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 60 informal papers submitted for discussion as of Day 4. 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 to 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 4 – Discussion of Papers

2024/75 (COSTHA); INF.54 (COSTHA) Used medical devices containing or packed with lithium batteries – COSTHA presented revised text in INF.54 that addressed the comments received on 2024/75. Belgium, the US, and Sweden supported the proposal as drafted. The Subcommittee adopted the proposal in INF.54.

2024/97 (CEFIC); INF.56 (Canada, CEFIC) Packing Group II metal packagings for organic peroxides and self-reactive substances –  CEFIC proposed revised text to address comments received on 2024/97.  The Subcommittee agreed to the proposals in INF.56.

2024/80 (Germany) New entry for UN2862 VANADIUM PENTOXIDE, non-fused form, with packing group II; INF.58 (Germany) Belgium, Australia, and China supported the proposal as written. The Subcommittee agreed to the proposals in INF.58.

Classification of Lithium Batteries – Due to the shared subjects of INF.16 and INF.41, these papers were discussed together. INF.35 was not discussed as the submitter of the document was not in attendance. However, Belgium offered to bring the paper to the Informal Working Group on Lithium Batteries (IWG) for consideration.

  • INF.16 (Belgium, France, RECHARGE on behalf of IWG); INF.35 (KFI) Hazard-based system for classification of lithium batteries – Belgium as the Chairman of the IWG presented the most recent developments with lithium battery classification. The full minutes of the August 2024 meeting were included in an Annex to INF.16. RECHARGE explained the three (3) proposals included in the paper. Proposal 1 detailed the new classification test. The test is intended to determine if cells and batteries will propagate readily and collect key data points for further categorization of the tested cells/batteries. Proposals 2 and 3 introduced two possible categorization schemes, one with a minimum granularity (4 categories) and one with a maximum granularity (6 categories). The Subcommittee was not asked to approve the proposals, but only to give opinions on the progress. It is recognized that the effort is only focused on identifying the hazards and does not address transportation conditions. INF.41 from Germany was also covered in discussion of this paper.
  • INF.41 (Germany) New classification system for lithium batteries and cells – Proposals with fewer UN numbers – Using the logic described in INF.16, Germany described two possible systems to implement the classification/categorization scheme. They suggested that either separate divisions could be assigned to the current entries (Div. 9A, 9B, etc.), or create new entries for each of the batteries (UN35XW for 9A, UN35XX for 9B, etc.).
  • The US encouraged the effort and preferred the minimum granularity. Austria shared that often too many categories are adopted in classification schemes only to be ignored by individual countries. They encouraged to keep the number of categories to a minimum. China voiced some concern with some of the conditions in the test. However, they agreed with Austria and the US to keep the number of categories to a minimum. The Netherlands preferred proposal 1 in INF.41 as new entries would create a more complicated system. France also agreed that using a division designation would be more practical than creating new entries for each category.
  • No proposals were adopted but the Subcommittee encouraged the IWG to continue their efforts in the next biennium The next meeting of the IWG will be in March 2025 in Shanghai, China followed by an in-person session in December 2025 in Geneva, Switzerland.

New Identification system – The UK submitted a series of documents on possible consequences of new categories. They presented both entries and possible packing instructions as well as additional consequential amendments.

  • 2024/82; INF.22 (United Kingdom) New identification system – lithium cells and batteries –additions to the Dangerous Goods List and special provisions – This paper introduced new entries based on the categorization scheme. INF.22 reflected changes based on the decisions made by the IWG.
  • 2024/83; INF.22 (United Kingdom) New identification system – lithium cells and batteries – packing instructions – These papers introduce packing instructions that would match with the new categories and entries. INF.22 updated the proposals in 2024/83.
  • 2024/84; INF.22 (United Kingdom) New identification system – lithium cells and batteries – additional and consequential amendments – The UK proposed modifying the existing battery hazard communication and special provisions.
  • 2024/85 (United Kingdom) New identification system – lithium cells and batteries – precedents and reasoning – In this document, the UK explained the reasoning behind the other 4 documents (2024/82, 83, 84, and INF.22), noting that they should be adopted during the current biennium.
  • RECHARGE opined the system proposed creates significant confusion for those classifying the batteries. Also, the current system permits the additional limitations or exceptions based on State of Charge and packaging. China did not support the proposals. They further commented that the paper mentioned that damaged batteries would not have a hazard that is greater than that for a fully charged battery. China disagreed with this comment. DGTA supported the UK approach with regards to cells as such granularity makes it easier for shippers to understand what entry to use. The US, the Netherlands, and Belgium believed there were aspects of the proposal that can be combined with the work from the IWG. However, they were not supportive of the broad proposals in these papers. France voiced concern that if SOC is used for classification and identification, that may change during the life of the battery. The agreed with other speakers that was premature to adopt INF.22 at this time. The UK argued that SOC should be considered for classification, not just as a mitigating measure similar to packaging.
  • Based on the discussion, the UK withdrew the proposals and indicated they would work within the IWG to further their recommendations. No proposals were adopted.

2024/70 (Austria) Clarification to packing instruction P903 as regards large cells and batteries with a robust outer casing – Austria proposed to clarify in P903 that large batteries with robust outer casing are not required to be in UN specification packaging. The UK, Finland, Spain, and Sweden supported Option 1. The US supported Option 2. France suggested that the word “alternately” could be applied to paragraphs 2-5. Belgium agreed with France. After further discussion, the Subcommittee agreed to Option 2 of the proposal and confirmed the correct translations for the Secretariat.

2024/101 (United States of America); INF.42 (United Kingdom) Proper shipping names for UN 3536 – The US shared a recent emergency response incident involving a cargo transport units that contained lithium ion batteries. However, the proper shipping name LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNITS does not communicate whether the batteries contained within are lithium ion or metal. To address, they proposed creating entries for Lithium ion batteries, lithium metal batteries, and sodium ion batteries installed in cargo transport units. They also included modifications to special provisions 360, 388, and 410 to address hybrid systems. In INF.42, the UK noted consequential amendments to 2.9.2 for both UN3536 and the lithium- and sodium-ion powered vehicle entries (UN3556, UN3557, and UN3558). They also voiced alternate suggestions to the special provisions. Sweden supported the proposals in 2024/101 but suggested SP410 should be applied to the new entries. France supported the proposals in 2024/101. They were also supportive of INF.42 but questioned the ability to adopt all the proposals on the basis of an informal document. China reminded the Subcommittee that they previously proposed introducing an entry for sodium ion batteries installed in cargo transport units. They supported the effort but were not sure the changes to the special provisions were enough to deal with hybrid devices. Spain pointed out 2024/112 also addresses the issue as well as INF.33. The UK pointed out paragraph 19 of INF.42 proposes a possible solution for units with multiple battery types. The Subcommittee agreed to the proposal in 2024/101 with the addition of SP410 to all entries. Proposals 1 and 5 from INF.42 that were deemed editorial were also adopted.

2024/64 (IATA) Amendment to special provision 388 to include nickel metal hydride batteries – IATA proposed adding reference to nickel-metal hydride batteries when installed in vehicles. Special Provision 388 directs the reader to the appropriate entry based on the composition of the battery. Although the text of SP388 in 2024/64 does not reflect the updated version as discussed in the 2024/58 (Draft changes to the Model Regulations), IATA suggested nickel-metal hydride batteries should be added in appropriate locations. They also shared that the ICAO Dangerous Goods Panel reviewed the proposal and supported adding the text to paragraphs 2 and 3 but were not in favor of adding it paragraph 5 as vehicles powered by nickel-metal hydride batteries would not be regulated under UN3171. China supported the proposal but added it would be appropriate to clearly state the exception for vehicles powered by nickel-metal hydride batteries. Belgium pointed out nickel-metal hydride batteries are only regulated by the sea mode. Thus, they agreed with China that the entry in paragraph 5 was not needed, or it should be clearly stated that such vehicles are not regulated. France agreed with Belgium. The US and Sweden also agreed paragraph 5 should not include the reference. COSTHA suggested to add a statement to paragraph 5 specifically exempting vehicles and equipment powered by nickel metal hydride batteries. Based on the discussion, the Subcommittee agreed to include the references in paragraphs 2 and 3, but not in paragraph 5 of 2024/64.

2024/110 (RECHARGE); INF.62 (RECHARGE) Lithium Battery test and definition of “rupture” in Section 38.3 of the Manual of Tests and Criteria – RECHARGE revised their proposal from 2024/110 on Day 3 to better describe what is meant by “exposure” or increased visibility. The Subcommittee adopted the provisions as presented in INF.62.

2024/59 (ISO) Acetylene cylinder marking – EIGA noted that the note in 6.2.2.7.3 should be included as required text in the same section as it details requirements, not just recommendations. This was previously supported in an INF paper discussion at the 65th Session. Therefore, EIGA proposed the change at this session. The change would have a consequential amendment to the note in 6.2.2.7.3. The US supported the proposal as drafted. Canada supported the change in proposal 1 but requested that in proposal 2, the mark only be applied when the cylinder has available space on the shoulder. Poland, France, Belgium, and Spain agreed with Canada. France did not believe proposal 2 was necessary. Austria questioned if there was an alternate method for applying the marking that would not damage the cylinder. If not, they supported both proposals. Germany and the Netherlands supported both proposals. EIGA shared that paint or labels may create confusion particularly for a mark that is intended to be permanent. Based on the discussion, EIGA amended proposal 2 to delete the Note in 6.2.2.7.3. The Subcommittee agreed to the changes in proposal 1 and to delete the note in proposal 2.

2024/61; INF.31 (ISO) Updated ISO standards in Class 2 – ISO provided updates to a number of ISO standards:

  • ISO 23876:2022 Gas cylinders – cylinders and tubes of composite construction – Acoustic emission examination (AT) for periodic inspection and testing.
  • ISO 11119-2:2020/Amd 1:2023, Gas cylinders – Design, construction and testing of refillable composite gas cylinders and tubes, Part 2: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with load-sharing metal liners, Amendment 1. This standard
  • ISO 11119-3:2020/Amd 1:2023, Gas cylinders – Design, construction and testing of refillable composite gas cylinders and tubes, Part 3: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with non-load-sharing metallic or non-metallic liners or without liners, Amendment 1.
  • All three of these standards are being reviewed by ISO and will be submitted to the Subcommittee for review at a future session.
  • No proposals were considered.

2024/62 (ISO) Updated ISO standards in Class 2 – ISO amended ISO 18119:2018/Amd 2:2024, Gas cylinders – Seamless steel and seamless aluminum-ally gas cylinders and tubes -Periodic inspection and testing – Amendment 2 and as a consequence, proposed modifying the note in 6.2.1.6.1 and updating the table in 6.2.2.4. The US supported the proposals. France questioned whether the inclusion of the ISO in the table meant that the existing standard should be revised. China agreed with France. The Subcommittee agreed to the proposal in paragraph 3 and will work with the Secretariat to ensure the table in 6.2.2.4 was correct.

2024/63 (ECMA) Proposal to amend 6.2.2.8 Marking of non-refillable UN cylinders – ECMA proposed to allow non-refillable UN cylinders with a diameter less than or equal to 40 mm be marked on their sides (instead of their shoulder) provided no harmful stress concentration is created and the minimal cylindrical shell wall thickness is maintained. Austria noted that in general, these cylinders are exempt from the mark. However, there are regional regulations where the manufacturers are required to apply the mark. They shared that each of these cylinders are still tested with the mark applied. Austria did not see a safety risk and thus supported the proposal. The UK questioned whether the application of the mark by laser could be recommended. The US, Spain, and Poland supported the proposal as drafted. China questioned whether them “may” meant it was an option or a requirement. The US explained that there already exists an option to use a label to apply the mark for these small cylinders. Austria further clarified that it is typically forbidden to stamp or engrave the mark on the side of the cylinder. Thus, use of the term “may” will allow the mark to be applied whereas it would normally be forbidden. The Subcommittee agreed to the proposal in 2024/63.

2024/81 (Germany); INF.59 (Germany) Periodic leakproofness re-testing of IBCs after two and a half years at the level of the design type test – Germany proposed to clarify that the periodic Leakproofness test for IBCs may be conducted at a reduced level than the original design type test. Germany argued that many competent authorities and industry currently understand this provision is already in practice. INF.59 proposed to include the clarification as a note in 6.5.4.4.2. The UK, Sweden, the Netherlands, and Canada supported the proposal. Canada and the US questioned whether the last sentence was necessary. Austria confirmed their belief that the last sentence was necessary. Poland understood the approach but felt the proposal was too general. Without specific parameters, the testing may not be enough to properly check the competency of the IBC. ICIBCA were supportive of the proposal. The UK confirmed the confusion noted by Poland and suggested consequential amendments may be necessary. Based on the discussion, the proposal in 2024/81 for the report and INF.59 with the deletion of the last sentence were adopted. Germany indicated they would return at a future session to address any specific provisions on period testing levels that should be detailed.

2024/89 (China) Proposal to clarify the requirements on punching holes as handles on the sides of 4G fibreboard box packagings – China argued that perforations of UN specification packagings with holes for ropes or handles compromises the integrity of outer packaging. They noted it is often not clear whether the design testing was conducted with or without the holes. China offered proposal 1 that would prohibit openings or perforations in UN specification packagings. Proposal 2 would permit such openings as long as the testing was conducted with the holes present. Germany opined that such openings are permitted as long as the testing is conducted with the openings. But they argued that the text in Proposal 2 was not appropriate either as there are situations other than ease of transport where an opening may be required. The US agreed with Germany and suggested the report could reflect the openings care acceptable as long as they are part of the design type testing. Spain supported Proposal 2 and noted the definition of a box in 1.2.1 include allowances for small holes for ease of handling. The UK shared experience with testing of perforated packaging, and added that UK test reports will include reference to holes and handles when present. They agreed a note in the report would be sufficient. Switzerland, IATA, and Belgium commented that the text in proposal 2 should be improved before adoption. Luxembourg and Austria asked how a user of the packaging would know that the openings were actually tested. They preferred the openings be noted in the packaging code or certification. Japan disagreed with the opinions of many of the Subcommittee and felt that openings would NOT be acceptable. They supported Option 1. China agreed with the majority of the delegations that spoke and they requested the report reflect the majority position. China withdrew the proposal but the Subcommittee agreed to include in the report that the majority supported that openings are permitted as long as the openings are part of the design type testing. No proposals were adopted.

2024/90 (China) Proposal on clarifying the definition of large packaging – China questioned whether the reference to volume in the definition of a large packaging means internal or external volume. The discussion of this paper was completed on Day 5.

End of Day 4

 

–COSTHA