The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 65th Session November 25 through December 4, 2024 in Geneva, Switzerland. There are 54 formal and 62 informal papers submitted for discussion as of Day 5. This session is the fourth of four sessions during the 2023-2024 biennium.

All daily sessions are to be held formally (interpreted). Therefore, papers are to be reviewed as listed on the agenda (INF.2) and final decisions will be taken when appropriate.

This summary is provided to assist you in following the discussions of the papers and is not intended as a full summary of document that was presented. Links to individual papers are provided to allow you to read the papers directly. Note that the Official report of the session will be made available by the UN Secretariat 3-4 weeks after the session concludes.

Day 5– Discussion of Papers

2024/90 (China) Proposal on clarifying the definition of large packaging – The Subcommittee continued discussion of this paper from Day 4. Germany recommended the term “capacity” be used to reflect their opinion that it is the internal volume. Sweden supported Germany’s approach. Poland did not believe it was an issue. The Netherland suggested that if the change is made, there may be a need to clarify it in other locations throughout the regulations. France supported the proposal with amendment from Germany. The US was not comfortable with the verbal amendment without further consideration. Canada agreed with the Netherlands that the change may have a bigger impact in P903 and in other packing instructions. Australia agreed with the US and preferred the original proposal. Based on the discussion, the Subcommittee adopted the proposal in 2024/90 as written.

2024/104; INF.7; INF.38 (Russian Federation) Development of a new section 6.9.4 “Requirements for the design, construction, inspection and testing of portable tanks with shells made of fibre reinforced plastics (FRP) materials intended for the transport of non-refrigerated liquefied gases” – The Russian Federation described the current status of FRP tanks and their implementation for the use of non-refrigerated liquefied gases. The encouraged the Subcommittee to develop a new section 6.9.4 as presented in previous sessions. FRP tanks are not currently authorized for non-refrigerated liquefied gases but the need for them is growing in industry. INF.7 provided examples of how these tanks would be used by industry, and INF.38 provided additional details and resources on the topic. Finland shared that such tanks are already used in sectors other than transport and supported discussion in an informal working group. Australia voiced some technical concerns and indicated they would provide contact information to the Russian Federation. France and Poland supported the WG as well. Poland also shared that there may be practical issues with the compatibility of some plastics and these issues should be considered. Germany felt that that the initial mandate of the FRP working group specifically excluded non-refrigerated liquefied gases and were not convinced that the burden of proof that the use of FRP tanks for the transport of these products had been established as of yet. The Netherlands supported discussion but also felt additional experience with the tanks is necessary before progressing forward. Spain, the UK, and the US agreed with Germany and the Netherlands. The US explained that having the tanks in non-transport does not automatically mean transport experience is gained as there are different stresses and dynamic forces that may potentially impact the FRP structure. Germany explained that that proof of concept to them would be data from a nationally authorized tank that has demonstrated the ability to transport non-refrigerated liquefied gases without failure. Although the Subcommittee appreciated the efforts to date by the Russian Federation on this topic, they requested a further proof of concept before an informal working group could be established. The Russian Federation indicated they would return in the next biennium with additional data to support the discussion. No proposals were adopted.

2024/107 (Belgium) Use of recycled plastics material for flexible intermediate bulk containers – Belgium proposed to clarify when recycled plastics may be used in the manufacture of flexible IBCs and that they are not permitted for the construction of IBC bodies. The proposed changes to 6.5.5.2.2 (Proposal 1) and 6.5.5.2.8 (Proposal 2). Germany supported the proposal with a minor editorial amendment of spelling out “fIBCs” to “flexible IBCs”. The US voiced confusion with the meaning of the second sentence in proposal 1, believing that it may conflict with the first sentence. Canada was in favor of allowing any parts of flexible IBCs to be of recycled plastics and therefore agreed with the US. Both the US and Canada supported the effort, however. France felt there needed to be a limit to the number of times a plastic material can be recycled as continual recycling may result in structural integrity degradation. Spain agreed with France and pointed to the definition in 1.2.1 for recycled materials. Switzerland supported the two proposals as drafted. The UK explained the second sentence in proposal 1 is to prevent someone from cutting a panel out of a flexible IBC and sewing it into a new IBC, but the proposed text does not fully address the problem. They did not support the proposal. China and Poland requested additional performance data as well as adoption of the ISO standard on the topic before making any final decisions. Austria supported proposal 2. The Netherlands were also cautious about adopting the text as drafted. ICIBCA supported the proposals reiterating the need for the material to be able to survive the tests, and therefore the origin of the “threads” is irrelevant. After further discussion, Belgium indicated they would prepare a revised proposal for consideration at this session. No proposals were adopted.

2024/99 (WCC); INF.61 (WCC) Transport provisions for small quantities of environmentally hazardous paints, printing inks, and related materials – Following the significant discussion on 2024/99, the WCC provided a revised proposal that added a new packing provision to P001 for paints, printing inks, and related materials. Germany suggested the transition period be limited to 10 years (31 December 2034). They further felt the drop test should be required and thus requested the word “capable” be removed. The Netherlands were concerned about the length of the transitional period. Canada, Australia, and the US supported the proposal. Sweden agreed with Germany and the Netherlands, and suggested additional notification should be included in related documentation. The UK noted concern about the precedent the proposal would make. France, Spain, and Belgium supported the proposal with the changes proposed by Germany. Austria opposed the approach. Norway supported the proposal but suggested a minor editorial edit. After further editing and by a majority vote (9-3), the Subcommittee agreed to the proposal in INF.61 as amended.

2024/91 (China); INF.60 (China) Proposal to allow articles classified as UN3363 to contain lithium batteries complying with special provision 188 – China provided a revised proposal to permit lithium batteries and sodium ion batteries in UN3363 but modifying SP301. Germany noted the proposed language would prevent certain articles that are currently covered under UN3363 from being shipped. They recommended using a US recommendation to reword the introduction paragraph slightly. The US also voiced concern the proposed text in Proposal 2 was superfluous and should be deleted. China argued they strongly preferred the additional language proposed in Proposal 2. The US and Belgium offered alternate language to address their concerns. After a short break, China agreed to provide a revised text in an informal paper later in the session. No proposal was considered.

2024/74 (RECHARGE, PRBA); INF.50/Rev.1 (RECHARGE, PRBA) Lithium ion battery testing – amendment to the T.5 short circuit test – Alternative text proposal for document ST/SG/AC.10/C.3/2024/74 – RECHARGE explained that in industry during the development of standards, a 3-tier approach is taken. Step one is to attempt to remove the hazard. Step 2 is to protect against the hazard through innovation. Step 3 is to develop procedures to reduce or mitigate the hazard. RECHARGE explained that they believed the purpose of the test was to determine how the battery responds to an external short circuit, not an internal short circuit. In some situations, the test methodology creates an extreme safety risk from high voltage. It is recognized the full hazard cannot be removed in these cases. However, industry can protect against the hazard through innovation. They offered a revised proposal to address batteries where the T.5 test is not practical. The US disagreed, and stated they believed the T.5 is a short circuit test and is specifically included to determine the reaction of a lithium battery to a short circuit. They wanted to see additional data and testing results before adopting such language. Germany agreed with the US, noting that they would like to review examples of how the new language would be applied. China agreed with other speakers. Based on the discussion, RECHARGE withdrew the proposal and indicated they would return with additional proposals at a future session. No proposals were adopted.

INF.39 (Germany) Recycled plastic materials for dangerous goods packaging – Information on revision of ISO 16103 – Germany provided a brief update on the revision to the ISO standard regarding recycled plastic materials. No proposals were considered.

2024/72 (Germany) Interpretation of paragraph 6.7.4.5.2 – Germany pointed out there are openings in portable tanks for flammable refrigerated liquefied gases used for filling and discharging as well as for vapour recovery. Those openings for filling and discharge must be fitted with at least three (3) mutually independent shut-off devices in series. Germany believed that vapour recovery openings have 3 devices and proposed changes to 6.7.4.5.2 to include a note clarifying this point Canada and the US shared that in their experience, the proposal would be a significant change to current interpretations in many regions. Although they agreed the change would improve safety, both the US and Canada preferred to consider the issue further, recognizing a potentially significant impact to existing portable tanks in service. The US was interested in further reviewing the intent of the vapour recovery opening. Belgium, Poland, China, Spain, the Netherlands, and France supported the proposal as drafted. Based on the discussion, Germany heard many of the ADR countries supported the proposal not as a note but as a requirement. Therefore, they modified their proposal to include the proposal in 6.7.4.5.2 as a requirement. Australia commented that the transition provision should be placed in a TP provision instead of 4.2.6, however that concept was determined to be overly complicated at this point in the biennium. By a majority vote, the proposals in 2024/72 as amended were adopted.

2024/96 (Poland) Modification of the fire resistance test provision contained in 6.9.2.7.1.5.1 of the Model Regulations – Poland proposed modifications to the Flexible portable tank provisions to address concerns regarding the fire test. France supported the proposal but suggested the changes should only be made to the FRP shell. The Netherlands supported the proposal as drafted. Germany and the US preferred not to adopt the changes to the first sentence. However, they both supported the rest of the changes. Poland agreed with the proposed changes by France and Germany. Based on the discussion, the Subcommittee agreed to the proposals in 2024/96 as amended.

INF.17 (United Kingdom) ISO Standard Updates – The UK listed a number of ISO standards that have been updated over the last few years and asked the Subcommittee for feedback as to whether the standards needed to be update in the Model Regulations. Germany shared that they would like to review the standards before considering updating the references. France noted ISO 6892:1998 has been updated several times in the last 25 years. They believed it would be beneficial to reference the specific sections of the ISO standards and their associated provisions in the Model Regulations. ISO noted that the standards referencing gases are monitored and updated by the ISO gases group and that is why those standards have been updated. This group would NOT be capable of addressing other ISO standards. The UK offered to present the standards at the next session and discuss the possible revisions during lunchtime work groups. The Chairman suggested the list would need to be prioritized and how the standards can be shared. The UK invited delegations interested in the project to contact them before the next session. No proposals were considered.

2024/78 (Germany, Republic of Korea) Prohibited packagings for substances which may become liquid during transport – The Republic of Korea noted confusion in 4.1.3.4 as to the prohibitions for packagings for solid materials that may become liquid in transport. They proposed changes to 4.1.3.4 applicable to single packaging and IBCs as well as a number of deletions in applicable packing instructions. The Secretariat pointed out the list in 4.1.3.4 is for packagings, large packagings, and IBCs. Given that some packagings in the list are combination packagings, it is illogical to change it to single packaging. The UK was satisfied with changing the introduction to the paragraph, but suggested a similar approach would be to delete 4.1.3.6 and introduce a statement that refers the reader to the relevant packing instructions for solids that may become liquid in transport. Australia agreed with the UK and offered additional minor edits. Belgium and Canada also supported the proposal. The US voiced confusion over the term “unless approved for the transport of liquids of packing group I” and was concerned the proposal would introduce additional restrictions into the regulations that are not currently present. The Subcommittee agreed to the proposals in 2024/78 as amended during the discussion.

2024/65 (Germany) Inclusion of “shipment after storage” in paragraph 1.5.1.3 – Germany proposed to add the term “shipment after storage” to 1.5.1.3 to clarify the applicability of the transport regulations to radioactive shipments after storage. The Subcommittee approved the proposal in 2024/65.

2024/66 (Germany) Transport under temperature control – requirements according to 7.1.5.4.2 – Germany proposed to clarify how that temperature sensors must be powered independently. The decision was made at the 64th Session to support the work, but they offered two options for clarifying language. Poland, and Switzerland supported the proposals and preferred Option 3. The US felt that the intent was to have two sensors but they are back-ups for each other. They preferred Option 2. Spain, France, China, Canada, and the Netherlands preferred Option 2. Belgium preferred option 3 but suggested the need for a transition period. Based on the discussion, Germany noted concern from some delegations that Option 3 may be more than a clarification. For that reason, they suggested that the Subcommittee consider Option 2. The Subcommittee agreed to Option 2 in 2024/66 without a transition period.

2024/67 (Germany) Amendment of special provision 172(d) for the transport of dangerous goods of class 7 – Germany noted inconsistency between 5.4.1.4.1 and special provision 172 applicable to radioactive materials. SP 172 would only require labeling of the predominant subhazard whereas 5.4.1.4.1 would require labels for all subsidiary hazards. They suggested two options to address the issue. The UK supported Option 1. China suggested that there may be additional wording changes in SP172 if adopted. The Subcommittee adopted the proposal in Option 1.

INF.8 (IDGCA) Amendments to the Model Regulations in Russian language – IDGCA identified several necessary corrections to the Russian translation of the Model Regulations. The Subcommittee agreed to the proposals in INF.8.

End of Day 5

–COSTHA