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 45 informal papers submitted for discussion as of Day 3. 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 3 – Discussion of Papers
2021/28 – Proposed amendments to packing instruction LP903 – PRBA proposed to modify LP903 to allow multiple cells or batteries in large packagings. They pointed out that LP906 was modified during the last biennium to allow for damaged/defective batteries and proposed similar changes to LP903 to maintain safety. The UK voiced support for the proposal with minor amendments. The Netherlands supported the proposal in principle but felt additional details needed to be added including who would determine the maximum amount per package and whether additional packaging requirements would be necessary. The US stated they remained worried that a large packaging containing many thousands of batteries could result from this approach. Sweden supported the proposal but agreed with the UK’s amendments. Spain did not support the proposal as written. Belgium noted LP906 requires a competent authority approval and pointed out such approval is not offered in this proposal. Other delegations, including Australia and China, provided support in principle but also suggested additional editorial changes were necessary. Based on the comments, PRBA indicated they would work with interested delegations and would return with a revised proposal. No proposals were adopted.
INF.15 – Cells and batteries installed in cargo transport units and 2.9.4 – Switzerland…France disagreed with Switzerland pointing out that 2.9.4 applies to batteries contain in such units, not the unit overall. The US also opposed the proposal. IATA believed that confusion raised by Switzerland is valid and welcomed the clarification in INF.15. France reminded the Subcommittee of the discussion on the naming of UN3536 and that discussion may have an impact on this approach. Based on the comments, Switzerland withdrew the proposal and indicated they would likely return in the future with a revised proposal. No proposal was adopted.
2021/26 – Increase of the limited quantity volume for Division 2.2 compressed gases – Building on efforts from the previous biennium, COSTHA proposed increasing the limited quantity value for Division 2.2 gases without a subsidiary risk, drawing comparisons to the aerosol provisions. Many of the Subcommittee were supportive of the effort in principle. But many added that significant data support and risk analysis was needed. Canada noted that as presented, only the provisions of 220.127.116.11 would apply and they preferred to add limitations in 3.4.1. The Netherlands stated that COSTHA was proposing an 8-fold increase in the volume and requested a thorough risk analysis to support the request. Belgium supported the effort, but agreed with others and pointed out that aerosols have a pressure limit of 15 bar. They preferred not to include liquified gases. The UK agreed with Belgium on omitting liquified gases. They also agreed with Canada that 3.4.1 should be amended to include provisions for cylinders. Sweden, France, and Germany agreed with the UK. Switzerland was not convinced the issue was needed. The US commented that with gases, potential energy was the main concern. Therefore, pressure limits needed to be addressed. Based on the comments received, COSTHA indicated they would review comments received and return at the next session with a revised proposal. No proposals were adopted.
2021/6; INF.5 – Special packing provisions for goods of Class 2 – 18.104.22.168.8 Requirements for valve protection – ISO proposed to clarify provisions for valve protection. They added additional data in INF.5. The Subcommittee supported the proposal as drafted. The proposal was adopted as presented.
2021/10; INF.39 – Updated ISO standards in Class 2 – ISO proposed updating several standards (ISO 11114-1:2020; ISO 16148:2016+Amd 1:2020; ISO 13088:2011+Amd 1:2020; ISO 1118:2015+Amd 1:2019) They provided additional amendments in INF.39. China proposed minor editorial changes to INF.39. The Subcommittee supported the proposals as amended by INF.39 and China. The proposals were adopted as amended in INF.39.
INF.38 – Report of the intersessional working group on the pV product limit for pressure receptacles – Germany reported on the progress of discussions on the pressure x volume product for pressure receptacles. Specifically, they looked at incidents involving gases and pressures that led to injuries/fatalities. The report addresses population density for risk analysis to determine reasonable risk. The paper offered no proposal but summarized the discussions to date. France supported continuing the effort but pointed out the group is not authorized to identify acceptable risks for competent authorities. Such decisions are addressed by laws in individual countries. Switzerland voiced concern that this effort was not necessarily in the scope of the Subcommittee. Germany pointed out the group effort is only to set a maximum pV limit, not to address risk analysis for competent authorities. No proposals were considered.
2021/4 – Criteria for passing the top lift test for wooden large packagings and fibreboard large packagings – revised version of ST/SG/AC.10/C.3/2020/64 – Germany…The UK fully supported the proposal as drafted. Belgium, Canada, the US, and others fully supported the proposal. The proposal was adopted as presented in 2021/4.
2021/20; INF.22 – Testing the non-combustibility related to packages for lithium batteries – Belgium proposed to clarify that the testing of non-combustibility should apply to insulation and cushioning for lithium batteries and not for the packaging as a whole. Sweden added additional consequential amendments that would also need to be changed. Additionally, Sweden suggested the need to define “non-combustible”. RECHARGE supported the Belgian proposal but opposed the addition of the note. They believed referencing a specific standard would imply that there is only one standard that could be used. Further, it suggested that packaging overall would need additional approval. Germany agreed with the proposal from Belgium and felt the note could be expanded to include any standards that could be used. The Netherlands did not support the note and added editorial comments to the Belgian proposal. The UK welcomed further discussion on the note. They also felt that the proposal could be reworded to reflect that packaging was authorized. The US did not feel the note was necessary. Germany supported the discussion and the note. DGAC agreed with other speakers in supporting the original proposal but opposed the inclusion of the note. They also pointed out if the note were adopted, it would raise questions about testing for combustibility for all packing instructions, and that creates significant complications to the Model Regulations. Australia, Canada, PRBA, and MDBTC agreed with the UK and DGAC. Based on the discussion, Belgium proposed to withdraw the proposal for adding the note and ask for a decision only on the changes to the first underlined text in each of the proposals in 2021/20. The Subcommittee agreed to the underlined text (except for the note) in each of the proposals in 2021/20.
INF.4 – Revision of ISO 535:1991 – Spain proposed updating ISO Standard 535:1991 Paper and board – Determination of water absorptiveness – Cobb Method. The new standard has been adopted as of 2014. Sweden, Brazil, UK, Austria, the Russian Federation, Mexico, and Germany supported the proposal. Germany pointed out the standard is currently being reviewed for revision and will likely be approved during this biennium. Based on the comments, the Subcommittee agreed to the proposal pending an update on the standard by the end of the biennium.
INF.6; INF.26; INF.42 – Regulatory aspects on the use of recycled plastics – Belgium shared research on plastic materials in the Model Regulations, noting significant discussions during the last biennium on “suitable plastic material”. Their goal is to create a unified position on reused plastic materials. They requested responses to a number of questions to build an understanding of current global positions. In INF.26, ICCR, ICIBCA, and ICPP provided responses to the questions, and they argued that there is no need to provide any definition of “suitable plastic material”. Industry and competent authorities currently understand the term as applied in the Model Regulations. The UK provided their responses in INF.42 and shared that the issue is very complicated as there are many different types of plastic materials. The real issue is that this section was developed with the concept of recycled plastics in mind. ICIBCA opined that the perceived use of the term “suitable” was intentional and serves to police and limit industry from using any type of recycled plastics without providing specific requirements. Germany explained that producers of recycled plastics from consumer products/waste clearly identify their materials are not intended for use in highly regulated industries. They believed additional clarification is needed. Belgium thanked delegations that responded, and added that they are concerned not all areas of the world are in agreement on this position. No proposals were considered.
2021/22; INF.40; INF.44– Classification of UN 1010, mixtures of butadienes and hydrocarbons – CEFIC shared a revised text from the discussion on this topic on Day 2. The US requested that the special provision be placed in square brackets for confirmation of the text at a later session in the biennium. Canada agreed with the US. CEFIC reminded competent authorities to sign onto existing MLA on this topic to ensure universal compliance. With the addition of text in square brackets, the Subcommittee agreed to the proposal as presented in INF.44.
2021/11; INF.30 – Resilience of fibre-reinforced plastics (FRP) portable tanks – The UK indicated concern on the resilience of FRP tanks. The UK requested feedback as to whether the text adopted during the last biennium is adequate. They provided editorial amendments in the Annex to the paper. INF.30 provided amendments to the previously adopted text as discussed and agreed by the FRP Tank Working Group. It was emphasized that the proposals in INF.30 which are editorial in nature needed to be adopted quickly so that they could be taken up by the Joint Meeting and IMO in their fall sessions. Finland, Spain, the US, Germany, and AESIG all supported adoption of the provisions in INF.30. The UK indicated they would return with a revised proposal at a future session. Based on discussions, the Subcommittee adopted the amendments in INF.30. The changes are requested to be in a Corrigenda for publication later in 2021.
End of Day 3