UN/CETDG/20/INF.13

Agenda item 2 (b)

COMMITTEE OF EXPERTS ON THE TRANSPORT OF DANGEROUS GOODS

(Twentieth Session, Geneva 7-16 December 1998)

PACKAGING INSTRUCTIONS

Comments on Information Paper 5 submitted by the

International Maritime Organization

Transmitted by the Expert from the United Kingdom

Background

Information Paper 5 submitted by the International Maritime Organization reports on the outcome of consideration by the DSC Sub-Committee's Editional and Technical Group (E&T Group) of the outcome of the September 1998 Frankfurt UN Working Group on Packing Instructions.

Having regard to subsequent written editorial comments received from participants in the Frankfurt UN Working Group and to the discussions held in the E&T Group a number of editorial corrections were made and inconsistencies removed from the final versions of the annexes to the Report of the Frankfurt Working Group (ST/SG/AC.10/1998/16) submitted to the UN Committee of Experts.

As a result, the expert from the United Kingdom believes that a number of issues raised by IMO in Information Paper 5 have already been satisfactorily resolved. The expert from the United Kingdom also believes that for a number of other points raised by IMO there are valid reasons not to make the changes proposed by IMO. The following commentary addresses each point raised in the IMO paper.

Commentary on IMO proposals

INF.5 Paragraph 6:

P800	Agreed - amended in final version submitted to UNCOE.

P801	Not adopted in final version submitted to UNCOE as RID/ADR requires PGIII.

INF.5 Paragraph 7:

SP11	The IMDG Code already permits 5M1 bags for UN1362. US/UK did not support in E&T.

SP14	Agreed - amended in final version submitted to UNCOE.

SP29	Agreed - amended in final version submitted to UNCOE.

The following SPP numbers do not appear in the paper to UNCOE:

SP66	Not necessary. P002 inner packagings note 3 indicates paper and fibre packagings shall not be used for PGI substances. SP67	As written this would apply to PGII and PGIII. Differing views were expressed in E&T Group. UK accepts for PGII but not for PGIII.

SP68	Already addressed in SP29.

SP69	If adopted this would apply to PGI, II and III. The UK would favour application to PGI and PGII only.

SP70	Addressed for UN2590 in PXC. UN2212 is probably an omission and needs to be corrected in the paper submitted to UNCOE.

SP71	Addressed in PXD

SP72	Addressed in PXB

SP73	The UK does not agree, as it could apply to PGII or III.

SP74	Unnecessary as UN1365 is in P003 and UN testing is not required.

SP75	UN1376 is assigned to P003 this is not strictly necessary, but could be accepted.

SP76	There are no such restrictions in RID/ADR and the UK did not support in E&T.

SP77	There are no such restrictions in RID/ADR and the UK did not support in E&T.

INF.5 Paragraph 8:

Class 4.1	An additional Special Packing Provision could be added to P409 to the effect that "UN1353................. are not permitted in bags". Alternatively have a new Packing Instruction P409A, without bags, could be added.

The UK does not believe that this is appropriate for UN1353 nitrocellulose soaked rags.

There appears to be a typographical error in the list of UN numbers shown as	UN 1388 and UN 4148 do not appear in the Dangerous Goods List.

Class 4.2	Same solution as suggested for Class 4.1 above.

UN2870	The current proposed inner packaging limit in P400 is 1 litre in indent (ii) and 4 litres in indent (iii).

UN3200 etc This proposal would require classifying these UN numbers in a new way. The

UK believes this should be considered further in the next biennium.

INF.5 Paragraph 9:

.1 Agreed - amended in final version submitted to UNCOE.

.2 Agreed - amended in final version submitted to UNCOE.

.3

.4 The UK does not agree.

.5 The UK does not agree.

.6 The UK does not agree.

.7 Should be considered further.

.8 Agreed - amended in final version submitted to UNCOE.

.9 The UK does not agree.

INF.5 Paragraph 10:

Packagings

UN1044	The UK believes it would be unrealistic to limit fire extinguishers to 55kg or 125kg. Ship/aircraft systems will far exceed this limit.

UN2857	Addressed in PXB

UN1194	Addressed in P099

UN1222	Could go to P099 in the UN list.

UN1261	Could go to P099 in the UN list.

UN1865	Could go to P099 in the UN list.

UN3256	Could go to P099 in the UN list.

UN1649	The UK believes that this should stay in P001 as this proposal is more

restrictive than RID/ADR.

UN1680)

UN1689)	Agreed - amended in final version submitted to UNCOE

UN1694)

UN3281	This would apply to all Packing Groups. The UK believes it should apply only

to PGI.

UN3124)

UN3125)	Could go to P099 in the UN list

UN3223)

UN1590)	Agreed - amended in final version submitted to UNCOE

UN1597)

UN1851	Agreed - amended in final version submitted to UNCOE

UN1812)	Agreed - amended in final version submitted to UNCOE

UN2937)

UN1777	The UK believes that this should be referring to UN1798

UN2444	Agreed - amended in final version submitted to UNCOE

UN3095)

UN3301)	Could go to P099 in the UN list

UN3096)

UN3094)

UN1835)	Agreed - amended in final version submitted to UNCOE

UN2949)

UN2215	Agreed - amended in final version submitted to UNCOE

UN2511	Agreed - amended in final version submitted to UNCOE

UN2834	Agreed - amended in final version submitted to UNCOE

UN3257	Agreed - amended in final version submitted to UNCOE

UN1517	Agreed - amended in final version submitted to UNCOE

UN3181	UK does not agree - retain P002

UN1366	Agreed - amended in final version submitted to UNCOE.

UN1370	Agreed - amended in final version submitted to UNCOE in P403A.

UN2793	Agreed - amended in final version submitted to UNCOE.

IBCs

UN1390	UK does not agree - retain IBC07

UN1456	Packing Group II is assigned to UN IBC05

UN1472	UN IBC05	)

)

UN1476	UN IBC05	)

)

UN1481	UN PGI IBC04 PGII 05 )

)

UN1483	UN IBC05	)

)	The UK does not agree that these substances

UN1490	UN IBC05	)	should be moved to IBC04A. Most are

)	currently permitted in flexible IBCs in the

UN1503	UN IBC05	)	IMDG Code

)

UN1509	UN IBC05	)

)

UN1515	UN IBC05	)

)

UN1516	UN IBC05	)

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