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 4. 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 4 – Discussion of Papers
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 – Belgium chaired the discussion on this topic in an informal discussion on Day 3. They indicated that the group agreed a batch of recycled plastics must be a homogenous mixture. Further, recycled materials must come from mechanical recycling systems, not chemical. The group also discussed how to determine whether packagings marked with “REC” could be included in recycling sources. The group had mixed views on whether large packagings should be included, so the group decided to address at a later date. Based on the discussion, the Belgium and ICPP/ICIBCA will submit a revised INF paper for review later in the session.
2022/61 (United States of America) Transport of certain ALKALI METAL DISPERSIONS (UN 1391) and ALKALI METAL DISPERSIONS, FLAMMABLE (UN 3482) in portable tanks – The US discussed the growing transport needs of alkali metal dispersions, particularly in the development of lithium batteries. They proposed including tank provisions for UN1391 ALKALI METAL DISPERSION and UN3482 ALKALI METAL DISPERSION, FLAMMABLE, but added a note to prevent the use of portable tanks for caesium and rubidium. Sweden supported the proposal and suggested additional indicators to highlight the prohibition for the two reactive metal dispersions in Special Provision 182. China supported the effort but questioned why TP1 was assigned to UN3482 and asked if T1 and T7 should be added. They suggested limiting the approach to lithium metal dispersions only. Germany requested TP17 be added to indicate thermal insulation on the tanks must not be flammable. The UK opined T13 is the correct tank instruction. Canada requested more details on the expected vapor pressure f the dispersions and preferred to assign TP2 until that data could be reviewed. Based on the discussion, the US indicated they would discuss with interested delegations and the paper will be reviewed again later in the session.
2022/62 (Chair of the informal group for fibre reinforced plastic (FRP)); INF.49 (Russian Federation) 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 – Based on an informal discussion on Day 1, the Russian Federation proposed revised text in INF.49 regarding service equipment on FRP tanks. The UK voiced concerns about using metal service equipment on FRP tanks and felt that still needed consideration. The Netherlands and US agreed with the UK and felt additional work was needed prior to adoption of the provisions. Based on the comments, the Russian Federation indicated they would return
INF.26 (France); INF.28 (IMO) IMO draft amendments to 5.5.4 of the IMDG Code Informal document and Outcome of the eighth session of the Sub-Committee on Carriage of Cargoes and Containers – France wanted to bring attention to discussed provisions in the IMDG Code for inclusion in Amendment 42-24. Specifically, provisions for data loggers, tracking devices, and sensors that contain dangerous goods have been incorporated into a new Section 5.5.4. But they shared the text adopted is significantly different and more restrictive than what is found in the Model Regulations. They questioned whether some of these changes should be considered for inclusion in Part 1 of the Model Regulations. IMO and the Chair of the IMO Editorial and Technical Group (US) pointed out the provisions were not adopted yet by CCC but have only been discussed. The US did not feel there was a necessity to bring these provisions back to the UN at this point and much of the text would be specific to the sea mode only. DGAC agreed with the US and cautioned bringing modal specific provisions into the Model Regulations. France reiterated their opinion that the examples provided were general in nature and would be beneficial for other modes to consider. Spain agreed with France and noted that while there are sea specific provisions included, there are other more general provisions that may be beneficial for multimodal transport. Luxemburg questioned some of the language used in the proposal and pointed out interpretation problems. IVODGA agreed that it is beneficial for this body to consider changes by the modes so that multimodal movement could be facilitated. But like others, they preferred not to include these specific provisions in the Model Regulations. IATA pointed out ICAO has not adopted any provisions on these topics and are looking at focusing on lithium battery powered devices. AEISG saw benefit from considering the text referencing restrictions on containers with explosive gas atmospheres. A key point noted in the proposed text is the change in title of 5.5.4. IMO changed the text from “Dangerous in equipment in use or intended for use during transport” to “Devices containing dangerous goods, which are in use or intended for use during transport”. Spain stated that if IMO thinks that the wording needed to be changed, it should be changed or at least considered by all modes at the UN. If the titles are different, it implies there is something different and results in serious difficulties in translation services and interpretations. France indicated they would continue these discussions at the next IMO E&T meeting scheduled for Spring 2023 and would consider bringing a formal paper to the 62nd session. No proposals were adopted
INF.27 (Secretariat) Update of references to standards in the Manual of Tests and Criteria Informal document – The ADN Safety Committee requested the UN Secretariat to confirm several ISO reference updates that appeared to be outdated. The Subcommittee discussed that while this might be seen as an editorial amendment, they wished for the information to be confirmed by ISO and other delegations. The Secretariat indicated they would work with ISO to confirm the changes. No proposals were adopted.
INF.30 (USA) Interpretations of the Model Regulations – The US shared feedback from delegations on the concept of unified interpretations from the Subcommittee. They provided a couple of examples how this agenda item could be used and requested the Agenda item be continued in the next biennium. AESIG, COSTHA, France, and Belgium strongly supported the continued work item and encouraged delegations to consider how to use such a system and how decisions or conclusions would be communicated and documented. MDTC supported the effort and suggested the conclusions could be maintained in a database that was searchable. The Subcommittee supported the overall effort described in the paper, and indicated the topic would continue into the next biennium. No proposals were considered.
INF.31 (USA) Implementation of the Model Regulations – The US shared their efforts to develop a consolidated list of countries that have implemented the UN Model Regulations into their domestic provisions. In the document, they provided an interactive layered map that can be accessed through the PHMSA website. Spain pointed out that some of the information appears to be outdated or incomplete, even for Spain. They shared that the UN has a similar system on their website regarding contacts for competent authorities and packaging testing authorities. However, they shared that data there was also not complete or outdated. Spain encouraged delegations to share information and update both systems so that everyone would have access to the information. They acknowledged some countries are not willing to share such information. CEFIC encouraged a synchronized system for adopting the UN provisions to ensure global implementation. SAAMI pointed out the benefit of having information on domestic modal regulations. The UK noted the significant effort to maintain such a database, but also encouraged such lists to at least include the UN edition number that the domestic regulations have incorporated. COSTHA, CLEPA, and Brazil aligned their comments with SAAMI and the UK. Brazil also shared that these lists become not just information for industry but also for individual State governments that can use the information for developing future domestic regulations. The Secretariat shared that such information is also beneficial when updating ECOSOC on the progress and status of Dangerous Goods Transport globally. Mexico explained that they do not have a legal system to adopt the UN Model Regulations as a whole and must do it by updating individual domestic regulations, but that such resources were very beneficial. The US indicated they would continue the effort and encouraged delegations to submit information to the UN Secretariat and the US delegation so that the information could be updated. No proposals were considered.
2022/70 (IATA); INF.45 (UK); INF.51 (IATA) Assignment of a new UN number to lithium battery powered vehicles – IATA presented the results of discussions on the proposals to adopt a new UN number for lithium and sodium battery powered vehicles. IATA pointed out they had received comments about new vs. used vehicles. They shared that such a concept was beyond the scope of this paper and suggested that the UN address separately. Minor amendments were offered over the microphone. Spain questioned whether there was a reason to create two separate entries for lithium metal or lithium ion entries given the conditions for both remain the same. They were also concerned with the statement in the new special provision that requires a document for vehicles containing sodium ion batteries at a 0% state of charge. They preferred to delete the words “Not dangerous goods”. The US preferred to delete the documentation requirement in the special provision altogether. Belgium agreed with both Spain and the US. The UK shared that there are 3 different UN numbers for the battery types, and therefore it was logical to adopt three different UN numbers for the vehicles as well. Additional amendments were offered over the microphone. Based on the discussion, the Subcommittee adopted the provisions in INF.51 as amended.
INF.13 (Republic of Korea); INF.18 (EIGA) Addition of special packing provisions of P200 to the dangerous goods list – The Republic of Korea noted that Column 9 includes particular packing provisions that apply to various entries. However, gases do not indicate when a particular provision is listed for that gas in P200. They proposed that the particular provisions listed in P200 should be included in Column 9. In INF.18, EIGA offered an alternate solution to simply indicate “see P200” in column 9. The US indicated this would create a change to a significant number of entries and preferred not to adopt. Spain supported any efforts to improve the text, but they liked the solution offered in INF.18. Belgium and Germany were opposed to the proposal noting that industry commented to them that referring to two different locations would be challenging. And putting the entries in two locations would lead to revision challenges. Based on the discussion, the Republic of Korea indicated they would review comments and consider a proposal for a future session. No proposals were adopted.
INF.14 (Republic of Korea) Amendments to 2.0.3.1(g) footnote 3, 2.6.2.2.4.1 note and 2.8.2.4 on the precedence of hazard – The Republic of Korea wanted to clarify the precedence of hazards for materials of Class 8 but also representing an inhalation toxicity. They felt that the Note in 2.6.2.2.4.1 and 2.8.2.4 should be included directly in 2.6.2.2.4.1. They offered two options for a solution. Canada supported the intent of the proposal but felt it did not adequately address all situations covered in the Note. Germany believed the existing language was sufficient and preferred not to change text. As a possible solution, Germany offered the concept of a flow chart for clarity. The US preferred to address this during the next biennium. Spain agreed with Germany. Based on the discussion, the Republic of Korea indicated they would return with a revised proposal at a future session. No proposals were adopted.
INF.17 (China) Clarification of the objects to which the provisions in special provisions SP361 and SP372 apply – China noted confusion on the testing requirements for ultracapacitor modules when its component capacitors are not subject to the regulations according to SP361 or SP372. They asked the Subcommittee for an opinion on the topic. The US believed the text is clear. If a module is being considered, the module would need to be tested. No proposals were considered.
End of Day 4
