UNSCOE TDG 50th Session – Day 4 Summary
The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 50th Session November 28-December 7, 2017 in Geneva, Switzerland. The following summary is provided to allow you to follow the discussion at the meeting. As of Day 4, there are 36 formal and 50 informal documents to be reviewed. Please find links to each individual document from the UN Website.
Discussion of Papers
Day 4
WP55 – Consolidated List of Amendments – The Subcommittee reviewed the agreed text from the previous three sessions. Amendments related to explosives were already confirmed on Day 1. The Subcommittee identified an inconsistency in the Lithium Battery testing table related to T.6. Participants indicated they would review the table during the morning break. All other adopted amendments were confirmed.
WP71 – Lithium Batteries, Section 2.9.4 and Special Provision 310 – PRBA noted redundant information in 2.9.4 and Special Provision 310 related to violent rupture during transport. They proposed to combine this information in Special Provision 310. France supported the proposal but pointed out it is found in the relevant packing instructions as well. Austria did not oppose the proposal but questioned the appropriate wording. Belgium agreed with France. The Netherlands preferred to keep the language in 2.9.4. The US also felt it was important to keep the information in 2.9.4. China stated the UN Manual and the Model Regulations are separate documents and preferred to keep information in each of them, but they could support the revision to SP310. Germany supported adopting the change in Special Provision 310. The UK noted 2.9.4 defines the classification section for lithium batteries and therefore, they felt the language should remain. IATA supported the proposal noting the current language in SP188 appears to exempt small cells and batteries from the current conditions of 2.9.4, which is not intended. Canada and Spain supported simplification but could not support the proposal as presented. Spain further noted 2.9.4 is referenced in other locations in the Model Regulations. Thus, adopting the provision would result in having to repeat the information elsewhere. Switzerland agreed with Spain and added the UN Manual is not translated into other languages as the Model Regulations are. France addressed the Spanish comments suggesting additional language related to vehicles and equipment. RECHARGE explained that not all cells/batteries are designed with short circuit protection but packaging is used to meet that requirement. After the RECHARGE explanation, France acknowledged there appears to be a contradiction and a change is needed. The Chairman indicated the text then appears to be a proposed change, not just elimination of a redundancy. The US agreed with the Chairman and reiterated their opposition to the proposal. France requested the report reflect the fact that cells/batteries that do not have short circuit protection as part of their design must be protected when packaged. Based on the comments from the Subcommittee, PRBA withdrew the paper and will return at a future session.
WP51 - Gas Tanks for Motor Vehicles – Germany presented provisions for the transport of vehicle fuel tanks containing gas, noting the need to have provisions to move such tanks for service, repair, and installation with certain amounts of gas contained within. COSTHA supported the proposal and added an editorial amendment if Option 2 is chosen. The Netherlands felt additional editorial amendments were necessary before they could support the proposal. Switzerland wondered whether the Subcommittee were “reinventing the wheel”. They preferred to refer to regulations in other documents than to include them in the Model Regulations. Belgium preferred to not include the standards in the proposal, and asked how one could determine if damage to a fuel tank would lead to a leak. They finalized their intervention by suggesting a full documentation should be required. The US suggested revising paragraph (f) to require the 20% limit to apply to all movements of the tanks, not just those from the manufacturer to the assembly plant. They also suggested changing the word “are” to “include” in the new special provision XXX, paragraph (a). Sweden supported Option 1 but suggested paragraph (c) could be refined to define which valves must be closed when there are more than 2 valves are included. Norway supported the proposal in principle. Spain supported Option 2 agreeing with others that they were not comfortable with including all the standards, but that was a previous request from the Subcommittee. Canada supported Option 1 and agreed with COSTHA’s suggestion regarding CSA B51 Part 2. They further proposed language to address Sweden’s concern in paragraph (c). The also indicated they would add two additional standards for Canada in the future. Austria supported the proposal but requested recalled tanks for safety purposes should be exempt from the proposal. France supported the proposal and suggested Option 2 would be easier to adopt the US revisions. They also reiterated Germany added the table in Option 2 at the request of the Subcommittee. France commented the concern over the 20% filling limit may be over limiting in the case of repairs or accidents where the limit would be impractical to implement. France preferred to keep the language as presented but was willing to work on revised language if the Subcommittee supported this point. OICA reminded the Subcommittee that a similar provision already exists in the ADR (SP660). In these cases, a safety check is conducted to ensure no leaks are present. Reducing the filling ratio for repair or accident is not practical and places a workplace safety risk on employees. The UK supported the proposal with the US addition of identifying the standard list as indicative, not exhaustive. Belgium reiterated their concern on high filling ratios for shipments other than from a manufacturer to an assembly plant. The US drafted language to address their concern. Paragraph (f) would then read “Except in the case of accident or repair, fuel gas containment systems transported from where they are manufactured to a vehicle assembly plant shall be filled with not more than 20% of their nominal filling ratio or nominal working pressure, as applicable.“ Germany responded that the full information on the transport document may not be known, and that is why the document exceptions were provided. The agreed with the amendments from Canada that addressed Sweden’s concerns, and suggested that Belgium’s concerns may be addressed at the modal level. The Subcommittee agreed Option 2 provided the best solution. Germany indicated they would draft an INF paper taking account of all the amendments provided to be reviewed later in the session.
INF50/INF5/INF25/INF49 – Consolidated Amendments on Corrosive Substances - Based on previous comments on WP50 and associated INF documents, Canada proposed revised text in INF49. Chapter 2.8 as a whole was presented. They proposed to remove the square brackets from 2.8.1.2. CEFIC explained the language in 2.8.1.2 is reproduced from and harmonized with GHS. The Secretariat questioned whether the square brackets were still necessary for the footnotes dealing with the OECD Guidelines. Switzerland indicated they had requested inclusion of a date, but as it has been proposed, there would be no transition measure for companies that have classified under a previous version. CEFIC confirmed the current language includes dates and application of the standard would only be for new classifications would not require retro-classification to the new standard. The Subcommittee discussed whether the OECD Guideline revisions would have an impact on classification, and whether a transition period was necessary. Ultimately, they decided the OECD Guideline changes did not have any significant impact on the classification and references to the Guidelines would be acceptable. The Subcommittee agreed to capture a note in the report to indicate that additional testing is not required, and to drop the square brackets on the Guidelines. After review of the document, the Subcommittee adopted the text as presented in INF49 including the removal of square brackets.
WP67/INF50 – Damaged/Defective Lithium Batteries – OICA updated the Subcommittee on the progress of the lunchtime working group on damaged/defective batteries. A new INF paper will be prepared and submitted for review by the Subcommittee later in the session.
WP70/INF41 – Polymerizing Substances and Emergency Response Information – Germany proposed to combine 7.1.5 and 7.1.6 and provided consequential amendments. In INF41, the UK provided comments on the proposal and provided editorial suggestions. The intent was restructuring of the text and not actually changing any requirements. Sweden supported the proposal in WP70 and provided several editorial amendments. The US supported the proposal in WP70 but had some concerns on INF41. Austria aligned their comments with the US. DGAC suggested the table in 7.1.5.2.5 could be updated for portable tanks to reflect “≤45 oC” instead of “oC”. Germany agreed to the proposals by Sweden, but voiced concern for adopting the proposal in paragraphs 3 and 5 of INF41. They also preferred not to adopt the change to the table at this time. They requested the Subcommittee take a decision on the paper as amended by Sweden. The UK suggested moving 7.1.5.3.6 to 7.1.5.2 as the paragraph didn’t apply to temperature control. Austria commented the paragraph did relate to temperature control and should stay. Belgium disagreed and supported the move of the paragraph. The UK indicated they would withdraw INF41 and readdress it in the next biennium. After discussion, the Subcommittee agreed to WP70 as amended by Sweden and the UK (movement of 7.1.5.3.6).
INF27 – Testing Method for Readily Combustible Solids – As a follow up from a previous session, Germany reviewed the wording in the N.1 Test in the UN Manual. Their continued investigation revealed there is “more to the story” and the issue needs further investigation. At the last session, new text had been adopted in square brackets. After further investigation, Germany believed the text was inappropriate and proposed to delete the previously adopted text. The US explained the section of the test being discussed is a screening method, and they preferred to keep the previously agreed language. The Netherlands preferred to discuss the issue further before finalizing the text, and thus supported the INF document. Belgium agreed with the US and opposed the proposal. DGAC added the challenges with determining when the test should start, and supported maintaining the text in square brackets. Given the paper addressed language in WP55, the Chairman took a position on keeping the text in Chapter 33 of the UN Manual. By a vote of 8 - 3, the text was maintained. The Subcommittee agreed to include the issue on the agenda for work for the next biennium as requested in INF27.
WP78/INF6 – Assignment of E-Codes – The US proposed to include language in the Guiding Principles on the rational for the excepted quantity provisions. The UN provisions were adopted prior to incorporation of the alphanumeric code (E-codes) currently in use. Therefore, the proposal was based on the language contained in the 2005-2006 ICAO TI. No changes to the Model Regulations were presented, but instead provided an explanation of the rationale behind the decisions made by the UN to adopt the provisions. Belgium asked if the list of specific footnotes was intended to include all items not permitted in EQ. The US noted the Guiding Principles already address the fact that materials that are forbidden on passenger aircraft are not permitted as EQ. They did not intend to capture all items. Sweden supported the proposal and suggested the UN should consider expanding E codes to low hazard articles. The Netherlands voiced challenges with determining what is permitted on passenger aircraft without understanding the rational from ICAO as to what is and is not allowed on passenger aircraft. The Subcommittee agreed to the proposal in WP78 and added a note in the report to work further with ICAO to determine further rational to consider.
WP57/INF3/INF3rev1 – Maximum Capacity of Composite Packagings (6HH1) – Based on testing data contained in INF3/INF3Rev1, ICPP proposed increasing the maximum capacity of 6HH1 for PG I from 120 L to 250 L. The US supported the amendment as proposed. Belgium supported the proposal, but added the drum given as an example would not have been approved in Belgium. The UK opposed the proposal indicating that the philosophy of capacity limits for composite packaging limited PG I packaging to ½ the limit for PG II or III. They suggested the opposite revision should be adopted; 6HA1 and 6HB1 capacities for PG I should be reduced to 120 L. They added decisions at the UN should not be based on economic need but on safety. Sweden indicated if the packaging can pass the testing provisions, they do not believe capacities should be limited. Germany supported the proposal as drafted. ICIBCA commented the limits were originally based on IMDG limits but the need to be flexible was acknowledged. Based on testing data, they supported the revision. Based on the discussion and a vote of 11-0, the Subcommittee agreed to the proposal as drafted.
WP79/INF34 – Testing Requirements for Bromine Portable Tanks – The US pointed out TP10 requires annual inspection of the lead lining to ensure the integrity of the lining remains. Bromine is reactive with aluminum and other metals. However, there is no grace period for transport if the lead lining has expired. Therefore, they proposed adding a 3-month period after emptying but before cleaning when the tank may be transported without approval. The US provided test data in INF34 supporting their proposal. The Chairman made a minor editorial correction. The UK supported the proposal. Belgium indicated they were the start of the problem as they discovered non-compliant tanks. They were concerned the 3-month period was very long compared to an annual inspection. The Netherlands stated they did not have a chance to review the data and indicated they needed different data to make their determination (original thickness). Canada and Austria also supported the proposal. In answer to the Netherlands, the US indicated industry practice is to start at 10mm. Further, they explained the data shows even when the lining has been reduced, the erosion did not occur more than 50% of the 5 mm thickness. The Subcommittee agreed to the proposal by a vote of 14-1.
WP51/INF53 - Gas Tanks for Motor Vehicles – Germany presented a revised proposal INF53 based on comments from the Subcommittee earlier on Day 4. They made an editorial amendment in paragraph (f), replacing “Exempt in” with “Except for”. Several small editorial amendments were suggested. Belgium questioned how tanks that were overfilled or damaged could be handled. Germany pointed out the situation would be addressed in Note 2. Based on the discussion, the Subcommittee agreed to adopt the proposal in INF53 as amended.
WP80 – Classification of Mixtures of Environmentally Hazardous Substances – The US pointed out text in 2.9.3.4.6.5.1 does not appear to be appropriate for inclusion in the Model Regulations. Instead this appeared to be appropriate for safety data sheets from the GHS. The Netherlands explained the purpose of the text is to explain to the transporter the data used for classification may not be complete. Therefore, it should be retained. Germany disagreed with the Netherlands stating classification is the responsibility of the shipper not the operator. They supported the proposal as drafted. CEFIC pointed out the classification data should be available in the SDS and would not be needed by the transporter. Belgium and France supported removing the text. The Subcommittee agreed to the proposal as drafted.
INF26 – Marking and Documentation of Large Salvage Packagings – Germany identified amendments necessary to fully incorporate the provisions of large salvage packagings into the Model Regulations. The Subcommittee agreed to the proposal in INF26.
End of Day 4