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 43 informal papers submitted for discussion as of Day 2. 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 2 – Discussion of Papers
2021/17 – Proposal to amend SP 366, making it also adjust to gallium contained in manufactured articles – China noted manufactured articles containing gallium represent a similar risk to those containing mercury although not toxic. While gallium is less hazardous than mercury, it still represents a corrosive risk. Therefore, they proposed a new entry and packing instruction for manufactured articles containing gallium. The US and Austria supported the adoption of the entry in Option 1 in Proposal 1 and 2 but questioned the need for dry ice consideration in PP41. Belgium and Sweden questioned whether it would be similar to ship these products under UN3547, ARTICLES CONTAINING CORROSIVE SUBSTANCES, N.O.S. Nevertheless, they preferred Option 3 in Proposal 1 and Option 1 in Proposal 2 in the paper. The Netherlands believed the adoption of this paper would unduly limit the use of gallium in such articles and therefore did not support the proposal. Spain preferred Proposal 1, Option 1, and Proposal 2, Option 2. France supported Proposal 1, Option 1 but did not have a preference for Proposal 2. Switzerland voiced concern that creating new entries for each article would result in hundreds of new entries. Therefore, they preferred Proposal 1, Option 3. The UK supported Proposal 1, Option 1. Germany questioned whether UN3363 DANGEROUS GOODS IN APPARATUS would be acceptable for this product. Based on the comments, China indicated they would revise the paper and resubmit a revised proposal for a future session. No proposals were adopted.
2021/22; INF.40 – Classification of UN 1010, mixtures of butadienes and hydrocarbons – CEFIC noted that the current entry for UN1010 BUTADIENES AND HYDROCARBON MIXTURE, STABILIZED applies to mixtures containing more than 40% butadienes. However, CEFIC believed this could lead to a misleading emergency response situation as mixtures below 40% may also require stabilization. Therefore, they proposed to revise the non-capitalized text in the entry to state “containing more than 20% butadienes”. They noted the Netherlands and Germany have entered into a Multilateral Agreement (MLA) on the issue already. The Netherlands, Germany, Poland, Canada, Sweden, and Belgium fully supported the proposal as drafted. Spain supported the proposal in principle but voiced concern that the resulting vapor pressure from a lower percentage of butadienes may require the use of different tank provisions. Spain requested a special provision be added to limit the vapor pressure of various components. The US questioned the percentage at which butadiene mixtures require stabilization. CEFIC noted there have been no reported incidents of these products since 2003 when the entry was introduced. CEFIC responded mixtures containing <20% butadiene would also require stabilization but they were not prepared to provide a minimum percentage. The Subcommittee supported the proposal but indicated they would await an informal paper from CEFIC, Spain, and the Secretariat that would include a special provision currently found in the ADR on the topic. Final adoption will be delayed until later in the Session.
2021/21; INF.24 – Transport conditions for UN2426 ammonium nitrate – Spain has been reviewing the proper shipping names in various texts to address differences caused by translation. As part of this effort, they noted some challenges with UN2426 AMMONIUM NITRATE. They noted that special provision 252 provides situations where such material is excepted from the Model Regulations. However, Spain added that ADR, RID, and IMDG Code add additional limitations that are not reflected in SP252. Therefore, they proposed modifying SP252 to include additional limitations found in the modal texts. In INF.24, Fertilizers Europe suggested the need to add a solution temperature limit when referencing the pH value. The Chairman of the EWG indicated general support for the proposal but added a number of additional comments were listed in INF.23 Report of the Explosives WG. France suggested that the temperature be mentioned after “measured” to avoid the impression that the solution would need to be transported at 25 oC. Australia was not convinced that the change was needed as appropriate provisions were already included in the modal texts. Belgium pointed out many of the provisions in the Spanish proposal come from Column 17 of the IMDG Code which is not mandatory. They preferred additional time to determine the full impact of making these provisions mandatory. Sweden supported including these provisions for all modes. The US agreed with Belgium and believed additional research on the impact to all modes was necessary. Based on the comments, Spain withdrew the proposal and will return with a revised proposal at a future session. No proposals were adopted.
2021/27; INF.36 – Fire suppression devices that contain a pyrotechnic material – COSTHA explained the value and nature of fire suppression dispersion devices and the fact that they meet the conditions of special provision 280. However, when these devices are not used or installed in vehicles, the current entry UN3268 SAFETY DEVICES may not be appropriate. The issue was extensively discussed during the previous biennium. Previous proposals were removed to allow a more general discussion of the topic in the context of 2021/15 Exit from Class 1. In INF.36, France reminded the Subcommittee of the previous discussions on the topic, including responses from the EWG. They shared a similar technology that serves the same purpose as the one described in 2021/27. They reiterated the device contains the same initiating materials used for traditional airbags but are used for improving safety both in and out of a vehicle application. They offered two possible solutions: a revision to the original COSTHA proposal to create a new entry for such devices or revise SP280 to include pyrotechnically initiated fire dispersion devices. The Chairman of the EWG explained that the group agreed UN3268 would not be the appropriate entry and that a new entry would be preferred. The group also suggested that while these are examples of articles that may be excepted from Class 1, a solution on this issue cannot wait for the broader solution. CLEPA preferred UN3268 remain for airbags and not be broadened to include devices not used in vehicles. France reminded the Subcommittee some of these fire suppressant dispersion devices are often installed in vehicles. So there is a clear overlap. France pointed out there are 3 questions mentioned in INF.36 that originated from the 57th Session, INF.51. The Chairman of the EWG offered to review these questions again through an intercessional correspondence group. The US commented that they have reviewed many different technologies that would fall under this description and noted that there is no limit to the amount of explosive material. SAAMI supported the effort to work intercessionally on the topic and added that the issue of classification inside a vehicle or outside could be considered. The UK felt additional data was needed before the EWG could consider the issue completely. COSTHA indicated they would work with the Chairman of the EWG, France, and others to continue to discuss intercessionally. France responded to the UK that the 3 questions are general in nature and that details on each of the types of devices had been shared individually and within 2021/27 and INF.36. Based on the discussion, COSTHA, France indicated they would work with the Chairman of the EWG to discuss the topic and report progress at the 59th Session. No proposal was adopted.
INF.9 – Problems with the practical implementation of P650 – Spain noted practical problems with P650 that were highlighted by the COVID-19 pandemic. Specifically, they noted concerns with package testing with regards to the pressure or drop test. They asked if other authorities had experienced the same problem, and proposed modifying P650 to clarify secondary packagings must meet the pressure test. Sweden is not aware of any package failures offered under P650. The UK was also not aware of any significant failures. Further, they pointed out the requirements are “capability” requirements and do not require actual testing. The purpose of P650 was to allow for packaging that does not require competent authority approval in order to keep the costs of packaging to a minimum. For these reasons, the UK did not support the proposal. Belgium agreed with the UK and felt much of the concern is due to failure to fully understand the intent of P650. They pointed out the packing instruction was originally based on PI650 in the ICAO TI and there may be additional details in that packing instruction that can provide clarity. They did not support making any changes to P650 at this time. The Netherlands was reluctant to require secondary packaging to meet the pressure requirement as it would limit packaging options that have proven safe today. IATA also indicated they were not aware of any problems in air transport. Based on the discussion, Spain withdrew the proposal. No proposal was adopted.
INF.25 – Clarification of generic concentration limits for skin corrosion classification in the UN Model Regulations – China requested clarification on the recently adopted methodology on corrosive mixtures. They questioned the actual criteria for assignment to PG I or PG II and how to use the various equations in Chapter 2.8 of the Model Regulations. Germany indicated that the calculations in the Model Regulations were correct and explained how to use the section. Belgium pointed out there are two methods in question. If you have detailed concentration values, then you would use the simplified equation. But if you do not have actual concentration values, you would use the more complicated equation. But if you use the more complicated equation with actual values, you would get a different result (PG II vs. PG I). Thus, there is a precedence of equations and that may need to be clarified in the text. Based on the discussion, China indicated they may consider submitting a formal proposal at a future session. No proposals were considered.
2021/7 – Germany requests an interpretation of the term “cargo transport unit” within the context of the transport of UN 3536 – LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNIT – Germany pointed out that the definition of a cargo transport unit and freight container requires compliance with the CSC provisions. If a container designed as UN3536 does not meet the CSC provisions, then they would not be approved for transport. Germany questioned whether other delegations agreed with this approach and asked whether clarification was needed. France suggested that the use of the existing term “CTU” was out of convenience, not to bring in the CSC provisions. They do not believe such units should be CSC compliant and suggested a change to the proper shipping name or addition to a special provision would be appropriate. Sweden and Switzerland pointed out road transport does not require CSC approval and did not believe it should apply. China has experienced the problems detailed by Germany. They proposed to change the proper shipping name to “Lithium [ion/metal] batteries installed in energy storage devices”. They also suggested special provision 389 be modified to include a notation that CSC compliance is not required for modes other than vessel. The Republic of Korea, RECHARGE, and Spain agreed with China. France offered several suggestions on possible proper shipping name suggestions. The US pointed out the definition of cargo transport unit also mentions transport vehicles which are not mentioned anywhere else in the Model Regulations. And there are methods that permit non-CSC-approved units to be moved by vessel including by RO/RO vessels. They supported adoption of a special provision clarifying that CSC approval is not required. PRBA agreed with the US. Based on the comments, Germany indicated they would work with interested parties and return with a formal proposal at a future session. No proposals were considered.
INF.32 – Lithium-ion batteries special provision SP188 update – RECHARGE and PRBA pointed out energy density is increasing significantly and consumer products are beginning to see cells and batteries that exceed SP188. Given SP188 was originally created to permit the movement of these types of devices, they recommended increasing the Wh limit for small batteries. They pointed out the original values were based on weight (equivalent lithium content) but current technology has reduced weight by at least 50%. Thus, there is justification for the modification (30 Wh/cell, 150 Wh/battery). France believed additional research was needed to consider the danger represented by the higher values. Germany shared France’s concern and felt higher energy density could lead to greater risks. The US pointed out the original values were not necessarily risk-based but instead a practical or intuitive level. That said, just because consumer devices are utilizing larger batteries is not enough justification to increase the values. They believed the work of the Informal Working Group on Lithium Batteries should be fully completed before moving forward in this area. Based on the comments, RECHARGE indicated they would consider the comments for a paper for a future session. No proposal was adopted.
INF.33 – Lithium-ion batteries testing, paragraph 38.3 (g) update – RECHARGE shared significant developments in battery technology and pointed out these changes are creating problems in using the short circuit test (T.5) to large format batteries. 38.3.3(g) already includes exclusion from the overcharge test (T.&) for very large batteries (>6200 Wh) if they have a system that is verified to provide overcharge protection. RECHARGE is proposing to extend this exception to include T.5 as well. Germany supported the effort in principle. But they requested additional data and detail on how a system could provide short circuit protection. Overcharge happens in very rare cases, but a short circuit is a more likely failure mode. France agreed with Germany. Based on the comments, RECHARGE indicated they would consider the comments for a paper for a future session. No proposal was adopted.
End of Day 2