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DGTA Interventions at UNSCOETDG 54th Geneva

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Chapter 3.3

SP 274         At the end, add the following new paragraphs:

“For UN 3077 and UN 3082 only, the technical name may be a name shown in capital letters in column 2 of the Dangerous Goods List, provided that this name does not include “N.O.S.” and that special provision 274 is not assigned.  The name which most appropriately describes the substance or mixture shall be used, e.g.:

UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (PAINT)

UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (PERFUMERY PRODUCTS)”

DGTA INTERVENTION (JIM POWELL)

This was the subject of a DGTA intervention. DGTA supported the idea that these items SHOULD be acceptable as a technical name, even though they were generic. One reason for that is that when these names are used on their own (i.e. “Paint”) it doesn’t require a technical name even though it’s a generic use name.

So why should UN3077 or UN3082 require it is “Paint” is the component?

DGTA did disagree with the methodology of inserting this special provision note in SP274. I argued that this would more properly be placed in the definition of a technical name, so that the overarching idea of a technical name could be supplemented by this information.

The UN Chair agreed but said this had already been discussed and it was felt that nobody would bother looking up the definition of a technical name and that safety was better served by showing it here, where people were more likely to see it.
===========================================================================================
LITHIUM BATTERY MARK DIMENSIONS

                   Chapter 5.2

5.2.1.9.2       In Figure 5.2.5, replace “120 mm” by “100 mm” and “110 mm” by “100 mm”.

In the last paragraph:

  • First sentence: replace “a rectangle” by “a rectangle or a square”.
  • Second sentence: replace “120 wide x 110 m high” by “100 mm wide ´ 100 mm high”
  • Fourth sentence: delete “/line thickness” and replace “105 mm wide x 74 mm high” by “100 mm wide x 70 mm high”

 (Reference document: ST/SG/AC.10/C.3/2018/115 as amended by informal document INF.55)

DGTA INTERVENTION

There was a lot of controversy about the size and shape of the lithium battery “mark.” There were a couple proposals to REDUCE the size of the mark but some of those proposals would mean that the brand-new mark that we just are getting used to in 2019 would be eliminated in 5 years. PRBA, MDBTC (Bob Richard), and DGTA were supportive of the smaller mark and specifically I commented that it would be hard to overestimate the credibility damage that would ensue if the regulators were to eliminate the label (“mark”) that they just adopted and made mandatory in 2019.

Other commenters concurred and MDBTC argued strongly to allow EITHER a rectangular or square shape.

In the end this is what was adopted as shown at left. This “new” lithium battery mark (dimension) will not change or eliminate anything but will allow the use of a smaller mark where needed.

Not as small as we wanted. For DGTA’s part I figured that if the 6.2 infectious label could be 50x50 are we saying that’s LESS dangerous than excepted lithium batteries and cells?

===============================================================================================

DGTA Did Not Support this paper by Spain proposing a change to some of the hazard labels. ST/SG/AC.10/C.3/2018/102 - (Spain) Optical differentiation of labels for gases (such as a red over green class 2 label.)
English DOC PDF

OTHER PAPERS OF INTEREST TO DGTA MEMBERS AND BOARD
ST/SG/AC.10/C.3/2018/115 - (PRBA, RECHARGE) Dimensions of the lithium battery mark
English DOC PDF

ST/SG/AC.10/C.3/2018/109 - (Netherlands) Provisions for data loggers and other equipment, containing electric energy storage and production systems, in use during transport
English DOC PDF

ST/SG/AC.10/C.3/2018/95 - (IPPIC) Technical names for environmentally hazardous goods of Class 9 (UN 3077 and UN 3082) (Reissued on 18 September) English DOC PDF (DGTA commented on this earlier)

ST/SG/AC.10/C.3/2018/94 - ST/SG/AC.10/C.4/2018/22- (IPPIC) Proposed amendment to the classification criteria for flammable liquids in Chapter 2.6 of the GHS
English DOC PDF

ST/SG/AC.10/C.3/2018/83 - (RECHARGE, OICA, PRBA, COSTHA) Applicability of packing instruction LP906
English DOC PDF

ST/SG/AC.10/C.3/2018/75 - (Germany) Classification of self-inflating recovery devices
English DOC PDF

ST/SG/AC.10/C.3/2018/72 - (Germany) Articles containing dangerous goods in excepted quantities
English DOC PDF

ST/SG/AC.10/C.3/201PDF8/59 - (France, RECHARGE) Report of the informal working group on hazard-based system for classification of lithium batteries English DOC PDF

ST/SG/AC.10/C.3/2018/51 - (PRBA, MDBTC, RECHARGE) Requirements for damaged or defective lithium cells and batteries in special provision 376
English DOC PDF

ST/SG/AC.10/C.3/2018/50 - (PRBA, RECHARGE) Testing of discharged primary lithium cells and batteries
English DOC PDF

ST/SG/AC.10/C.3/2018/47 - (DGAC, COSTHA) Proposal to amend special provision 375 as it applies to UN Nos. 3077 and 3082 (Environmentally Hazardous Substances) English DOC PDF

ST/SG/AC.10/C.3/2018/37 - (PRBE, RECHARGE) Harmonization of the proper shipping names of UN Nos. 3481 and 3091
English DOC PDF

ST/SG/AC.10/C.3/2018/26 - (Canada) Review of the definition of infectious substance and the table in 2.6.3.2.2.1
English DOC PDF

ST/SG/AC.10/C.3/2018/25 - (Canada) Clarification of performance testing requirements for infectious substances packaging in Chapter 6.3
English DOC PDF

ST/SG/AC.10/C.3/2018/17 - (Canada) Review of Canada’s transport of dangerous goods training provisions
English DOC PDF

ST/SG/AC.10/C.3/2018/7 - (Germany) Name and description of UN No. 3363
English DOC PDF

This topic was modified 5 years ago 8 times by Jim Powell

   
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