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 56 informal papers submitted for discussion as of Day 2. 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 2 – Discussion of Papers

2024/80; INF.48 (Germany) New entry for UN 2862 VANADIUM PENTOXIDE, non-fused form, with packing group II – Germany proposed to include a new PG II entry for UN2862 VANADIUM PENTOXIDE noting that data for inhalation hazards suggest a PG III designation may not be appropriate for all such products. They added clarifying text in lower case type in INF.48 but added that the SP reference was in error. Spain and China supported the proposal with editorial amendments. Australia supported INF.48, Proposal 1 but recommended a transitional period be contained in a TP reference. The US, the UK, Belgium, France, CEFIC, and Sweden also supported the proposal. Austria requested a longer transitional period (2030). The Secretariat questioned whether the PG III entry should have a converse statement (<10% respirable particles). Germany indicated they would prepare an INF paper for review later in the session to address the recommended changes and include the transitional period in a TP provision. No proposals were adopted.

2024/87 (China, Cefic) Listing of Artemisinin and derivatives in 2.5.3.2.4 – CEFIC and China proposed to update the listing for the organic peroxide Artemisinin and derivatives, an antimalaria drug developed by China. As a result, one listing would be removed and five (5) new listings would be added. The Netherlands, US, Sweden, the UK, Germany, and Belgium supported the proposals. Based on the discussion, the Subcommittee agreed to the proposals in 2024/87

2024/88 (China) Packing group assignment for flammable solids other than metal powders – China noted a number of practical challenges with conducting the classification tests for metal powders. For this reason, they suggested the Subcommittee consider modifying the test method and introducing a decision tree to aid in proper classification. They were not proposing any changes during this biennium but interested in support for the effort. The Netherlands agreed with the effort. Canada questioned whether the wording in the decision tree “Is the wetted zone test applicable?” should be “is the wetted zone test practical”. The UK suggested the extreme ranges should be used for classification, not the average. Belgium agreed with Canada. The US recommended the topic be discussed at the IGUS and then be reviewed by the Energetics Working Group. China indicated they would return with a proposal at a future session. No proposals were adopted.

2024/91 (China) Proposal to allow articles classified as UN 3363 to contain lithium batteries complying with special provision 188 – China suggested that SP301 appliable to UN3363 should be revised to recognize that articles under UN3363 might contain lithium batteries. They pointed out that the ARTICLES CONTAINING… entries require approvals to ship by air and have similar restrictions by sea. Given the broad number of consumer products that contain lithium batteries, they felt the approach was justified. Sweden supported the approach but recommended the reference to non-removable batteries be removed, and the packaging performance requirements should be contained within P907. France recommended sodium ion batteries be included. Belgium pointed out SP188 contains a 30 kg gross mass requirement ONLY when batteries are shipped alone. Applying a 30 kg limit to all UN3363 would be overly restrictive. They shared the same logic applies to the drop test capability. As an alternative, Belgium suggested simply referencing applicability of the lithium battery entries would be a way forward. The US was supportive of the approach but agreed with Belgium that many of the proposals were not consistent with how the requirements were applied for other entries. They opined that leaving the battery in the device would be safer than removing the battery. The Netherlands pointed out 2.0.5.5 requires hazards under than Class 9 will always take precedence. They questioned whether this approach would comply with 2.0.5.5. Norway suggested that Proposal 2 should end after the word “secured”. The UK supported the approach in principle. China indicated they would prepare a revised proposal in an INF paper for review later during the session. No proposals were adopted. 

2024/71; INF.49 (Italy) Wearable airbag system – Italy explained that there are many wearable airbag systems currently in the market, and the classification of the products varies significantly. To provide a clear system, Italy proposed to clarify that such devices should be covered either under UN2990 LIFE-SAVING APPLICANCES, SELF-INFLATING (proposal option 1) or UN3268 SAFETY DEVICES (proposal option 2). They offered revisions to either SP296 (UN2990) or SP289 (UN3268). The US was not willing to consider a full exception. But they suggested SP296 could be modified to include reference to safety devices that were approved as UN3268 and thus allow them to move as UN2990. The UK preferred this to be reviewed by the EWG and have additional limitations applied. Austria preferred Option 2. France believed the issue needed to be reviewed further and was not supportive of a full exception. COSTHA preferred Option 1 but agreed with the US that reference to UN3268 in SP296 applicable to UN2990 may solve the problem. Belgium agreed with the US and COSTHA and preferred to see a solution during this biennium. SAAMI felt the EWG would only be needed to consult if the full exclusion is considered. If the material is deemed to be in Class 9, it can be addressed by the Subcommittee. AESIG supported both proposals and recommended removing the 25 kg limit. Spain preferred to cover them under UN3268. Sweden and the Netherlands preferred UN2990. Based on the discussion, the Subcommittee agreed to hold a lunchtime working group on Day 2 to find a possible solution forward.

2024/92 (China) Adding fire test procedures for UN 3164 in section 31 of the Manual of Tests and Criteria – China pointed out the specifics of the fire test required by SP283 are not defined. For this reason, some regions cannot adequately enforce the use of the test. They suggested creating a new Sub-section in Section 31 to address all Class 2 gases. COSTHA noted a large number of these devices that are currently on the market that have not demonstrated an issue with the current provisions. If the Subcommittee agrees to move forward, current practices should be included in the discussion. France did not believe new provisions needed to be included in Section 31. The US and the Netherlands agreed with COSTHA that looking at current industry practices would be preferred over creating new testing requirements. China indicated they would return with additional proposals in the next biennium. The Subcommittee agreed to include the item under the Programme of Work for the 2025-2026 Biennium.

2024/95 (Gafta) Entries for seedcake, UN 1386 and UN 2217 – Based on industry testing, GAFTA explained that there is no longer a need for UN2217. Testing has indicated that industry standards keep the moisture and oil content within limits identified in UN1386. They proposed deleting UN2217 and revising SP142 to include moisture and oil content limits for certain seedcakes. Finland was supportive of the approach but requested additional detail on the use of the N.4 for testing. IVODGA supported the proposal. China, the US, Spain, the Netherlands, Sweden, and Austria requested additional data before making a final decision. They questioned the use of the N.4 test noting human experience that has shown concern for with data purely from the N.4 test. The US suggested additional testing may need to be done that requires a longer storage time before the test is conducted, similar to what was done with fishmeal. Belgium and Argentina supported the paper and offered editorial revisions. The Netherlands suggested seedcake with a moisture content of 13% and an oil concentration of 4% should at least be tested. Based on the discussion, GAFTA withdrew the proposal but indicated they would return at a future session in the next biennium. No proposals were adopted.

2024/97 (Cefic) Packing group II metal packagings for organic peroxides and self-reactive substances – CEFIC explained that historically, there was a statement in the Model Regulations that indicated metal packagings meeting the criteria of internal pressure test for PG I shall not be used. This was at one point dropped due to a lack of reference to specific testing requirements. However, CEFIC and Germany have conducted additional tests, and the concerns for additional pressurization remain. Therefore, they proposed to reintroduce the requirement. Canada supported the proposal but suggested an additional note would be necessary to direct the packer to ask additional information of the packaging manufacturer since the packaging marking would not reflect the point above. Austria supported the proposal with the additional note from Canada. Sweden supported the proposal as drafted. The UK argued that the premise of the proposal is flawed. They opined there should be no expectation that a metal drum should be tested in a bonfire as that is not a normal condition of transport. The UK did not see a benefit or a reason for the proposal. France, the Netherlands, and the US agreed with the proposal as drafted and the added note from Canada. Belgium supported the proposal but felt the note may create a problem with the packaging manufacturers. CEFIC explained that industry already works with the packaging manufacturers to ensure the packaging complies with the proposal. But they felt having it stated would prevent future shippers from believing they could use a jerrican or other metal packaging that is pressure tested to PG I. CEFIC also noted that heating of liquids in confinement is indeed a standard condition that is necessary to test against. Given that organic peroxides may become heated in an accident or emergency and as a result, metal packaging that will not permit venting and will create additional confinement should not be permitted. Austria provided editorial amendments. By a majority vote, the Subcommittee agreed to the proposal in 2024/97. Canada indicated they would consider providing an INF paper on the note for review later in the session.

2024/98 (Germany) Deletion of the entry UN 2941 Fluoroanilines – Based on previously submitted data shared with the Subcommittee, Germany proposed to delete the entry UN2941 FLUOROANINES. As a consequence, they also proposed to include several Fluoroaniline entries in the alphabetical list for reference. Canada and Sweden supported the proposals. China added that the same problem exists for Chlorophenols. They recommended a broader approach be taken to address other examples where a generic entry exists. They were not convinced that all the entries should be included in the alphabetical listing. Belgium supported the proposal. The US commented the German proposal puts the responsibility on the shipper to properly classify the material and they supported the approach. Spain also supported the proposal. By a majority vote, the Subcommittee agreed to the proposal in 2024/98 with minor editorial amendments.

2024/58; INF.36 (Secretariat) Consolidated list of draft amendments – The Secretariat returned to 2024/58 and INF.36 to address remaining issues related to the draft amendments to the 24th Revised Edition related to infectious substances. The Secretariat recommended incorporating Notes 1, 2 and 3 into the required text and the indicative list. FAO commented that the entry for UN2900 includes the word “only” in lowercase text. This word causes confusion for shippers and carriers. They recommended dropping the word “only” even though it is not proposed in the paper. Belgium supported moving Note 1 to the first paragraph 2.6.3.2.2.1. Note 3 will be moved to the table. Note 2 will remain as currently written. FAO reiterated the problem with the table in 2.6.3.2.2.1 with the word “only”. The Chairman commented that the wording change proposed by FAO would need to be addressed in a formal proposal. Finally, the Secretariat also addressed the necessity to address hybrid vehicles. The Subcommittee agreed to the changes proposed by the Secretariat. These changes will be reflected in an Annex to the report. 

End of Day 2

–COSTHA