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 63 informal papers submitted for discussion as of Day 6. 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 6 – Discussion of Papers

2024/76 (COSTHA) Variations of flame symbol design – COSTHA proposed to adopt language in include a new sentence in 5.2.2.2.1 to clarify that minor variations in the design of labels that do not detract from the intended meaning of the symbol are acceptable. Sweden, Poland, China, the US, and Switzerland supported the proposal as drafted. IATA requested to remove the word “also”. The Netherland felt reference to other modes would be difficult and that “minor difference” would not be enforceable. Austria and Belgium preferred to include examples as given in the ICAO Technical Instructions. But DGAC and France felt that such examples should be included in a note, vs. actual text. COSTHA preferred to move forward with the text as presented and offered to return in the next biennium with a proposal for a note listing examples. Based on the discussion, the Subcommittee agreed to the proposal in 2024/76. COSTHA will return in the next biennium with a proposal for an associated note.

2024/100 (Secretariat) Scope of 6.4.2.14 and alignment with the IAEA Regulations for the Safe Transport of Radioactive Material – The Secretariat identified a number of inconsistencies that have developed between the Model Regulations and the IAEA SSR-6, Rev. 1 document. They recommended referring the issues to IAEA for further feedback. The Secretariat also asked several questions in paragraph 19. Sweden believed that 6.4.2.14 should apply to excepted packages as the package design may impact the activity rate. Germany and the Netherlands agreed with Sweden. Belgium agreed the paragraph should apply, but felt the placement would put the responsibility with the manufacturer instead of the consider. Based on the discussion, the Subcommittee agreed to forward the document to the IAEA for review. No proposals were considered.

2024/91; INF.60/Rev.1 (China) Proposal to allow articles classified as UN 3363 to contain lithium batteries complying with special provision 188 – China offered revised language to address previously raised concerns on the text in INF.60 from the US. The US stated they supported the proposal as revised. The Subcommittee supported the proposal as drafted in INF.60/Rev.1.

INF.19 (Kingdom of the Netherlands) Approval of packaging for damaged or defective cells and batteries – The Netherlands shared that they have limited experience with testing for packaging intended for damaged or defective lithium batteries. They asked the Subcommittee for feedback and also proposed adding the words “approved or” to the relevant packaging instructions to state an approval may be issued. Belgium explained they work with packaging manufacturers on tests to be conducted and then eventually “approve” the packaging. Therefore, they supported the modification. Germany agreed with Belgium and stated the text proposed is common practice. The US and UK supported the proposal as drafted. The Chairman noted that it is general practice to only take decisions on informal papers if there was no further impact to practice. The Netherlands commented that speakers stated it was a clarification of current practice. Based on the discussion, the Subcommittee adopted the proposal in INF.19.

INF.18/Rev.1 (Kingdom of the Netherlands) Transport of articles containing gas in open cryogenic receptacle – The Netherlands shared challenges with large cryogenic articles that are shipped under P006. They proposed new language in P006 and a new special provision XXX to be applied to the entry UN3538 to clarify performance requirements for such articles. France supported the proposal as drafted and recommended paragraph 7 was a necessary editorial addition. The US supported the proposal but preferred to review the proposal with industry as to date, the concerns over 2.2 gases were reviewed but not all conditions of cryogenic language. Belgium supported France on paragraph 7 but agreed with the US on paragraph 8. The US argued that introducing a packaging instruction to P006 without the new special provision would create more confusion. Based on the discussion,

INF.28 (Spain) Placards on the sides of cargo transport units – Spain noted confusion as to how many placards are required to be placed on each side representing a single hazard. For example, if two flammable liquids are placed in a cargo transport unit, the regulations state that only one placard “may” be placed on the CTU. Does this mean that more than one is NOT permitted? The main differences were between the English and French versions. Spain proposed text in the various languages that would allow multiple placards on a container. The US felt the existing language was permissive and thus would allow multiple placards if the shipper chooses to. The UK, France, and Luxemburg agreed with the US. France offered a minor editorial amendment to the French version. The Subcommittee discussed the various interpretations on the French language. Based on the discussion, Spain agreed to work with interested delegations on revised text and will submit a revised proposal at a future session. No proposals were adopted.

INF.9 (United Kingdom) Multimodal transport of portable tanks and MEGCs – The UK asked the Subcommittee their opinions in the use of portable tanks and MEGCs in multimodal movement. The shared ISO 10855-1 applies to movement of these units by sea but may add some conditions by other modes that are not appreciated. Germany agreed with the UK that packaging meeting the provisions of CSC 1972 would satisfy the conditions of 6.7.1.1 and felt the standard should be reviewed for “additional requirements” that could be applied to other modes. The US was supportive but wanted to be sure that the conditions were reviewed closely before adopting. The UK indicated they would return at a future session with related proposals. No proposals were considered.

INF.51 (ICAO) Information on amendments to the Technical Instructions for the Safe Transport of Dangerous Goods by Air – ICAO updated the Subcommittee on changes to the ICAO TI, noting two revisions that may be important to the Model Regulations.

  • They noted an additional change was made in SP388 to include sodium ion batteries packed with and contained in equipment in the examples.
  • They also include sodium ion batteries in the provisions for data loggers.
  • Based on the discussion, the Subcommittee agreed to the proposal in paragraph 2 related to SP388.

2024/107; INF.63 (Belgium) Use of recycled plastics material for flexible intermediate bulk containers – Based on the discussion on 2024/107, Belgium presented revised text in 6.5.5.2.2 and 6.5.5.2.8 to permit the use of recycled plastics material for flexible IBCs. They offered two options to each proposal. The US, Austria, the Netherlands, Poland, and France supported Option 2. The UK did not support either proposal noting that there are manufacturers in the market today that have packaging that would not meet the criteria in 1.2.1 but have been shown to meet the performance criteria and were approved as a “W” packaging. By a majority vote, the proposals in Option 2 were adopted.

Electric power generation and storage systems – Papers 2024/112 and INF.33 were addressed together

  • 2024/112 (Switzerland) Electric power generation and storage systems installed in cargo transport units – Switzerland described units that contain lithium ion batteries but also an engine that has a diesel fuel tank. The purpose of the unit is to provide power to external units. While they felt UN3536 LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNIT may be appropriate, it might also be considered to be covered under UN3528 MACHINERY, INTERNAL COMBUSTION, FLAMMABLE LIQUID POWERED. Switzerland also shared that another system that is powered by a hydrogen fuel cell. In this case, the unit would be best described as UN3529 MACHINERY, FUEL CELL, FLAMMABLE GAS POWERED. They asked for clarification as to how to address these differences.
  • INF.33 (United States of America) Lithium Batteries Installed in cargo transport units – New agenda item – The US shared incidents related to these entries, particularly noting that the type of lithium battery contained within is not indicated. They also pointed out different units that have been historically covered under this entry in Figure 1 and Figure 2 and questioned whether the Subcommittee needed to revise the entry to limit the design.
  • Sweden agreed with Switzerland that units that contain both batteries and diesel fuel or fuel cells, the entries UN3528/UN3529 as appropriate. They also opined that perhaps the introduction of a 9A placard should be introduced to communicate the presence of batteries. The UK were not convinced that the machinery entries were correct. But they agreed with the US that Figure 1 would not be considered a cargo transport unit. Finland, the Netherlands, Belgium, and Germany welcomed the discussion and agreed that perhaps additional entries need to be considered for hybrid systems. The US commented that as the generators described in the Switzerland papers are applied to the UN3529 entry, the provisions of the hydrogen cylinders is removed. Thus, additional work is necessary to ensure consistency across all entries.
  • The Subcommittee agreed to the proposal from the US to add the issue to the Programme of Work for the next biennium. No further proposals were considered.

INF.25 (Germany on behalf of IWG) Status report for the GHS informal working group on combinations of physical hazards – Germany provided updates on the efforts on the Informal working group on combinations of physical hazards. Germany invited any interested delegations to contact the GHS representative from Germany. No proposals were considered.

2024/69 (SAAMI) Use of expert judgment related to explosives testing in GHS Chapter 2.17 – SAAMI discussed the TDG Subcommittee as the focus for the classification of physical hazards and its impact on GHS discussions. They pointed out the concerns in the paper do not impact the Model Regulations but instead address concerns in GHS and in the Manual of Tests and Criteria, Section 5 which applies to sectors other than transport. They pointed out existing 4.1 entries that may be self-classified without explosive testing but might require testing under the GHS. GHS has previously indicated that testing is not required to apply GHS criteria. But SAAMI requested the GHS Subcommittee to explain that expert judgement may be used for classification for 4.1 mixtures. The US felt the existing language in the GHS was clear that additional testing is not required. China differed from the US and believed the proposal should be considered by the Energetics Working Group (EWG) to determine if self-classification is truly possible. The Netherlands agreed with China. The UK requested a deeper explanation as to which UN numbers should be included, the definition of mixture, and the definition and limits of expert judgement. AEISG supported the proposals by SAAMI and pointed out industry is facing problems outlined in the paper. The Subcommittee did not endorse the paper as presented but encouraged further discussion within the EWG. No proposals were considered.

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 proposed changes to the GHS and Manual of Tests and Criteria for mixtures of nitrocellulose. As a consequence of previous discussions in the session, INF.10 included a proposal to modify special provision 393 accordingly. The Subcommittee indicated they would relate to the GHS Subcommittee that proposals A and B and C, as amended by INF.10, were supported. No proposals were adopted.

2024/105 (FEA) Aerosols – alignment of special provision 63 with special provision 362 – Based on previous discussions on this topic, FEA proposed to align the text of Special Provision 63 with associated language in the GHS. This included clarifying that Division 6.1 and Class 8 propellants from PG I are not permitted, and further, aerosols that contained substances listed in the proposed paragraph (f) were also prohibited. Germany offered alternate wording for the standard references in paragraph 14. China suggested paragraph (f)(iii) should be worded in the reverse. The US argued that aerosols containing expellant OR propellant of 6.1/8 PG I were prohibited and offered additional amendments. The Netherlands supported the proposals as amended. FEA agreed with the verbal amendments. Based on the discussion, the Subcommittee agreed to the proposals in 2024/105 as amended.

2024/111; INF.4 (United States); INF.11 (United Kingdom, FEA); INF.45 (United States, United Kingdom, Germany, FEA) Proposal for clarification to the aerosol category 3 criteria – The US noted inconsistencies between GHS category 2 and 3 aerosols. After meeting with interested delegations, they prepared INF.45 to revise categories 1-3 for flammable aerosols. In INF.11, the UK and FEA had provided comments to 2024/111 but those comments were included in INF.45. The Subcommittee endorsed the amendments as presented in INF.45.

INF.26 (Germany) Information about the evaluation of binary sensitivity tests – Germany informed the Subcommittee of binary sensitivity tests that are available for use in both GHS and TDG tests. Evaluation of the testing is important to understand data from binary tests (for example, when a test gives a yes or no response). They encouraged delegations to review the systems. No proposals were considered.

INF.64 (United States) Proposal to cover substances and mixtures that emit flammable vapours and gases in annex 11 of the GHS – The US reported on efforts to address substances that emit flammable vapours and gases but are not already classified based on those properties. The group will continue to review and publish guidance on procedures and examples. No proposals were considered.

2024/77 (COSTHA) UN 3164 installed in equipment or apparatus – COSTHA pointed out discrepancies between different modal regulations as to how UN3164 ARTICLES, PRESSURIZED, PNEUMATIC/HYDRAULIC are treated when installed in equipment. They asked the Subcommittee whether this was intentional or whether it was expected to be a harmonized approach. The US commented that it would be their interpretation that if the article met the exception, then it would always be out of regulation. But if it were being shipped as UN3164, then the machinery would be regulated as such. The Netherlands agreed with the US and did not feel any clarification was necessary. The UK and IATA, however, noted that the original intent of the exception in ICAO was to recognize that if the safety provisions of UN3164 were met and then installed in a piece of equipment, then additional protections would be already applied. Further, identifying a large piece of machinery as UN3164 would be inappropriate. IATA preferred to see a harmonized approach and suggested the ICAO language could be used. COSTHA indicated they would consider proposals for a future session. No proposals were considered.

INF.15 (COSTHA) Flammable gases in non-refillable pressure receptacles – COSTHA explained that the with the introduction of HFO/HFC blends, many of the new refrigerant gases entering the market. They proposed to introduce a new entry: REFRIGERANT GAS, FLAMMABLE, N.O.S. as well as creating a new special provision that details the GHS 1B classification and would allow non-refillable cylinders to be used for these gases up to a 25 L capacity. The US was supportive of the effort and encouraged the issue be presented in a formal paper in the future. COSTHA indicated they would return with a formal proposal for the 66th Session and invited any delegations to contact COSTHA prior to the meeting. No proposals were considered.

INF.14 (COSTHA) Low flammability and non-flammable refrigerant gases – Programme of Work for 2025-2026 – Following from INF.15, COSTHA explained that the non-refillable cylinder limit and new entry were only one of several issues impacting the refrigeration industry. They proposed to include a new agenda item for the 2025-2026 biennium to allow delegations to submit papers on the topic. The Subcommittee was supportive and added the topic to the official Programme for the next Biennium.

INF.52 (United States of America) Evolution of transport systems and the Model Regulations – New agenda item – The United States shared DG transportation has evolved, as has new mechanisms for testing, transporting, and communicating dangerous goods. They proposed adding the effort to the 2025-2026 Program of Work. The Subcommittee was supportive and added the topic to the official Programme for the next Biennium.

INF.55 (Australia) Criteria for flammable liquids under the Model Regulations and the GHS – Australia pointed out small differences between the TDG and GHS criteria for flammable liquids. They shared that a liquid that might be classified as a Class 3 PG I but end up a GHS category 3. They did not propose any changes but requested the TDG Subcommittee consider adding the item to the 2025-2026 Programme of Work. CEFIC opined that GHS and TDG regulate different sectors. And thus, there may be intentional differences between the two sets of regulations. The Subcommittee agreed to add the item to the next biennium.

Hermetically sealed packagings – The Netherlands submitted two documents related to this topic.

  • INF.13 (Kingdom of the Netherlands) Incidents with hermetically sealed packagings – The Netherlands provided examples where hermetically sealed packagings were involved in incidents and noted the problems that led to the incidents.
  • INF.12 (Kingdom of the Netherlands) The usage of the term “hermetically sealed” in the Model Regulations – The Netherlands noted there are 150 entries that require hermetically sealed packaging. Of those, they noted 51% were assigned to Division 6.1 Toxic substances but noted there does not appear to be a clear assignment logic. They believed there is a rationale to apply hermetically sealed packaging to Div. 6.1, PG I and Div. 4.2, PG I.
  • Spain and Belgium supported the effort, agreed the logic should be further considered, and a need to define what is meant by the term. Austria cautioned removing the other hazard classes from such packing assignment as there may be other reasons why hermetically sealed packaging is required for specific entries. CEFIC shared that hermetically sealed should not require zero leakage as practical application to packaging would be impossible. Instead, international standards for inhalation hazards provide clear limits for leakage. They encouraged the Subcommittee to consider industry standards before making any final decisions. The UK questioned whether the incidents involved outbound or inbound shipments. Recently filled packaging may have residual vapor or gas above or around the packaging and may give a false reading of leakage. They agreed with CEFIC and voiced caution in the effort. DGAC shared the comments by CEFIC and the UK.
  • The Netherlands indicated they would return with a formal proposal at the 66th Session. No proposals were considered.

INF.32 (ISO) Updating a reference to ISO Standard in the Manual of Tests and Criteria – No representative from ISO was present. Thus, this paper was carried over to the next session. No proposals were considered.

INF.24 (RECHARGE) Clarification of the requirements for the inner packaging applicable according to the special provision 188 – This paper was withdrawn. No proposals were considered.

INF.46 (China) Amendment to section A6.4.1 of the Manual of Tests and Criteria – China noted an editorial amendment in Appendix 6 of the Manual of Tests and Criteria. There were no oppositions. The Subcommittee agreed for the Secretariat to review and update as appropriate.

INF.47 (China) Proposal to add CAS numbers in lists in 2.5.3.2.4 and 2.4.2.3.2.3 – China pointed out chemical and transport names for self-reactive and organic peroxides may vary when compared to entries in the relevant tables in 2.5.3.2.4 and 2.4.2.3.2.3. They provided examples in Annex 1 to the document. China asked the Subcommittee if adding the CAS number to the lists would be beneficial. Austria supported the effort but noted that providing a single CAS number may be difficult. The US also voiced reservations about maintaining the list and ensuring the CAS numbers assigned are correct. CEFIC noted that CAS numbers do not properly account for mixtures/solutions and were opposed to the approach. China indicated they would consider the comments provided for future work. No proposals were considered.

End of Day 6

–COSTHA