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June 4, 2014 1 UNECE Sub-Committee of Experts on the Transport of Dangerous Goods Forty-fifth session Geneva, 23 June 2 July 2014 http://www.unece.org/trans/danger/meetings.html http://www.unece.org Industry Segment UN Paper Summary Agenda Item 1: Adoption of the Agenda ST/SG/AC.10/C.3/89 17 January 2014 Provisional agenda for the forty-fifth session DOC PDF ST/SG/AC.10/C.3/89/Add.1 11 April 2014 Provisional agenda for the forty-fifth session Addendum DOC PDF UN/SCETDG/45/INF.12 2 June 2014 Provisional timetable Note by the secretariat DOC PDF Agenda Item 2 (a): Explosives and related matters: tests and criteria for flash compositions Explosives ST/SG/AC.10/C.3/2014/59 In the year 2000, a large explosion in a fireworks storage facility in Enschede in the Netherlands occurred. It became obvious that a lot of fireworks was not correctly classified and after extensive

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Page 1: Agenda Item 1: Adoption of the Agenda ST/SG/AC.10/C.3/89 45 Doc... · 2014-06-17 · Agenda Item 1: Adoption of the Agenda ST/SG/AC.10/C.3/89 17 January 2014 Provisional agenda for

June 4, 2014 1

UNECE Sub-Committee of Experts on the Transport of Dangerous Goods

Forty-fifth session Geneva, 23 June – 2 July 2014

http://www.unece.org/trans/danger/meetings.html http://www.unece.org

Industry Segment UN Paper Summary

Agenda Item 1: Adoption of the Agenda

ST/SG/AC.10/C.3/89 17 January 2014 Provisional agenda for the forty-fifth session

DOC PDF

ST/SG/AC.10/C.3/89/Add.1

11 April 2014 Provisional agenda for the forty-fifth session Addendum

DOC

PDF

UN/SCETDG/45/INF.12

2 June 2014 Provisional timetable Note by the secretariat

DOC

PDF

Agenda Item 2 (a): Explosives and related matters: tests and criteria for flash compositions

Explosives ST/SG/AC.10/C.3/2014/59

In the year 2000, a large explosion in a fireworks storage facility in Enschede in the Netherlands occurred. It became obvious that a lot of fireworks was not correctly classified and after extensive

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June 4, 2014 2

7 April 2014 Classification of fireworks Transmitted by the expert from the Netherlands

DOC

PDF

discussions the default table for the classification of fireworks was developed and introduced in the Model Regulations in 2005.

Explosives UN/SCETDG/45/INF.5 16 April 2014 Behaviour of waterfalls in large quantities; results of a research project Transmitted by the expert from the Netherlands

DOC

PDF

In document ST/SG/AC.10/C.3/2014/59 the expert from the Netherlands proposes changes to the classification of fountains and to the default table with regards to 1.1G classification of fountains, with consequential amendments in paragraph 2.1.3.5.1, note 2 of 2.1.3.5.5 and Appendix 7.

Agenda Item 2 (b): Explosives and related matters: Review of test series 6

Explosives

NAAHAC

ACR

ST/SG/AC.10/C.3/2014/1 3 February 2014

Manual of Tests and Criteria

Correction to Figure 10.3: Procedure for Assignment to a Division of Class 1 Transmitted by the Institute of Makers of Explosives (IME) and the Sporting Arms & Ammunition Manufacturers’ Institute (SAAMI)

DOC PDF

At the forty-third session of the Sub-Committee (TDG), the

Working Group on Explosives (EWG) discussed a problem with

the flow chart in Figure 10.3 of the Manual of Tests and Criteria.

The EWG was of the opinion that the flow from Box 32 to 33

infers that the 6 (d) test is required for all 1.4S candidates. The

EWG noted that this is not the case, as the 6 (d) test is only

required for the eight 1.4S entries to which special provision 347

applies.

Explosives ST/SG/AC.10/C.3/2014/4

14 March 2014

In Introduction, reports on the status of the review of the Series 6 Tests in the UN Manual of Tests and Criteria

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June 4, 2014 3

Manual of Tests and Criteria

Recommendations for improvement of the Series 6

Tests

Transmitted by the Institute of Makers of Explosives

(IME)

DOC PDF

Explosives ST/SG/AC.10/C.3/2014/42

1 April 2014

Proposal for an alternative for the test 6 (c) for the

testing of CARTRIDGES, SMALL ARMS (UN No.

0012)

Transmitted by the expert from Germany

DOC

PDF

In accordance with paragraph 16.6.1.1 of Section 16 of the Manual of Tests and Criteria (ST/SG/AC.10/11/Rev.5), the Test 6 (c) is performed on packages of an explosive substance or explosive articles, or unpackaged explosive articles, to determine whether there is a mass explosion or a hazard from dangerous projections, radiant heat and/or violent burning or any other dangerous effect when involved in an external fire.

Explosives ST/SG/AC.10/C.3/2014/42 1 April 2014 Proposal for an alternative for the test 6 (c) for the testing of CARTRIDGES, SMALL ARMS (UN No. 0012) Transmitted by the expert from Germany

DOC

PDF

In accordance with paragraph 16.6.1.1 of Section 16 of the

Manual of Tests and Criteria (ST/SG/AC.10/11/Rev.5), the Test

6 (c) is performed on packages of an explosive substance or

explosive articles, or unpackaged explosive articles, to

determine whether there is a mass explosion or a hazard from

dangerous projections, radiant heat and/or violent burning or

any other dangerous effect when involved in an external fire.

Explosives ST/SG/AC.10/C.3/2014/53 At the previous session of the Sub-Committee of Experts on the

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June 4, 2014 4

1 Informal document INF.58, para. 13

4 April 2014 Manual of Tests and Criteria Proposed field-portable gas fuel UN 6(c) test assembly Transmitted by the expert from the United States of America

DOC

PDF

Transport of Dangerous Goods, the United States of America

described research in the development of a practical and field-

portable gas fuel UN test 6(c) assembly (see informal document

INF.47, 44th session).

Agenda Item 2(c): Explosives and related matters: Review of tests in parts I and II of the Manual of Tests and Criteria

Explosives ST/SG/AC.10/C.3/2014/6 17 March 2014 Manual of Tests and Criteria Recommendations for Improvement of Series 1 (a) and 2 (a) Gap Tests and Series 1 (c) and 2 (c) Time/Pressure Tests Transmitted by the Institute of Makers of Explosives (IME)

DOC

PDF

At the thirty-ninth session of the Sub-Committee, the Working Group on Explosives (EWG) discussed issues of difficulty in conducting tests outlined in the Manual of Tests and Criteria, and recommended to the Sub-Committee1 that the EWG conduct a review of the tests mentioned in Parts I and II of the Manual with a view to

Explosives ST/SG/AC.10/C.3/2014/11

24 March 2014

At the forty-first session of the Sub-Committee (TDG), 25 June –

4 July 2012, the Chairman of the Working group on Explosives

submitted a paper on the “Difficulties in carrying out

classification tests” (refer INF.26, 2012), outlining:

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June 4, 2014 5

Manual of Tests and Criteria

Review of Test Series 8

Transmitted by the Australian Explosives Industry

and Safety Group Inc. (AEISG)

DOC

PDF

Explosives UN/SCETDG/45/INF.4

17 April 2014

Review of tests in parts I and II of the Manual of

Tests and Criteria

Transmitted by the Chairman of the Working Group

on Explosives

DOC

PDF

In document ST/SG/AC.10/C.3/2013/43, submitted for the 44th

session, proposals for the improvement of Test Series A, C and E

and the corresponding tests in Test Series 1, 2, 8 and Appendix 7

are given. This informal document was earlier submitted as

informal document INF.6 at the 44th session and gives the

proposed changes to the current text of the Manual of Tests and

Criteria highlighted with “track changes”. The full text is given on

the next pages.

Agenda Item 2(d): Explosives and related matters: review of packing instructions for explosives

Explosives ST/SG/AC.10/C.3/2014/20

27 March 2014 Review of packing instructions for explosives Transmitted by the Sporting Arms & Ammunition Manufacturers’ Institute (SAAMI)

DOC

PDF

At the forty-third session of the Sub-Committee, SAAMI submitted ST/SG/AC.10/C.3/2013/18. SAAMI sought a clarifying amendment that when metal packagings are not allowed by PP48, packaging components representing a minimal percentage of the overall package can still be metal. The intent was to allow light weight lids of sheet metal on plastic packages for UN 0509. The discussion was summarized in the report of the Working Group on Explosives in paragraph 12 of informal document INF.61/Rev.1. The working group agreed with the proposal in principle.

Agenda Item 2(e): Explosives and related matters: Miscellaneous

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June 4, 2014 6

Explosives ST/SG/AC.10/C.3/2013/3 23 January 2014 Classification of Ammunition, Smoke, containing titanium tetrachloride Transmitted by the expert from Austria

DOC PDF

With the introduction of N.O.S entries for TOXIC BY INHALATION substances and the identification in the dangerous goods list of substances which are toxic by inhalation (Special Provision 354), the classification of UN 1838 TITANIUM TETRACHLORIDE was changed from class 8 to class 6.1. There was no change regarding the entries for “Ammunition, Smoke”, although titanium tetrachloride is referred to as a smoke-producing agent.

Explosives ST/SG/AC.10/C.3/2014/5 14 March 2014 Harmonized international standard for explosives traceability markings Transmitted by the Institute of Makers of Explosives (IME)

DOC PDF

Establish a harmonized format for such markings and add a new section 1.4.4 to Chapter 1.4 of the Model Regulations that describes said harmonized format.

Explosives ST/SG/AC.10/C.3/2014/22

27 March 2014

Classification of articles under UN No. 0349 Transmitted by the expert from Italy

DOC

PDF

Paragraph 2.1.2.1.1 of the Model Regulations on the Transport of Dangerous Goods states that the 1.4S classification code can be assigned in case of:

Explosives ST/SG/AC.10/C.3/2014/37

1 April 2014 Treatment of examples in Section 1.1.2 of the Manual of Tests and Criteria

At the forty-third session, the Sub-Committee considered SAAMI’s proposal ST/SG/AC.10/C.3/2013/17 to amend the introductory portions of the Manual of Tests and Criteria. SAAMI suggested to append text to section 1.1.2 to provide instruction for the use of examples within test procedures. This is because classification activities have been impeded by prescriptive enforcement of these examples without benefit to safety.

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June 4, 2014 7

Transmitted by the Sporting Arms and Ammunition Manufacturers’ Institute (SAAMI)

DOC

PDF

Explosives ST/SG/AC.10/C.3/2014/39

1 April 2014 New entry for “Rocket motors” 1.4C Transmitted by the expert from Canada

DOC

PDF

Three entries exist for rocket motor articles consisting of solid

propelling charges in the Dangerous Goods List of Chapter 3.2

of the Model Regulations:

(a) UN0186, ROCKET MOTORS, 1.3C

(b) UN0280, ROCKET MOTORS, 1.1C

(c) UN0281, ROCKET MOTORS, 1.2C

Explosives ST/SG/AC.10/C.3/2014/48 3 April 2014 Determination of friction sensitiveness using the Allegany Ballistics Laboratory (ABL) friction machine Transmitted by the expert from the United States of America

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Sensitiveness of a substance to friction stimuli must

be determined to ensure the safety of people and

protection of property during shipment.

Explosives ST/SG/AC.10/C.3/2014/51 7 April 2014 Determination of impact sensitiveness using the Modified Bureau of Mines (MBOM) Impact Machine Transmitted by the expert from the United States of America

DOC

PDF

Sensitiveness of a substance to impact stimuli must be

determined to ensure the safety of people and protection of

property during shipment.

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June 4, 2014 8

Explosives ST/SG/AC.10/C.3/2014/52 3 April 2014 Thermal stability test at 75°C using the simulated bulk auto-ignition temperature (SBAT) apparatus Transmitted by the expert from the United States of America

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Determination of the thermal stability of a substance is required to

ensure the safety of people and protection of property during

storage and transport. The current test methodology can present

significant hazards during handling of 50 to 100 grams of primary

explosive material. We recommend that an additional test be

added to Type 3(c) for determining the thermal stability of a

substance. The SBAT thermal stability test significantly reduces

the hazards during handling, has equivalent or better temperature

control and temperature monitoring, and matches the sensitivity

of the existing instrumented thermal stability test in Test 3(c).

Explosives ST/SG/AC.10/C.3/2014/55 7 April 2014 Proposal to clarify what is meant by; “as presented for transport” in SP280 Transmitted by the Council on Safe Transportation of Hazardous Articles (COSTHA)

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UN3268 has the special provision of SP280 which states;

“This entry applies to safety devices for vehicles, vessels or

aircraft, e.g. air bag inflators, air bag modules, seat-belt

pretensioners, and pyromechanical devices, which contain

dangerous goods of Class 1 or of other classes, when

transported as component parts and if these articles as

presented for transport have been tested in accordance with

Test Series 6(c) of Part 1 of the Manual of Tests and Criteria,

with no explosion of the device, no fragmentation of device

casing or pressure receptacle, and no projection hazard nor

thermal effect which would significantly hinder fire-fighting or

emergency response efforts in the immediate vicinity.”

Explosives UN/SCETDG/45/INF.10

19 May 2014 Proposal concerning the format of approvals issued by Competent Authorities for Class 1 Dangerous Goods Transmitted by the expert from the United Kingdom

DOC

PDF

As part of the underlying principles of the Model Regulations,

competent authorities are charged with ensuring compliance

with the Regulations, including the monitoring of the

classification of dangerous goods, to ensure the requirements

of the Regulations are being met in practice. As part of its role

in ensuring that the safety obligations of the various participants

in the modal regulations are met, the competent authority for

the United Kingdom is often called upon to consider Competent

Authority Documents1 (CAD) produced by a number of

competent authorities for the classification of substances and

articles in Class 1 (Explosives).

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June 4, 2014 9

Agenda Item 3: Global harmonization of transport of dangerous goods regulations with the Model Regulations

Consumer Products

Retailers

Chemical

Manufacturers

ST/SG/AC.10/C.3/2014/38 1 April 2014 Assignment of flammable liquids in packing group II to packing group III according to their viscosity Transmitted by the International Paint and Printing Ink Council (IPPIC)

DOC

PDF

In accordance with the provisions of 2.3.2.2 in the Model Regulations, viscous flammable liquids of Class 3, such as paints, enamels, lacquers and varnishes, can be placed in packing group III on the basis of their viscosity, coupled with other criteria. The table in 2.3.2.2(a) includes viscosity criteria expressed as the flow time in seconds from a flow cup test.

IVODGA

Chemcial Manufacturers

ST/SG/AC.10/C.3/2014/41 7 April 2014 Packagings for water-reactive materials Transmitted by the expert from Germany

DOC

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During the last session, the Sub-Committee took note of International Maritime Organization’s (IMO) decision to strengthen the provisions on packagings for substances which react dangerously with water (see ST/SG/AC.10/C.3/2013/41 together with informal documents INF.3, INF. 4 and INF.5).

Agenda Item 4(a): Listing, classification and packing: polymerizing substances

Chemical Manufacturers

ST/SG/AC.10/C.3/2014/31

31 March 2014 Classification of polymerizing (stabilized) substances Transmitted by the Dangerous Goods Advisory Council (DGAC)

DOC

PDF

At its prior two sessions the Sub-Committee

considered the question of the classification of

polymerizing substances not meeting the criteria for

any hazard class on the basis of documents

submitted by DGAC, most recently, at the forty-fourth

session, document ST/SG/AC.10/C.3/2013/62. While

no final conclusions were reached, several

fundamental principles were agreed regarding the

classification of such substances. Importantly, and

based on input from the IGUS Energetic and

Oxidising Substances Group (EOS), it was agreed

that such substances should not be classified as self-

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June 4, 2014 10

reactive substances of Division 4.1, and need not be

evaluated under the associated test regime.

Moreover, while DGAC had originally suggested

addressing only substances that are stabilized by

temperature control, several Sub-Committee

members expressed the view that chemically

stabilized substances should also be considered.

Varying views were offered regarding an appropriate

class in which to place these substances, with

Divisions 4.1 and 4.2, and Class 9 offered as

candidates, as well as the possibility of a new

Division 4.4 – although it was questioned whether

the number of substances that might be addressed

and the risk posed warranted a new division with

associated new labels and placards. Based on these

prior discussions, DGAC has continued to consider

this question, and now offers the proposals in this

document for consideration by the Sub-Committee.

Agenda Item 4(b): Listing, classification and packing: Classification inconsistencies (application of criteria versus dangerous goods list)

Chemical Manufacturers

ST/SG/AC.10/C.3/2014/23 28 March 2014 Classification inconsistencies (application of criteria versus dangerous goods list) Transmitted by the European Chemical Industry Council (CEFIC)

DOC

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In the report of the Sub-Committee on its forty-third session held in Geneva from 24 to 28 June 2013 (ST/SG/AC.10/C.3/86), the following summary on the discussion is shown:

Chemical Manufacturers

ST/SG/AC.10/C.3/2014/40

There are four UN entries related to ammonia and its aqueous solutions (UN 1005, UN 3318, UN 2073 and

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June 4, 2014 11

2 April 2014 Classification of ammonia solutions Transmitted by the expert from Fertilizers Europe

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UN 2672). There are inconsistencies in the classification of one of the entries, UN 2073.

Agenda Item 4(c): Listing, classification and packing: miscellaneous

Aerosol WG

Consumer Products

Retailers

Life Sciences

ST/SG/AC.10/C.3/2014/7 12 March 2014 Packaging provisions for waste aerosols Transmitted by the expert from the United Kingdom

DOC

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The expert from the United Kingdom believes that there are some anomalies in the large packaging provisions for waste aerosols

ST/SG/AC.10/C.3/2014/10 24 March 2014 UN 3170 Aluminium smelting by-products or aluminium remelting by-products Transmitted by the experts from Spain and Norway

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The aim of this proposal is to ensure safety in the transport of UN 3170 ALUMINIUM SMELTING BY-PRODUCTS or ALUMINIUM REMELTING BY-PRODUCTS

ST/SG/AC.10/C.3/2014/13

24 March 2014 Editorial amendment to P 906 Transmitted by the expert from Germany

DOC

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An amendment to the proper shipping name of Nos. 3151 and 3152 was adopted on the basis of document ST/SG/AC.10/C.3/2013/55 (Germany) during the last session of the Sub-Committee. The scope of those two shipping names was extended to cover halogenated monomethyldiphenylmethanes which have similar chemical and ecotoxicological properties to polychlorinated biphenyls (PCBs) and polychlorinated terphenyls (PCTs).

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Radioactive ST/SG/AC.10/C.3/2014/21

27 March 2014 Neutron radiation detectors – minor amendments Transmitted by the Dangerous Goods Advisory Council (DGAC)

DOC

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This document seeks to resolve a difficulty with the requirements in the final paragraph of SP373 as they pertain to small radiation detection systems (i.e., with 1 gram or less of boron trifluoride per detector). SP373 was adopted for inclusion in the eighteenth revised edition, on the basis of ST/SG/AC.10/C.3/2012/60 (and Corr.1). It covers the transport of neutron radiation detectors and detection systems containing small amounts of boron trifluoride at low pressures and in high integrity containment devices (radiation detectors).

Consumer Products

Retailers

Chemical

Manufacturers

NAAHAC

ST/SG/AC.10/C.3/2014/32 31 March 2014 Polyester resin kits containing Division 4.1 substances Transmitted by the Dangerous Goods Advisory Council (DGAC)

DOC

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DGAC has become aware that the base material in some polyester resin kits may not meet the definition of Class 3 (Flammable liquid) and would more appropriately be described as a Division 4.1 (Flammable solid). Currently polyester resin kits are limited to those with a Class 3 (Flammable liquid), Packing Group II or III base material component. These kits are consigned under the entry UN 3269, Polyester resin kit, PG II or PG III. It is proposed that a new entry be included in the Dangerous Goods List (DGL) for polyester resin kits that contain a Division 4.1 (Flammable solid), Packing Group II or III substance as the base material. If approved, this would permit products with a viscous base component containing flammable solvent(s) (e.g., styrene monomer) that do not meet the definition of a liquid; however, are considered a flammable solid when tested according to the Model Regulations.

ACR ST/SG/AC.10/C.3/2014/33 31 March 2014 Clarification of requirements applicable to UN 2000, celluloid Transmitted by the Dangerous Goods Advisory Council (DGAC)

DOC

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At a previous session, the Sub-Committee agreed to include a provision in 2.2.2.4 to indicate that sports balls are not subject to the Model Regulations. 2.2.2.4 states: “Gases of Division 2.2 are not subject to these Regulations when contained in the following: Balls intended for use in sports”. Nevertheless, it has come to DGAC’s attention that some manufacturers of tennis table (ping pong) balls that are manufactured from celluloid are transporting them as regulated goods under the entry UN 2000, Celluloid. Some airline personnel and competent authorities have suggested that celluloid tennis table balls are subject to the transport regulations and questioned whether the exception in 2.2.2.4 applies. DGAC has uncovered Safety Data Sheet documents related to celluloid tennis table balls. While some may think that it should be obvious that celluloid table tennis balls are

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not subject to the Model Regulations there appears to be a need for clarification.

ST/SG/AC.10/C.3/2014/43 1 April 2014 PP83 Transmitted by the expert from the United Kingdom

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PP83 was first included the thirteenth edition of the Model Regulations and was primarily intended to allow the carriage of UN 2813 (water reactive solid, n.o.s.) in small quantities in inner packagings without the threaded closures previously required under P403. The main usage was foreseen as a heating mechanism for ready meals for military personnel, campers and hikers.

Chemical Manufacturers

Oil Industry

ST/SG/AC.10/C.3/2014/49 2 April 2014 Classification and hazard communication provisions for crude oil Transmitted by the experts from Canada and the United States of America

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North America is experiencing a significant increase in crude oil supply, bolstered both by growing production in the Canadian oil sands and the recent expansion of shale oil and natural gas production in the United States of America and Canada.

ACR

Life Sciences

ST/SG/AC.10/C.3/2014/50 7 April 2014 Provisions for insulation of packages containing dry ice Submitted by the expert from the United States of America

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In January 2010 research was initiated through the United States of America Transportation Research Board (TRB) to develop a decision tool(s) to assist passenger and cargo-only aircraft operators in determining the maximum quantity of dry ice that can be safely carried as cargo. As part of the research, the properties of dry ice and packaging were explored and, in particular, heat transfer analysis was conducted to determine the correlation between package (and unit load device) insulation and sublimation rates. The research is now complete and the final report is freely available on the web at the following URL: http://apps.trb.org/cmsfeed/TRBNetProjectDisplay.asp?ProjectID=2661

Chemical Manufacturers

ST/SG/AC.10/C.3/2014/57 4 April 2014 Packing requirements for UN1873

At the forty-third session, COSTHA presented in documents ST/SG/AC.10/C.3/2013/30 and informal document INF.5 arguments and test data supporting the compatibility of packagings constructed of plastic with high concentration perchloric acid. Comments received during the forty-third session were included in document ST/SG/AC.10/C.3/2013/64 which was

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Transmitted by the Council on Safe Transportation of Hazardous Articles (COSTHA)

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presented at the forty-fourth session. Discussion during the forty-fourth session resulted in the creation of informal document INF.50 (44th session).

Radioactive ST/SG/AC.10/C.3/2014/60 9 April 2014 Subsidiary risks for uranium hexafluoride Transmitted by the expert from Austria

DOC

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A proposal for a new UN number was approved by the IAEA Transport Safety Standards Committee at its twenty-second session (TRANSSC 22, June 2011). It was recommended to establish a fifth UN number for “Radioactive material, excepted package” for uranium hexafluoride (UF6) with less than 0.1 kg per package.

Chemical Manufacturers

UN/SCETDG/45/INF.6 4 April 2014 Packing requirements for UN1873 Additional information (Test Report) relating to ST/SG/AC.10/C.3/2014/57 Transmitted by the Council on Safe Transportation of Hazardous Articles (COSTHA) PDF

UN/SCETDG/45/INF.13

23 May 2014 Classification under UN 2211 and UN 3314 Transmitted by the European Chemical Industry Council (CEFIC)

As earlier has been demonstrated in proposal ST/SG/AC.10/C.3/2011/30 concerning Polymeric beads, expandable and Plastics moulding compounds, evolving flammable vapours, there is a big difference in respect of different materials ability to give off flammable vapours. Due to these differences it was suggested to implement a new method that could determine if there was a risk for formation of flammable atmospheres in the container or not

UN/SCETDG/45/INF.15 Labelling of UF6 packages with a radioactive label and a

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3 June 2014 WNTI Information Position Paper on UF6 Subsidiary Hazards (Results of extended/continued literature search) Transmitted by the World Nuclear Transport Institute (WNTI) WNTI Position paper on UF6 subsidiary hazards (May 2014)

DOC

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corrosive label has been practised for decades, based on decisions taken in UN meetings in 1980 and re-confirmed in 1994 (see Ref. 1).

UN/SCETDG/45/INF.15/Ref.1 UN/SCETDG/40/INF.18

Provisions for uranium hexafluoride with less than 0.1 kg per package PDF

UN/SCETDG/45/INF.15/Ref.2

RECOMMENDATIONS FOR PROVIDING PROTECTION DURING THE TRANSPORT OF URANIUM HEXAFLUORIDE

PDF

UN/SCETDG/45/INF.15/Ref.3

Provisional information dates 9 September 2011 PDF

UN/SCETDG/45/INF.15/Ref.4

4 June 2-13

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Transmitted by the World Nuclear Transport Institute (WNTI) PDF

UN/SCETDG/45/INF.15/Ref.5 Chemical Toxicity of Uranium Hexafluoride Compared to Acute Effects of Radiation Final Report PDF

UN/SCETDG/45/INF.15/Ref.6

4 June 2014 Interim guidance on the safe transport of uranium hexafluoride Transmitted by the World Nuclear Transport Institute (WNTI) PDF

UN/SCETDG/45/INF.15/Ref.7

4 June 2014 Acute toxicity of uranium hexafluoride, uranyl fluoride and hydrogen fluoride Transmitted by the World Nuclear Transport Institute (WNTI) PDF

UN/SCETDG/45/INF.15/Ref.8

4 June 2014 International Chemical Safety Cards

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Transmitted by the World Nuclear Transport Institute (WNTI) PDF

UN/SCETDG/45/INF.15/Ref.9

4 June 2014 Uranium fluoride Transmitted by the World Nuclear Transport Institute (WNTI) PDF

UN/SCETDG/45/INF.15/Ref.12 4 June 2014

Acute chemical toxicity of uranium Transmitted by the World Nuclear Transport Institute (WNTI) PDF

UN/SCETDG/45/INF.15/Ref.13

4 June 2014

Toxicity of uranium Transmitted by the World Nuclear Transport Institute (WNTI) PDF

Agenda Item 5(a): Electric storage systems: testing of lithium batteries

Agenda Item 5(b): Electric storage systems: Safety procedures for damaged or defective lithium batteries

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Agenda Item 5(c): Electric storage systems: Large Batteries

Agenda Item 5(d): Electric storage systems: thermal batteries UN/SCETDG/45/INF.11

20 May 2014 New UN number for thermal batteries Transmitted by the expert from Germany

DOC

PDF

The expert from Germany submitted a proposal for a new entry for thermal batteries to the forty-second session (ST/SG/AC.10/C.3/2012/64) which was not discussed due to lack to time. Therefore, the proposal was presented to the forty-third session in document ST/SG/AC.10/C.3/2013/64. The experts who spoke supported the proposal by Germany in principle, but had some comments which should be taken into consideration for a revised proposal.

Agenda Item 5(e): Electric storage systems: miscellaneous

Lithium Batteries

Battery WG

ST/SG/AC.10/C.3/2014/12

24 March 2014 Transport of lithium batteries of small productions runs or prototype lithium batteries in equipment Transmitted by the expert from Germany

DOC

PDF

Special provision 310 excludes batteries from production runs consisting of not more than 100 cells or batteries and prototypes when these are transported for testing from the application of the testing requirements in sub-section 38.3 of the Manual of Tests and Criteria.

Lithium Batteries

Battery WG

ST/SG/AC.10/C.3/2014/18 25 March 2014 Lithium batteries – appropriate hazard communication Transmitted by the expert from the United Kingdom

Following discussion of ICAO’s papers ST/SG/C.10.C.3/2013/49 and informal document INF 48 at the forty-fourth session, a lunchtime working group, chaired by the Vice-Chairman, met to consider the issue of appropriate hazard communication for lithium metal and ion batteries (UN numbers 3090, 3091, 3480 and 3481).

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DOC

PDF

Lithium Batteries

Battery WG

ST/SG/AC.10/C.3/2014/45 9 April 2014 Report on the second meeting of the informal working group on testing large lithium batteries Transmitted by the expert from France (in his capacity as Chairman of the informal working group), PRBA, RECHARGE and COSTHA

DOC

PDF

The informal working group meeting was held in Brussels on 11 February 2014. It was co-organized by RECHARGE, PRBA and COSTHA. A total of 40 participants from both the Sub-Committee of Experts on the Transport of Dangerous Goods (TDG) and industry attended the meeting. The expert from France, Claude Pfauvadel, chaired the meeting.

Lithium Batteries

Battery WG

FRENCH ONLY

ST/SG/AC.10/C.3/2014/47

9 April 2014

Transport de prototypes de batteries et piles au

lithium

Communication de l’expert de la France

DOC

PDF

Agenda Item 6(a): Transport of gases: Global recognition of UN and non-UN pressure receptacles

Agenda Item 6(b): Transport of gases: miscellaneous

Gases ST/SG/AC.10/C.3/2014/14 24 March 2014 Packing instructions P200 and P206 for collective entries Transmitted by the expert from Germany

At its forty-forth session, the Sub-Committee considered a proposal to amend packing instructions P200 and P206 and to include instructions how to calculate the filling ratio and test pressure when a liquid phase of a fluid is charged with a compressed gas (see ST/SG/AG.10/C.3/2013/41). Some experts considered that this would be better addressed through standards and that it was not desirable to include such detailed calculation formulae in regulations which should contain the essential requirements. Others supported the proposal in general

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DOC

PDF

and provided some editorial remarks.

Gases

Packaging

ST/SG/AC.10/C.3/2014/15 24 March 2014 Material requirements regarding elongation for non-refillable cylinders Transmitted by the expert from Germany

DOC

PDF

The material properties of metallic cylinders are determined by their chemical composition and the heat treatment applied – if any.

Gases ST/SG/AC.10/C.3/2014/16 24 March 2014 Salvage pressure receptacles Transmitted by the expert from Germany

DOC

PDF

The Sub-Committee decided at its thirty-seventh session in June 2010 (ST/SG/AC.10/C.3/74) to incorporate provisions on the use and approval of salvage pressure receptacles.

Gases ST/SG/AC.10/C.3/2014/27

28 March 2014

Insertion of new ISO standards for filling in P200 Transmitted by the International Organisation for Standardisation (ISO)

DOC

PDF

ISO TC 58/SC4 has published several standards on covering inspection at the time of filling. Industry representatives believe these standards are a positive contribution to the safety of pressure receptacles and would like to see these standards included in the United Nations Model Regulations.

Gases ST/SG/AC.10/C.3/2014/28

28 March 2014

Insertion of new and replacement ISO standards in

This paper proposes the following standards for inclusion in section 6.2.2 concerning UN pressure receptacles. These are:

ISO 11515:2013 Gas cylinders – Refillable composite reinforced tubes of water capacity between 450 L and 3000 L – Design, construction and testing and

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6.2.2 Transmitted by the International Organisation for Standardisation (ISO)

DOC

PDF

ISO 10462:2013 Gas cylinders – Acetylene cylinders – Periodic inspection and maintenance.

Gases ST/SG/AC.10/C.3/2014/29

28 March 2014 Hydraulic pressure testing of pressure receptacles Transmitted by the International Organisation for Standardisation (ISO), the European Cylinder Makers Association (ECMA) and the European Industrial Gases Association (EIGA)

DOC

PDF

The text of 6.2.1.5.1 (g) concerns the hydraulic pressure test during the initial inspection and test of pressure receptacles. It reads:

“A hydraulic pressure test. Pressure receptacles shall withstand the test pressure without expansion greater than that allowed in the design specification.”

Gases ST/SG/AC.10/C.3/2014/36

1 April 2014 Proposal to add a special provision for HYDROGEN, REFRIGERATED LIQUID (UN 1966) and HELIUM, REFRIGERATED LIQUID UN 1963 Transmitted by the European Industrial Gases Association (EIGA)

DOC

PDF

Certain types of portable tanks, and specifically those that are used to transport Hydrogen, refrigerated liquid (UN 1966) and Helium, refrigerated liquid (UN 1963), have a special type of insulation system to cope with the low temperatures of these products which are at below minus 250°C.

Agenda Item 7(a): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: Fuels in machinery or equipment

NAAHAC ST/SG/AC.10/C.3/2014/17 During its forty-fourth session, the Sub-Committee discussed

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24 March 2014

Fuels in engines and machinery

Submitted by the expert from Belgium and DGAC

DOC

PDF

the issue of fuels in engines and machinery extensively (see

ST/SG/AC.10/C.3/2013/67 (DGAC), informal documents INF.7

(DGAC), INF.59 (Belgium on behalf of the lunchtime working

group) and decided the following:

Agenda Item 7(b): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: Articles containing small quantities of dangerous goods

NAAHAC

ACR

Consumer

Products

Retailers

Life Sciences

ST/SG/AC.10/C.3/2014/44

3 April 2014

Articles containing small quantities of dangerous

goods

Transmitted by the expert from the United Kingdom

DOC

PDF

At the forty-fourth session, the United Kingdom presented informal document INF.36 which set out a number alternative options for addressing articles containing small quantities of dangerous goods within the Model Regulations.

ST/SG/AC.10/C.3/2014/46 9 April 2014 Proposal for correction to 1.1.1.9 Transmitted by the expert from the Russian Federation

DOC

PDF

Corrections are necessary in sub-section 1.1.1.9 of the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations, eighteenth revised edition.

Agenda Item 7(c): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: Used medical devices

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Life Sciences ST/SG/AC.10/C.3/2014/56 7 April 2014 Used medical devices or equipment Transmitted by the Council on Safe Transportation of Hazardous Articles (COSTHA)

DOC

PDF

During the forty-second, forty-third and forty-fourth sessions of the Sub-Committee, COSTHA has submitted documents addressing difficulties with implementing the exceptions noted in 2.6.3.2.3.9. Specifically, the requirement for the package to be capable of withstanding a 1.2 m drop test is problematic. Proving capability is difficult.

Agenda Item 7(d): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: Environmentally hazardous substances

Agenda Item 7(e): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: Terminology

Agenda Item 7(f): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: marking and labelling

ST/SG/AC.10/C.3/2014/9 24 March 2014 Use of the terms “mark” and “marking” in the Model Regulations Transmitted by the expert from the United Kingdom

DOC

PDF

During discussions of the Secretariat’s paper ST/SG/AC.10/C.3/2012/96 at the 42nd session, experts queried the distinction between the terms “mark” and “marking” as used in the Model Regulations. Neither is defined in Chapter 1.2. The expert from the United Kingdom delegate explained her understanding orally and agreed to provide a paper on the subject during the next biennium (see ST/SG/AC.10/C.3/84,para 47).

Chemical Manufacturers

ST/SG/AC.10/C.3/2014/24

28 March 2014 Marking of portable tanks

Compliance with the general requirements on placarding and marking of cargo transport units causes substantive issues considering the specific properties of small portable tanks, which are not being presented as a single cargo transport unit. Regarding a global harmonization of transport of dangerous

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Transmitted by the European Chemical Industry Council (CEFIC)

DOC

PDF

goods regulations with the Model Regulations, this issue was discussed at the forty-third meeting of the Sub-Committee of Experts on the Transport of Dangerous Goods resulting in a request to CEFIC for an official document on this topic.

Packaging ST/SG/AC.10/C.3/2014/26

28 March 2014 Marking of inner receptacles of composite IBCs Transmitted by the International Confederation of Plastics Packaging Manufacturers (ICPP)

DOC

PDF

At the forty-fourth session of the Sub-Committee, the marking of the date of manufacture of plastics inner receptacles of composite IBCs was discussed in detail on the basis of ICPP informal document INF 58.

Packaging ST/SG/AC.10/C.3/2014/35

1 April 2014

Marking on packages Transmitted by the European Industrial Gases Association (EIGA) and the European Liquefied Petroleum Gas Association (AEGPL)

DOC

PDF

Within 5.2.2.2, (Provisions for labels), 5.2.2.2.1.2 allows for cylinders of Class 2 to display labels which have been reduced in size according to ISO 7225:2005 on the non-cylindrical part (shoulder) of such cylinders. This ensures that labels are visible during transport. This provision accommodates the majority of cylinders in service.

Packaging ST/SG/AC.10/C.3/2014/58 4 April 2014 Marking requirements in Chapter 3.3 special provisions Transmitted by the expert from the United Kingdom

Following discussion of the Secretariat’s comments on issues raised by the RID/ADR/ADN harmonisation working group (informal document INF 37) at the forty-third session, the expert from the United Kingdom agreed to submit a paper to clarify requirements on the size for marking required in special provisions (para 88, ST/SG/AC.10/C.3/86). This was because delegates expressed uncertainty about minimum requirements for the additional package marks specified in some special provisions.

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DOC

PDF

UN/SCETDG/45/INF.9 16 April 2014 Correction to ST/SG/AC.10/C.3/2014/9 Note by the secretariat

DOC

PDF

In the English version, in the table under paragraph 10., the rows

for amendments to 4.1.8.4, 4.2.4.5.6, 6.3.4.2 (g) and 6.6.3.1

Agenda Item 7(g): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: packagings

Packaging ST/SG/AC.10/C.3/2014/19 26 March 2014 Use of large salvage packagings Transmitted by the expert from Germany

DOC

PDF

Provisions on large salvage packagings have been incorporated in the eighteenth revision of the revised edition of the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations. The Sub-Committee agreed to a definition and amendments to chapter 6.6 on the basis of document ST/SG/AC.10/C.3/2011/24 (Belgium and Germany).

Packaging ST/SG/AC.10/C.3/2014/34 1 April 2014 Leakproofness testing procedures Transmitted by the expert from Sweden

DOC

PDF

At the previous sessions of the Sub-Committee, the expert of Sweden has raised issues concerning inspection and testing of packagings and IBCs in accordance with paragraphs 6.1.1.3 and 6.5.4.4. In December 2013 Sweden presented the result of a survey containing a number of questions relating to testing procedures (see informal documents submitted to the 44

th

session INF.18 + INF.18/Add.1 and INF.18/Add.2). Even though it was difficult to draw straightforward conclusions from the answers, the result from this survey indicated that applied test methods, test pressures and durations varied considerably depending on for example properties of packagings and IBCs, and production rate.

Agenda Item 7(h): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: portable tanks

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Agenda Item 7(i): Miscellaneous proposals for amendments to the Model Regulations on the Transport of Dangerous Goods: Scope of section 5.5.3

Agenda Item 8: Electronic data interchange for documentation purposes

Agenda Item 9: Cooperation with the International Atomic Energy Agency

Agenda Item 10(a): Guiding principles for the Model Regulations: Assignment of E-Codes

Agenda Item 10(b): Guiding principles for the Model Regulations: Miscellaneous

Agenda Item 11(a): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Desensitized explosives

Explosives

GHS

ST/SG/AC.10/C.3/2014/2−ST/SG/AC.10/C.4/2014/2

27 March 2014 Implementation of a new Chapter 2.17 “Desensitized Explosives” in the GHS and implementation of “Classification procedures, test methods and criteria relating to the class of desensitized explosives” in a new Part V of the Manual of Tests and Criteria Transmitted by the expert from Germany DOC PDF

During the last sessions of the Sub-Committee of Experts on the Transport of Dangerous Goods (TDG Sub-Committee), of the Working Group on Explosives and of the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS Sub-Committee), the proposal for implementation of a new chapter 2.17 “Desensitized Explosives” in the GHS and implementation of “Classification procedures, test methods and criteria relating to the class of desensitized explosives" in a new part of the United Nations Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria was discussed (Informal documents INF.13 (TDG Sub-Committee, 43

rd session) and INF.5 (GHS

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Sub-Committee, 25th session)).

Agenda Item 11(b): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Pyrophoric gases

Chemical Manufacturers

GHS

ST/SG/AC.10/C.3/2014/54−ST/SG/AC.10/C.4/2014/5

7 April 2014 Proposal to include pyrophoric gas as a hazard category in the flammable gases hazard class of the GHS Transmitted by the expert from the United States of America

DOC

PDF

This working paper and accompanying informal paper (INF.4, 27

th session GHS, INF.7, 45

th session TDG)

follows several papers submitted to the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS Sub-Committee) and the Sub-Committee of Experts on the Transport of Dangerous Goods (TDG Sub-Committee) proposing that pyrophoric gases be included in the flammable gases hazard category of the GHS. The paper reflects work performed by experts from Germany, Sweden, United Kingdom, Canada, the European Industrial Gases Association (EIGA), the Compressed Gas Association (CGA), and the United States of America. A summary of the submittals regarding this hazard is presented in paragraphs 2 through 4 for the Sub-Committee’s reference.

Chemical Manufacturers

GHS

UN/SCETDG/45/INF.7 UN/SCEGHS/27/INF.4

17 April 2014 Proposal to include pyrophoric gas as a hazard category in the flammable gases hazard class of the GHS (track-changes) Transmitted by the expert from the United States of America

DOC

PDF

This document contains the text of GHS Chapter 2.2, Annex 1 and Annex 3, as amended in accordance with the proposed list of amendments in document ST/SG/AC.10/C.3/2014/54–ST/SG/AC.10/C.4/2014/5. Amendments are shown in visible mode (“track-changes”).

Agenda Item 11(c): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Criteria for water-rreactivity

Agenda Item 11(d): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Tests and criteria for oxidizing solids

Chemical ST/SG/AC.10/C.3/2014/30−ST/SG/AC.10/C.4/201 Test O.2 (test for oxidizing liquids) of the Manual of

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Manufacturers

GHS

4/4

28 March 2014 Use of cellulose in UN Test 0.2 (Test for oxidizing liquids) and UN Test 0.3 (Test for oxidizing solids) Submitted by the expert from France

DOC

PDF

Tests and Criteria determines the oxidizing properties of liquid substances. The GHS refers to this test method as well for the purposes of classification of oxidizing liquids.

Agenda Item 11(e): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Classification criteria and flammability categories for certain refrigerants

Agenda Item 11(f): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Expert judgement/weight of evidence

Agenda Item 11(g): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Corrosivity criteria

Chemical Manufacturers

GHS

Life Sciences

ST/SG/AC.10/C.3/2014/25−ST/SG/AC.10/C.4/2014/3

31 March 2014

Update on the work of the intersessional informal joint working group on corrosivity criteria Transmitted by the expert of the Netherlands on behalf of the intersessional joint TDG-GHS working group on corrosivity criteria

DOC

PDF

During the twenty-sixth session of the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the expert from the United Kingdom transmitted the outcome of the Joint Working Group on Corrosivity in informal document INF.27. The Joint Group confirmed the correlation between the GHS sub-categories 1A, 1B and 1C with Packing Groups I, II and III respectively where these are based on human, animal or in vitro data. The challenge was in assigning packing groups in the transport sector when the GHS alternative methods, particularly the additivity and non-additivity approaches, were applied. A

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further challenge lay in identifying additional criteria for when Packing Group I should be assigned for substances and mixtures classified as GHS sub-category 1A and not included in the Dangerous Goods List.

UN/SCETDG/45/INF.3 UN/SCEGHS/27/INF.3

31 March 2014 Addendum to the update on the work of the intersessional informal joint working group on corrosivity criteria Transmitted by the expert of the Netherlands on behalf of the intersessional informal joint TDG-GHS working group on corrosivity criteria

DOC

PDF

Reference is made to documents ST/SG/AC.10/C.3/2014/25 and ST/SG/AC.10/C.4/2014/3.

Agenda Item 11(h): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Hazard communication

Agenda Item 11(i): Issues relating to the Globally Harmonized System of Classification and Labelling of Chemicals: Miscellaneous

GHS ST/SG/AC.10/C.3/2014/61−ST/SG/AC.10/C.4/2014/8 9 April 2014 Use of the Manual of Tests and Criteria in the context of the GHS Note by the secretariat

DOC

PDF

The Manual of Tests and Criteria contains criteria, test methods and procedures intended to be used for the classification of dangerous goods according to the provisions of Parts 2 and 3 of the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations, but also for the classification of chemicals presenting physical hazards according to the GHS.

UN/SCETDG/45/INF.8 UN/SCEGHS/27/INF.5

Reference is made to document

ST/SG/AC.10/C.3/2014/61–

ST/SG/AC.10/C.4/2014/8.

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10 April 2014

Use of the Manual of Tests and Criteria in the context of the GHS:

Introduction of the Manual

Note by the secretariat

DOC

PDF

UN/SCETDG/45/INF.8/Add.1 UN/SCEGHS/27/INF.5/Add.1

10 April 2014

Use of the Manual of Tests and Criteria in the context of

the GHS: Part I (Sections 10 to 15) of the Manual

Note by the secretariat

DOC

PDF

Reference is made to document

ST/SG/AC.10/C.3/2014/61–

ST/SG/AC.10/C.4/2014/8.

UN/SCETDG/45/INF.8/Add.2 UN/SCEGHS/27/INF.5/Add.2

10 April 2014 Alignment of the Manual of Tests and Criteria with the GHS: Part I (Sections 16 to 18) of the Manual Note by the secretariat

DOC

PDF

Reference is made to document

ST/SG/AC.10/C.3/2014/61–

ST/SG/AC.10/C.4/2014/8.

UN/SCETDG/45/INF.8/Add.3 UN/SCEGHS/27/INF.5/Add.3

10 April 2014

Reference is made to document

ST/SG/AC.10/C.3/2014/61–

ST/SG/AC.10/C.4/2014/8.

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Use of the Manual of Tests and Criteria in the context of the GHS: Proposed amendments to Part II of the Manual Note by the secretariat

DOC

PDF

UN/SCETDG/45/INF.8/Add.4 UN/SCEGHS/27/INF.5/Add.4

10 April 2014 Use of the Manual of Tests and Criteria in the context of the GHS: Proposed amendments to the Introduction and Part I of the Manual Note by the secretariat

DOC

PDF

Reference is made to document

ST/SG/AC.10/C.3/2014/61–

ST/SG/AC.10/C.4/2014/8.

UN/SCETDG/45/INF.8/Add.5 UN/SCEGHS/27/INF.5/Add.5

10 April 2014 Use of the Manual of Tests and Criteria in the context of the GHS: Proposed amendments to the Appendices of the Manual Note by the secretariat

DOC

PDF

Reference is made to document

ST/SG/AC.10/C.3/2014/61–

ST/SG/AC.10/C.4/2014/8.

UN/SCETDG/45/INF.14 UN/SCEGHS/27/INF.6

27 May 2014 Dust explosion hazards

This document is submitted to elucidate the position of CEFIC regarding the discussion on dust explosion properties and GHS. Documents considered are the informal documents INF.28 (26th session, report of the informal working group on dust explosion hazards), informal document INF.21 (Canada) and informal document INF.16

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Transmitted by the European Chemical Industry Council (CEFIC)

DOC

PDF

(USA/Canada/Australia). This information paper is also submitted to the Sub-Committee of experts of the Transport of Dangerous Goods being the focal point for physical-hazards.

Agenda Item 12: Other business

ST/SG/AC.10/C.3/2014/8 17 March 2014 Principles for consideration of informal documents, submitted to the Sub-committee of Experts on the Transport of Dangerous Goods Transmitted by the expert from China

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In 2012, 102 working documents and 146 informal documents were submitted; the ratio of informal documents to working documents was 143%. In 2013, there were 70 working documents and 117 informal documents; the ratio of informal documents to working documents was 167%. It seems that the ratio of informal documents to working documents submitted to the Sub-Committee shows an increased trend year after year. Moreover, many informal documents were submitted just a few days before the meeting or even were submitted during the meeting. The delegates and experts often have no sufficient time to study and consider carefully these informal documents, and have even less time to seek more comments from the national industry experts while their opinions are very important regarding the technical issues as decisions may cause unpredictable impact on the industry. Although these informal documents may be discussed at the meeting, the expert from China doubts that it is possible to get full and accurate feedback at such short notice, and thinks that, as a consequence, many problems may occur, notably in relation to satisfactory and complete access to the information which is necessary for checking, or even because obtention of erroneous opinions.

Agenda Item 13: Adoption of the report