While the newly proposed packing instructions are intended to be largely a reordering of the existing requirements, some substantive changes are being introduced which will impact shippers. These changes will be discussed at the forthcoming Dangerous Goods Panel meeting when HAZMAT Packager & Shipper again provides a detailed report on the decisions of the DGP

Background
A new proposed set of ICAO packing instructions was released by the ICAO Secretariat for comment on August 17. If adopted the proposed packing instructions would replace most of the packing instructions currently provided in Part 4 of the ICAO Technical Instructions on the Safe Transport of Dangerous Goods by Air. Commenters were given until September 21 to review and provide formal comments. The new proposal and comments will be considered at the 21st session of the Dangerous Goods Panel (DGP21) to be held in early November 2007. This analysis, prepared by the technical advisory staff of HAZMAT Packager & Shipper, looks at this new effort.
A previous report on the results of the Memphis ICAO DGP meeting, and “select group” on the Packing Instructions appears in the May/June 2007 issue of HAZMAT Packager & Shipper, p. 10.

When the ICAO Dangerous Goods Panel met as a Working Group (ICAO WG) in Memphis, TN in the spring of this year, significant issues on a version of the packing instructions were raised in working papers and through online comments ICAO received. Based on comments, a small group consisting of representatives from the United Kingdom, the United States and IATA met to consider what changes to the proposed packing instruction document were acceptable to them. At that time, it was agreed that the group would produce by August a revised document following a basic outline provided to the Memphis ICAO WG, so as to afford the opportunity for those affected to provide comments by September.

While the August 2007 document (DGP/21-WP/4) containing the newly revised packing instructions is identified as the result of a working group, the term working group is a misnomer. The group preparing the document was not a working group in the sense normally understood at international meetings. Instead this proposal is the result of three ICAO participants – the UK, the US and IATA. In this respect it would be more appropriate to call this document a joint proposal by three ICAO Panel members.

While the revised packing instructions are an improvement over the last packing instruction proposal, lingering concerns remain. The concerns can be grouped into three categories, including:

1. New requirements;
2. Ease of use; and
3. Implementation.

Each of these is discussed. To facilitate understanding, an example of a family of packing instructions as provided in DGP/21-WP/4 is shown in the figure at the end of this report. This series of packing instructions is for class 3 materials with or without subsidiary risks.

NEW REQUIREMENTS
While the packing instructions are intended to be largely a reordering of the existing requirements, some substantive changes are being introduced in the proposal. Substantive changes may correct existing requirements; some may be the consequence of improving consistency among substances of comparable hazard; and others are unrelated to reformatting based on the drafters opinions of how to enhance safety. CEFIC representing the European Chemical Industry and having advisory status at the Dangerous Goods Panel has recently submitted a six page document highlighting detailed substantive changes and questioning the need for them. These comments will be discussed at DGP21.

Examples of substantive changes include:

1. Inner packagings for PG I liquids would be required to be contained in a liner with absorbent material. The added volume required to accommodate absorbent material will likely mean that packagings for PG I liquids will have to be redesigned and retested.

2. Inner packagings containing PG II and III liquids would have to be fitted with a secondary means of holding the closure in place (e.g., tape, friction sleeves, locking wires). If a secondary means is not practicable, the inner packagings will have to be placed in a liner.

3. Bags would no longer be authorized for UN 3077 Environmentally Hazardous Solids NOS, and

4. Plywood drums (1D), fiber drums (1G) and metal jerricans would be eliminated as possible single packagings or as a possible outer packaging for combination packagings in the case of many packing instructions.

5. Some substances would be forbidden from transport by passenger aircraft, cargo and passenger aircraft or as limited quantities.

The first two examples of changes were included on DOT’s (PHMSA and FAA) initiative as part of their effort to reduce leakages from packages being shipped by air. As reported in the July/August 2007 edition of Hazmat Packager and Shipper, PHMSA convened a public meeting on June 21on improving the integrity of packagings used in air transport. At that meeting PHMSA stated its intent of using a rationalized, data driven approach based on risk/cost assessments in its effort to decrease air incidents. The two example proposals appear to be a deviation from this stated approach in that no clear justification has yet been provided. While other ICAO participants have recommended keeping substantive changes unrelated to reformatting out of the document, the DOT has insisted that they be included.

The latter three examples represent changes that can only be identified through a comprehensive evaluation as has been done by CEFIC. No explanation has yet been provided for these changes. These and many others will likely have to be discussed point by point at DGP21.

The above changes and others identified by CEFIC aside, the new packing instructions are not likely to significantly impact the manner in which the vast majority of substances are packaged and transported under the ICAO TI. Authorized packagings in common use will continue to be authorized with quantity limits adjusted up or down in some cases, based on the author’s method of taking each substance’s hazards into account in assigning quantity limits. The reformatted packing instructions are for the most part a reorganization of existing packing instruction requirements.

With changes being relatively minor, one has to then consider whether reorganization is worthwhile, and whether the costs of changing justify substituting the proposed packing instructions for the present ones.

EASE OF USE
In embarking on the effort to reformat the packing instructions, earlier DGP meetings identified a number of objectives that relate to the ease of using the packing instructions including changes that would

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