IPPIC's class 9 proposals remain on working agenda for upcoming UN biennium.
Unfortunately, since this was the last meeting of the biennium and there were an overwhelming number of proposals submitted to the SubCommittee for consideration, time ran out before IPPIC's papers could be discussed. While IPPIC will reconsider its strategy with regard to these papers prior to the start of the 2013-2014 Biennium, there was a very positive development on Class 9 materials that will lend some guidance to the coatings industry.
A proposal to deregulate small quantities of Class 9 materials was submitted by a Working Correspondence Group that was orchestrated at the June UNSCETDG meeting. This group was led by the U.S. delegation from the U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA), and many other competent authorities and industry experts participated in this effort. IPPIC contributed to the discussions and assisted with the proposed language. While there was some discussion of the proposal at the December meeting--which was complete deregulation of single or combination packagings of five liters or less--it was adopted as presented, with no changes. While this proposal does not specifically address paint, printing inks, adhesives, and resin solutions as Class 9 materials, these goods will be able to take advantage of the complete deregulation if shipped in packagings of five liters or less. More importantly, the SubCommittee also voted to continue the work of the Working Correspondence Group to determine if there were other accommodations that could be made for Class 9 materials that do not undermine safe transportation.
This accomplishment at the UNSCETDG is significant for the paint and coatings industry. When IPPIC first began discussions at the UN two years ago about the problems encountered with shipping these newly reclassified Class 9 materials, there was almost no willingness to entertain discussions or seek any solutions. The adoption of a small quantity exemption represents a big step forward on the part of the competent authorities in recognizing the magnitude of this problem in transportation.
Products in the adhesives, printing inks, printing ink-related materials, paints, paint-related materials, and resin solutions industries that contain little or no solvent and have historically been treated as nonhazardous and nonregulated for transport (Class 3, Flammable, and Class 8, Corrosive) are being classified in Class 9, Environmentally Hazardous, through the new application of the environmental hazard definition of the Globally Harmonized System for Classification and Labeling of Chemicals (GHS). This new classification has ramifications for all aspects of chemical use, including their transport. IPPIC is seeking a specific, numeric, proper shipping name that will alert emergency and first responders to the content of a package in the event of an incident so that they know what they are dealing with, and the potential risks. IPPIC is requesting a Class 9 entry for these specific instances to make it clear to emergency responders and avoid the burdensome proper shipping name of "Environmentally Hazardous Substance, n.o.s.," supplemented with technical names.
IPPIC also asked that the UNSCETDG recommend an increase to the threshold limit set for packing group III adhesives, printing inks, printing ink-related materials, paints, paint-related materials, and resin solutions which are assigned to UN3082 from five liters to 30 liters by adding a new special packing provision to Packing Instruction P001.
Plastic pails in quantities of 5, 10, 20, 25, and 30 liters are standard containers used by paint contractors for small, medium, and large jobs, and are transported in very high volumes. Currently, such products that meet the definition of an environmentally hazardous substance are not regulated for transport in the United States in packages less than 450 liters. Special Packing Provision PP1 exempts packagings of five liters or less from the performance tests in chapter 6.1. Consequently, five-liter containers do not need to be UN specification packagings for any mode of transport. However, plastic pails greater than five liters are required to be UN specification packaging.
Use of a UN specification packaging has been problematic for manufacturers and shippers. End-use customers find the UN specification pails difficult to open for color adjustment and then to close again in accordance with the packaging instructions for transport. In addition, the added expense of UN specification packaging for extremely low hazard products far exceeds any benefit in safety.
IPPIC believes that an increase in the packaging exception limit set for packing group III adhesives, printing inks, printing ink-related materials, paints, paint-related materials, and resin solutions that are assigned to UN3082 would simplify use and transport for industry and end-users without prejudicing safety or the work of emergency responders. Of note, IPPIC was instrumental in introducing the PPI Special Packaging Provision into the UN Model Recommendations.
In moving forward to the next biennium, IPPIC must decide on its strategy. The question whether to resubmit these proposals must be made prior to the filing deadline at the end of March.
Contact ACA's Heidi McAuliffe (firstname.lastname@example.org) for more information.
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|Title Annotation:||ACA Issues In-Depth|
|Date:||Jan 1, 2013|
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