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By Andy Altemos, Senior Technical Advisor November, 2007
The DGP completed its work on development of amendments to be incorporated into the 2009/2010 edition of the ICAO Technical. The DGP considered both amendments to align with UN recommendations as well as other amendments. The UN Amendments considered include: Excepted quantities provisions, Environmentally hazardous substances, Radioactive materials, and fuel cells. Other amendments considered include: Requirements for loading cargo aircraft only materials, Cargo aircraft only label, Dry ice, Lithium batteries and Dangerous goods considered “not restricted”. Packing Instructions are covered separately in this issue.
The biennial formal meeting of the full ICAO Dangerous Goods Panel (DGP) was held at ICAO Headquarters in Montreal from 5 to 16 November 2007. The meeting considered several amendments to Annex 18 of the Convention on International Civil Aviation (“the Chicago Convention”), as well as certain non-recurrent work items identified by the DGP or its parent body, the ICAO Air Navigation Commission (ANC). In addition, and what is undoubtedly of most direct relevance to readers, the DGP completed its work on development of amendments to be incorporated into the 2009/2010 edition of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (“the Technical Instructions”). This article will focus on the DGP’s discussions in relation to the latter task by highlighting some of the more significant amendments adopted for incorporation into the Technical Instructions. Readers should note in this connection that corresponding amendments will also be incorporated into the 2009 edition of the IATA Dangerous Goods Regulations (the DGR). Both the 2009/2010 edition of the ICAO Technical Instructions and the 2009 edition of the IATA DGR are expected to take effect from January 1, 2009. Ed. Note: Mr. Altemos discusses the Dangerous Goods Panel’s Adoption of the Revised and Reformatted Packing Instructions on page 11 of this issue.
Amendments to Align with UN Recommendations.
A majority of the amendments to the Technical Instructions adopted by the DGP are intended to implement the amendments to the UN Recommendations on the Transport of Dangerous Goods (“the UN Model Regulations”) adopted by the UN Committee of Experts on the Transport of Dangerous Goods at its meeting in December 2006 - as already incorporated into the Fifteenth Revised Edition of the UN Recommendations. Included in this category of amendment, for example, are a number of amendments to the Dangerous Goods List in the Technical Instructions as necessary to reflect new or amended entries appearing in the List in the UN Recommendations, revisions to the packaging provisions for certain dangerous goods, amendments to the provisions for the construction, testing, and marking of UN packagings, and a host of other amendments. The amendments adopted by the UN were summarized in articles previously appearing in this publication, and for the most part these were incorporated directly into the Technical Instructions without significant discussion or alteration. However, the following issues and amendments arising from the alignment of the ICAO Technical Instructions with the UN Model regulations are of particular note.
Excepted quantities provisions. The DGP adopted amendments to align the ICAO excepted quantities provisions with the new UN provisions for excepted quantities - including transferring the excepted quantities provisions from Section 2.4 in Part 1 to a new Chapter 5 in Part 3. The text of the new Chapter 5 aligns virtually identically with the new Chapter 3.5 in the UN Model Regulations - including the incorporation of the five UN “E-codes” that are used to specify the inner packaging and outer packaging quantity limits for each item of dangerous goods allowed to be transported under the excepted quantities provisions. Use of the E-codes necessitated the addition of a new column in the Dangerous Goods List in Table 3-1 - to be inserted following the current column 8 (“UN packing group”) - in which the appropriate “E-code” will be indicated for each dangerous goods entry permitted to be transported under the excepted quantities provisions. Also adopted in the alignment with the UN Model Regulations is the UN “excepted quantities mark” - which will be required to be displayed on excepted quantities packages in air transport from January 1, 2009.
Environmentally hazardous substances. At the prior formal meeting of the full DGP in 2005, it had been decided that it would be premature to introduce the then-new UN criteria for classification of substances hazardous to the environment and the associated documentation and marking provisions (including the “dead tree and fish” marking) into the ICAO Technical Instructions. This was largely due to the fact that it had been reported that IMO had at that time decided not to implement the new criteria in its International Maritime Dangerous Goods Code (IMDG Code) until January 1, 2009. Since the implementation date for these requirements under the IMDG Code, as well as in various other international modal transport regulations (e.g., the ADR), is approaching, the question of incorporation of the new Class 9 criteria for environmentally hazardous substances into the Technical Instructions was revisited by the DGP. The main issue in this regard was whether classification under these criteria and compliance with the associated description and marking requirements should be made mandatory for air transport under the Technical Instructions, or whether, as is currently provided in Special Provision A97, goods may optionally be classified and otherwise identified in air transport as environmentally hazardous when required under other national or international regulations.
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