTM D7169 in that regard, and the difficulties in determining hydrogen sulphide concentrations in the vapour phase.
The expert from Canada promised to continue to share information on the ongoing discussions as it becomes available.
South Korea had been looking at newly produced test data on toxicity and proposed that a toxic subsidiary risk should be indicated for UN 2248, 2264 and 2357. The Sub-committee took note of the proposal, which was contained in an informal document, and suggested that South Korea submit an official proposal, taking into consideration the changes to the conditions of transport that would be required as a consequence.
The second part of this report on the UN TDG Sub-committee’s summer 2016 session in next month’s HCB will cover discussions on energy storage systems (in particular lithium batteries), the transport of gases, miscellaneous proposals for amendment of the Model Regulations, global harmonisation and issues relating to GHS.
[post_title] => UN: Summer in Switzerland
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[post_modified] => 2016-12-02 10:42:40
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UN: Summer in Switzerland
The UN experts are closing in on the 20th revised edition of the Model Regulations. Pay attention, as these changes will impact operations soon enough