By Andy Altemos, Senior Technical Advisor    July, 2007

The Thirty-First Session of the United Nations (UN) Sub-Committee of Experts on the Transport of Dangerous Goods was held in Geneva from 2 to 6 July 2007. This was the first session of the Sub-Committee in the 2007/2008 biennium. In his report, Mr. Altemos highlights the salient aspects of the meeting. Major topics include packaging, consumer commodities, limited quantities, dangerous goods entries, classification, provisions for gases, definitions, and training.

Editors Note: The official draft of the UN Sub-Committee meeting minutes and the report of the working group on limited quantities can be found on HAZMAT Packager & Shipper HazMat Reference Gateway at www.hazmatship.com where this presentation is now posted.

The Thirty-First Session of the United Nations (UN) Sub-Committee of Experts on the Transport of Dangerous Goods was held in Geneva from 2 to 6 July 2007. This was the first session of the Sub-Committee in the 2007/2008 biennium. Bob Richard, Deputy Associate Administrator of DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA), assumed his new role as Sub-Committee chairman, and Claude Pfauvadel, the representative of France on the Sub-Committee, served as vice-chairman.

As is typical of any first session of the two-year cycle on which the Sub-Committee operates, a number of items were discussed but relatively few final decisions of substance were taken. Decisions on many of the issues discussed were postponed for further consideration at a future session based on additional information to be developed. Nevertheless, the Sub-Committee considered several important matters and adopted a number of amendments to the UN Recommendations on the Transport of Dangerous Goods (“the Model Regulation”). This summary outlines the Sub-Committee's discussions and decisions on some of the more significant items found on the agenda.

Publication of the Updated UN Recommendations
The Fifteenth Revised Edition of the UN Recommendations, incorporating the amendments adopted by the Committee of Experts at its most recent session in December 2006, has been published and made available to the Sub-Committee members. In addition, Amendment 2 to the UN Manual of Tests and Criteria should be published shortly - again consisting of amendments adopted by the Committee in December 2006.

PART 1 - PACKAGING

Packaging and Packaging Provisions
The Sub-Committee adopted a Spanish proposal to amend the criteria in 6.1.5.3.6.3 for passing the drop test for composite and combination packagings. The intent of the amendment is to clarify the extent to which an outer packaging may be ruptured or breached, and the package still be considered to have passed the test. This was done by adding a condition that “inner receptacles, inner packagings, or articles shall remain completely within the outer packaging”. A second proposal by Spain to revise the provisions prescribing the height of the drop for “large packagings” in 6.6.5.3.4.4 to align the presentation with the corresponding drop test provisions for (non-bulk) packagings in 6.1.5.2.5 was also adopted. However, these changes are editorial in nature, and do not result in any substantive change to the drop heights required for the testing of large packagings.

As a result of the decision taken during the last biennium to add an additional provision to the criteria for passing the drop test for IBCs, a new 6.5.6.9.5(d) now appears in the UN Model Regulation. This paragraph provides that, after performance of the required drop, IBCs may not exhibit loss of contents or damage which renders the IBC unsafe to be transported for salvage or disposal It must be capable of being lifted by appropriate means until clear of the floor, for five minutes. A late “INF” document submitted by France suggested that a suitable transitional period for this additional requirement should be adopted along the same lines as the transitional provision that had been adopted for the IBC vibration test also newly incorporated into the latest edition of the UN Model Regulation. The Sub-Committee agreed, and provisions were adopted to clarify that IBCs manufactured before 1 January 2011, and which conform to a design type which was not required to meet the new 6.5.6.9.5(d) at the time the drop test was performed, may continue to be used.

Based on a proposal by the United States, the new Packing Instruction P804 for bromine (UN 1744) was revised to require the use of intermediate metal packagings when bromine is packaged in combination packagings. The Sub-Committee agreed that this requirement had been inadvertently omitted from the new packing instruction, and that this change should go forward immediately as a correction to the current edition of the UN Model Regulation. The United Kingdom representative noted that this could cause serious problems as some bromine producers have for many years employed plastic intermediate packagings. The Sub-Committee recognized this as a problem, but decided that the introduction of an additional provision allowing plastic intermediate packagings would, in fact, be a “change” to the packing requirements that could not also be processed immediately as a “correction”. However, in its report the Sub-Committee invited the modal regulatory agencies to take account of this problem when incorporating the new Packing Instruction P804 into the modal transport regulations.

A document by the International Air Transport Association (IATA) noted that the UN Model regulation Packing Instruction P099 (packaging to be approved by the competent authority) was indicated for a number of entries for which either Packing Instruction P001 or P002, as appropriate, was referenced in one or more of the modal transport regulations or in the DOT regulations. Based a proposal in this document, the Sub-Committee agreed to replace the reference to P099 in nine Dangerous Goods List entries with a reference either to P001 or P002 - depending on whether the entry covered a liquid or solid material.

The International Dangerous Goods and Containers Association (IDGCA) had proposed to revise the definition for flexible intermediate containers (FIBCs) to allow a maximum capacity of 10 cubic meters only for transport of Packing Group III solids. This suggestion was met with a rather cool reception for various reasons - not the least of which was that most Sub-Committee members did not believe there was a demonstrated interest or need for such packagings. However, there was some interest in the concept so IDGCA indicated an intention to submit another proposal in a future session.

Packing Instruction P620, applicable to Category A infectious substances, was amended to include a provision already appearing in Packing Instruction 650. This is to except from regulation up to 30 ml of dangerous goods in Classes 3, 8 or 9, included in the package (1) for stabilizing the infectious substance, (2) for maintaining its viability, (3) for preventing the degradation of the infectious substance, or (4) for neutralizing the infectious substance.

A United States document noted that certain portable tank instructions (namely, “T9” and “T21”) were assigned to a limited number of Packing Group I solids - for example, certain solid organometallic substances entries. These tank instructions do not allow bottom outlets on portable tanks - which in the case of solid substances makes loading and unloading difficult if not impossible. Therefore, the United States proposed to add a footnote to the table of portable tank instructions in 4.2.5.2.6. This footnote would state that when the “Bottom outlets” column in the table indicates for a particular packing instruction that bottom outlets are “Not Allowed”, bottom outlets conforming to the requirements of 6.7.2.6.2 (two serially mounted closures) nevertheless are authorized. This would be on the condition that the substance to be transported in the tank is a solid at all temperatures encountered under normal conditions of transport. This proposal was adopted.

PART 2 – CONSUMER COMMODITIES AND LIMITED QUANTITIES

Limited Quantities and Excepted Quantities
After several unsuccessful attempts over the last four years to reach an agreement on provisions for “consumer commodities”, the Sub-Committee again tackled the question - this time based on a proposal by the Association of Hazmat Shippers (AHS). The AHS proposal was relatively simple. Basically, the proposal was to establish a new UN number without an actual shipping description associated with the number, but rather with a cross reference to a paragraph in the “limited quantities” provisions in Chapter 3.4. This paragraph would state that this UN number be marked within the limited quantities diamond marking when the goods on the package were “consumer products ready for use, which are substances intended or suitable for retail sale or distribution for personal or household consumption, including pharmaceutical products”.

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