The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding its 58th Session remotely 28 June – 2 July 2021. There are 31 formal and 42 informal papers submitted for discussion as of Day 1. This session is the first of four sessions to be held during the 2021-2022 biennium.
Unlike the 57th Session from December 2020, 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. Given the virtual nature of the meeting, there are only four (4) hours each day dedicated to discussion of the papers. This means that discussions on some papers may be limited, and final decisions may be deferred to a later meeting in the biennium.
This summary is provided to assist you in following the discussions of the papers. Note that the Official report of the session will be made available by the UN Secretariat 3-4 weeks after the session concludes.
Day 1 – Discussion of Papers
The Chairman and Secretariat welcomed delegates to the session and noted that the meeting is being held via teleconference. The Secretariat also explained that conditions at the Palais des Nations continue to be difficult and plans for the December session will not be made for several more months. It is still possible that the December session may continue to be held virtually. The Secretariat reminded delegates that the deadline for official documents for the 59th Session will be 3 September 2021.
INF.23 – Report of the Working Group on Explosives – The Chairman of the Explosives Working Group (EWG) presented the results of the discussions held during 14-16 and 18 June 2021. Please refer to INF.23 for the full discussions and conclusions on each of the papers from the EWG. Each of the papers was also briefly introduced during Plenary session and the comments below reflect any additional discussion on the paper during Plenary.
- 2021/14; INF.10 – Report of the 6d – ICG – No additional comments were shared by the Subcommittee. SAAMI encouraged delegates to review the questions raised in the EWG report on this topic and provide comments prior to the December session. No proposals were considered.
- 2021/15 – Exit from Class 1 – France supported the effort by the paper and pointed to 2021/27 from COSTHA and INF.36 from France that shared previous discussions on this topic. The UK was not supportive of the effort and believed the existing criteria were sufficient. The US also voiced concern about expanding the exemption from Class 1. Switzerland explained they have additional examples of articles that cannot currently take advantage of the existing text and thus they supported the effort. They opined the articles represent the hazard, not the materials contained within. France pointed out in 2021/27 from COSTHA, articles when used in an automobile are classified as Class 9 but when not used in an automobile would remain a Class 1. Therefore, there is a paradox regarding end use. France supported moving on specific examples in the short term. Further discussion on 2021/27 and INF.36 will be held later in the session. SAAMI noted that they, IME, and COSTHA would continue the effort and encouraged interested delegations to provide additional comments before the next session. No proposals were considered.
- 2021/19 – Thermal flux calculation in the 6(c) test – Spain questioned whether there was a proposed change to the constant in the paper, and what impact that would have on the units. The Netherlands explained that Option 2 in the China paper did not change the constant and addressed the concerns from Spain. The Secretariat noted the spelling issue could be addressed as a correction instead of a formal amendment. The UK preferred to see some examples of the problems raised before making any decisions. China explained their confusion was only on the equation and units, not on any specific results from actual testing. Mexico also supported the proposal by China. Based on the comments received, the Subcommittee agreed to the proposals in 2021/19, Option 2.
- INF.8 – Waiver of 8(d) test when UN3375 assigned using 8(c) test – No additional comments were shared by the Subcommittee. IME will continue to move the effort forward. No proposals were considered.
- 2021/13 – PP70 of P137 – No additional comments were shared by the Subcommittee. The UK will continue to move the effort forward. No proposals were considered.
- INF.12 – Definition of explosives – No additional comments were shared by the Subcommittee. Sweden will continue to move the effort forward. No proposals were considered.
- INF.17 – Novel pyrotechnic formulations for fireworks – No additional comments were shared by the Subcommittee. The UK will continue to move the effort forward. No proposals were considered.
- INF.21 – New entry for 5-Trifluoromethyltretrazole, sodium salt (TFMT-Na) in acetone as a desensitized explosive – No additional comments were shared by the Subcommittee. CEFIC will continue to move the effort forward with a formal proposal at a future session. No proposals were considered.
- The Netherlands also addressed several miscellaneous items under paragraph 18 of INF.23 including issues regarding the Koenen Test (editorial correction), Appendix 10 A.10.2.3.8, electronic detonators, and a clarifying point on INF.8.
- Koenen Test item – The Subcommittee supported the change as a correction but preferred the issue be addressed in a formal proposal to the next session. No proposals were adopted.
- Appendix 10 A.10.2.3.8 – The Subcommittee supported the change as a correction but preferred the issue be addressed in a formal proposal to the next session. No proposals were adopted.
- Electronic detonators – The paper only addressed implementation problems. Sweden noted that transitional measures are different for many countries and they requested input from delegations as to how long an appropriate transition period should be. IME noted longer transition periods were preferred. Spain commented that their industries were struggling with countries that had not yet adopted the new entries (the US being one of them). The UK did not feel a transition period was needed as existing product in stock could be shipped as it was previously classified. The US noted that national legislation may take a significant amount of time, and therefore was in favor of a longer transition period. IME added that the existing numbers must remain to cover existing product and indicated they would return with a formal proposal to address. No proposals were considered.
- Clarification point on INF.8 – No additional discussion was made on paragraph (d). No proposals were considered.
- Additional papers reviewed by the EWG will be discussed under the assigned Agenda item in the Plenary session.
2021/1 – Correction and alignment of 18.104.22.168, 22.214.171.124.4.1, and 126.96.36.199 in the English and French versions – Canada noted contradictions between the English and French versions regarding the classification of Division 6.1 inhalation hazard and Class 8. Proposals were suggested in both the English and French versions to clarify the point. The Netherlands agreed that a contradiction exists. However, they believed preference to a Class 8 may have been intended. Therefore they suggested additional research was needed. Further, the Netherlands added that if both oral and dermal toxicity is not available, the changes would make one of the Notes unusable. France supported the proposal as drafted and disagreed with the comments of the Netherlands. China supported the discussion and preferred additional historical research be conducted on the original intent of these sections. Belgium and Germany aligned with the Netherlands and China. The UK disagreed with the proposal and believed that in all cases presented, Class 8 should result as the higher precedent. Based on the discussion, Canada withdrew the proposal and will work with interested delegations to prepare a revised proposal at a future session. No proposals were adopted.
2021/3 – New UN entries for chlorophenols – Germany proposed four (4) new entries for chlorophenols. CEFIC pointed out the proposal is for chlorophenols but the SDS is for dichlorophenols. Thus they preferred additional detail on how to use the entries for mono-, di- , penta- or other isomers of chlorophenols. The Republic of Korea and Sweden supported the proposal. The Netherlands made a number of comments on the paper including concerns over whether all chlorophenols should be treated the same. Further, the proposal offered in the paper does not appear to follow the rationalized approach. The requested additional data to support the proposal. The US, China, Belgium, and France agreed with CEFIC and the Netherlands that additional research is needed. Based on the comments, Germany withdrew the proposal and will submit a revised proposal at a future session. No proposals were adopted.
2021/12 – New special provision to UN 3538 – The UK proposed language to cross-reference articles containing gases under pressure with existing exceptions in 188.8.131.52. Belgium preferred Option 1. The US and the Netherlands did not support either option. The Netherlands felt that the initial pressures would be too high for either option to be of practical use. Switzerland did not oppose the approach and felt it would be a worthy clarification. China supported the proposal in principle but suggested the language would be beneficial in 184.108.40.206 as well as associated with other similar entries. The UK requested the report reflect the fact that the Subcommittee felt the provisions of 220.127.116.11 would apply to suitable articles under UN3538. Switzerland suggested this topic could be the basis for a UN interpretation. Based on the comments, the UK withdrew the proposal. No proposals were adopted.
2021/16 – Proposal for unifying animal species for evaluation test of acute dermal toxicity in GHS and Model Regulations – China pointed out discrepancies between the GHS and Model Regulations when reviewing preferred animal species for testing for oral, dermal, or inhalation toxicity. In some cases, rat or rabbit is noted, while in others, albino rabbit is preferred. China recommends adding rats to the list of acceptable species for dermal toxicity. Canada believed modifying the species list could result in changes to existing classifications. Thus they preferred to research the issue further. Also, they noted the continued efforts for in-vitro testing that would reduce or eliminate animal testing. Belgium agreed with Canada and questioned whether the term “albino” was still necessary. Germany did not feel dermal exposure for rat was comparable to humans and preferred to retain the rabbit requirement. The US voiced concern that as proposed, industry could choose a more favorable LD50 value if data were available for both species. For that reason, they requested that when data for both are available, that the lower or more conservative value must be used. The UK agreed with Canada and opposed the proposal. The Netherlands agreed that something needed to be done as the GHS and Model Regulations should be harmonized. However, they agreed with others that data from rats could reduce the amount of animal testing and thus supported the ongoing discussion. Based on the comments, China withdrew the proposal. No proposals were adopted.
2021/18 – UN packing group of magnetized material – China proposed to remove the PG from the entry UN2807 MAGNETIZED MATERIAL noting that the materials are not required to use UN specification packaging. ICAO fully agreed with the proposal as drafted. Switzerland questioned whether there should be PG I or II level. The Chairman clarified that UN2807 is only regulated by air and there is no reason to have criteria to differentiate PGs. Based on the comments, the Subcommittee agreed to the proposal as presented in 2021/18.
End of Day 1