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UN PROGRAM Palais des Nations, Geneva, Switzerland European Headquarters of the United Nations Transport of Dangerous Goods and Globally Harmonized System of Classification and Labelling
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Member Companies
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LIAISON CLASS MEMBERS
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IME is a Non-Governmental Organization (NGO) that participates in the work of two closely related UN groups: UN Sub-Committee of Experts on the Transport of Dangerous Goods (TDG) UN Sub-Committee of Experts on the Globally Harmonized System for Classification and Labelling of Chemicals (GHS) What …
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… and Why The work of these two UN groups:
impacts the safe use and handling of dangerous goods in transport and other sectors such as the workplace and public commerce and are the basis of globally harmonized international regulations including the: Hazardous Materials Regulations of the U.S. Department of Transportation (49 CFR Parts 100 – 185) and the Hazard Communication Standard of the Occupational Safety and Health Administration (29 CFR ) … and Why
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Recommendations on the Transport of Dangerous Goods, Model Regulations (TDG)
Manual of Tests and Criteria (TDG) Globally Harmonized System of Classification and Labelling of Chemicals (GHS) What they Produce
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Related to transportation:
Dangerous goods classification Security of dangerous goods Packaging of dangerous goods Hazard communication Placarding Labeling Marking Shipping papers Model for US Hazardous Materials Regulations (DOT) Recommendations on the Transport of Dangerous Goods, Model Regulations (TDG)
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Related to transportation and other sectors:
Managed by the TDG’s Working Group on Explosives (EWG) Logic for dangerous goods classification Tests and acceptance criteria to support dangerous goods classification Required under Hazardous Materials Regulations (DOT) for explosives classification and approval Manual of Tests and Criteria (TDG)
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Related to transportation and other sectors:
Defers to TDG Model Regulations for transport Provides guidance for other sectors Globally harmonizes hazard communication elements such as labels and safety data sheets Model for US Hazard Communication Standard (OSHA) Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
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this group (see next slide)
IME works within this group (see next slide) Advisory (as needed) Where we fit in at the UN
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Structure & Operations
Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of Chemicals TDG Sub-Committee GHS Sub-Committee Operate on an odd/even biennial basis (i.e., 2019/2020) Sub-committees meet 4 times per biennium (EWG meets 2 times per biennium) Summer (June/July): Sub-committees and EWG Winter (November/December): Sub-committees only Committee meets at end of biennium (December) to ratify work completed by sub-committees Structure & Operations
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How the Sub-Committees Work
Delegations submit documents for debate within the sub-committees: Working Documents (formal proposals) Informal Documents (preliminary proposals and comments on formal proposals) Proposals are refined throughout one or more biennia Sub-committee accepts, notes, or rejects proposal (TDG, simple majority & GHS, consensus) Accepted proposals are reviewed and ratified by the Committee Model Regulations and the GHS document are normally published during first half of following biennium, the test manual is published as needed (amendments issued in the interim) Recommendations are then considered by national, international, and modal authorities for incorporation into their regulations (this may take another one to two years. How the Sub-Committees Work
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The EWG Working Group on Explosives
Due to the specialized nature of explosives issues, TDG Sub-committee assigns proposals addressing explosives and related issues to its Working Group on Explosives (EWG). EWG meets separately during the TDG meeting and reviews assigned issues and makes recommendations for further developing, rejecting, and/or accepting proposals. Work of the EWG is summarized in a report that is delivered to TDG Sub-committee at beginning of the 2nd week. TDG Sub-committee endorses continuing work and approves or rejects proposal recommendations. EWG serves in an advisory capacity to GHS on explosives hazards. The EWG
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Participation in the Sub-Committees
Governments USA PHMSA OSHA Others Specialized Agencies & International Governmental Bodies ICAO – air IMO – maritime IAEA – atomic energy WHO – world health Participation in the Sub-Committees
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Participation in the Sub-Committees
Non-Governmental Organizations IME – commercial explosives AEISG – Australian commercial explosives SAAMI – sporting ammunition DGAC – dangerous goods COSTHA – safe transportation of hazardous materials IATA – air transport Others Participation in the Sub-Committees
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IME Representation UN Consultant (contractual)
IME’s head of delegation Currently serves as EWG secretary Maintains IME UN-related webpages: Fully supported by IME under contract Currently assigned: David Boston (IME member Owen Oil Tools, LP) Subject Matter Experts/Advisers (voluntary) Supports UN Consultant Provides technical expertise on specialized topics Partially supported by IME as approved by IME president Currently assigned: Noel Hsu (IME member Orica USA, Inc.) and Jackson Shaver (IME member Daicel Corporation) Current IME Delegation at the UN (l to r) Jackson Shaver, David Boston, Noel Hsu IME Representation
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Current Projects Review of test manual in the context of the GHS
EWG project. Remove transport specificity where not required and make more general to apply to all sectors covered by GHS. Status: Completed and approved 2017/2018 biennium. 7th rev. of the test manual should be available end of 2019. Implementation: Must be implemented by national, international, and modal authorities before becoming effective, most likely on 1/1/2021. Current Projects
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Current Projects Review of GHS Chapter 2.1 (explosives)
Under review by GHS informal correspondence group (ICG) and EWG Remove classification related to transport and make more appropriate for all sectors 2 new proposed GHS classification categories: 1 – explosives that have not been assigned transport classification 2 – explosives that have been assigned transport classification. Sub-divided into 2A (high hazard), 2B (medium hazard) and 2C (low hazard) Accepted by EWG and ICG at 55th TDG and 37th GHS (Summer 2019) Status: Expected completion in 2019/2020 biennium. Updates yet to be completed: GHS labels, GHS SDS, text of GHS chapter 2.1. Current Projects
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Clarification of applicability of UN 0220 Ammonium nitrate
IME proposal. Amend Special Provision 370 to better identify to what the entry applies. Status: Approved by the TDG at its 54th Session (Nov/Dec 2019). To be included in 21st Rev. of the Model Regulations (due mid-2019). Implementation: Must be implemented by national, international, and modal authorities before becoming effective, most likely on 1/1/2021. Current Projects
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Current Projects Improvement of Test Series 8 (UN 3375)
IME/Canada proposal. 8(c) Koenen test determined to be unsuitable for evaluating emulsions with high water content and low volatility oils – give false positives (failures). Add minimum burning pressure (MBP) test to evaluate candidates that fail Koenen test. If the substance that failed the Koenen test had a time to reaction greater than 60 seconds and water content greater than 14%, then MPB test may be performed. If MBP is > 5.6 MPa, UN 3375 is possible. Status: Approved by the TDG at its 54th Session (Nov/Dec 2019). To be included in 7th Rev. of the test manual (due end of 2019). Implementation: Must be implemented by national, international, and modal authorities before becoming effective, most likely on 1/1/2021. Current Projects
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Current Projects Review of UN standard detonator
Joint project between IME and Germany (BAM). Used in evaluating explosives when standardized detonator output is needed for the evaluation. Update current European and USA versions and combine into a single standard specification. Status: Was on hold until completion of the review of test manual in the context of the GHS. Now that the review is complete, expect work to continue during 2019/2020 biennium. Current Projects
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Current Projects New entries for electronic detonators AEISG proposal.
Applies to field programmable electronic detonators New entries in Division 1.1B, 1.4B, and 1.4S. Similar transport requirements to electric detonators Status: Complete. To be included in 21st rev. of the Model Regulations due mid-2019. Must be implemented by national, international, and modal authorities before becoming effective, most likely on 1/1/2021. Current Projects
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EWG Work Program for 2019/2020 Biennium (1 of 3)
Review of test series 6. The mandate of this review is to remove over specifications, redundancies, impractical specifications (due to limited or no availability of test materials), and to otherwise provide improvements to the test series drawing upon decades of experience performing the tests and assessing test results. Improvement of test series 8. Work will continue with a goal to improving the 8(c) Koenen Test used for classifying ANEs into UN 3375 (Division 5.1) and seeking practical improvements or alternatives to the 8(d) Vented Pipe Test used for evaluating the suitability of ANEs for containment in tanks as oxidizing substances (i.e., UN 3375). EWG Work Program for 2019/2020 Biennium (1 of 3)
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EWG Work Program for 2019/2020 Biennium (2 of 3)
Review of tests in parts I, II and III of the Manual of Tests and Criteria. Nothing specific has yet been identified for this item. UN standard detonator. Discussed previously. Review of packing instructions for explosives. Nothing specific has yet been identified for this item. Application of security provisions to explosives N.O.S. Nothing specific has yet been identified for this item. Test N.1 for readily combustible solids. Nothing specific has yet been identified for this item. EWG Work Program for 2019/2020 Biennium (2 of 3)
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EWG Work Program for 2019/2020 Biennium (3 of 3)
Review of Chapter 2.1 of the GHS Purple Book. Discussed previously. Energetic samples. Nothing specific has yet been identified for this item. Issues related to the definition of explosives. Sweden will lead an informal correspondence group to investigate further. Review of packaging and transport requirements for ANEs. Nothing specific has yet been identified for this item. EWG Work Program for 2019/2020 Biennium (3 of 3)
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Thank you David Boston Institute of Makers of Explosives
c/o Owen Compliance Services P.O. Box 765 Godley, TX IME Headquarters Institute of Makers of Explosives 1212 New York Ave., NW Suite 650 Washington, DC Thank you
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