Joint Meeting hears from working groups

THE EXPERTS’ EXPERTS

MULTIMODAL • THE JOINT MEETING’S AUTUMN 2020 SESSION HEARD FROM SEVERAL WORKING GROUPS LOOKING INTO SPECIFIC TECHNICAL ISSUES, WITH SOME CHANGES ADOPTED

THE AUTUMN SESSION of the Joint Meeting of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods of the UN Economic Commission for Europe (WP15) took place between 10 and 18 September 2020, with a longer meeting to take account of the loss of the spring session due to Covid-19 restrictions. The decisions that were due to be made at the spring session and were held over to the autumn meeting were therefore too late for inclusion in the 2021 texts of RID, ADR and ADN, the regulations that govern the transport of dangerous goods by rail, road and inland waterway, respectively, and will have to wait until 2023.

The meeting was chaired by Claude Pfauvadel (France) with Silvia García-Wolfrum (Spain) as vice-chair. It was attended by representatives of 25 countries as full members and representatives of the European Commission, EU Agency for Railways (ERA) and 18 non-governmental organisations.

The first part of this report on the autumn Joint Meeting (HCB December 2020, page 58) concentrated on the discussions of the Working Group on Tanks and the decisions that it made that were approved in plenary. This second part of the report (HCB January 2021, page 48) covered progress made by the Working Group on Standards and a number of papers and proposals on the interpretation of the regulations and for their amendment. This final part of the report looks at the feedback from working groups and relations with other bodies.

Before that, the European Industrial Gases Association (EIGA) brought delegates up to date with the progress being made in the US to facilitate the international transport of approved pressure receptacles to and from Europe. It had been anticipated that the US Department of Transportation (DOT) would instigate a formal approval procedure by mid-2020, though there had been no indication by the time of the Joint Meeting. EIGA promised to continue to work with the US DOT and its US counterpart, the Compressed Gas Association (CGA) and to report back to the Joint Meeting. [Some action did emerge later, as part of a miscellaneous rulemaking by the US Pipeline and Hazardous Materials Association.]

BLEVE WORKING GROUP Spain reported on the 14th session of the informal working group on the reduction of the risk of a boiling liquid expanding vapour explosion (BLEVE), which had taken place in Madrid in October 2019 and had heard presentations from a number of expert bodies. That meeting resolved to present the Joint Meeting with some measures that had identified as offering ways to reduce or prevent the development of a BLEVE event. These were: 1. The installation of metallic mudguards on vehicles, which have been shown to prevent the propagation of tyre fires to the other areas of a vehicle. 2. The installation of engine fire suppression systems, to prevent the spread of fire to the cab, which has been shown to present a high risk of a BLEVE. 3. The installation of safety (pressure relief) valves, which have been shown to prevent a BLEVE in all cases except those where the tank is subjected to a very intense and localised heat source. 4. The introduction of technical devices for general traffic safety, since most accidents involving dangerous goods start as a normal traffic accident. This item specifically included the introduction of advanced emergency braking systems and lane departure warning systems. 5. The installation of screening between the cab and the tank, to prevent propagation of fire between the two; work is still going on to model such occurrences.

6. The use of expanded aluminium alloys (EAA), which again is a work in progress.

Experience with EAA tanks since 1980 is not promising but recent developments may offer better protection. The Joint Meeting agreed to prioritise the first three of these measures and some delegations felt it would be useful to consider them together. The measures included in the fourth item were, the meeting felt, already addressed by the World Forum for Harmonisation of Vehicle Regulations (WP 29), though the informal working group had considered taking those requirements further for tank vehicles in dangerous goods service. The Joint Meeting also agreed on the further work suggested under the fifth item, although the sixth item was seen as too uncertain to warrant consideration at this time. The Netherlands representative recommended further investigation of the impact of thermal coatings.

RISKS AND HAZARDS Romania provided a report of the February 2020 session of the informal working group on the use of the terms ‘risk’ and ‘hazard’, which had focused on drafting proposals for amendment to the UN Model Regulations. Those proposals were due to be analysed at the next session of the UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) and informal discussions had indeed taken place online during the June/ July virtual session.

Romania’s paper included a lengthy list of possible textual amendments, though most relate to the French language version of the Model Regulations. It is evident, however, that there are many instances in the English language version where ‘risk’ is used inappropriately.

This presentation generated several comments, which Romania said it would take into account in preparing a revised document for further consideration by the TDG Subcommittee.

CARRIAGE OF WASTES A paper from Germany returned to the issue of the difficulties – impossibilities, even – of complying with the requirement to determine the self-accelerating polymerisation temperature (SAPT) when waste polymerising material is involved. It may well be that the original information is unavailable, different products have been mixed, or the effectiveness of a stabiliser cannot be ascertained. Discussions have been held with the waste disposal sector on approaches that might be taken to ensure that polymerisation cannot happen when transporting waste but each transport has to be assessed on its own merits.

It would be useful if, as a first step, the Joint Meeting could settle on some provisions for the transport of polymerising waste in packages to provide the appropriate legal basis for such carriage.

Germany had brought this topic up at the Joint Meeting in March 2019 and, since then, an informal working group had met on three occasions and drawn up some ideas. These were combined into a proposed new special provision. Most delegates who expressed an opinion were supportive in principle but some felt more detailed specifications were needed. Germany offered to prepare a revised proposal for the next session.

France put forward a proposal to permit the carriage in bulk of waste containing asbestos, noting that RID/ADR prohibits the carriage of UN 2212 and 2590 asbestos in bulk. France has a national derogation to allow the local transport of waste containing asbestos under certain conditions and a meeting of the informal working group on the transport of hazardous waste in early March 2020 had invited France to bring its ideas to the Joint Meeting. Its paper contained a number of specific proposals for amendment.

While several delegates endorsed the concept in principle, there were several comments on the details of the proposal. The French representative offered to take all comments on board in the preparation of a revised proposal for the next Joint Meeting.

The European Federation of Waste Management and Environmental Services (FEAD) provided more detail on the outcome of the March meeting of the informal working group and put forward three proposals arising from its discussions. The first of these sought to clarify the scope of UN 3509, the relatively

ADDITIONAL BLEVE PROTECTION FOR PRESSURISED

TANKS IS LIKELY, WHILE THE EXPERTS CONTINUE

TO WRESTLE WITH PROBLEMS RELATING TO THE

new entry designed to cover empty, uncleaned packagings that no longer meet the definition of ‘packaging’. This appears to be contradicted by the Note to 4.1.1.11, which deals with empty packaging that still fulfils the definition of packaging when it is being sent for recycling or recovery. This causes confusion, as does the wording in special provision 663 and it was here that FEAD sought an amendment.

After discussion and further tweaks to the text, the Joint Meeting agreed the following to replace the first paragraph under ‘General provisions’ in SP 633: Packagings, discarded, empty, uncleaned with residues presenting a primary or subsidiary hazard of Class 5.1 shall not be loaded in bulk together with packagings, discarded, empty, uncleaned with residues presenting a hazard of other classes. Packagings, discarded, empty, uncleaned with residues presenting a primary or subsidiary hazard of Class 5.1 shall not be packed with other packagings, discarded, empty,

THE JOINT MEETING WILL LOOK TO HARMONISE WITH

RECENT CHANGES IN THE MODEL REGULATIONS uncleaned with residues presenting hazards of other classes in the same outer packaging.

The second paper from FEAD addressed problems experienced by the requirement to include on the transport document the quantity of goods being transported; in the case of waste, this is often not feasible. The informal working group had proposed allowing an estimate, with certain restrictions, to be shown instead. The idea was not supported in the proposed form and FEAD volunteered to review it and return with a revised proposal.

Finally, FEAD looked at the use of sheeted transport units to carry waste; this is currently permitted for UN 3175 and 3243 but not 3509, although there are some national derogations and a multilateral agreement, M287, in ADR. FEAD reasoned that the potential risks involved in the transport in sheeted containers of UN 3509 is no greater than that involved with UN 3243.

The Joint Meeting accepted the argument and added ‘VC1’ in column (17) of the Dangerous Goods List against UN 3509. FEAD also reported that the next meeting of the informal working group on the transport of hazardous waste had been scheduled to take place in early October but, due to Covid-related restrictions, would be held online instead. PRESSURE RECEPTACLES EIGA provided a report of the informal working group on provisions on equipment for tanks and pressure receptacles, which had been reconvened to look into amendments adopted by the UN TDG Sub-committee in December 2019 and how RID/ADR/ADN could be harmonised with them in their 2023 editions. The informal working group had requested that work on tanks should be dropped from its remit, as the informal working group on the inspection and certification of tanks had undertaken a thorough review and revision of all aspects of the conformity assessment of tanks and their service equipment.

EIGA’s paper included a lengthy list of the amendments that will be needed to harmonise with the Model Regulations, which was welcomed by the Joint Meeting. It was felt that these should be considered alongside other amendments already adopted for the next edition of the Model Regulations and that the proposed amendments should be passed to the Ad-hoc Working Group on the Harmonization of RID/ADR/ADN with the UN Recommendations for a final decision.

ACCIDENT AND RISK MANAGEMENT France provided an update on the discussions of the informal working group on the

improvement of the report on occurrences, which had met in mid-February 2020 and had since then, due to Covid-19 restrictions, continued work by correspondence. With the help of ERA, existing reporting mechanisms were examined, with a view to settling on a system that would be more specific to the transport of dangerous goods.

It was felt that the working group’s drafts covered all the data points necessary to understand an accident, although it was stressed that the report form should be kept as simple and short as possible. It was acknowledged, though, that operators might have difficulty in gathering all the information needed within the one-month time frame mentioned in 1.8.5. It may be necessary to have two reports, the first containing the information needed in the short term, with a follow-up containing information gathered from other sources.

There had been discussions on the viability of collecting and collating incident reports through country-based electronic and automated systems, which could then be forwarded automatically to the respective secretariats.

At the Joint Meeting, there were several comments on the purpose of reporting on accidents, the use of harmonised criteria and future steps in the further clarification of procedures. It was recommended that the informal working group should resume its work at report back to the Joint Meeting at its next meeting in March 2021.

OTHER BUSINESS The European Association of Dangerous Goods Safety Advisers (EASA) asked for a reassessment of its consultative status, currently limited to topics relating to 1.8.3. This was widely supported, so its consultative status will henceforth cover all RID/ADR/ADN subjects.

The secretariat informed the Joint Meeting of the decisions and recommendations made by the Inland Transport Committee on the implementation of its strategy on sustainable transport and innovative technologies to 2030, including the carriage of dangerous goods by different transport modes. Delegates were invited to comment on the document through the secretariat or the chair of the Joint Meeting.

On a vote, Claude Pfauvadel and Silvia García Wolfrum were re-elected as chair and vice-chair, respectively, for 2021.

The next Joint Meeting is due to be held in Bern from 15 to 19 March, though this is likely to take place in a virtual format. The Ad hoc Working Group on the Harmonisation of RID/ ADR/ADN with the UN Recommendations is scheduled to meet from 21 to 23 April.