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 48 informal papers submitted for discussion as of Day 2. 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.
2022/75 (Secretariat); 2022/49 (Germany); INF.39/Rev. 1 (Secretariat) Consolidated list of draft amendments – Although these documents were reviewed and adopted on Day 1, the UK pointed out that the proper shipping names for Sodium Ion Batteries was not consistent with other similar proper shipping names. They proposed to modify the names to read as: SODIUM ION BATTERIES CONTAINED IN EQUIPMENT or SODIUM ION BATTERIES PACKED WITH EQUIPMENT with organic solvents. The Subcommittee agreed to the proposal from the UK.
2022/53; INF.23; INF.24 (World LPG Association, Liquid Gas Europe) Present and future products in the LPG Industry, amendment of UN numbers, discussion points and proposals – The WLPGA explained that the liquid petroleum gas (LPG) industry is moving toward a bioLPG and a renewable resource. This includes an increase in dimethyl ether (DME) to existing propane mixtures. In the US, DME concentrations are already at 5% in the US although 15-20% may soon be possible. However, the existing definitions within the Model Regulations do not adequately describe these new products, and the entries for PETROLEUM GASES, LIQUIFIED (UN1075) and HYDROCARBON GAS MIXTURE, LIQUIFIED (UN1965) should be modified to reflect these changes. Options for proposals were presented in 2022/53 and INF.23. The UK supported the effort and requested additional data regarding the nature of the new mixtures and their impact to existing service equipment (valves, etc.). They were not supportive of making reference to renewable sources in the proper shipping name, however. France commented the proposals were in line with the Subcommittee’s goals for supporting renewable energy and the report should reflect this fact. They preferred INF.23 as it would not make any modifications to existing proper shipping names. The US also preferred INF.23 if it provided industry necessary clarity and support. Spain and China were in agreement with other speakers. Belgium preferred to have a description that is more specific to mixtures of DME but added there are other chemicals described as DME and thus requested that the chemical nature be spelled out. In INF.24, WLPGA proposed a new entry for bioLPG with the additive of DME. France and Spain commented that if there is a clear emergency response difference or hierarchy on which entries to choose, such an approach would be appropriate. The US recognized that non-transport-related concerns, such as storage or handling, may need additional communication. If this is the case, then the US indicated they would be open to considering a new entry. WLPGA emphasized that a 10-20% DME mixture would essentially be a new product and would not be an LPG. They thanked the Subcommittee for the comments and indicated they would return with additional formal proposals in the next biennium. No proposals were considered.
2022/54 (Germany) Proposal to add class 8 as subsidiary hazard to UN 1040 ETHYLENE OXIDE or ETHYLENE OXIDE WITH NITROGEN up to a total pressure of 1 MPa (10 bar) at 50 °C – Germany proposed adding a corrosive subhazard to ethylene oxide and mixtures of ethylene oxide and shared their research on the topic. They recognized the volatility and rapid evaporation of ethylene oxide. CEFIC supported the GHS designation of a subhazard as Class 8, but pointed out the practical experience with spills of ethylene oxide may not result in a corrosive nature in transport. The US pointed out the testing presented is for a liquid solution of the material, whereas the proposal is regarding a gas mixture. Thus they were cautious in adopting the approach. China also opposed the proposal. Based on the discussion, Germany withdrew the proposal. No proposals were adopted.
2022/56 (WCC); INF.47 (WCC) Transport provisions for small quantities of environmentally hazardous paints and printing inks (and related materials) – The World Coatings Council (WCC) reiterated the challenges with shipping paints and coatings that do not meet Classes 1-8 but that meet the requirements for environmentally hazardous substances (EHS). In addition, the availability of UN specification packaging appropriate for these productions is very limited and costly. WCC pointed out there is no specific UN entry for paints and coatings that are EHS materials and thus must be offered as UN3082 or UN3077. These new options would allow for a specific exception for quantities up to 30 L/30 kg through a new special provision. The UK did not feel end use should have an impact packaging or classification. Spain believed that the continued use of additives that EHS in paints and coatings are the root of the problem and they did not believe such materials should be treated differently than other EHS materials. The US opined that solutions should be sought at the regional or state level. But they were open to considering modifications to the packing provisions. Belgium did not believe the problem is as significant as described in the paper adding some of the situations described are already excepted from regional regulations. Canada supported the proposal in principle but preferred to make changes to SP375 instead. They also felt that an exception to UN specification packaging for EHS materials up to 30 L/30 kg may be acceptable. Based on the discussion, WCC withdrew the proposal. No proposals were adopted.
2022/64 (China) Fire test required in special provisions 283 and 371 – China proposed modifications to SP371 and SP283 to detail the requirements for the fire test used in these special provisions. The US, Canada, COSTHA, the Netherlands and Belgium supported the proposal for SP371. However, all delegations wished for additional time to consider the proposals to change SP283. Based on the discussion, the Subcommittee adopted the proposal for SP371 but withdrew the proposal in SP283.
INF.11 (Spain) Fire test required in special provisions 283 and 371 – While reviewing 2022/64 for the UN discussion, Spain recognized the term “to rocket” in Spanish translates as either “start to move like a rocket” or “break like a rocket”. To clarify the intent of the term is “start to move like a rocket”, Spain suggested text for the Spanish version of the Model Regulations. The Secretariat indicated they could make the change as they move through the translations of the next version of the regulations. Brazil supported. Based on the discussion, the Subcommittee adopted the proposal in INF.11.
2022/65 (China) Amendment to 188.8.131.52 of the Model Regulations – China suggested that the word “and” should be removed from 184.108.40.206 as the current list of proper shipping names does not include a situation where more than one proper shipping name includes the word “and” as an option. Further, the logic of providing two or more names at the same time for documentation or marking is faulty. Canada, Spain, and Belgium supported the proposal. Based on the discussion, the Subcommittee adopted the proposal as drafted.
2022/67 (China); INF.25 (Spain) Proposals for polyester resin kit – China pointed out inconsistencies in the application of packing groups to POLYESTER RESIN KITs (UN3269 and UN3527). They believed that POLYESTER RESIN KITS should be treated the same as CHEMICAL KITS and therefore proposed deleting the packing group options and modify the text of SP236 to detail how to determine the appropriate packing group to be assigned. They also pointed out the limited quantity amounts per package were inconsistent with the Guiding Principles, suggesting that the maximum per inner packaging should be limited to 1L/1Kg based on a possible PG II determination. In INF.25, Spain explained that in 2015, the Subcommittee agreed to increase the limit to 5L/5kg. They offered alternative text to the SP236 proposed language in 2022/67. The US supported the explanation by Spain of the Guiding Principle language and noted they were not inclined to reverse the previous decision based on the language in the paper, and preferred to leave the text as is. Canada did not support the proposals in either 2022/67 or INF.25. Belgium and Brazil agreed with previous speakers. DGAC shared that the original proposal was based on existing industry practice, but noted that there are several other entries that are also afforded a greater LQ value. They agreed with previous speakers that the text should remain unchanged. Based on the discussion, China withdrew the proposal. No proposals were adopted.
2022/68 (Netherlands); 2022/72 (Cefic, DGAC); INF.19 (Netherlands); INF.21 (Cefic, DGAC) Revision of the classification of tetramethylammonium hydroxide – The Netherlands proposed creating a PG I option for TETERAMETHYLAMMONIUM HYDROXIDE SOLUTION (TMAH) with a percentage of 8.75% as a threshold as well as indicating a toxic primary hazard for PG I and PG II mixtures. Further, they introduced percentages for determination of PG II and III. In 2022/72 and INF.21, DGAC acknowledged that mixtures of this material do represent a toxic hazard. However, they did not believe the percentages proposed in 2022/68 were appropriate they also argued that classification should be based on human experience, but the Model Regulations do not give guidance for PG determination on human experience. Instead, the Model Regulations are based on animal testing. They proposed alternate concentrations. In INF.19, the Netherlands discussed when data between human experience and animal testing should be used. In their opinion, when human experience is available, it must take precedence over animal testing data and added the animal testing data referenced in 2022/68 did not meet the provisions of the Model Regulations. They requested the Subcommittee discuss whether animal testing data should be considered when human experience is available. Spain fully supported the discussion in INF.19 stating that human experience must take precedence over any animal testing and supported the proposals in 2022/68. The US supported the proposal in Option 1 of INF.21. They noted in their review of fatalities involving TMAH, the data showed the vast majority occurred as a result of TMAH concentrations greater than 25%. Canada disagreed and preferred to the more conservative approach offered in 2022/68. Japan supported Option 2 in INF.21. Germany acknowledged the arguments on both sides and encouraged additional testing. Belgium supported Options 1 or 2 in INF.21. Given the significantly divided Subcommittee, the Chairman recommended the topic be discussed informally at the end of Day 2, and the papers be considered for adoption later in the week. The Subcommittee agreed. No proposals were adopted but will be considered later in the session.
2022/70 (IATA); INF.45 (UK) Assignment of a new UN number to lithium battery powered vehicles – After discussing the topic in previous sessions, IATA proposed the adoption of a new entry for vehicles powered by lithium ion or sodium ion batteries. They also included a new packing instruction that provides a packaging exception for vehicles with a net mass >30 kg. In INF.45, the UK recognized the power system of the vehicle should be reflected in the proper shipping name. As a result, they proposed 2 options, either a single NOS entry or 3 new entries with different proper shipping names, but following the same logic as presented in 2022/70. The US supported both proposals and suggested additional discussion could be had in an informal discussion. France supported the proposals in 2022/70 but would also support the modification in proposal 1 of INF.45. They also opined the last sentence of SP360 should be included in the new packing instruction at the end of the first paragraph. China recommended several revisions to 2022/70 to explain how to navigate new entry and existing entries. Sweden preferred the entries be treated as articles and require marking per 220.127.116.11 on the packaging, handling device, or article itself. Germany wanted to add clarity as to how vehicles being shipped for disposal or recycling would apply to these provisions. Discussions on this topic will be completed on Day 3. No proposals were adopted.