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 59 informal papers submitted for discussion as of Day 6 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 6 – Discussion of Papers
INF.12 (Secretariat); INF.12/Rev.1 (Secretariat) Draft Resolution 2023/… of the Economic and Social Council – The Chairman noted a revised paragraph from Spain had been added to the Draft Resolution in INF.12/Rev.1. The paper was not discussed at length but introduced so delegations could comment on the draft when necessary. The proposal was supported as drafted in INF.12/Rev.1
2022/48 (Germany) Some issues arising from GHS work on combinations of physical hazards – Germany shared challenges identified in the informal working group on combinations of physical hazards. Many times problems and odd interpretations are created by notes that are not part of the required text. They further questioned whether some situations addressed by notes would actually exist. The paper listed the following issues. Subcommittee comments to the proposals are included for each:
- Aerosols – The Netherlands and the US explained that the intent of the Note to SP63 is to prohibit pyrophoric, self-heating or water-reactive substances and mixtures in aerosols.
- Chemicals under pressure – The Netherlands shared in their opinion the items prohibited in SP362 may also be appropriate to apply to SP63.
- Test C.1 for corrosives to metals – The US explained the test is to determine the ability to corrode steel or aluminum if it is released from the packaging. If a material were corrosive to steel or aluminum but not identified as a dangerous good, it may not be cleaned as well as if it were recognized as corrosive. The Netherlands further explained that this test is also used for testing compatibility within portable tanks. Compatibility with packaging and plastics are handled separately. DGAC confirmed their understanding the provisions were adopted to address spills in conveyances. CEFIC also confirmed Test C.1 was not intended to include gases, only solids and liquids.
- Self reactives and organic peroxides – Delegates discussed the benefit of revising the note in 2.8.2.2 and 2.15.2.2. The US explained the note was intended to be broad and may cover other hazard classes beyond just flammability. France and CEFIC believed in the context of GHS might be of benefit to point out other hazards such as toxic and corrosive hazards. The UK opined the Model Regulations already required a shipper to consider classification under other hazard classes and suggested the note should remain broad.
Based on the discussion, Germany indicated they would report back to the Informal Working Group on the topic and consider proposals for a future session. No proposals were considered.
2022/50 (Germany, United States of America); INF.4 (Germany and United States of America); INF.20 (AEISG); INF.42 (UK); INF.59 (Germany, USA) Amendments to the classification of desensitized explosives according to the GHS – Germany presented changes to be adopted in Chapter 2.17 of the GHS and Section 51 of the Manual of Tests and Criteria regarding desensitized explosives. They shared that there was no intention to make any substantive changes to transport conditions but only to introduce and clarify what exists in the Model Regulations. INF.4 included a clean version of the proposed text. In INF. 20, AEISG supported the proposals in 2022/50 but noted consequential amendments that would be required. AESIG and the UK supported addressing the problems identified in Issue 1 of INF.20 during the next biennium. The UK also supported the proposals in 2022/50 but provided suggested changes in INF.42 that also incorporated concerns raised by AEISG in INF.20. Their main concern addressed preventing a mass explosion for desensitized explosives by requiring certain tests within Test Series 3. Proposals in INF.42 that addressed concerns from INF.20 were differed to a future session. A revised INF.59 was developed incorporating all changes discussed. Based on the discussion, the proposals in INF.59 were adopted.
2022/52 (Germany, Chair of Working Group on Explosives) Flammable liquids: Open-cup and closed-cup testing for the flash point – Germany proposed to strongly encourage the use of closed cup testing methods for flash point determination and suggested changes to identify when open cup testing would be permitted. They added an amendment from Canada that would allow for existing open cup testing data if it was previously provided. The US supported the proposals but preferred to drop the word “strongly” as it is not commonly used in the Model Regulations. Belgium supported the proposal in principle but preferred the language be clearer that closed cup testing “shall” be used except in the cases noted. China was not supportive of the changes and felt a 5 oC was not enough of a correction. They preferred language presented at a the 60th Session, 2022/10. The US agreed with China that the current text in 2.3 of the Model Regulations is more precise. It was suggested that the value “5.6 oC” should be used. After further discussion, the Subcommittee agreed to delete the word “strongly”, revise the value to 5.6, and replace “or in case available data is used” with “or when open cup test data is already available.” With these modifications, the Subcommittee agreed to the proposal as amended. The proposals will be forwarded to the GHS Subcommittee with the Subcommittee’s endorsement.
INF.58 (RECHARGE, PRBA) Informal Working Group on reuse or repurpose of lithium batteries – PRBA and RECHARGE presented slides from a previous call discussing efforts to review terms of reference and provide definitions, best management practices, and regional regulations on the reuse and repurpose of lithium batteries that may lead to changes in the Model Regulations. The presentation was included in INF.58. In general, the group did not believe regulating through definitions was beneficial but saw the need to identify how to confirm reuse/repurposed cells/batteries remained in conformance with UN38.3, and identify if an additional test(s) would be necessary. The group will continue to meet in 2023 and will report back to the Subcommittee on progress. No proposals were considered
2022/66 (China); INF.44 (UK) Metal powders and powders of metal or metal alloys in Test N.1 – China believed the testing criteria for metal powders should be expanded to include metal alloy powders. They proposed language in the Manual of Tests and Criteria. In INF.44, the UK proposed an alternate method for the same issue but would only add a note instead of modifying significant text. The US and CEFIC agreed with China but preferred the UK approach. Based on the discussion, the Subcommittee agreed to the proposal in INF.44. The conclusion will be transmitted to the GHS Subcommittee for consideration.
INF.5 (Secretariat) Use of the terms “rated capacity”, “nominal energy” and “watt-hour rating” in the English, French and Spanish versions of the Model Regulations and the Manual of Tests and Criteria – The Secretariat identified inconsistent usage of the terms rated capacity, nominal energy and watt-hour rating across multiple languages. In an attempt to correct the issue, they proposed moving to the term “nominal energy” wherever “watt-hour rating” is used, and addressed using the International System of Units (SI) for watt-hours. They also proposed a number of similar changes in the French and Spanish versions. RECHARGE preferred to remain with Wh as it is a recognized energy unit in IEC standards globally. France was also cautious adopting the change as it may introduce confusion. IATA strongly opposed the proposal in English noting “Wh” is referenced in all transport texts and even regional regulations. The US and PRBA shared the same opinion as others and believed that changing the terms would lead to significant confusion. Belgium commented they originally supported the proposal to move to SI units. However, they recognized the change may have unintended consequences. They generally supported the remaining proposals in the document. Spain supported deleting “watt-hour rating” and move to “nominal energy”. Germany preferred to use the term “nominal energy”. Canada aligned their comments with Belgium. The Subcommittee indicated general support for several proposals in the paper. The Subcommittee was divided on changes to the English and French version changes. But there was general support for the Spanish edits as well as modification to the formula in proposal 6. Given the proposals were contained in an informal paper, the Secretariat agreed to return with a revised proposal in a future session. No proposals were adopted.
INF.37 (China) Transport provisions for composite batteries consisting of both lithium ion cells and sodium ion cells – China pointed out new industry research is leading to batteries that use both lithium ion and sodium ion battery technologies. China suggested when this occurs, the transport conditions should be in accordance with those for lithium ion batteries. France agreed with the approach. The US pointed to special provision 387 that addresses hybrid lithium metal/lithium ion batteries. They believed a solution would be to create a special provision similar to SP387 to address the transport conditions as well as testing conditions. Based on the discussion, China indicated they would return with a revised proposal at a future session. No proposals were considered.
INF.38 (China) Amendments to labelling requirements of packages in the UN Model Regulations – China proposed requiring an enlarged lithium battery Class 9 label (Model 9A) for packagings having a capacity of greater than 3m3. The label would have a minimum dimension of 250mm x 250mm. The US supported the principle of what was being proposed, but noted it would have significant consequences that goes beyond just lithium batteries. Sweden agreed with the US and requested the Subcommittee discuss the topic at a future session. The UK was not in favor of increasing the size of the labels but would accept a compromise to add additional labels opposite sides of the package similar to labeling for IBCs. China indicted they would return with a revised proposal at a future session. No proposals were adopted.
INF.32 (China) Amendment of Section 51.4.4.2 (e) of the Manual of Tests and Criteria – China believed there was an error in paragraph 51.4.4.2(e). They proposed a modification to address the error. Spain, CEFIC, and the US supported the proposal but requested the paper be considered formally. China indicted they would return with a revised proposal at a future session. No proposals were adopted.
INF.33 (China) Suggestions for adjusting test temperatures of UN Test 3(c) and UN Test 4(b) – China noted that as climate changes, the maximum temperatures encountered in transport are also increasing. UN Test 3(c) and 4(a) uses a test temperature of 75 oC. They suggested increasing the test temperature to 85 oC. CEFIC pointed out the paper is discussing melting temperatures of the explosive, but is proposing changes to decomposition tests. They felt the solution does not address the problem. DGAC suggested the Explosives Working Group should review the proposal. China indicted they would return with a revised proposal at a future session. No proposals were adopted.
INF.34 (Germany) Refrigerating machines and heat pumps – Germany pointed out heat pumps operate on the same principle as refrigeration machines. Therefore they believed the exceptions provided for refrigeration machines could be applied to heat pump systems. They proposed adding a note to special provisions 119 and 291. Sweden, France, Belgium, and the US supported the proposal but preferred to add a new proper shipping name instead. IATA supported the proposal as drafted. The UK suggested adding an entry in the index that referred to the UN entries for refrigeration machines. Germany indicted they would return with a revised proposal at a future session. No proposals were adopted.
INF.35 (China) Transport classification of diesel fuel – China asked for clarity as to whether diesel fuel with a flashpoint above 60 oC should be regulated as a Class 3. If so, they proposed adding SP 223 to UN1202 DIESEL FUEL. France shared that China was misinterpreting the ADR and materials greater than 60 oC would not be subject to the ADR, but added that the petroleum industry agreed that if diesel fuel batches had flashpoints immediately above 60 oC, they may still be included UN1202. The US also confirmed their understanding that if the flashpoint of the material were above 60 oC, the material would not be regulated as an entry. RPMASA shared that if diesel fuel with a high flashpoint could be deregulated, that would support the issue that they had raised regarding the Ukraine and the use of flexitanks at the last session. China indicted they would return with a revised proposal at a future session. No proposals were adopted.
INF.40 (CLEPA) Amendment to packing instructions P902 and LP902 – CLEPA pointed out many interpret the requirement for packagings for safety devices in P902 to meet the requirements of PG III, but not allow PG II or PG I packaging. They proposed modified language to clarify higher level packaging may be used. The US, France, Belgium and the UK did not feel the language was necessary but agreed they could be used. COSTHA supported clarification of the text and agreed with CLEPA that additional wording would be necessary. CLEPA indicated they would return with a revised proposal at a future session. No proposals were adopted.
INF.55 (RPMASA) Progress report on South Africa’s Dangerous Goods Supply Chain Task Group (DGSC-TG), providing a positive impact on implementation of the UN Model Regulations, as well as Dangerous Goods Training & Capacity building – RPMASA updated the Subcommittee on regulatory efforts in South Africa’s Dangerous Goods Supply Chain Task Group. Developed in response to the 2020 Beirut incident, the Task Force is a cooperative effort between Regulators and Industry experts and includes 5 working groups to address various aspects of supply chain compliance. The group has expanded from Classes 1 and 5.1 to include other hazard classes. The group has identified gaps to be addressed including harmonization with international standards and adopting training requirements. Future efforts include sharing developed resources and best management practices with other States, and researching actions taken by others that could be further incorporated into the DGSC-TG efforts. No proposals were considered.
End of the Discussion of Papers at the 61st Session
