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19th REVISED EDITION OF THE UN MODEL REGULATIONS

JEFF HART

(Former Chairman of the UN Sub-Committee of Experts on the Transport of Dangerous Goods)

THE REGULATIONS TO BE COVERED

The United Nations Recommendations on the Transport of Dangerous Goods Model Regulations 19th revised edition applicable from 1 January 2015.

Global, multi-modal but not mandatory.

Transposed to mandatory modal regulations for international transport from 1 January 2017 (subject to usual transitional periods).

THE REGULATIONS TO BE COVERED

There are also changes to the Manual of Tests and Criteria 5th. Revision (up to Amendment 2).

19th. Revision available in hard copy but this and 6th. MTC not yet available on UNECE website.

This presentation not comprehensive - full

details of all amendments are available at: http://www.unece.org/trans/danger/danger.htm

http://www.unece.org/trans/danger/danger.htm�

UN MODEL REGULATIONS - MANUAL OF TESTS AND CRITERIA

1.1.2 clarifies that examples given under test procedures are illustrative and provided for guidance only.

“1.1.3 In situations where the proper

classification of substances and articles of certain Hazard Classes or Divisions for transport is the responsibility of the Competent Authority, it is normal and accepted practice that due consideration will be given to testing or classification results of other Competent Authorities when provided.”

UN MODEL REGULATIONS - MANUAL OF TESTS AND CRITERIA Amendments to Test 1 (a), 2 (a) and 8. Old US

apparatus permitted for Test Series 3.

Clarifications and amendments to Test 6 (c) bonfire test and new Test 6 (e) for small arms ammunition.

New layout and some minor amendment for screening procedure for substances that may have explosive properties in 3.3 (c) of Annex 6.


‘Waterfalls’ to be classified as 1.1 G or 1.3 G on basis of HSL test rather than Series 6 tests.

Explosives WG will continue to look at: tests

and criteria for flash composition; amendments to 1(c) and 2 (c) time/pressure tests; further review of Test Series 6; traceability markings.


New 2.1.3.7 giving guidance on standardised CA classification document.

New Chapter 2.17 for criteria and tests for desensitised explosives for GHS (but no impact for transport).

Amendments to lithium battery classification tests; amendments to definitions of cell; component cell; battery; single cell battery adopted.


Amended Manual of Tests and Criteria (inc. Amendment 1 & 2 and 2013/14 amendments) to be published early 2015 as 6th revised edition.

To be edited to reflect use by both TDG and GHS and published as 7th revised edition in 2017. Needs careful review to ensure ‘editorial’ amendment is not substantive change.

UN MODEL REGULATIONS - 19th REVISED EDITION

1.1.1.7: “The requirements of the standard that do not conflict with these Regulations shall be applied as specified, including the requirements of any other standard, or part of a standard, referenced within that standard as normative.”

1.2.1 ‘aerosol’ is now described as ‘an

article consisting of…’ and ‘tube’ now of seamless or composite construction.


1.2.1 “Design life, for composite cylinders and tubes, means the maximum life (in number of years) to which the cylinder or tube is designed and approved in accordance with the applicable standard;”

1.2.1. “Service life, for composite cylinders and tubes, means the number of years the cylinder or tube is permitted to be in service;”


1.2.1 Salvage pressure receptacle capacity increased to 3000 litres (but restricted to contain only pressure receptacles of total of 1000 litres water capacity).

Classification inconsistencies – listing versus

data. New text in 2.0.0.2 and Guiding Principles (with CA approval use generic or n.o.s. entry first or usual UN no. with additional hazcom where transport conditions the same).


2.3.2.2 kinematic viscosity provisions revert back to align with RID/ADR.

2.3.2.5 viscous liquids which are also

environmentally hazardous not subject to other provisions when in single/combination packagings of 5 l/kg or less.

UN MODEL REGULATIONS - 19th REVISED EDITION Sub-classification of 56 polymerizing substances

in Division 4.1 with new transport provisions. 2.5.3.2.4 entries in the list of organic peroxides

amended.

New organic peroxide entries added to IBC 520.

PCBs (UN 3151 & 3152) now include halogenated monomethyldiphenylmethanes.

UN MODEL REGULATIONS - 19th REVISED EDITION UN 1005 and UN 3516 add new SP379 on

ammonia dispensing systems.

UN 1415 Lithium now permitted in T9 tanks with TP 7 and TP 33 applied.

UN 2813 PP83 deleted (meals ready to eat).

UN 2983 (ethylene/propylene oxide mix)

moved from P200 to P001.


UN 2211 (polymeric beads) new SP 382 for test method (U1 in MTC) to demonstrate no flammable vapour thus not subject to regulations.

UN2000 (celluloid) SP383 exemption for table

tennis balls packaged under certain conditions.

UN 3171 battery powered vehicles/equipment SP 240 greatly expanded.


UN 3166 new approach to separate vehicles from engines/machinery and improve hazard communication. UN 3166 now restricted to vehicles.

New UN 3528 flammable liquid engines/machinery; UN 3529 flammable gas engines/machinery; UN 3530 engines/machinery in Class 9.

These attract new PI 005. SP363 deleted from hydrocarbons and hugely expanded to apply provisions to new UN numbers.

UN MODEL REGULATIONS - 19th REVISED EDITION SP 310 concerning prototype and low production

run batteries amended and added to UN 3091 and UN 3481 (batteries in equipment) and new PI 910.

New UN 3527 POLYESTER RESIN KIT, solid base material added in Division 4.1; SP 236 amended accordingly and new P412 assigned.

SP mark wording shall be at least 12 mm unless otherwise indicated elsewhere.

UN MODEL REGULATIONS - 19th REVISED EDITION UN 3170 (aluminium by products) has BK1

(sheeted) removed; SP244 amended to add cooling to ambient before loading, protection from water ingress and ventilation.

UN 2977 & 2978 UF6 has 6.1 sub risk added;

UN 3507 becomes 6.1 with 7 & 8 sub risk and P603 assigned (which is P805 renumbered). SP369 amended.


SP 361 and 372 Amended to read: “Capacitors manufactured after 31 December 2013/2015 (respectively), shall be marked with the energy storage capacity in Wh.”.

New SP 378 on radiation detectors applied to UN Nos. 1006, 1013, 1046, 1056, 1065, 1066, 1956, 2036.


SP 225 add ‘Fire extinguishers shall be manufactured, tested, approved and labelled according to the provisions applied in the country of manufacture.’ but NOTE: means provisions applicable in the country of manufacture or those applicable in the country of use.

New SP380 - if a vehicle is powered by a

flammable liquid and a flammable gas internal combustion engine, it shall be assigned to UN 3166 VEHICLE, FLAMMABLE GAS POWERED.”


Excepted packages for liquids may use the outer packaging to contain absorbent material as the means of containing breakage/leakage of the entire contents of the inner packagings (see 3.5.2 (b)).

Non-metal packagings for explosives may

contain small metal parts e.g. fastening clips, hinges etc. (PP48).


P200 (2) (d) NOTE: For pressure receptacles which make use of composite materials, the maximum test period shall be 5 years. The test period may be extended to that specified in Tables 1 and 2 (i.e. up to 10 years), if approved by the competent authority of the country of use.

New P200 (3) (e) and P206 (3) concerning calculation of internal pressure for liquefied gases charged with compressed gases.


New P200 (4) on filling pressure receptacles by qualified staff using appropriate equipment and procedures that can be met by meeting standards referenced.

ISO references and end dates in P200 updated.

P207 for UN 1950 now to prevent ‘excessive’

movement.


New P208 for adsorbed gases: (1) (b) “Cylinders constructed before 1 January 2016 in accordance with 6.2.3 and a specification approved by the competent authorities of the countries of transport and use” may be used.

P502 PP28 for UN1873 now permits plastics.


New LP200 for UN 1950 at PGII performance level and addition to L2 “The large packagings shall be designed and constructed to prevent dangerous movement of the aerosols and inadvertent discharge during normal conditions of transport.”.

SP 381 gives transitional period to 31/12/2022.


Amendments to 4.1.1.12, 6.1.1.3 and 6.5.4.4 such that:

“Every packaging/IBC intended to contain liquids (or solids discharged under pressure for IBCs) shall successfully undergo a suitable leakproofness test. This test is part of a quality programme as stipulated in 6.1.1.4 which shows the capability of meeting the appropriate test level indicated in 6.1.5.4.3/6.5.6.7.3.”

UN MODEL REGULATIONS - 19th REVISED EDITION Improved hazard communication in Class 9 for

lithium batteries. Transitional period to 31/12/2018.

More to follow? Unfortunately not!

UN MODEL REGULATIONS - 19th REVISED EDITION SP188 amended to apply battery handling mark

Place for UN number(s) Place for telephone number [if not shown elsewhere on the package] The mark shall be in the form of a rectangle with hatched edging. The dimensions shall be a minimum of 120 mm wide x 110 mm high and the minimum width of the hatching shall be 5mm. The symbol (group of batteries, one damaged and emitting flame, over the UN number for lithium ion or lithium metal batteries or cells) shall be black on white. The hatching shall be red. If the size of the package so requires, the dimensions/line thickness may be reduced to not less than 105 mm wide x 74 mm high. Where dimensions are not specified, all features shall be in approximate proportion to those shown.’

Minimum dimension 120 mm

Minimum dimension

110 mm

.


Reduced size placards and marks permitted for portable tanks not more than 3000 litres with insufficient available surface area. UN number not less than 25mm, placards/marks not less than 100 x 100mm.

If all compartments of CTUs have to bear the same placards only one each side need be displayed. Portable tanks not more than 3000 litres and insufficient area may replace placards with labels.


Standards and end dates in Chapter 6.2 updated.

6.2.2.1.1 Notes 1 and 2 amended to require composite cylinder design for not less than 15 year life (rather than unlimited) and ‘design life longer than 15 years shall not be filled after 15 years from the date of manufacture, unless the design has successfully passed a service life test programme. The service life test programme and the results shall be approved by the competent authority of the country of approval that is responsible for the initial approval of the cylinder design.’


6.2.2.7.4 composite cylinders and tubes to be marked ‘FINAL year/month’ if limited life or ‘SERVICE year/month if 15 year or non-limited life (from date of manufacture/initial inspection).

6.7.2.19.8 (a) and 6.7.3.15.8 (a) clarifies for

portable tank inspections that “the wall thickness shall be verified by appropriate measurement if this inspection indicates a reduction of wall thickness.”

UN GUIDING PRINCIPLES

Guiding Principles updated to reflect 18th revised edition.

Guiding Principles for providing future

transitional periods for UN pressure receptacles adopted.

Guiding Principles for Packing Instruction

template adopted. Illustrations for LQ package marking adopted.

CONCLUSION

Must look at the definitive texts for complete detail in order to plan ahead and ensure compliance.

Look at reports of UN meeting discussions – it is

the shape of things to come. Make sure your competent authority and trade

association is aware of your views before meetings – it does help shape decision making!

[email protected]

THANK YOU FOR YOUR ATTENTION!

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