New INTEREC Chairman Steve Schulte talks about technical issues with Dr. Charles Ke of PHMSA during a break.

The UN Transport Sub-Committee recently completed its second meeting of the current biennium November 30-December 9. DGAC staff and delegates attended to present DGAC Members' comments and concerns on a number of issues.

DGAC Member delegates were: Andy Altemos, HMT Associates; Ron Klein, DelValCo Consultant; Steve Schulte, Ecolab; Jay Johnson, Inmark; Neil McCulloch, Labelmaster; Frits Wybenga and Mike Morrissette, DGAC.

UN Transport Sub-Committee Chairman Bob Richard was detailed to another position within DOT this fall and was therefore unable to attend the UN meeting. The meeting was chaired by Vice-Chairman Claude Pfauvadel (France).

Two DGAC papers were considered at the meeting:

2009/49 and INF 15 – Implementation of the GHS Criteria in the UN Model Regulations on the Transport of Dangerous Goods. Many DGAC members expressed serious concerns about a Netherlands' proposal to incorporate detailed provisions of the GHS on corrosive substances into the Model Regulations in order to "harmonize" the two sets of regulations. Of particular concern were the provisions on "extreme pH" that in many cases could result in an incorrect classification. In addition, the GHS provisions are lengthy, complicated and confusing compared with the straight-forward requirements in the Model Regulations for Class 8. DGAC's papers and meeting comments helped persuade the Transport/GHS working group on this issue that there was no need to reproduce in full the GHS text on corrosivity in the Model Regulations – a very good result for members transporting these substances.

DGAC representatives Andy Altemos, Steve Schulte and Mike Morrissette confer about DGAC papers on Class 8 harmonization that were presented a short time later.

"De Minimis" quantities of dangerous goods. A U.S. proposal to introduce provisions for transporting "de minimis" quantities into the Model Regulations was adopted with minor revisions. Excepted quantities of dangerous goods assigned to codes E1, E2, E4 and E5 will not be subject to the regulations provided that the maximum quantity of material per inner packaging is limited to 1 ml for liquids & gases and 1 g for solids, the provisions of 3.5.2 (packagings) and 3.5.3 (tests for packages) are met, and the maximum net quantity of dangerous goods per outer packaging does not exceed 100 g for solids or 100 ml for liquids and gases.

DGAC began an effort several years ago to include requirements for "de minimis" quantities in U.S. hazmat regulations with a successful petition for rulemaking to DOT. We also submitted a proposal to the UN Transport Sub-Committee which, although not adopted, established the concept internationally. DGAC helped guide the current discussions at the UN meeting to a successful conclusion. Although the provisions are similar to those for excepted quantities, further relief is provided from marking of packages and documentation.

The position of the word WASTE on the transport document – A UK paper to revise the Model Regulations with respect to the position of the word WASTE on the transport document was withdrawn. The proposal was made in order to align with European road, rail and inland water regulations. This paper caused concern among DGAC members because the IMDG Code, ICAO Technical Instructions and U.S. regulations follow the present positioning of WASTE specified in the Model Regulations. In a recent decision, the European regulations were revised to conform with the UN Model Regulations.

DGAC Members will receive a full meeting report in January.