IHMM Today December 1, 2020

IHMM UPDATES

Department of the Interior / Bureau of Reclamation – CHMM Recognition

Through the outstanding efforts of a few close friends, the Department of the Interior’s Bureau of Reclamation recognizes the IHMM CHMM credential for its hydro dam construction and operations work. IHMM appreciates the Department’s recognition of an outstanding credential and the professionals who work so hard to attain it and maintain it.

IHMM’s credential recognition efforts are constant and ongoing, both at the federal and state levels. IHMM seeks recognition for all of its credentials, not only one. You can play an important role in this effort, and please see the next article.

IHMM & AHMP Launch 45 in 5 – National Credential Recognition – December 15, 2020

On December 15, 2020, IHMM and AHMP will be gathering the first round of state volunteers to scope out what we need to do and how we need to do it. This is just the beginning. 

In 2019 Mark Bruce from AHMP and Gene Guilford from IHMM worked on a project to get the Commonwealth of Pennsylvania to recognize the CHMM and CDGT credentials. With Mark’s work on the ground in  Pennsylvania, we succeeded. We have already succeeded in 5 states.

In the two weeks since the launch, we have added Delaware, Florida, Texas, California, Washington, Georgia, Ohio, Tennessee, Alabama, Maryland, Virginia, and Massachusetts as the next states for us to work on.

Now Mark at AHMP and Gene at IHMM has launched 45 in 5, getting the other 45 states to recognize our credentials in 5 years. If we can find a volunteer like Mark in 45 other states we can work with those volunteers on crafting the right message to the right agencies in state governments across the country. If we find enough volunteers we can get this done in less than 5 years.

Here’s what we ask each volunteer to do:

• Take a template letter we write and send it to the right people at the right agencies of state governments
• IHMM & AHMP will identify the agencies and the people to contact
• Follow up after sending the letter
• IHMM will engage all of our certificants and AHMP will engage all of its members in each state to communicate with the agencies in support of the recognition

Let’s get the rest of the country on board. Volunteer using this form > https://forms.gle/xVJ7UgwcfomWTpdR9

Hazardous Materials Society Annual Meeting – December 16, 2020

The Board of Directors of the Hazardous Materials Society (HMS) has scheduled their 1^st Annual Virtual General Membership Meeting of the Society to 4:00 PM Eastern Time, Wednesday, December 16, 2020, so as not to conflict with the AHMP meeting scheduled for December 9^th. This meeting date allows IHMM certificants who are active in AHMP to attend both meetings.

The HMS General Membership Meeting is your opportunity to meet the HMS Board, and to be updated on what the HMS Board and its newly formed Committees worked on in 2020 and their plans for next year. Your host will be Bob West, HMS Board Chair. We anticipate the meeting to be up to one hour in length. Access information for the meeting will be provided via future e-mail messages.

IHMM is a member of COSTHA and is pleased to bring all IHMM certificants this report of the UNSCOE TDG Meetings

The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 57^th Session remotely November 30 – December 8, 2020. There are 78 formal and 54 informal papers submitted. However, several the papers have been deferred until the next biennium due to the lack of general support leading up to the remote session.

Summary of submitted papers

The daily sessions are being held in two segments: Unofficial and Official. The Unofficial segment will occur in the early session each day and will provide participants the opportunity to discuss papers that are generally supported but may have some details to be worked out. The Official segment will be used to finalize decisions on papers. Not all papers are to be discussed in the informal sessions. Therefore, to follow a particular paper, you may have to review the discussion in both the Unofficial and Official segments. The full list of papers to be discussed can be viewed in INF.2.  Papers that are listed in INF.2 as Ready for decision (in parentheses in the title of the paper) will be discussed in the Official segment only. Papers that are listed as Informal session will be discussed first in the Unofficial segment. Papers that are listed as Deferred will not be discussed during the 57^th Session.

This summary is provided to assist you in following the discussions of the papers.

Informal Session – Day 1

INF.38 – Report of the Working Group on Explosives – The Report of the Explosives Working Group (held on November 17-18 remotely) was briefly discussed. The Chairman noted the report will be discussed at the Official Session to consider the few items that were agreed during the EWG session (found in paragraph 13 of INF.38).

2020/10/Rev.1 – Transport of portable fire extinguishers in accordance with special provision 225 – Germany proposed to add a note to special provision 225 indicating that fire extinguishers that are shipped with hoses or nozzles detached but in the package are still considered fire extinguishers. The Subcommittee discussed the wording of the note, in particular, questioning whether the term “pressurized extinguishing agent” is the correct term. Based on the discussion, the paper was referred to the Official session for a decision.

2020/12 – Introduction of a new entry for (7-Methoxy-5-methyl-benzothiophen-2-yl) boronic acid as a self-reactive substance in section 2.4.2.3.2.3 of the Model Regulations – CEFIC introduced a new self-reactive substance used in the pharmaceutical industry. The material is more than 88% boronic acid with water and other impurities. Based on the nature of the material, CEFIC proposed a new entry in the self-reactive table list in 2.4.2.3.2.3. To answer a question from China, the substance is only self-reactive in the presence of water. Thus, the proposal is to minimize the water content. No amendments were proposed during the informal session. Based on the discussion, the paper was referred to the Official session for a decision.

2020/68; 2020/15 – Consequential amendments related to the introduction of “TEMPERATURE CONTROLLED” in 3.1.2.6 and reference to “MOLTEN” as part of the proper shipping name in the transport document – Spain proposed to require the words “TEMPERATURE CONTROLLED” instead of the word “STABILIZED” as part of the proper shipping name when the material is stabilized by temperature control. This would better describe the conditions under which the material is being transported. The proposals were presented in 2020/68 but based on comments from other delegations, they believed the original proposals that were presented in 2020/15 would be better supported. The US agreed with Spain. DGAC questioned whether the term “STABILIZED” remained necessary in the proposal in paragraph 17. CEFIC agreed with DGAC. Based on the discussion, 2020/15 was referred to the Official session for a decision.

2020/18; INF.52; INF.53 – Modifications concerning Salvage Pressure Receptacles – Germany pointed out a need to permit pressure receptacles of up to 1,000 litres in salvage pressure receptacles with a water capacity of up to 3,000 litres. They offered 3 proposals. In INF.52, ECMA believed the proposed changes (in particular the pressure*volume (pV) limit introduction) would have an impact all pressure receptacles and therefore requested additional discussion be held intercessionally. Germany responded in INF.53 that based on their research, they believed a pV limit is necessary and provides an appropriate level of safety. ECMA did not oppose proposal 3 in 2020/18, but Germany pointed out that without Proposal 1 and 2, there is no clear benefit to Proposal 3. France agreed with ECMA and preferred to discuss the concept of risk assessment before adopting Proposals 1 and 2. Based on the discussion, Germany proposed to refer Proposal 3 to the Official session for a decision. Proposal 1 and 2 was withdrawn and will be discussed during the next biennium.  

2020/21/Rev.1; INF.5; INF.20; INF.45 – Request for a new UN number for cobalt dihydroxide powder – RPMASA explained that cobalt dihydroxide powder had been transported without incident for more than 40 years before the material was reclassified as a toxic by inhalation material. This had profound implications on the industry. Over several sessions, the Subcommittee discussed providing a gradational approach to classification, noting that powders containing <10% respirable particles would not meet the definition of a Div. 6.1. These materials would then be regulated as UN3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. Background information was shared in INF.5 and INF.20. However, a revised proposal was presented in INF.45. The new proposal clarified the material would be subject to IBC07 and flexible IBCs would be permitted with sift-proof liners and introduced a new entry for Cobalt Dihydroxide Powder. The US did not believe the proposals in paragraphs 14 and 15 were necessary noting they could have impacts to other sections of the Model Regulations, and thus preferred them be removed. They also pointed out the special provision proposal in paragraph 16 was written in a mandatory fashion, meaning that materials with less than 10% respirable particles would automatically be considered UN3077 regardless of whether it met the definition of an Environmentally Hazardous Material. They also preferred the SP proposal be removed. Belgium agreed with the comments by the US. The Netherlands did not believe the bracketed text was necessary in Paragraph 13. They agreed with Belgium and the US regarding paragraphs 14-16. The UK voiced opposition to adding point (5) to IBC07 in Paragraph 18. France echoed the comments already presented. Canada, China, Sweden and Germany shared their support for the revisions. Comments on the special provision, however, were divided with many preferring to keep it while others wished it removed. Based on the discussions, RPMASA revised the proposal to drop the proposals in paragraphs 13-15, drop the amendment to IBC07 (adding a bullet (5)), and revised the text for the SP in paragraph 16. The Subcommittee did not have extensive discussion on the proposals for the Guiding Principles as they will be discussed later in the session or during the next biennium. Based on the discussion, the proposals in INF.45 as amended during the discussion was referred to the Official session for a decision.

2020/41 – Revisions to Special Provision 301 – IATA proposed an amendment to special provision 301 to specifically exclude explosives and flammable gases from UN3363. Based on feedback on the paper, they suggested the Subcommittee consider Proposal 2 only. The US supported proposal 2. The Netherlands also agreed and pointed out a typo in the proposal (UN3037 should be UN2037). Based on the discussion, Proposal 2 was referred to the Official session for a decision.

End of Informal Session – Day 1

Official Session – Day 1

INF.38 – Report of the Working Group on Explosives – The Chairman reviewed the conclusions from the EWG Report.

• Review of Test Series 6 – EWG to continue review topic in next biennium. No actions taken.
• Improvement of Test Series 8 – EWG to continue review topic in next biennium. No actions taken.
• Review of tests in parts I, II and III of the Manual of Tests and Criteria – Proposed text was included in Annex 3, Amendment 1. Proposals were adopted as presented in Annex 3, Amendment 1.
• Review of packing instructions for explosives – Proposed text was included in Annex 2, Amendment 1. Proposal was adopted as presented in Annex 2, Amendment 1.
• Test N.1 for readily combustible solids – Proposed text was included in Annex 3, Amendment 2 and 3. Proposals were adopted as presented in Annex 3, Amendment 2 and 3.
• UN Gap Test – Proposed text was included in Annex 3, Amendment 4. Proposal was adopted as presented in Annex 3, Amendment 4.
• Exclusion from Class 1 – COSTHA agreed to discuss during the next biennium. No actions taken.
• Use of the terms “risk” and “hazard/danger” – Discussion was deferred to next biennium. No actions taken.
• Review of GHS Chapter 2.1 – The EWG proposed and endorsed text to be presented to the GHS Subcommittee to incorporate the classification criteria for Class 1. The text was endorsed by the Subcommittee.
• Changes to Manual of Tests and Criteria – The EWG proposed and endorsed consequential changes to the Manual of Tests and Criteria that would be applied if the GHS Subcommittee adopted the recommended GHS Chapter 2.1 text. – The text was endorsed by the Subcommittee.

2020/6 – Clarification of control and emergency temperatures for formulations listed in packing instruction IBC520 and portable tank instruction T23 – CEFIC and the Republic of Korea proposed to clarify a link between IBC520 and the list of organic peroxides for substances that are not listed in both locations. Thus, they proposed adding text to several locations in the Model Regulations. The Subcommittee agreed to the proposals as presented.

Due to technical difficulties, the rest of the Official Session on Day 1 was cancelled and will be covered under Day 2.

End of Official session – Day 1

New rules and regulations come into force as of January 1, 2021!

Shippers, freight forwarders, airlines, airports and other key industry stakeholders should take note of these changes and follow the correct guidance by using the latest editions of the IATA Manuals. Not following all the exact air cargo rules can have significant implications on your business such as delays, fines, and other serious implications.

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