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UN experts make progress
LET’S GET BUSY
MULTIMODAL • DESPITE THE DIFFICULTIES OF MEETING IN PERSON, THE UN EXPERTS HAVE MADE A LOT OF PROGRESS TOWARDS THE 23RD REVISED EDITION OF THE MODEL REGULATIONS
THE UN SUB-COMMITTEE of Experts on the Transport of Dangerous Goods (TDG) held its 59th session this past 29 November to 8 December 2021, with Duane Pfund (US) in the chair and Claude Pfauvadel (France) as vice-chair. It was attended, either in person or online, by representatives of 23 countries, the EU, the Intergovernmental Organisation for International Carriage by Rail (OTIF), the UN Food and Agriculture Organisation (FAO), the International Civil Aviation Organisation (ICAO), the International Maritime Organisation (IMO), the World Health Organisation (WHO) and 25 non-governmental organisations. In addition, observers from Latvia, Luxembourg and Turkey also took part.
This second meeting of the Sub-committee for the current biennium would in more normal times be the busiest of the four sessions; however, ongoing Covid-19 response measures, financial constraints triggered by the UN liquidity crisis, renovation work at the Palais des Nations that limited the number of meeting rooms available for hybrid meetings and the allocation of interpretation services all meant that the volume of work was less than might have been hoped.
The first part of this two-part report on the session (HCB March 2022, page 48) covered a surprisingly thin list of proposals relating to explosives and a rather longer agenda of proposals for amendment in terms of classification, listing and packaging, which covered such subjects as quinone dioxime, gallium in articles, tetramethylammonium hydroxide and ammonium nitrate (hot concentrated solution). This second part covers the remaining discussions at the session. ENERGY STORAGE SYSTEMS Never a regulatory meeting goes by, it seems, without some further changes to the very many and varied provisions relating to the transport of lithium batteries in one form or another. A very important project, therefore, is the development of a hazard-based classification system for lithium batteries and cells, which – if successful – could put an end to that constant process of refining the rules.
The informal working group on hazardbased classification of lithium batteries had met by video conference in December 2020 and May 2021 and France and the European Association for Advanced Rechargeable Batteries (Recharge) provided the Subcommittee with an update on its discussions. A major issue appears to be the repeatability of test results and variations in test methods. After a series of tests undertaken by various laboratories, it was found, for instance, that the cell format, state of charge (SOC) and heating rate can all have a significant impact on cell hazards and the propagation of heat. The working group had made a start on more tightly defining the test protocols so as to reduce that variability in results.
France, which under Claude Pfauvadel is chairing the working group, said it expects the group to extend its discussions on batteries and will report back during the Sub-
committee’s session in June/July 2022; it is hoped that its work can be completed by the end of this year. Belgium stressed the importance of the project, especially as other bodies looking to improve safety in the transport of lithium batteries are awaiting its results.
Returning to more normal proceedings in the area of lithium batteries, Recharge and the Rechargeable Battery Association (PRBA) proposed a change to packing instruction LP903. They noted that the lithium battery industry is confidently expected to experience significant growth over the next decade, with massive new production plants due to open in many parts of the world, each capable of producing billions of lithium ion cells per year. To accommodate this growth, the joint proposal said, it is imperative that the limitation in LP903 to one cell, battery or item of equipment per large packaging be removed.
The Sub-committee understood the position and supported the intent of the proposal; however, it was felt that the changes proposed could have unintended consequences and needed to be refined and clarified in a number of areas. Consideration of the topic will resume at the next session, with a revised proposal promised.
At the previous session, Recharge had highlighted the fact that technical progress in lithium battery manufacture means that it is now possible to produce batteries with a higher energy content without adding to weight. As a result, batteries for smartphones and power tools can now easily exceed the maximum limit in special provision 188, which is expressed in Watt-hours (Wh). At the last session, the Sub-committee was concerned that batteries with a higher energy density may present a higher hazard and it declined to make a change to SP188.
Following data collection work by the informal working group on hazard-based classification of lithium batteries, Recharge presented some data that indicate that the hazard (heat of reaction) presented by a lithium ion battery is related to its weight, not its Wh content. It invited the Sub-committee’s opinion on this. The experts acknowledged that there is no clear correlation between the heat of reaction and the energy density; Recharge offered to seek feedback from the informal working group and will return with a formal proposal at the next session.
Belgium arrived with a problem that has emerged when lithium batteries (UN 3090, 3091, 3480 or 3481) are offered for transport Who do you contact for the latest DG compliant labels?
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by air, namely that is unclear which provisions of 2.9.4 have to be met, particularly bearing in mind the applicable special provisions (and especially SP 188). It offered an additional paragraph for SP 310 to make the situation clearer.
The Sub-committee agreed that when lithium cells or batteries are offered for transport they must meet the provisions of 2.9.4, and that when they are transported under SP 310 only those provisions of 2.9.4 relating to the testing requirements in 38.3 of the Manual of Tests and Criteria do not need to be met. Most Experts also agreed that a clarification of SP 310 would help matters, though there was no agreement on whether the Belgian proposal was enough. A revised proposal will be forthcoming.
Belgium also sought to clarify what “transported for testing” refers to in SP 310, since it appears it is being interpreted differently by different competent authorities. Its paper offered two alternative ways of clarifying the meaning, of which the Subcommittee preferred to add a new Note after the first paragraph of SP 310:
“Transported for testing” includes, but is not limited to, testing described in the Manual of Tests and Criteria, part III sub-section 38.3, integration testing and product performance testing.
SODIUM ION BATTERIES While there is still much work to be done on lithium batteries, the Sub-committee was invited in 2020 to start thinking about how to regulate the transport of sodium ion batteries, which are emerging as an alternative, in both the Model Regulations and the Manual of Tests and Criteria. It had been decided to defer the matter to the 2021/22 biennium, as there had not been sufficient time to look at the initial proposals in any great detail.
THE UN EXPERTS HAD DRAWN UP PROVISIONS
APPLICABLE TO MOBILE ENERGY STORAGE UNITS
COMPRISING A CTU CONTAINING SHELVES OF BATTERIES
In the meantime, the RID and ADR states had initiated multilateral agreements on the transport of sodium ion batteries with an organic electrolyte, based on some proposals made at the December 2020 session of the UN Sub-committee, with some amendments. France now arrived with a detailed set of proposals for inclusion in various parts of the Model Regulations and Section 38.3 of the Manual of Tests and Criteria.
The Sub-committee welcomed France’s proposals, as well as further information provided by KiloFarad International (KFI) on the intrinsic hazards of sodium ion batteries. It was minded to accept some of the proposals, though more work is clearly needed to complete the requirements. To start with, in 2.9.2, after the section for lithium batteries, a new section is added:
Sodium ion batteries 3551 SODIUM ION BATTERIES with organic electrolyte 3552 SODIUM ION BATTERIES with organic electrolyte CONTAINED IN EQUIPMENT or SODIUM ION BATTERIES with organic electrolyte PACKED WITH EQUIPMENT
The basic requirements are laid down in a new 2.9.5: Sodium ion batteries
Cells and batteries, cells and batteries contained in equipment, or cells and batteries packed with equipment containing sodium ion, which are a rechargeable electrochemical system where the positive and negative electrode are both intercalation or insertion compounds, constructed with no metallic sodium (or sodium alloy) in either electrode and with an organic non aqueous compound as electrolyte, shall be assigned to UN Nos. 3551 or 3552 as appropriate.
NOTE: Intercalated sodium exists in an ionic or quasi-atomic form in the lattice of the electrode material.
They may be transported under these entries if they meet the following provisions: (a) Each cell or battery is of the type proved to meet the requirements of applicable tests of the Manual of Tests and Criteria, part III, sub-section 38.3. (b) Each cell and battery incorporates a safety venting device or is designed to preclude a violent rupture under conditions normally encountered during transport; (c) Each cell and battery is equipped with an effective means of preventing external short circuits;
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(d) Each battery containing cells or a series of cells connected in parallel is equipped with effective means as necessary to prevent dangerous reverse current flow (e.g., diodes, fuses, etc.); (e) Cells and batteries shall be manufactured under a quality management program as prescribed under 2.9.4 (e) (i) to (ix); (f) Manufacturers and subsequent distributors of cells or batteries shall make available the test summary as specified in the Manual of Tests and Criteria, Part III, sub-section 38.3, paragraph 38.3.5.
For existing entries in the Dangerous Goods List, “401” is added in column (6) against UN 2795 and UN 3292; in column (2) against UN 3292, “SODIUM” is replaced by “METALLIC SODIUM OR SODIUM ALLOY” twice. There are also two new entries:
THE PROVISIONS FOR PRESSURE RECEPTACLES ARE
EXPECTED TO HAVE TO CHANGE TO REFLECT AN
UN 3551 SODIUM ION BATTERIES with organic electrolyte
UN 3552 SODIUM ION BATTERIES with organic electrolyte CONTAINED IN EQUIPMENT or SODIUM ION BATTERIES with organic electrolyte PACKED WITH Free DG Label ID poster with every orderEQUIPMENT.
Both are assigned to Class 9, with “0” in column (7a) and “E0” in column (7b). Special provisions 188, 230, 310, 348, 376, 377, 384, 400 and 401 are assigned to both entries, with SP 360 also assigned to UN 3552. Packing instructions P903, P908, P909, P910, P911, LP903, LP904, LP905 and LP906 are assigned to both entries.
That has entailed some amendments to the Alphabetical Index and also to existing special provisions, though those are minor in nature. There are, though, two new special provisions: 400 Sodium-ion cells and batteries and Tel: +44 (0)870 850 50 51 sodium-ion cells and batteries contained in or Email: sales@labeline.com packed with equipment, prepared and offered for transport, are not subject to other provisions of www.labeline.com these Regulations if they meet the following: (a) The cell or battery is short-circuited, in a way that the cell or battery does not contain
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electrical energy. The short-circuiting of the cell or battery shall be easily verifiable (e.g., busbar between terminals); (b) Each cell or battery meets the provisions of 2.9.5 (a), (b), (d), (e) and (f); (c) Each package shall be marked according to 5.2.1.9; (d) Except when cells or batteries are installed in equipment, each package shall be capable of withstanding a 1.2 m drop test in any orientation without damage to cells or batteries contained therein, without shifting of the contents so as to allow battery to battery (or cell to cell) contact and without release of contents; (e) Cells and batteries when installed in equipment shall be protected from damage. When batteries are installed in equipment, the equipment shall be packed in strong outer packagings constructed of suitable material of adequate strength and design in relation to the packaging’s capacity and its intended use unless the battery is afforded equivalent protection by the equipment in which it is contained; (f) Each cell, including when component of a battery, shall only contain dangerous goods that are authorized to be transported in accordance with the provisions of Chapter 3.4, and the quantity of the dangerous goods in the cell shall not exceed the quantity specified in Chapter 3.2 Table A Column 7a. 401 Sodium ion cells and batteries with organic electrolyte shall be transported as UN 3551 or 3552 as appropriate, sodium-ion batteries with aqueous alkali electrolyte shall be transported as UN 2795 BATTERIES, WET, FILLED WITH ALKALI, electric storage.
Similarly, in most of the relevant packing instructions, amendments are made to refer to the new entries as well as to the existing lithium battery entries, while “or sodium ion” is added after “lithium ion” in various places. Specific reference to sodium ion batteries is also added in 5.2.1.9 and 5.2.2.1.13.1.
There are also a lot of changes in the Manual of Tests and Criteria to make
THERE WAS AN INTERESTING DISCUSSION ABOUT
CARDBOARD BOXES, WITH CHINA IN PARTICULAR
CONFUSED ABOUT HOW TO TRANSLATE THE reference to sodium ion batteries alongside lithium ion cells or batteries. More substantial amendments are found in a new paragraph at the end of 38.3.2.1:
All sodium ion cell types shall be subjected to tests T.1 to T.6. All rechargeable sodium ion battery types, including those composed of previously tested cells, shall be subjected to tests T.1 to T.5 and T.7. In addition, rechargeable single cell sodium ion batteries with overcharge protection shall be subjected to test T.7. A component sodium ion cell that is not transported separately from the battery it is part of needs only to be tested according to tests T.6. A component sodium ion cell that is transported separately from the battery shall be subjected to tests T.1 to T.6. A sodium ion 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.
There is a new definition in 38.3.2.3:
Sodium ion cell or battery means a rechargeable electrochemical cell or battery where the positive and negative electrode are both intercalation or insertion compounds (intercalated sodium exists in an ionic or quasi-atomic form in the lattice of the electrode material) constructed with no metallic sodium (or sodium alloy) in either electrode and with an organic non-aqueous compound as electrolyte.
There is a new 38.3.3 specifying the number and condition of cells and batteries to be tested, with amendments to what now becomes 38.3.3.1 to make that specific to lithium cells and batteries and a new 38.3.3.2 on the testing of sodium ion cells and batteries.
TRANSPORT OF GASES The Council on Safe Transportation of Hazardous Articles (COSTHA) continued with its appeal to increase the limited quantity volume for Division 2.2 gases that do not present a subsidiary hazard, along the lines of those found in special provision 653 in ADR. While, as before, there was general support for the proposal to increase the limited quantity limit from 120 ml to 1 litre and this seemed agreeable for inland transport modes, there remained concern over the absence of a detailed justification, particularly as regards air transport. COSTHA planned to discuss the matter further with those Experts who spoke, with a revised proposal likely.
The chair of the inter-sessional working group on the pV-product limit for pressure receptacles (Dr Georg W Mair, Germany) reported on the group’s third meeting, which
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took place on 25 October. Pressure receptacles already in service seem to have a test pressure volume product of less than 1.5 million bar litres and therefore fulfil the assumed ‘red line’ to limit a worst-case consequence. However, pressure receptacles with a test pressure volume product of more than 1.5 million bar litres may be marketed within the next years. This is particularly true in the case of hydrogen, which is expected to Free DG Label ID poster with every order be shipped in much greater quantities. The group is also looking at the issue of salvage pressure receptacles.
The working group has agreed to compare the consequences caused by hydrogen tubes with test pressure-volume products of 1.5m, 2.0m and 3.6m bar litres. While, as already noted, those with a pV-product of less than 1.5m bar litres are below the assumed safety threshold, for the 3.6m bar litre equipment many scenarios are beyond that red line.
The Sub-committee encouraged the group to continue its work and to report back at the next session.
The European Industrial Gases Association (EIGA) had spotted that, in packing instruction P200, two filling rations are given for UN 1008 Boron trifluoride, UN 1859 Silicon tetrafluoride and UN 2198 Dichlorosilane. However, in all three cases, while special packing provision ‘a’, indicating that aluminium alloy pressure receptacles must not be used, is indicated for the first filling ratio, it is missing from the second. This, EIGA said, was an obvious error.
The Sub-committee agreed and made the 5 necessary changes as corrections to the 22nd revised edition of the UN Model Regulations. EIGA was also asked to check whether similar corrections were warranted elsewhere, such as for UN 1001 and 3374.
EIGA also reported that the Joint Meeting of RID/ADR/ADN Experts had at its autumn 2021 session adopted transitional provisions for the amendments to 6.2.1.5.2, 6.2.2.7.3(k) and (l) and 6.2.2.11. Something similar should also be included in the Model Regulations, EIGA argued, albeit the Model Regulations do not show dates when each edition comes into force or is superseded.
The Sub-committee gave its support in principle for the idea, with some experts surprisingly preferring to add a specific date.
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THE PROVISIONS RELATING TO THE USE OF DRY ICE AS A
COOLANT HAVE BEEN CLARIFIED
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However, as the proposal was contained in an informal document, it was decided to wait for an official proposal, ideally at the next session, so that it can be finalised before the next editions of RID, ADR and ADN enter into force in 2023.
Spain had found several instances where long out-of-date standards are still referenced in Chapter 6.2.2; while it acknowledged that, once a revised standard is introduced, reference to the previous version is generally maintained for a period of time, some of the examples its paper showed had expired as long ago as 2008. While the proposal was welcomed, some Experts preferred to keep the references to old standards in case they were needed for the inspection of equipment that is still in use. The International Standardisation Organisation (ISO) offered to take a close look at the references and return with a revised proposal, if it was deemed appropriate.
PACKAGING PROPOSALS China referred to the Sub-committee’s clarification at its 57th session that the wording “fibreboard boxes” in 6.1.4.12 includes “corrugated fibreboard boxes”, noting that no other international regulation or standard includes such a concept. China felt that this made it difficult to reflect in translations of the original text – such as Chinese – the actual meaning. It hoped for further discussion and perhaps a clarifying note to be agreed.
The Sub-committee took the point but, rather than adopting China’s proposal, decided to amend the heading of 6.1.4.12 to read “Fibreboard (including corrugated fibreboard) boxes”. Delegations were also encouraged to see if similar amendments were needed elsewhere in Chapters 6.1, 6.5 and 6.6.
Spain looked back to the introduction in the Model Regulations of Chapter 5.5 and, in particular, the provisions in 5.5.3 covering those substances used for cooling or conditioning purposes during transport that may present a risk of asphyxiation. At the time, the packing instructions that referred to cooling with dry ice, nitrogen or other substances were not reviewed systematically; Spain had already drawn the Joint Meeting of RID/ADR/ADN Experts to problems in complying with special provision 593 in RID/ ADR, which references packing instruction P203, the latter not reflecting the changes in 5.5.3.
While the Joint Meeting adopted an amendment at the behest of Spain, the proposal prompted a more general discussion on the different packing instructions that refer to cooling and it was felt that a more structured review would be valuable. Spain had since then undertaken a detailed review and arrived with a lengthy proposal to add wording along the lines of “When dry ice or other refrigerants are used as a coolant, the requirements of 5.5.3 shall apply” in P620, P800, P901 and P203. The Sub-committee acceded to the request.
Spain had less success with its proposal to delete 4.1.1.12, as its text on leakproofness testing is duplicated in 6.1.1.3 and 6.5.4.4.2. As Part 4 of the Model Regulations covers the use of packagings and Part 6 their construction and testing, it seemed illogical that the leakproofness test should be covered in 4.1.1.12.
Most Experts who spoke acknowledged the intent of Spain’s proposal but felt that the text is useful for users of packagings, though some thought it could be reviewed and shortened. Spain offered to prepare a revised document for the next session.
Another paper from Spain reported on problems experienced with the practical implementation of packing instruction P650, at least partly in the transport of samples from Covid-19 testing. Its concerns centred on the testing requirements, notably whether
THE WORDING OF PROVISIONS CONCERNING ROLLING
HOOPS ON DRUMS HAS CAUSED CONFUSION, ACCORDING
TO INDUSTRY, AND HAS NOW BEEN CLARIFIED TO AVOID
completed packages shall be capable of passing the test or actually undergo and pass them.
Most Experts saw this as a compliance problem, though some stressed there was a need to clarify the application of the provisions. Following a lunchtime meeting, the Sub-committee agreed that amendments were necessary and Spain offered to organise an inter-sessional meeting on the topic for early 2022. In the meantime, the Subcommittee adopted a correction to the Spanish version of P650 for the 22nd revised edition of the Model Regulations.
China remarked on the key role the target plays in the drop test; deviations in terms of strength, size or flatness could lead to different results. Standard ISO 2248:1985 includes specific parameter values and China thought these should be included in 6.1.5.3.4 to help laboratories in the proper conduct of the drop test.
Most Experts who spoke did not support the proposal, saying it needed further improvement. Germany informed the Sub-committee that research on the drop test for packagings is ongoing and looks in particular at the parameters mentioned in the proposal from China; the results of that research are expected to be available in 2023. The Sub-committee agreed to resume discussion once it has further information from that research.
Turkey followed up on earlier discussions about water-resistant paper bags, noting that 5M2, 5L3 and 5H3 bags are all required in the Model Regulations to “prevent the entry of moisture”. Some manufacturers include small perforations in one or more layers of those bags, for the release of air, which are listed in EN ISO 16106:2020. Turkey’s question was: how can water/moisture resistance be evaluated in the case of bags with these ‘micro-holes’? Some Experts provided feedback and offered to send more detailed information to the delegate from Turkey.
PORTABLE TANKS The International Dangerous Goods and Containers Association (IDGCA) had presented proposals at the previous session for amendments to Chapter 6.7 of the Model Regulations and, at the request of the Sub-committee, now came back with a revised proposal with further justification. Its concern is that 6.7.2.18.2(a) refers to ISO 1496-3:1995, but that this standard applies to tank containers, rather than portable tanks as a whole, which is the intent of the paragraph. Again, however, there was little support for the proposal, with some experts being of the opinion that it is the standard that needs to be amended. Delegates were invited to send comments in writing to IDGCA.
In a rather similar vein, Canada queried the relationship between the definition of ‘fine grain steel’ in 6.7.2.1 and ASTM E112-96 and EN 10028-3, Part 3, which are referenced in that section. The UN definition refers to a ‘ferritic grain size’, whereas ASTM E112 does not mention ‘ferritic grain size’, only the austenitic grain size in a ferritic steel. Canada sought feedback and clarification on whether an amendment to the UN Model Regulations is warranted. The Sub-committee largely agreed that the definition needs to be clarified but did not support the deletion of ‘ferritic’ from the definition. Canada plans to consult with the US and those Experts who spoke so as to be able to return with a new document.
Canada made more headway with its proposal to amend Section 41.3 of the Manual of Tests and Criteria relating to the impact testing of portable tanks and multipleelement gas containers (MEGCs). In some instances, Canada’s competent authority has found that test facilities only measure a container’s dimensions for conformity after the final impact, although 41.3.4.4 states that the test result for each impact shall be considered individually. Canada felt that this needs to be set out more explicitly and offered text to be added to 41.3.4.4 for that purpose. The Sub-committee could not see a reason to deny the request but has kept the adopted text in square brackets pending confirmation. At present it reads:
The relevant dimensions of the portable tank or MEGC shall be measured after every impact to ensure conformity with the dimensional requirements regarding handling, securing and transfer from one means of transport to another.
The informal working group on FRP service equipment for portable tanks had met several times in the second half of 2021 and its chair offered some details on its discussions, which focused on the development of and justification for FRP service equipment for use
THE EXPERTS WERE INVITED TO CONSIDER WHETHER
THE CURRENT REQUIREMENTS FOR PLACARDING
CONTAINERS WITH CERTAIN CLASS 7 ITEMS ARE
on metallic and FRP portable tanks. It is making headway on design approval and design criteria and the Sub-committee encouraged it to continue its work, including approval provisions and inspection and testing requirements.
MISCELLANEOUS PROPOSALS Canada and the International Confederation of Drum Manufacturers (ICDM) returned with a formal proposal to clarify what they felt was an ambiguity in 6.1.4.1.4 relating to the use of rolling hoops on drums. That states that the body of a drum with a capacity greater than 60 litres “shall, in general” have rolling hoops. The use of “shall” implies a mandatory requirement, which is then weakened by “in general”. As a result, some national regulations have made the requirement mandatory (“shall”) while others have made it optional (“may”). ICDM confirmed that rolling hoops are intended to ease handling and not to improve safety in transport.
Recalling discussions at the previous session, the Sub-committee accepted the proposal and replaced the first sentence in 6.1.4.1.4 (for steel drums), 6.1.4.2.3 (for aluminium drums) and 6.1.4.3.3 (for other metal drums) with: “Drums may have rolling hoops, either expanded or separate”.
South Korea felt that the provision in 4.1.2.1 that requires IBCs used for the transport of liquids with a flash point of 60°C or lower or powders liable to dust explosion to be protected against electrostatic discharge (ESD) should be strengthened with a requirement for such IBCs to bear a mark to show that ESD prevention measures have been taken. There was little support for the idea: some felt that the mark could be misleading, others that it was really a training issue. France suggested it might as a first step be worth clarifying whether the current provisions are applicable during transport or only during loading and discharge. South Korea may return with a revised proposal.
Spain and Sweden had looked through the existing transitional provisions and proposed the deletion of those that are outdated; the Sub-committee agreed but left the amendments in square brackets pending later confirmation. Spain also spotted an outdated transitional provision in the Note to special provision 384, which likewise has been deleted pending confirmation.
GLOBAL HARMONISATION ICAO and WHO appealed for a change to the provisions for genetically modified microorganisms (GMMOs) and genetically modified organisms (GMOs) (UN 3245), specifically to exclude from the Model Regulations those pharmaceutical products that contain GMMOs and GMOs. At the 57th session of the UN TDG Sub-committee, it had agreed that, by definition, vaccines containing such products are not subject to the Model Regulations when they are authorised for use by the relevant competent authorities but, nevertheless, ICAO and WHO felt that a clearer text would help avoid problems. ICAO noted that its Technical Instructions have been amended in a similar way.
The Sub-commmittee agreed with the proposal and added a new paragraph at the end of 2.9.2:
Pharmaceutical products (such as vaccines) that are ready for use, including those in clinical trials, and that contain GMMOs or GMOs are not subject to these Regulations.
The secretariat submitted a paper with a number of corrections to the English and French language versions of the UN Model Regulations and Manual of Tests and Criteria that had been identified by recent sessions of the Joint Meeting and the Working Party on the Transport of Dangerous Goods (WP15). These corrections are mainly editorial in nature and were all adopted by the Sub-committee.
IMO’s Editorial & Technical (E&T) Group informed the Sub-committee about its work to
THE 22ND REVISED EDITION OF THE ORANGE BOOK WILL
INFORM THE CHANGES COMING TO THE MODAL
REGULATIONS IN 2023, BY WHICH TIME THE 23RD REVISED
update the International Maritime Dangerous Goods (IMDG) Code, during which two items had cropped up that might warrant changes to the Model Regulations. Firstly, a reference to SCO-III material has been added to 5.3.1.1.5.1 of the IMDG Code, which will require a placard on large freight containers carrying unpackaged SCO-III material, in line with Section 571 of the International Atomic Energy Agency’s (IAEA) Regulations for the Safe Transport of Radioactive Materials (SSR-6); a comparable amendment might be appropriate in the Model Regulations.
Further, the E&T Group made a correction to the equation for electrical resistance in the table in 1.2.2.1 of the IMDG Code. This should probably also be reflected in the Model Regulations. Both amendments will be addressed later on the basis of an official proposal.
South Korea noted that IMO’s Subcommittee on Carriage of Cargoes and Containers (CCC) has been reviewing the special provisions in the IMDG Code, which have sometimes been identified as being the root cause of mis-declaration of goods. Its paper brought to the attention of the Sub-committee some particular problems with SP 141, which is assigned to UN 2969 Castor beans or Castor meal. SP 141 excepts from the regulations those products “which have undergone sufficient heat treatment so that they present no hazard during transport”, but there are no criteria mentioned. This makes it difficult to apply. The Sub-committee felt further discussion of this was needed and will continue at the next session.
Following the adoption of revised provisions for the transport of cobalt dihydroxide powder (UN 3550) at the 57th session, the Responsible Packaging Management Association of Southern Africa (RPMASA) and the International Confederation of Plastic Packaging Manufacturers (ICPP) offered some additional text for the Guiding Principles. There was general support for this and an official proposal may be offered at the next session.
Germany reported on some proposals to amend the provisions for desensitised explosives in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), which, if confirmed, will require some changes in the Manual of Tests and Criteria. Some comments were offered, which will be used to provide an updated document for consideration by the TDG Sub-committee and the Working Group on Explosives at the next session. That next session, the 60th, is scheduled to take place from 27 June to 6 July.
