On June 12, 2013, the Pipeline and Hazardous Materials Administration (PHMSA) held a public meeting in preparation for the 43rd Session of the Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) which will be held in Geneva Switzerland from June 24-June 28, 2013. The purpose of the PHMSA meeting was to consider a number of proposed amendments to the UN Recommendations on the Transport of Dangerous Goods (“UN Model Regulations”) and get stakeholder input on their effect ahead of 43rd Session of the UNSCOE TDG. Any amendments that are subsequently agreed to by UNSCOE TDG will be submitted for final consideration at the UN Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labeling of Chemicals to be held in December 2013. If approved by this Committee, the amendments will be incorporated into the 19th Revised Edition of the UN Model Regulations.
The proposals reviewed during PHMSA meeting potentially impact four categories of dangerous materials: (1) Class 1 - Explosives; (2) Class 2 - Gases and Cylinders; (3) Electric Storage Systems (including Lithium Batteries); and (4) Classification, Packaging and Miscellaneous Proposals. PHMSA’s position on the categories and certain specific proposals is presented below.
Class 1 - Explosives
Out of the eight proposals reviewed in the Class 1 category, five are fully supported by PHMSA. One agreement that has PHMSA’s unqualified support is a Swedish amendment that would allow for ammonium nitrate emulsion or gel to be transported with Blasting Explosives, with the entire load treated as containing blasting explosives. PHMSA believes that since ammonium nitrate emulsion or gel contains water, adding them to a shipment of Blasting Explosives would not increase the risk of fire.
Class 2 - Gases and Cylinders
In the Gases and Cylinders category, both proposals are supported by PHMSA. However, PHMSA did express concern over the wording of Working Paper 9, which is a proposal to allow the use of composite cylinders with a limited service life of fifteen years. While PHMSA agrees in principle, it does question whether the proposed marking provides a strong enough indication of the authorized life of the cylinder.
Electric Storage Systems
In the Electric Storage system category, PHMSA supports four proposals. PHMSA disagrees with one proposal that would delete the documentation requirement in Paragraph (g) of Special Provision 188, which concerns lithium batteries. PHMSA continues to believe that redundancy is important when communicating that shipment contains lithium batteries. For this reason, PHMSA does not support this proposal, as it suggests that the current requirements reduce the safety benefit.
Classification, Packaging and Other Miscellaneous Proposals
The final nineteen proposals pertained to Classification, Packaging and other Miscellaneous Proposals. PHMSA fully supports nine of them. The proposal that generated the most interest in this section was Working Paper 32, which would remove the drop test capability for health care devices with a mass greater than 12 kg. The drop test involves dropping the package from a height of 1.2 meters and ensuring that is capable of sustaining the fall with no loss of contents. PHMSA does not support this removal, as there is already no requirement that the package prevent damage to the equipment and no requirement for a physical test of the package’s strength. PHMSA is concerned that should the drop test requirement is removed, the only remaining requirement for the transport of equipment containing a Class B infectious substance would be an outer package marking and that there would be no provisions to ensure the integrity of the package during transport. The industry representatives present at the meeting expressed concern about performing drop tests on medical equipment weighing more than 12 kg, voicing worries about the drop test damaging the potentially expensive medical equipment being shipped.
For more information on UNSCOE TDG or hazardous materials transportation contact Ronce Almond at (202) 457-7790.