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 3. 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 3 – Discussion of Papers

2024/99 (World Coating Council) Transport provisions for small quantities of environmentally hazardous paints, printing inks, and related materials – Noting the limited availability of appropriate UN specification packaging for liquids, the WCC proposed a new packing provision applicable to UN3082 Environmentally Hazardous Substances, LIQUID, N.O.S. that would authorize non-UN specification plastic packaging for mixtures of EHS materials up to 30 liters. They noted that certain additives necessary to preserve the paint is highly toxic to the environment. However, the additives represent <1% of the total mixture. WCC explained that the material would remain fully regulated for transport and no additional exceptions are proposed other than the packaging provision. The US, Canada, and Australia supported the proposal as drafted. China supported the proposal but requested that when the provision is applied, the technical name of the additive and the related M factor should be included as part of the proper shipping name. The Netherlands were not convinced the approach was correct and believed UN specification packaging is readily available. Sweden shared the opinion of the Netherlands adding a lower carbon footprint is not a valid reason for exempting UN packaging. Germany and France were also opposed the proposal. Belgium suggested a specific exception for performance testing after the tinting process may be possible. Norway explained that they developed a multilateral agreement in 2021 that exempts the UN specification. This agreement will expire in 2027 but may be extended to allow industry to develop new adequate packaging. France and Austria noted a willingness to extend the agreement but were opposed the proposal. The UK felt the approach may undermine the credibility of the current classification system by providing an exception that could be used for many products beyond paint and coatings. RPMASA shared that while UN packaging may be available in many parts of the world, it is not necessarily available in developing regions and would not likely be available in the near future. They supported the proposal and encouraged delegations to consider the global impact given the very small amounts of the EHS components being discussed. WCC further explained new preservatives that are being mandated by other regulations will be introduced into paint formulations in 2026. This will effectively regulate all water-borne paints. They reiterated the provision would not deregulate the material, but only provide an exception from the UN packaging requirement. The WCC indicated they would work on a revised proposal for consideration later in the session. No proposals were adopted.  

2024/102 (United States of America) Provisions for UN 2029 Hydrazine anhydrous – The US proposed to reverse a previous decision to restrict the use of gas cylinders and receptacles when shipping UN2029 HYDRAZINE ANHYDROUS. The original decision was to prevent over pressurization in cylinders that may result in an explosion. However, after adopting, the aerospace industry shared that cylinders are commonly used and have a long safety record. They proposed to remove PP5 from UN2029 and add a new packing provision that would limit the internal pressure of filled cylinders. China did not oppose the proposal but requested additional measures be adopted to prevent over pressurization. Spain questioned why the temperature of 65 oC was included in proposal 2. Canada supported both proposals. Japan shared their experience with the movement of UN2029 and agreed to the removal of PP5. France explained the temperature is a standard measurement found in many of the gas packing instructions. They supported both proposals. The UK requested additional data as to why 65 oC was chosen. Belgium and the Netherlands supported both proposals. Based on the discussion, the Subcommittee adopted both proposals in the 2024/102.

2024/106; INF.20 (Belgium) Classification and transport of UN 2372 (1,2-di-(dimethylamino) ethane) – Based on new test data, Belgium argued UN2372 1, 2-DI-(DIMETHYLAMINO ETHANE) should be assigned corrosive and toxic sub-hazards. They proposed to add these sub-hazards to the entry, revised the authorized tank provisions, and provided a 5-year transition period. China supported proposal 1 but preferred to keep Tank instruction T4. Spain, Canada, France, and Germany supported proposals 1 and 2 and preferred Option 2 for proposal 3. The Netherlands felt the corrosivity data suggested a PG I assignment. The US, the UK, and Sweden supported proposal 3, Option 1. DGAC preferred proposal 3, option 3. By a majority vote, Proposals 1 and 2 and Proposal 3, Option 1 were adopted

2024/103; INF.34 (United Kingdom, United States of America); INF.40 (Germany); INF.53 (Germany, United States, and United Kingdom) Proposed changes to the Koenen test specifications – INF.53 included revised text from earlier discussions on 2024/103 and related documents regarding the Koenen test specifications. The Subcommittee adopted the provisions as presented in INF.53.

2024/71; INF.49; (Italy); INF.57 (Italy) Wearable airbag system – Italy presented a revised proposal on the wearable airbag system. The Subcommittee confirmed such devices should be covered under the entry UN2990 LIFE SAVING APPLIANCES. Therefore, they proposed modifications to Special Provision 296 that explained that approved safety devices classed and covered under UN3268 SAFETY DEVICES may be installed in life saving appliances. They also proposed clarifying language in SP 280 applicable to UN3268 SAFETY DEVICES but shared they inadvertently omitted some existing text in SP280. Belgium, France, the Netherlands, the US, and Sweden supported the changes to SP296 as well as Option 1 for SP280. The Subcommittee adopted the provisions as presented in INF.57 including Option 1 for SP280

INF.37 (Cefic on behalf of ICG) Informal correspondence group on polymerizing substances and self-accelerating polymerization temperature (SAPT) – CEFIC updated the Subcommittee on discussions regarding stabilized and non-stabilized polymerizing substances and the impact of temperature. For non-stabilized materials, a self- accelerating polymerization temperature (SAPT) will be required. But for stabilized substances, a polymerization induction time (PIT) will be required. CEFIC indicated the correspondence group will continue to work on the topic during the next biennium. The Netherlands, Belgium and the US supported the continued work. No proposals were considered.

2024/74; INF.50 (PRBA, RECHARGE) Lithium ion batteries testing – amendment to the T.5 short circuit test – RECHARGE explained that there are batteries on the market and in development that charge wirelessly and others where the terminals are not accessible during the UN38.3 testing. Because the standard conditions of an external short circuit are not practical or require partial disassembly of the battery to access the terminals, they proposed to add a new paragraph to the UN Manual of Tests and Criteria 38.3.3.1 that would describe how to test such batteries or, exempt such batteries from the T.5 test with certain conditions. Based on comments received on 2024/74, RECHARGE provided revised proposed text in INF.50. The US questioned the purpose of the T.5: 1)to test a design type only when terminals are exposed and to see what happens to the battery, or 2) force the battery into a short circuit regardless of the terminal access to determine battery response. They were not supportive of the proposed text and indicated they had some recommended changes to the text. The Netherlands agreed with the US and voiced confusion over the reference to “specialized tools for final installation”.. France voiced support for the proposal for wireless charged batteries and explained that for high voltage batteries, there is an existing problem with the current wording of the T.5 test. While not perfect, France opined the proposal in INF.50 was the best possible option at the moment. The Republic of Korea supported the proposal but preferred to get additional clarity on size limits for the conditions. The UK questioned whether the T.5 test could be conducted before the battery was fully assembled. RECHARGE explained that for high voltage batteries are generally not capable of passing the T.5 test. Best practice today is to apply a device that will disconnect the terminal and prevent current flow through the battery. The component stays with the battery throughout the transportation mode and is only removed upon installation in equipment or vehicles. The device would then be added if the battery were later transported. For this reason, there is no data that would be lost if the T.5 was excluded. The US stated that the application of a device to protect the terminals would not be an acceptable design to pass the test. RECHARGE indicated they would work with delegations and return in the session with a revised proposal. No proposals were adopted.

2024/79 (Republic of Korea) Clarification of the installing and fixing methods for UN 38.3 Lithium battery testing – The Republic of Korea proposed to permit fixtures to secure the cell/battery to the UN38.3 design type testing. RECHARGE pointed out such fixtures might remove heat from the cell/battery and therefore additional clarity was needed to explain how the fixtures may be used such that they will not impact the test conditions or results. The US agreed with RECHARGE and argued that any fixture would not prevent the conditions of the test be “faithfully transmitted” to the subject cells/batteries. China agreed with the principle of the proposal, but preferred additional details be defined. France shared that pouch cells will expand in a vacuum and thus compression from a fixture may create a less restrictive condition. The Republic of Korea withdrew the proposal and indicated they would return at a future session with a revised proposal.

2024/108 (PRBA, RECHARGE) Repairing, refurbishing, or remanufacturing of lithium ion cells and batteries and implications on safety and UN 38.3 testing requirements – RECHARGE proposed a new note in the UN38.3.2.2 explaining that batteries that are repaired, refurbished, or remanufactured with non-original parts or components or in a manner that would result in a deviation from the original design type would require retesting. Germany supported the proposal but also suggested the introduction to the note should read “Note: The type of change that might would be considered to differ…”. The US also supported the proposal and the additional change proposed by Germany. Belgium requested the Note to be added to 2.9.4 include a reference to the UN Manual of Tests and criteria. Sweden agreed with others that the language proposed was not ideal but served its purpose. They requested additional clarity on what remanufacturing, repairing, and refurbishing means during the next biennium. France noted the French translation needed to be reviewed as the language did not match that in the English version. The Netherlands and China also supported the proposal. China however questioned whether the replacement of original parts of any type could lead to possible safety issues. The Subcommittee agreed to the proposals in 2024/108 with minor amendments.

2024/109 (PRBA, RECHARGE) Exception for equipment containing both lithium batteries and lithium button cells – RECHARGE explained that previously adopted text regarding the exception for button cells in SP188 refers only to one (1) button cell installed in equipment. They noted the existing exception applies to any number of button cells when installed in equipment, not just one. RECHARGE proposed to modify the exception to explain that where equipment contains one or more button cells, the need to apply the battery mark is excepted. Austria and China suggested a limit to the number of cells should be applied. China also argued that there are no energy or size limits to button cells, only a description of the shape of the cell. The US and Belgium believed the proposal was only a clarification of existing text and noted the robustness of button cells that are further installed in equipment. RECHARGE agreed that the definition of a button cell should be further defined. By a majority vote, the Subcommittee agreed to the proposal in 2024/109.

2024/110 (PRBA, RECHARGE) Lithium battery test and definition of “rupture” in section 38.3 of the Manual of Tests and Criteria – RECHARGE described a battery design where the cells or modules are not fully enclosed. Thus, it could be interpreted that if any part of component cells is visible after the test, the battery was considered to have ruptured. They proposed to include a NOTE explaining that exposure of solid materials that is already intended by its original design would not be considered a rupture. Germany supported the proposal. Spain believed the proposal inappropriately changed the full definition of rupture and would not cover liquid or gas releases. The Netherlands agreed with Spain. The US explained liquids and gases are addressed in other definitions such as leakage and venting. The US and Belgium supported the proposal. RECHARGE clarified the main point of the paper was to address the term “exposure”. RECHARGE indicated they would revise the proposal and return with an INF paper for consideration during this session. No proposals were adopted.

End of Day 3

–COSTHA