The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 65th Session November 25 through December 4, 2024 in Geneva, Switzerland. There are 54 formal and 50 informal papers submitted for discussion as of Day 1. This session is the fourth 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 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 1 – Discussion of Papers
INF.27 (Secretariat) Reception by NGO’s – SAAMI invited interested delegations to attend the Annual NGO reception following the Plenary session on Day 2. All parties were invited. No proposals were considered.
2024/58; INF.36 (Secretariat); INF.29 (Germany) Consolidated list of draft amendments – The Secretariat shared the draft amendments to the 23rd Revised Edition of the Model Regulations. A number of editorial amendments were shared by delegations verbally. INF.36 addressed additional changes to the 2.6 that were discovered by the Secretariat during final reviews. INF.29 from Germany addressed modifications on the Chlorophenol entries. All provisions were adopted and square brackets in 2024/58, INF.36 and INF.29 were removed as amended during the discussion.
2024/103; INF.34 (United Kingdom, United States of America); INF.40 (Germany) Proposed changes to the Koenen test specifications – The US and UK pointed out the steel referenced in the Koenen Test is no longer available. Over the past 2 years, a correspondence group reviewed possible solutions and consequential amendments. Proposals referencing alternate sheet steel as well as additional changes to the Koenen Test were included in 2024/103 as well as a track-changes version in INF.34. In INF.40, Germany noted that the thickness referenced would result in a failure of many of the cylinders currently used. They also preferred the test be described in a more general manner, and noted the pressure rate is inconsistent with current test observations. They supported the paper but requested the proposals in 2024/103 be referred to the Energetics Working Group during the next biennium. CEFIC shared that the tubes come from two different suppliers in the EU and both confirmed they meet the 0.5 mm thickness requirement. The Netherlands and SAAMI supported the discussion and finding a solution during the current biennium. The US explained that all three issues mentioned in INF.40 would be addressed in a further INF to be submitted later in the 65th Session. The Subcommittee indicated they would review the revised proposals when the new INF paper is available. No proposals were adopted
INF.23 (Cefic) Alternative polyethylene foam for the safe transport of small amounts of energetic samples according to PP95 of Packing Instruction P520 – CEFIC explained that many energetic samples are packed under PP95 using polyethylene foam with a certain density. However, referenced foam is no longer commercially available. They proposed an interim solution by allowing a higher density foam and further indicated they would return in the next biennium with a more comprehensive solution. The US, Germany, France, the Netherlands, and the UK supported the proposal in INF.23. The UK suggested including a maximum foam density. The Subcommittee suggested alternate language. Based on the discussion, the Subcommittee agreed to the proposal as drafted in INF.23.
2024/60 (Chair of the Working Group on Explosives) Proposal to change the name of the Working Group on Explosives into the Working Group on Energetics – The UK noted that the Explosives Working Group addresses materials that are not explosives but would be considered Energetic. Therefore, they proposed to change the name of the Working Group to the Energetics Working Group. The Secretariat noted that the Explosives Working Group was originally recognized by ECOSOC in 1959 but was then incorporated in 1989 into the TDG Subcommittee as an Informal Working Group. Therefore, there are no issues from ECOSOC that would prevent the name change. CEFIC the Netherlands, and SAAMI supported the change. The Netherlands reminded the Subcommittee that the EWG works with most of the tests in the Manual of Tests and Criteria. Based on the discussion, the proposal was adopted.
2024/94; INF.6 (China on behalf of the informal correspondence group) Report of the informal correspondence group on the revision of subsection 51.4 of the Manual of Tests and Criteria regarding the burning rate – Based on discussions from previous sessions and a correspondence group, China proposed a number of changes to 51.4 of the Manual of Tests and Criteria. The full text of 51.4 were reproduced in INF.6. The Netherlands, Germany, and the US supported the proposal. The Secretariat added some editorial amendments. Based on the discussion, the Subcommittee adopted the proposals as drafted.
2024/93; INF.10 (United States of America) Consideration of nitrocellulose mixtures in chapter 2.17 (Desensitized explosives) of the Globally Harmonized System, Section 51 of the Manual of Tests and Criteria and special provision 393 of the Model Regulations – The US offered revised text to address nitrocellulose mixtures. 2024/93 is a replication of proposals previously presented to the GHS and detailed required amendments to the UN Manual and Model Regulations. The US indicated that the proposal in Paragraph 7 was withdrawn. INF.10 contained additional clarification addressing the testing of dry or unmodified nitrocellulose. The Netherlands and UK supported the proposals in both documents. 2024/93, paragraphs 3, 4, and 5 were recommended to the GHS. Paragraph 6 was adopted as amended by INF.10. Paragraph 7 was withdrawn.
INF.21 (United Kingdom) Classification of thermites and thermite containing articles – The UK has discovered a number of examples where thermites and modified thermites were offered as Div. 4.2 materials or as deregulated. It was noted that there appeared to be confusion between competent authorities and industry as to how thermites should be classified under the Model Regulations. The UK offered to chair a correspondence working group on the topic. The Netherlands acknowledged that a large amount of thermites are not subject to regulation, however they were supportive of further research. Spain, China, and the US agreed with the Netherlands. The Subcommittee supported the formation of an intersessional correspondence group to review the topic. Interested delegations were encouraged to contact the UK. No additional proposals were considered.
2024/68 (SAAMI) New definition for single packagings – SAAMI proposed to include a definition of “single packaging” in the Model Regulations, noting that although used extensively, the term is not currently defined. They also pointed out that Packing Instructions 130 and 132 would have consequential amendments. Sweden, Belgium, Austria, Australia, Spain, the US, and the UK supported Proposal 1, Option 1 and Proposal 2. Germany and China offered slightly modified language to Proposal 1 suggesting that the definition should prohibit the use of inner packagings in single packagings, and suggested P130 and P132 should be reformatted. DGAC argued that the language proposed by Germany and China was an over-reach. SAAMI indicated they would develop an INF paper on proposal 2 for review later in the session. Based on the discussion, the Subcommittee agreed to Proposal 1, Option 1.
2024/73; INF.5 (Germany) Transport of liquid organic hydrogen carriers – new special provision to UN 3082 – Germany proposed adding a special provision to UN3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. to clarify that the entry cannot be used for liquids that contain more than 0.5 L(H2)/kg(LOHC). In INF.5, Germany shared additional research on LOHC and the limit proposed. Spain, Finland, the US, and supported the proposal. The US suggested to reword to be in a permissive language vs. a prohibition. Belgium provided additional editorial suggestions. China opined that a chemical-specific special provision assigned to a generic entry may not be appropriate and may not guide a reader to the provision. Canada preferred to take a more directed approach and develop additional guidance on the topic. Austria supported the proposal. Australia and the UK supported comments from China and preferred to see a new UN entry. France questioned whether the packagings authorized have been tested for increased pressures that would result from the Special Provision. Germany did not believe the proposal was component specific and preferred to keep it general and apply to many different LOHCs. But they also shared that if an LOHC is currently listed in the table separately, that entry should be applied. They agreed to revise the proposal to be a positive limit as suggested by the US. France pointed out that the packing instructions authorized for UN3082 may not be appropriate given the LOHC and possible resulting pressure. The US and Germany opined that gas would not be an issue at the proposed concentration. Based on the discussion, the Subcommittee agreed to the text as amended.
2024/75 (COSTHA) Used medical devices containing or packed with lithium batteries – COSTHA proposed revisions to the Used Medical Device exception in 2.6.3.2.3.9 to permit the inclusion of lithium or sodium ion batteries. The revised text would require such devices to be prepared in accordance with relevant provisions to lithium or sodium ion batteries. Canada supported the document but added editorial amendments. They preferred the alternate language in paragraph 4. China, Belgium, Australia, the US, MDTC and Sweden supported the proposal as amended by Canada and agreed with paragraph 4. China further questioned whether used batteries should be further evaluated before being shipped. Austria preferred to split the lithium battery exception to a separate paragraph. Belgium recommended to refer to cells and batteries in all locations. Based on the discussion, COSTHA agreed to draft an INF paper with the revised text to be considered later in the session. No proposals were adopted.
2024/86 (China) Amendment to 2.0.2.7 – China the text in 2.0.2.7 that refers to “one or more substances”, pointing out that if there is only a single substance, it should be described as the listed entry. Germany, Spain, and Sweden supported to review the text. Both Germany and the Secretariat offered alternate language. Austria supported the option offered by Germany. The US supported the simplified version in paragraph 6 as it would not result in a change to the intent of the original language. France and the Netherlands agreed with the US. China agreed with commentors that paragraph 6 would be preferred and asked the Chairman for a decision on this proposal. By a majority vote, the Subcommittee agreed to the proposal in paragraph 6.
End of Day 1
–COSTHA
