The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 63rd Session November 27-December 6, 2023, in Geneva, Switzerland. There are 26 formal and 42 informal papers submitted for discussion as of Day 1. This session is the second of four sessions during the 2023-2024 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 what 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
The Subcommittee took note that Claude Pfauvadel from France will be stepping down from the Vice Chairman position. A new Vice Chairman will be identified on the morning of Day 5.
INF.33 (Secretariat) Reception by NGO’s – The planned NGO reception will be held after the meeting on Day 2. Retiring delegates will be recognized.
INF.16 (Germany); INF.32 (SAAMI) Bursting pressure test method for Koenen steel tubes – Germany explained the Koenen test used for determining bursting pressure in explosives has been around for approximately 70 years. However, the original tubes used for the tests are no longer available, and additional testing indicated that burst pressures for newer tubes showed significant differences. They questioned whether additional clarification is needed for the test given the new materials. In INF.32, SAAMI explained that since 2017, the alloys for the original tubes are not available. As a result, the UK and US initiated a Round-Robin testing program that includes 13 participating organizations. Once the effort is completed, recommendations will be presented to the Subcommittee. The Netherlands, France, the UK, AESIG, and the US shared support for both approaches and commented that comparative testing will be necessary once the UK/US initiative is completed. CEFIC added they would submit additional proposals on the topic to address high and low explosive materials. Germany felt it was important to determine the proper testing necessary before conducting actual testing. The Subcommittee generally agreed that the Koenen Test should be reviewed and requested interested delegations to submit comments and proposals to the 64th Session and the Explosives Working Group. No proposals were considered.
INF.20 (Cefic) Transport of energetic samples – CEFIC noted the need for a default system to transport small quantities of energetic materials for testing. They proposed allowing materials identified in Appendix 6 of the UN Manual of Tests and Criteria to be assigned an entry as a self-reactive substance Type C for testing but also require limited additional testing. The US, Spain, Germany, and the Netherlands generally supported the approach but cautioned that the proposal does not limit the amount of materials that could be shipped under this proposal. The Netherlands felt the approach was pragmatic and the values proposed were conservative. Based on the comments, CEFIC indicated they would submit a revised proposal for the 64th Session for consideration by the Explosives Working Group. No proposals were adopted.
2023/47 (SAAMI) Including an acceptable level of risk in classification criteria – SAAMI argued the regulations are written to reduce risk in transport. But in many areas, the Subcommittee operates as if risk must be reduced to zero. Risk must be managed but if it is not acknowledged by the Subcommittee, impractical approaches result. COSTHA supported the effort. France pointed out the Guiding Principles already address risk to some extent and state that risk should be eliminated or reduced to the absolute minimum. But they also noted the approaches to Class 3 or Class 8 are different than Class 1, and regional authorities may add additional restrictions based on a belief that the regulations are not restrictive enough. The US shared that in the introduction to the Guiding Principles (section 0), the proposal suggested by SAAMI already exists. Both France and the US opined the Subcommittee has the responsibility to evolve the regulations to meet new technologies and a dynamic state of the art. The UK also supported the discussion. They preferred not to include references to acceptable injury levels as are included in GHS. But they questioned whether a system could be adopted for competent authorities to measure whether risk had been reduced to the extent possible. The Netherlands and Spain felt the language in the Guiding Principles was adequate and that the goal is minimal risk, not zero risk. France noted the EU has posted documents on measuring risk in regulations. They are not specific to dangerous goods. SAAMI indicated they may return at a future session with a revised proposal. No proposals were considered.
2023/49 (COSTHA) Introduction of New Entries for QDO – Test reports for support – COSTHA proposed 2 new entries for 1,4-benzoquinone dioxime, a 1.4C and a 4.1 desensitized explosive. The US supported the proposal in principle but questioned the use of PG II vs. PG I, and further suggested that the phlegmatizer and concentration range should be referenced. They recommended a revised proposal be discussed at the Explosives Working Group at the next session. Sweden supported the Class 1 entry but questioned the need for the 4.1 entry. Belgium did not believe SP XYZ is necessary and recommended simply referring to SP28. They also suggested the list of desensitized explosives should be updated. SAAMI pointed out that the phlegmatizer would likely be included in any testing approval. Therefore, if a testing approval is provided, the phlegmatizer would be listed. COSTHA explained that other 4.1 desensitized explosives are assigned PG II and therefore it would be inconsistent to assign PG I. They further agreed to consider the inclusion of the phlegmatizer in the 4.1 entry. COSTHA indicated they would return at the 64th Session with a revised proposal. No proposals were adopted.
2023/51 (Spain) Net explosive weight – Spain proposed to remove the term “net explosive weight” from the definition of net explosive mass noting that weight and mass are two different terms. Poland, Austria, Belgium, and Canada supported the proposal. The US pointed out the existing definition was crafted specifically to explain the practical use of the term and removing it would likely lead to confusion in industry. They did not support the proposal. AESIG pointed out that there are other units, such as pressure, where a common or regional term is used. The Chairman noted the Explosives Working Group previously did not support the proposal. By a majority vote, the proposal in 2023/51 was adopted.
INF.42 (Cefic) Screening procedures for estimating the SADT of 50 kg packages – CEFIC pointed out challenges with determining the SADT for packages of 50 kg when the SADT is above 75 oC. They presented a method that could be used. No comments were made. CEFIC indicated they would be submitting a formal proposal at the next session and requested interested delegations to provide comments before the next session. No proposals were adopted.
INF.30 (WHO) Improvements to the utilization and classification of the indicative list of Category A infectious substances – WHO pointed out the recent outbreak of Monkeypox has led to a need to update the indicative list of Category A infectious substances at a higher frequency. They proposed the UN Model Regulations include a reference to the WHO official website where the indicative list may be updated rapidly. The US pointed out the list in the Model Regulations is indicative, not an unfailing list. They were not comfortable with removing the list and providing only a reference to the WHO website, but they agreed that it should be communicated as to how the list is to be used. Belgium, Canada, Spain, FAO, and France agreed with the US, and Canada provided possible language that could be added to the introduction to the indicative list. The topic was referred to the lunchtime WG on infectious substances on Day 3.
2023/48 (COSTHA, DGTA, FAO); INF.23 (COSTHA, DGTA, FAO) Infectious substance transport – COSTHA, DGTA, and FAO, with support of WHO proposed a lunchtime working group to discuss a list of potential challenges with the existing infectious substance regulations. INF.23 provided additional details on each of the topics. The Subcommittee was supportive of the session on Day 3. COSTHA will chair a lunchtime Working Group on Infectious Substances as outlined in INF.23.
2023/45 (Russian Federation on behalf of informal working group) New sub-chapter 6.9.3 “Requirements for design, construction, inspection and testing of fibre reinforced plastic (FRP) service equipment for portable tanks” and new section 42 “Fire resistance test of FRP service equipment for portable tanks” for the Manual of Test and Criteria – The Russian Federation shared the results of the informal working group on FRP service equipment from the last session. They received additional comments from several delegations and requested a parallel session on Day 2 and 3 to discuss. Australia, the US, and the UK shared additional concerns over the proposals but supported the additional discussion. The FRP Working Group will report on their discussions on Day 4.
2023/32 (WLPGA); INF.12 (WLPGA) Present and future products in the LPG industry – proposal for a new UN number – WLPGA explained that as part of the decarbonization in the LPG industry, the inclusion of dimethyl ether (DME) is a key addition. The higher the DME concentration, the higher the decarbonization percentage. So, this is a growing trend. To provide clear information to emergency responders, they proposed introducing a new entry “Hydrocarbon and Dimethyl Ether Gas Mixtures, Liquified”. INF.12 provided revised proposals based on feedback from delegations prior to the session. The UK and Canada were in general support of adopting a new entry, but not for the reasons provided. The US explained that they would expect to see additional packaging requirements between the new or existing entry but that was not included in the proposal. Belgium provided several consequential amendments that would also be necessary. Spain shared that their industry was not supportive of the approach. Based on the discussion, a lunchtime work group will be held on Day 2 to discuss the proposal further.
2023/33 (Germany) Adequate UN entry for 2,4-Dichlorophenol with a possible solution for all chlorophenols – Germany noted that 2,4-dichlorophenol represents both a toxic and corrosive hazard. Yet, the existing entries for chlorophenols, liquid and chlorophenols, solid are assigned only a 6.1 hazard. They proposed two options: 1) add a special provision that requires the appropriate N.O.S. entry be used when 2,4-dichlorophenol is offered for transport, or 2) introduce two new entries representing the corrosive and toxic hazards. Spain preferred Option 2 but questioned the IBC packing instruction. Canada also supported Option 2 and asked why similar entries were not proposed for the liquid entries. China preferred to make minimal changes to the entry, and thus preferred Option 1. They also identified other entries where similar problems arise, and suggested the Subcommittee find a more comprehensive solution. CEFIC and the US supported Option 1. Sweden, Austria, and France preferred Option 2. The UK voiced support for the principle but stated that both options needed additional work. The discussion ended for the day, and the paper will be concluded on Day 2.
End of Day 1
