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UN makes final touches to changes
LAST CHANCE SALOON
MULTIMODAL • THE UN EXPERTS ENDED THE BIENNIUM WITH A PACKED AGENDA, MANAGING TO ADOPT FURTHER CHANGES TO THE NEXT EDITION OF THE ORANGE BOOK
THE UN SUB-COMMITTEE of Experts on the Transport of Dangerous Goods (TDG) held its 54th session – the fourth and final session of the 2017/18 biennium – this past 26 November to 4 December in Geneva. It was chaired by Duane Pfund (US) with Claude Pfauvadel as vice-chair.
The meeting was attended by experts from 18 countries, observers from Ireland, Slovakia and Turkey, and representatives of the EU, the Intergovernmental Organisation for International Carriage by Rail (OTIF), the UN Food and Agriculture Organisation (FAO), the International Atomic Energy Agency (IAEA), the International Civil Aviation Organisation (ICAO), the International Maritime Organisation (IMO), the World Health Organisation (WHO) and 32 non-governmental organisations.
The main task of the Sub-committee was to agree the final list of amendments that will appear in the 21st revised edition of the UN Recommendations on the Transport of Dangerous Goods – the ‘Model Regulations’ or ‘Orange Book’ – for formal adoption at the session of the UN Committee of Experts on TDG and the Globally Harmonised System of Classification and Labelling (GHS) that followed immediately afterwards.
The Sub-committee is not keen on starting new business at the final session of the biennium, preferring to spend its time reviewing decisions already taken and finalising outstanding issues. Nevertheless, there was some new business put before the experts, all of which was knocked back for further consideration or for deliberation in another forum.
DRAFT REVIEW The first item on the agenda was a review of the draft amendments adopted at the three previous sessions. Those that related specifically to explosives or to the Manual of Tests and Criteria were referred to the Working Group on Explosives, while the other amendments were confirmed by the plenary meeting, with some exceptions.
Firstly, the planned amendment to 1.1.1.2(c) relating to lithium battery-powered cargo tracking devices and data loggers, which had been left in square brackets pending a final decision, was deleted, as the topic was the
GENEVA OFFERS DELEGATES SOME PEACE AND QUIET
subject of a broader proposal that appeared later in the session.
The decision taken at the December 2017 session to add a packing group I entry for UN 1390 alkali metal amides was also rescinded on the basis of test data provided by the US.
The new packing instructions P622 and LP622, applicable to UN 3549, were adopted but with some additional changes following an oral presentation by FAO. That clarified that the instructions apply not simply to material of UN 3549 but more specifically “to waste of UN 3549 transported for disposal”.
The planned amendments to 7.1.5.4.5(b) to (e), adopted on the basis of earlier discussions by the UN ECE Working Party on the Transport of Dangerous Goods (WP15), were also dropped. Intersessional discussions determined that the text that had been provisionally adopted for the UN Model Regulations might lead to misinterpretation; this fact was to be brought to WP15’s attention, after which the issue might return to the TDG Sub-committee.
The secretariat had also provided a consolidated list of corrections to the 20th revised edition of the UN Model Regulations, which would be circulated as an official corrigendum; experts were asked to communicate any further corrections so that they could be included.
EXPLOSIVES ISSUES The Working Group on Explosives met from 26 to 30 November parallel to plenary under the chairmanship of Ed de Jong (Netherlands). The Working Group was, though, unable to reach consensus on many of the issues facing it; these were sent back to plenary for further consideration.
The Institute of Makers of Explosives (IME) returned to the search for a more appropriate test than the Koenen Test (UN Test 8(c)) for evaluating certain emulsions for classification under UN 3375 ammonium nitrate emulsion or suspension or gel. After lengthy investigation and discussion, the minimum burning pressure (MBP) test, already in use by a number of ammonium nitrate manufacturers for internal uses, had been identified; however, proposals at earlier sessions for its inclusion had failed to reach consensus.
Although the Working Group had not agreed amendments on this topic, it had prepared changes to the proposals in the IME paper for discussion in plenary. It was finally agreed to include the MBP test as UN Test 8(e), to be applied to substances that fail Test 8(c). This will involve several amendments in the Manual of Tests and Criteria, including to Figure 10.4 and Sections 18.1, 18.2 and 18.6.1.4, and a new Section 18.8 describing the test. Other changes relevant to GHS would be brought to the attention of the GHS Sub-committee.
Another IME paper returned to the issue of ammonium nitrate assigned to UN 0222, Division 1.1D; this product is not in commercial manufacture but during earlier discussions several delegates expressed their wish to retain the entry as it is useful for dealing with contaminated product. The Working Group had agreed that it was also useful for special cases and for fertilisers that fail test series 2.
IME, rather than pressing its request for UN 0222 to be deleted, now took a different tack, maintaining that the presence of this entry can cause misunderstanding and incorrect application. It proposed a revision to the text of special provision 370, which applies only to UN 0222. The Working Group recommended that the Sub-committee adopt the revision, which it did. It involves the amendment of the first sentence of SP 370 to read: “This entry only applies to ammonium nitrate that meets one of the following criteria:”. The two criteria that follow will be linked with “or” rather than “and”, as at present. And a new paragraph is added after the indents: This entry shall not be used for ammonium nitrate for which a proper shipping name already exists in the Dangerous Goods List of Chapter 3.2 including ammonium nitrate mixed with fuel oil (ANFO) or any of the commercial grades of ammonium nitrate.
The US returned to its proposal to allow certain pyrotechnic articles of UN 0431 to use the default fireworks classification table. Discussion at the previous session had raised concerns over the proposed limitation to articles “intended for professional use only”; the revised US proposal was more specific. Further concerns were now expressed about a precedent being set for extending the applicability of the table. In the end, however, and after further clarification, the amendment to 2.1.3.5.2 was adopted. This involved the addition, after “or 0336” in the first sentence of that paragraph, of “, and articles to UN 0431 for those used for theatrical effects meeting the definition for article type and »
1.4G specification in the default fireworks classification table in 2.1.3.5.5”.
The UK sought to sort out the allocation of large packing instruction LP101; discussions at earlier sessions it was felt that LP101 was only appropriate for items that could have PP67 or L1 applied to them but, after further discussions, the UK had pressed its point. The Sub-committee now agreed to add “LP101” under “P130” in column (8) of the Dangerous Goods List for UN Nos 0005, 0007, 0012, 0014, 0033, 0037, 0136, 0167, 0180, 0238, 0240, 0242, 0279, 0291, 0294, 0295, 0324, 0326, 0327, 0330, 0338, 0339, 0348, 0369, 0371, 0413, 0414, 0417, 0426, 0427, 0453, 0457, 0458, 0459 and 0460.
Another paper on a similar theme from the UK fared less well. This was based on the fact that PP67 (in P130) and L1 (in LP101) apply the same provisions to the same articles. The UK felt there is a problem insofar as there is no definition of “large and robust”, and that articles that meet the criteria may be consigned unpackaged and therefore cannot meet the package test requirements. The UK proposed deleting PP67 and L1 and drawing up a new special provision, which would allow dutyholders to consider the provisions relating to large and robust items without having to refer to the packing instructions.
The UK paper was supported by Finland, with some amendments, which raised further issues about specific items. The Working Group gave some support to both arguments but also felt that packing instruction P101 gives the competent authority the ability to specify if a packaging is required or not. The Sub-committee concurred. Due to a lack of support, the UK proposal was withdrawn.
Germany returned to the topic of self-inflating recovery devices and their classification. These devices function in the same was as life-saving appliances (UN 2990) or safety devices (UN 0503 and 3268). Germany proposed a new entry in the dangerous goods list, while also raising the possibility of assigning such devices to one of the new entries for articles, most likely UN 3538. The Working Group was not totally convinced and part of the German proposal was withdrawn. However, the Subcommittee did agree to add at the end of 2.0.5.4 a new sentence: However, this section applies to articles containing explosives which are excluded from Class 1 in accordance with 2.1.3.6.4.
The Working Group had made headway on its tasks in respect of the review of Chapter 2.1 of GHS. It had reviewed the technical criteria for assignment of explosives to subcategories 2A, 2B and 2C in GHS, without necessitating consequential changes in the TDG classification system. It was noted that this would provide an improved system of addressing the classification of explosives in packaging configurations other than those used in transport. The Working Group will continue to provide technical advice and support to the GHS Sub-committee, as needed.
The Working Group had gone through the secretariat’s consolidated list of amendments already adopted and made a few editorial adjustments.
FIREWORKS REGULARLY PRESENT THE UN EXPERTS
WITH TRICKY DECISIONS ON CLASSIFICATION
The European Chemical Industry Council (Cefic) returned with more information to support its proposal to regulate the transport of energetic substances, including explosives and self-reactive substances, in small quantities for the purposes of testing. Both the Working Group and the Sub-committee were still unconvinced, citing a lack of sufficient technical background, although the Working Group had at least acknowledged the need for action. Cefic will continue to work on the proposal and come back with another paper during the 2019-2020 biennium.
Sweden argued that the term “manufactured with a view to producing a practical explosive or pyrotechnic effect”, which is in 2.1.1.1(c) of the Model Regulations as part of the definition of Class 1 as well as in the Manual of Tests and Criteria, is being used incorrectly in the GHS, as most of the text concerning Class 1 in the Model Regulations has been copied over to Chapter 2.1 of GHS. In addition, the word “practical” appears to be redundant in most places where the term is used.
The Working Group recommended, and the Sub-committee approved, the deletion of “(2.1.1.1(c))” from the second sentence of 2.1.3.3.1 of the Model Regulations. Other elements of the Swedish proposal relating to the Manual of Tests and Criteria were withdrawn for further work.
Sweden had also spotted what it thought was an error in the Manual of Tests and Criteria. Section 16.5.1.4(c) requires selection of the initiation system for packaged substances not intended for use as explosives on the basis of Text 6(a). However, the current text requires the use of whichever initiation system that gives a “+” result. This is not defined. Sweden’s paper offered a solution, which was accepted. The text of 16.5.1.4(c) will now read: Substances not intended for use as explosives, but provisionally accepted into Class 1, should be tested using whichever initiation system gave evidence of a mass explosion in a type 6 (a) test.
LISTING, CLASSIFICATION AND PACKAGING Cefic reverted with a revised version of its proposal to amend packing instructions P400 and P404 to address issues concerning inner receptacles of combination packagings filled with pyrophoric solids. While the existing provisions have proven to ensure safety during transport, there are occupational safety hazards related to the need to reseal receptacles after partial emptying of their contents. In particular, small residues of pyrophoric substances adhering to threaded closures may react critically due to friction when the closures are screwed back on.
The Sub-committee was happy with Cefic’s latest proposal and agreed to amend P400 and P404 in similar ways, firstly by deleting reference to threaded closures and then by adding a new text to specify: Inner packagings shall have threaded closures or closures physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transport.
Cefic also appealed for the inclusion of some exemptions from the provisions of the Model Regulations for the newly adopted UN numbers for polymerising substances. Based on experience so far with the transport of polymerising substances, and by analogy with exemptions for Class 1 articles in packaging, Cefic believed that some relief could be provided, with restrictions.
Several delegations supported the concept but, given that the provisions for polymerising substances had only been introduced two years before, many felt that more experience was needed before considering exemptions. Some ideas were offered for improving the proposal and Cefic, stressing industry’s need for such an exemption, will submit a revised proposal at the next session.
Spain renewed its appeal to have barium carbonate exempted from the provisions. As it is a barium compound, it is currently classified under UN 1564, Division 6.1. However, Spain contended, test results for barium carbonate show it does not meet the criteria for Division 6.1 and it should therefore be treated in the same way as barium sulphate which, by dint of special provision 177, is not subject to the Model Regulations.
There was not much backing for the proposal, with some experts pointing out that barium carbonate can be toxic to humans when ingested. Due to lack of support, the proposal was withdrawn. »
Another proposal from Spain fared rather better. Following proposals prepared by Cefic and the European Industrial Gases Association (EIGA), it seemed sensible that chemicals under pressure (UN 3500 to 3505) should be treated in the same way as aerosols in terms of their assignment to one of the three divisions of Class 2. The Subcommittee agreed and added reference to chemicals under pressure immediately after reference to aerosols in 2.2.1.3 and the Note to 2.2.2.1.
Belgium came back with a firm proposal to clarify the provisions for the marking of inner receptacles of intermediate bulk containers (IBCs), after having canvassed opinion at the previous session. The Sub-committee found its proposal, after some amendments, acceptable and amended the end of the first paragraph of 6.5.2.2.4 to read:
THE PAINT INDUSTRY SUCCEEDED IN ITS PROPOSAL
TO AVOID THE NEED TO PROVIDE LENGTHY AND
NORMALLY INCOMPREHENSIBLE TECHNICAL NAMES
ON SHIPPING DOCUMENTS, A CHANGE THAT WILL It shall be durable, legible and placed in a location so as to be readily accessible for inspection after assembling the inner receptacle in the outer casing. When the mark on the inner receptacle is not readily accessible for inspection due to the design of the outer casing, a duplicate of the required mark on the inner receptacle shall be placed on the outer casing preceded by the wording “Inner receptacle”. This duplicate shall be durable, legible and placed in a location so as to be readily accessible for inspection.
The International Paint and Printing Ink Council (IPPIC) returned to its plea for amendment of the requirement to provide technical names for substances classified as environmental hazardous substances, nos and transported under UN 3077 or 3082. In the paint business, such technical names can be very long, complex and of no help to the emergency services. It appealed for 3.1.2.8.1.1 to be amended to allow the use of generic names for UN 3077 and 3082.
After some discussion, it was decided that the best route to clarity was to make a change to special provision 274, adding new paragraphs at the end: For UN 3077 and UN 3082 only, the technical name may be a name shown in capital letters in column 2 of the Dangerous Goods List, provided that this name does not include “N.O.S.” and that special provision 274 is not assigned. The name which most appropriately describes the substance or mixture shall be used, e.g.: UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (PAINT) UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (PERFUMERY PRODUCTS)
ELECTRIC STORAGE DEVICES While the experts continue to struggle with an effective means of regulating lithium batteries in transport, they are also faced with understanding the risks posed by cells and batteries using other chemistries. Switzerland returned to the issue of sodium nickel chloride batteries, presenting a lengthy paper with technical details to support its contention that these batteries do not present a hazard in transport and, therefore, should be exempted from the regulations.
There was limited support for the proposal. Some felt that, as sodium nickel chloride batteries are transported as enclosed
systems, they should be subject to drop or vibration tests. Others felt that, as the batteries contain substances that are themselves classified as dangerous goods in transport, they should not be completely exempted. An example of a way forward may be found in the treatment of sodium batteries, assigned to Division 4.3 on account of their sodium content but with specific transport conditions addressed in a special provision.
The Sub-committee eventually agreed that a partial exemption could be justified. However, the experts felt that other factors need to be examined. Switzerland will revise its proposal in light of those comments and will present a new document at the next session.
Informal documents from the International Air Transport Association (IATA), France and the European Association for Advanced Rechargeable Batteries (Recharge) advised the Sub-committee that a meeting of the informal working group on lithium battery classification was to take place the following week; they also updated the Sub-committee on the thinking behind the proposed riskbased classification approach. There are several definitions outstanding and also a need to determine the criteria by which to assess fire initiation and propagation.
The Rechargeable Battery Association (PRBA) and Recharge reiterated the problems shippers often have in complying with the labelling and marking requirements for packages of lithium batteries. Such packages can vary widely in size and the marking requirements also vary considerably. Their joint paper proposed amendments to 5.2.1.9.2 to make it easier for shippers to meet the requirements, particularly on smaller packages.
The paper was supported by the Medical Device Battery Transport Council (MDBTC), which offered an alternative solution, although the Sub-committee preferred to adopt some of the changes suggested by PRBA and Recharge. Specifically, these allow the mark required in 5.2.1.9.2 to be rectangular or square, with a minimum size of 100 mm by 100 mm; if the size of the package so requires, the dimensions can be reduced to not less than 100 mm by 70 mm; the reference to “line thickness” has been removed.
TRANSPORT OF GASES At an earlier meeting of WP15, Ireland had sought to include provisions for waste gas cartridges of UN 2037, similar to those already in place for waste aerosols of UN 1950. WP15 indicated that, as this is a multimodal issue, the proposal should be put to the TDG Sub-committee in the first place. Ireland came with proposals to amend special provision 327, add a new special packing »
provision to packing instruction P003, amend PP87 in P207 and amend LP200.
The proposal was adopted with some amendments. It was also noted that the transport of empty gas cartridges and gas cylinders for reprocessing or disposal is an issue that needs detailed examination by the modal authorities; it is possible that this may result in further amendments to the Model Regulations.
SP 327 is amended by adding “and waste gas cartridges” after “waste aerosols” in three places. A new fourth sentence is added: Waste gas cartridges, other than those leaking or severely deformed, shall be packed in accordance with packing instruction P003 and special packing provisions PP17 and PP96, or packing instruction LP200 and special packing provision L2.
A new paragraph is added at the end: Waste gas cartridges that were filled with gases of Division 2.2 and have been pierced are not subject to these regulations. A new special packing provision is added to P003: PP96 For UN 2037 waste gas cartridges carried in accordance with special provision 327, the packagings shall be adequately ventilated to prevent the creation of dangerous atmospheres and the build-up of pressure.
In PP87 in P207, “flammable atmospheres” is replaced by “dangerous atmospheres”. Reference to waste gas cartridges is added to LP200, the last sentence of which is amended to follow the text of PP96. In the Dangerous Goods List in Chapter 3.2, against UN 2037, “327” is added in column (6), “LP200” is added in column (8) and “PP96” is added against “P003” in column (9).
The International Standardisation Organisation (ISO) reported that, after undertaking a review of the references in Chapter 6.2 that had been requested by the Sub-committee at the last session, it had not found any redundant standards. ISO will make a proposal at the next session to introduce a reference to ISO 18119:2018.
At the previous session ISO had proposed the introduction of a reference to ISO 17879:2017 Gas cylinders – Self-closing cylinder valves – Specification and type testing. It had not been adopted at the time, as some experts questioned the need for the increase in the pressure value for the burst test. Subsequent discussions between ISO, EIGA and the Compressed Gases Association (CGA) resulted in a compromise proposal. Reference to the standard is added in the table in 6.2.2.3 but a Note is appended: “This standard shall not be applied to self-closing valves in acetylene service.” Reference to this standard is also added in 4.1.6.1.8, accompanied by a new paragraph: For pressure receptacles with self-closing valves with inherent protection, the requirements of annex A of ISO 17879:2017 shall be met.
At the previous session, ISO had also proposed updating the LC50 values of eight toxic gases that were changed in the 2018 revision of ISO 10298 and are now different from those shown in the Model Regulations. The Sub-committee had asked for more information on the sources of the new data, which ISO now provided.
Several experts noted that the toxicity data relating to UN 2196 tungsten hexafluoride and UN 2098 phosphorus pentafluoride are not publicly available and it was not thought appropriate to make changes on the basis of derived data. Sweden indicated that the toxicity data for UN 1008 boron trifluoride were significantly different from those contained in Annex VI to the European Commission’s Classification, Labelling and Packaging (CLP) Regulations. No changes were adopted for these three entries.
However, it was agreed that new LC50 values be adopted in Table 2 in P200 for: • UN 1859 silicon tetrafluoride (450 is replaced by 922) • UN 2188 arsine (20 is replaced by 178) • UN 2202 hydrogen selenide (2 is replaced by 51) • UN 2534 methylchlorosilane (600 is replaced by 2810) • UN 2676 stibine (20 is replaced by 178).
Cefic came back to the issue of liquid/ gas-based suppression systems used in fire control. These are not classified under UN
LIQUID/GAS FIRE SUPPRESSION SYSTEMS WILL 1044 fire extinguishers, as they meet the Note of SP 225. Cefic noted that gas-based suppression systems are assigned to UN 1956 compressed gas, which have a maximum test period for periodic inspection of 10 years. Liquid/gas systems are assigned to UN 3500 and have a maximum test period of five years, despite having a lower pressure than gas/ gas mixtures. This seemed anomalous. Cefic proposed adding a special packing provision to P206 to extend the maximum test period for such systems to 10 years.
The Sub-committee agreed with Cefic and adopted a new special packing provision in P206: PP97 For fire extinguishing agents assigned to UN 3500 the maximum test period for periodic inspection shall be 10 years. They may be transported in tubes of a maximum water capacity of 450 l conforming to the applicable requirements of Chapter 6.2. HCB
The second part of this two-part report on the UN TDG Sub-committee’s last session in next month’s HCB will cover other miscellaneous changes, global harmonisation and issues related to the GHS. There will also be a condensed overview of all the main changes made to the Model Regulations that will appear this year in the 21st revised edition.