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 3. 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.
2022/70 (IATA); INF.45 (UK) Assignment of a new UN number to lithium battery powered vehicles – The Subcommittee continued discussion of the new entry for lithium ion and sodium ion battery powered vehicles. IATA noted that based on the discussion from Day 2, they will prepare an INF paper incorporating the comments for review later during this session. A new proposal will be considered later in the session
2022/73 (COSTHA) Fire suppression devices that contain a pyrotechnic material – COSTHA proposed two new entries for fire suppressant dispersion devices, Class 1.4S and Class 9 options. The proposal took into account previous discussions and comments from the Subcommittee, and included a special provision to distinguish between the two options. France supported the paper, noting that since COSTHA originally brought the topic forward, many new systems have been introduced on the market. They described a few different types of systems, and the differences between them. France added that if these devices were installed in a vehicle, the may be considered as a UN3268 SAFETY DEVICES. Further, they offered some revisions to the proposed special provision. Finland also supported the proposal noting their previous concerns were addressed. Spain was not convinced the classification system presented was clear and preferred to further develop the concept. They also wished to see the proposal address potential other dangerous goods generated by the devices. Finally, they questioned the use of the term “normally occupied spaces”. AEISG preferred to use the term “suppressant” and supported the proposal. Sweden, Germany, Belgium, and the UK agreed with Spain voicing opposition. Specifically, the UK felt materials expelled from the devices should be addressed for toxicity, etc. They also commented the maximum temperature on the outside of the package should not exceed 100 C and questioned why Test 6(a) and 6(b) should be excluded. The US supported the proposal and pointed out the Class 9 option is not a deregulation and added additional safety measures that would not be required otherwise. Canada supported the proposal but indicated the Class 9 entry should require packing instruction P902. France, SAAMI, and the US disagreed with some delegations that argued the proposal violated the principles of classification. They pointed out the proposal includes a number safety measures that far exceed what is necessary for 1.4S transportation. SAAMI reiterated the difficulties with transporting explosives and opined that devices that meet the additional measures detailed in the special provision should not be impacted by those difficulties. Following an informal session, COSTHA indicated they would prepare an INF paper to incorporate discussed changes to the proposal.
2022/76 (Secretariat); INF.3 (Secretariat) Amendments to packing instructions – The Secretariat proposed modifications to various packing instructions to address inconsistencies and formatting. The full details of the changes were identified in INF.3. In proposal 4, the Secretariat questioned whether the mass reference in P520 was a net or gross mass. CEFIC, the US, and Belgium replied that they believed it was a net mass. The Subcommittee adopted the provisions as presented in INF.3 with minor amendments
2022/77 (Secretariat) Portable tank instructions and portable tank special provisions (follow-up to ST/SG/AC.10/C.3/2022/39) – The Secretariat proposed deletion of TP1 to UN0331 and modifications to the Guiding Principles to explain why there remains unused portable tank instructions in the Model Regulations. Proposal 2 to delete TP31 from UN1381 and UN1422 was withdrawn from consideration. Spain supported the proposal but suggested that TP31 should still be removed from UN1422. Given the Secretariat had withdrawn Proposal 2, the Subcommittee agreed to Proposals 1 and 3, but did not consider Proposal 2.
2022/68 (Netherlands); 2022/72 (Cefic, DGAC); INF.19 (Netherlands); INF.21 (Cefic, DGAC) Revision of the classification of tetramethylammonium hydroxide – Belgium updated the Subcommittee on the informal discussion on Day 2. The group agreed that human experience should take precedence in classification, but when animal testing is also available, it should also be considered even if the data is not specifically recognized by UN provisions. Belgium noted that the authors of the two papers would be preparing an INF paper for consideration later in the session. No proposals were considered.
2022/58 (Cefic); 2022/63 (China); INF.6 (Cefic); INF.46 (UK); INF.48 (CEFIC) Assignment of Special Provision 28 to liquid desensitized explosives in the Dangerous Goods List of the Model Regulations INF.48 – Based on discussions on Day 1, CEFIC prepared a revised proposal in INF.48 to address the comments received. The Subcommittee agreed to the proposal as drafted in INF.48.
INF.9 (Germany) Adequate UN entry for 2,4-Dichlorophenol with possible solution for all chlorophenols – Germany pointed out that 2,4-Dichlorophenol is normally covered under the entries UN2020 or UN2021, CHLOROPHENOLS which is assigned a toxic hazard. However, this chemical also exhibits a corrosive hazard that other chlorophenols do not. They proposed several options to resolve the issue. Canada supported Option 3. They also pointed out the alphabetical listing would need to be revised to include all new UN listings. Belgium also supported Option 3. CEFIC requested additional time to review as it was unclear to them different formulations may be affected by the change. Based on the discussion, Germany indicated they would return with a revised proposal at a future session. No proposals were adopted.
2022/74 (COSTHA) Increase of the limited quantity volume for Division 2.2 compressed gases – COSTHA proposed increasing the limited quantity authorized amount for four (4) non-flammable, non-liquified gases. The provisions align with ADR Special Provision 653, although the mark designated in the ADR would be replaced in the Model Regulations by the LQ mark. Belgium supported the proposal but questioned whether the intent of the exception is for all surface transport or only ground. They also felt the Guiding Principles would need to be updated. Canada also supported but recommended deleting reference to 4.1.6 and “For Air Transport” as the Modal Bodies could make that decision. Spain preferred not to change the limited quantity amounts in column 7A. The Netherlands voiced concern for moving the materials by vessel and preferred to see a safety justification before adopting. Germany suggested adding a marking “Not for air transport”, and add an outer packaging. Further, they also felt the changes to Column 7A were not necessary. The Chairman pointed out shipments for air would still require full marks, labels, and documents. The US did not see the benefit of the provision and preferred it to be handled in a regional manner. Based on the discussion, COSTHA indicated they would draft an INF paper addressing the recommended changes for review later in the session.
INF.7 (ISO) Updated ISO standards in Class 2 – ISO proposed updates to 3 ISO standards:
- ISO 11119-1:2020 Gas cylinders – Design, construction and testing of refillable composite gas cylinders and tubes – Part 1: Hoop wrapped fiber reinforced composite gas cylinders and tubes up to 450 L
- ISO 11119-2:2020 Gas cylinders – Design, construction and testing of refillable composite gas cylinders and tubes – Part 2: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 L with load-sharing metal liners
- ISO 11119-3:2020 Gas cylinders – Design, construction and testing of refillable composite gas cylinders and tubes – Part 3: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 L with non-load-sharing metallic or non-metallic liners or without liners – Amendment 1
With minor editorial amendments, the Subcommittee agreed to the proposals as drafted
2022/60 (ISO) Updated ISO standards in Class 2 – ISO presented updates to 2 ISO Standards:
- ISO 9809-4:2021 Gas Cylinders – Design, construction and testing of refillable seamless steel gas cylinders and tubes – Part 4: Stainless steel cylinders with an Rm value of less than 1100 MPa.
- ISO 23826:2021 Gas Cylinders – Ball valves – Specification and testing.
After addressing various questions from participants, the Subcommittee adopted both proposals in 2022/60.
INF.41 Report of the intersessional working group on the pV product limit for pressure receptacles – Germany updated the Subcommittee on the continuing efforts to consider a maximum pV product for pressure receptacles. Several associations noted they are still reviewing with their members and collecting data on the impact. The included potential draft language for future consideration in an Annex to the document. The Chair of the group indicated they would hold an additional meeting before presenting the proposals at the 62nd Session. No proposals were considered.
2022/69 (ICPP, ICIBCA) Proposal to permit increased use of recycled plastics material to attain ECOSOC 2030 Goals; 2022/71 (Belgium) Amending the definition of recycled plastics material – ICPP noted that recent changes to regional regulations are forcing the increased use of recycled materials. This impacts the ability to source plastics for UN specification packaging manufactured from recycled plastic materials. To address the challenge, they proposed changes to the definition of Recycled Plastic Materials to provide additional flexibility in using recycled plastic materials. In 2022/71, Belgium addressed the same issue but offered two options to address the issue, noting the need to have a closed loop system to limit the “open source” of recycled plastics. Both authors indicated a strong need to adopt a solution at this session. They asked the Subcommittee to indicate whether a modification is supported, and then which option would be preferred. Germany supported Option 2 from 2022/71. Germany felt that using the proposal in 2022/69 would not provide for enough oversight for production testing. The Netherlands supported Option 1 in 2022/71 but noted that 2022/69 was very similar and recommended a blending of these two options. The UK opposed the proposal to expand recycled plastics to large packagings. The US supported the proposals by Belgium in 2022/71. France supported the effort and preferred Option 1 of 2022/71. Austria supported Option 2 of 2022/71 but would accept any of the options given. Luxembourg supported the 2022/69 proposal. Brazil preferred Option 2 of 2022/71. ICIBCA acknowledged delegations concerns over the term “industrial packagings” and that the use of the term in the proposals in 2022/69 might open the source of the materials to a broad range of packaging. But they shared that additional limitations in their proposal would require extensive knowledge of where the materials were being sourced. Germany added that if Option 1 of 2022/71 was adopted, they wished to see measures included that would permit competent authorities to conduct additional testing if they deem necessary. Belgium and IPCC indicated they would work together to develop an INF paper for review later in the session. No proposals were adopted.