The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 61st Session November 28 – December 6, 2022 in Geneva, Switzerland. There are 32 formal and 39 informal papers submitted for discussion as of Day 1. This session is the final of four sessions during the 2021-2022 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 1 – Discussion of Papers
2022/75 (Secretariat); 2022/49 (Germany); INF.39/Rev. 1 (Secretariat) Consolidated list of draft amendments – The Subcommittee reviewed the draft amendments to the UN Manual of Tests and Criteria as well as the UN Model Regulations previously adopted during the biennium. The items were reviewed individually to give delegations the opportunity to confirm or oppose. Comments were made on the following paragraphs:
- The Netherlands commented the change in Chapter 2.5 may need to be confirmed as correct and asked whether the number 3106 should be 3105. The Secretariat indicated they would review and update the modification as necessary.
- Regarding Special Provision 204, Germany proposed 2022/49 to support the removal of the square brackets. The Subcommittee agreed without additional comment.
- The Secretariat indicated that the two paragraphs in square brackets in Special Provision 310 were added by the Secretariat believing it was an inadvertent omission. Belgium, as one of the original authors, agreed.
- In Special Provision 401, the second sentence was updated to indicate “…sodium ion cells and batteries” at the request of the US.
- In INF.39/Rev.1, the Secretariat suggested additional language to 188.8.131.52 as editorial language to clarify the point, correct a mistake in 184.108.40.206, renumber 38.3.3 and add a new heading that was inadvertently omitted. The Subcommittee agreed to the proposals as drafted.
- In 220.127.116.11, the Subcommittee agreed to remove the extra word “constructed”.
All other provisions were adopted without discussion. The Subcommittee adopted the proposals as presented in 2022/75.
All other provisions were adopted without discussion. The Subcommittee adopted the proposals as presented in 2022/75.
2022/78 (OTIF); INF.15(IATA) Special Provision 388 – OTIF originally proposed to retain the words “or equipment” in Special Provision 388. However, in INF.15, IATA explained why the wording was originally deleted. Satisfied with the IATA Retort, OTIF withdrew the proposal. No proposals were adopted.
2022/62 (Chair of the Informal Group for Fibre Reinforced Plastic Tanks (FRP)) Sub-Chapter 6.9.3 “Requirements for design, construction, inspection and testing of fibre reinforced plastic (FRP) service equipment for portables tank” and amendments to Sub-Chapter 6.9.1 – The Chairman of the Informal Group for Fibre Reinforced Plastic Tanks presented the provisions for FRP service equipment in 2022/62. However, due to the amount of changes, the Russian Federation requested a lunchtime working group on Day 1 to consider any final changes to the proposal. The full details of the paper will be reviewed on Day 4. Belgium indicated they had several concerns and would participate in the discussion on Day 1. No proposals were considered.
INF.43 (IME) Response to informal document UN/SCETDG/60/INF.42 (IME) – IME commented that a previous paper submitted by RPMASA on ANEs suggested that Test Series 8(d) should not apply if Test Series 8(e) had been conducted. IME questioned whether the ANEs proposed would be subject to Test Series 8(e) in any case. IME and RPMASA indicated they would continue the discussion of the topic during the next biennium. No proposals were considered.
2022/57 (Cefic) Manual of Tests and Criteria, section 18.104.22.168.3 and section 20.2.5 regarding self-heating test N.4 for organic peroxides and polymerizing substances – Following up on previous papers, CEFIC proposed changes to the UN Manual 22.214.171.124.3 and 20.2.5 to exclude organic peroxides Type A and polymerizing substances from the N.4 test as these materials would likely result in a false positive. The US commented that CEFIC had addressed previously shared concerns and indicated support for the proposal. The Netherlands commented they had experienced false positives for these materials and thus supported the proposal as well. Canada also voiced support. The Subcommittee adopted the proposal as drafted.
2022/47 (Sweden) Amendment to definition “pyrotechnic substance” and introduction of definition “explosive or pyrotechnic effect” – Sweden noted that previous proposals adopted by the Subcommittee on definitions to “pyrotechnic substance” and “explosive or pyrotechnic effect” were recognized as having an impact to GHS definitions. The proposal requested both the TDG and GHS Subcommittees adopt the provisions in 2022/47. The Subcommittee supported the definitions but discussed what would happen if GHS did not adopt. The UK, US, and Spain supported the proposals as drafted. The Netherlands also supported, and shared that it is common practice for the TDG Subcommittee to adopt and then allow GHS to consider. They added that the definition would not be limited to Section 1.2 of the Model Regulations and there may be necessary consequential amendments throughout the Model Regulations and GHS. SAAMI commented the proposals were generally supported at the 60th Session and did not feel putting the language in square brackets was necessary. The Chairman indicated square bracket use in this situation would be a courtesy to the GHS Subcommittee. Based on the discussion, the proposal was adopted as drafted and will be sent to the GHS for concurrence.
2022/55 (COSTHA, SAAMI) Research in relation to the 6d Test and exit from Class 1 – SAAMI shared continued research regarding the exit from Class 1 and requested the topic be included in the Plan of Work for the next biennium. No proposals were considered.
2022/58 (Cefic); 2022/63 (China); INF.6 (Cefic); INF.46 (UK) Assignment of Special Provision 28 to liquid desensitized explosives in the Dangerous Goods List of the Model Regulations – CEFIC noted that SP 28 was not applied consistently to all desensitized explosives. China independently identified the same concern. Therefore, a combined proposal was presented in INF. 6. The UK supported the effort, but added justification for 5 additional entries to be considered for inclusion. CEFIC and China supported the UK amendment. Canada pointed out that in certain circumstances, the amount of liquid dilutant necessary to apply SP28 may not be clearly identified. To address this, they recommended adding a sentence to SP28. France supported the proposals but questioned whether the amendment given by Canada would solve the problem, using UN2557 as an example. The US believed that SP241 (applied to UN2557) required that any dilutant applied must not evaporate or separate during transport. Thus they felt that the concerns of France were already addressed. France responded that SP241 is a classification requirement where SP28 is a packing requirement. But they agreed that the situation would be very unlikely. The Secretariat pointed out that the original proposal included the application of PG II but that was not in INF.6. CEFIC clarified that the addition of PG II would not be necessary based on existing text. Based on the discussion, the CEFIC indicated they would work with Canada and return with a revised proposal during this session.
2022/59 (Cefic, WONIPA); INF.8 (Cefic, WONIPA) Classification of nitrocellulose membrane filters for diagnostic and other life science applications – CEFIC and WONIPA proposed to provide an exception for nitrocellulose membrane filters commonly used for diagnostic and life science applications. Previous comments requested additional burn testing to see how quickly they burned. Results indicated that the filters burn rate very slowly. As a result, CEFIC and WONIPA proposed a special provision (presented in 2022/59) that detailed the required construction of the filters that would be eligible for exception. The UK, the US, Canada, and Sweden supported the proposal as drafted. The Netherlands felt that the ISO standard referenced in the SP should have a date (perhaps 2007). They further asked what “tightly wound” meant. CEFIC explained that part of the production process requires the rolls be tightly wound to create the filters. Therefore, providing a performance for winding was not necessary. The Netherlands noted that given CEFIC’s comments, perhaps the text was not necessary. However, others felt the text provided some benefit. Based on the discussion, the Subcommittee adopted the proposals as drafted.
2022/46 (Secretariat) Specific activity and activity concentration – Based on a previous proposal by Spain, the Secretariat confirmed with IAEA that a new note explaining “activity concentration” and “specific activity” were synonymous. Therefore, they proposed to adopt the original note as drafted by Spain during the 60th Session. Spain, Sweden, Australia, and Brazil supported the proposal. Belgium shared their previous request that the language be amended to add “of the material” to each term. The Secretariat shared that IAEA preferred to keep the text as proposed. Based on the discussion, the Subcommittee adopted the proposal as drafted.
2022/51 (Germany); INF.16 (FEA, HCPA) Differentiation between UN 1950 aerosols and UN 2037 receptacles, small, containing gas (gas cartridges) and proposed marking requirements for UN 2037 receptacles, small, containing gas (gas cartridges) – Germany believed there is no clear distinction between UN1950 and UN2037 and argued that based on the current text, the two entries are differentiated by whether a release mechanism was attached (Aerosols – Yes, Receptacles, small – No). They suggested a number of proposals to codify the differences. FEA and HCPA argued against the proposal pointing out several of the examples provided in 2022/51 include a self-closing valve. They argued this is the clear distinction, not the actual spray cap. FEA explained that any changes in this approach would have significant impacts to existing products when there is no clear safety concern. Spain pointed out the current definition of an aerosol requires the inclusion of a release device and argued that several examples given in INF.16 would not meet this definition. Thus, they felt a change was necessary to at least align the regulations with industry interpretations. France acknowledged the positions of both sides and felt additional work was needed to find a resolution. France suggested the work be continued in the next biennium. They also opined an aerosol should aerosolize something to be considered an aerosol. But they also commented that external views might not reveal what is actually contained within. Just because a spray cap is not visible may not discount the item from being an aerosol. The US were not prepared to support the proposals in 2022/51 and agreed with France. Finland supported the proposal in principle but agreed additional review may be necessary. WLPGA agreed with FEA and did not feel the proposals were ready for adoption. China noted that several of the proposals are based on language in the ADR/RID, such as the definition addition in paragraph 8, but left out key limitations. China also noted significant burdens would be placed on industry for UN2037 if labeling were introduced. Luxemburg agreed with France and suggested additional discussion was necessary. Sweden had received questions on the topic and therefore believed something needed to be done to clarify. Belgium and Switzerland agreed with Sweden and further added their support for looking at whether pure gases could be an aerosol. The UK voiced caution for the approach noting significant potential impacts to very long standing provisions. France suggested the Subcommittee provide a list of topics of concern for Germany to address in their future work. Based on the discussion, Germany withdrew the proposal but indicated they would return to this topic during the next Biennium and requested delegations contact them for additional discussion.
End of Day 1 – From COSTHA, IHMM is a member of COSTHA