By Andy Altemos, Senior Technical Advisor    January, 2008

The Thirty-Second Session of the United Nations (UN) Sub-Committee of Experts on the Transport of Dangerous Goods was held in Geneva from 3 to 7 December 2007. This was the second of four sessions scheduled to be held in the 2007/2008 biennium. A number of significant issues were discussed. Although in many cases no final conclusions were reached, some amendments to the UN Recommendations on the Transport of Dangerous Goods (“the UN Recommendations” or “the Model Regulations”) were adopted. This report is presented in five parts, by general subject areas such as: Non-Bulk Packaging, Intermediate Bulk Containers, Portable Tanks, and Packaging Provisions, Classification, Limited Quantities, Gases and Cylinders, and Other Matters: Dry Ice, Radioactive Materials, Plant Pathogens, and Electronic Data Interchange.

Geneva: The Thirty-Second Session of the United Nations (UN) Sub-Committee of Experts on the Transport of Dangerous Goods was held in Geneva from 3 to 7 December 2007. This was the second of four sessions scheduled to be held in the 2007/2008 biennium. A number of significant issues were discussed. Although in many cases no final conclusions were reached, some amendments to the UN Recommendations on the Transport of Dangerous Goods (“the UN Recommendations” or “the Model Regulations”) were adopted. Consideration of the unresolved issues is expected at the next session of the Sub-Committee in July 2008 when additional information and revised proposals become available. This summary outlines discussions and decisions related to some of the more significant items on the Sub-Committee's agenda. The report is presented in five parts, by general subject areas.

Part 1: Non-Bulk Packaging, Intermediate Bulk Containers, Portable Tanks, and Packaging Provisions

Packagings, IBCs and Packing Provisions
Several documents were considered by the Sub-Committee which affect packaging standards or packing instructions - two of which were “late” (“INF”) papers raising very significant issues.

Permeability of Plastics Packagings. A late document on this subject was submitted by Germany. It reported the results of a study commissioned by the German Ministry of Transport on the potential for an explosive atmosphere developing in freight containers owing to permeation of flammable liquids through plastics packagings (including intermediate bulk containers (IBCs)). On the basis of calculations and data obtained from the actual transport of instrumented freight containers, the study concluded that, depending on the liquid contained, explosives atmospheres can be generated within freight containers by permeation through commonly used packagings - and in some cases, in relatively short time periods (i.e., hours or days rather than weeks). In the presentation by Germany, the permeability standards in the DOT Hazardous Materials Regulations (HMR) appear to have been particularly called into question. In light of the study, it was suggested by Germany that the current qualitative standard for permeability in the UN Model Regulations (i.e., that any permeation that may occur not constitute a danger under normal conditions of transport) may not be sufficient. Therefore, the German delegation indicated its intent to submit proposals for more specific permeation standards to the next session. It invited comments and suggestions from other delegations in this regard.

Composite IBCs. Another late document, submitted jointly by Australia, Canada and the United Kingdom, noted issues that recently had been identified in connection with the “re-bottling” or “cross-bottling” of composite IBCs. These operations are currently addressed in the UN Model Regulations under the provisions for “repair”, “remanufacturing” and/or “routine maintenance” of IBCs. While it seemed that all of the problems and issues identified in the document were a result of the disregard of the current provisions in the UN Model Regulations governing these operations, the Sub-Committee nevertheless decided to establish an inter-sessional correspondence group to further explore the issues. The correspondence group will examine current practices for composite IBC rebottling and cross-bottling. It will review how the relevant provisions of the Model Regulations are applied in practice. Finally, it will explore the methods used by manufacturers, users, repairers, and remanufacturers to assure quality and production of IBCs that comply with the regulations. The correspondence group is to submit a report of its findings to the July Sub-Committee meeting. At that time any amendments to the Model Regulations necessary to address the issues identified are to be considered.

Packing Instruction 901. Packing Instruction P901, applicable to “Chemical kits” and “First aid kits”, was amended to clarify that when such kits are shipped with dry ice, the current 10 kg limit on the quantity of dangerous goods in the package is exclusive to the mass of the dry ice. In addition, a sentence was added to require that when dry ice is used as a refrigerant, the package must be designed and constructed to permit the release of gaseous carbon dioxide to prevent the build-up of pressure in the package that could rupture the packaging.

Portable tanks
Several proposals addressing the provisions for portable tanks were considered by the Sub-Committee. A document submitted by Canada noted that there is confusion regarding how information is to be displayed on the required metal identification plate for UN portable tanks. For example, are the letters “UN” to be displayed, or should it be the standard UN symbol as used on other types of packagings., Also, the current paragraphs specifying the information required on the metal identification plate for most portable tanks and MEGCs are confusing. They “mingle” the requirements for the listing of information required on the data plate with the format in which that information is to be provided. It was agreed that the information required on portable tank data plates should be clarified and rationalized. Canada is to submit a new document for the July session taking account of the questions and comments offered by the Sub-Committee...

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