IPPIC Proposal to be Considered by UN Transport of Dangerous Goods Committee
November 6, 2018
A proposal developed by the International Paint and Printing Ink Council (IPPIC) will be considered at the upcoming meeting of the United Nations’ Subcommittee of Experts on the Transport of Dangerous Goods (UNSCETDG) from Nov. 26 – Dec. 4 in Geneva, Switzerland. The proposal, which ACA helped craft, seeks to alleviate technical name requirements for environmentally hazardous substances.
Paints and printing inks are high volume commodities in the global marketplace. With the move toward water-based formulations (estimated to represent some 50 percent of liquid products overall) and other non-solvent-borne products such as powder coatings, a high percentage of these goods is now regulated as Class 9 due to environmental hazards. These products are transported under entries UN 3077 or UN 3082 of the Dangerous Goods List (“ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID/LIQUID, N.O.S.”) accordingly.
This classification creates many issues related to documentation and marking, such as a lack of clear information on the exact nature of the dangerous goods — which can hinder the task of emergency responders and cause consignments to be delayed or stopped pending clarification — as well as practical difficulties in appending long, and often incomprehensible, technical names to the proper shipping name. IPPIC has been working to identify solutions that would mitigate these problems and make the regulatory requirements more commensurate with the hazard.
To ensure consistency between national regulatory systems governing every mode for the transport of dangerous goods (TDG), the United Nations established appropriate harmonization mechanisms, which occur biennially during the meeting of the UNSCETDG. Every four meetings (every two years), the Subcommittee compiles meeting proceedings into an updated version of the UN Model Regulations — recommendations on the transport of dangerous goods. The model regulations are used by many countries as a basis for the country’s TDG regulations. ACA, through its Transport Committee and IPPIC, is proactively engaged in efforts to harmonize the model regulations to ensure efficiency and cost-effectiveness for cross-border and multi-modal shipments of paint and allied products.
Rather than uncertainty concerning the ability to use generic names as technical names, IPPIC is proposing a special provision that enables the UNSCETDG to identify names within the Model Regulations that are considered to provide clear and valuable information to transport handlers and emergency responders, and to permit their use as technical names.
IPPIC’s proposal suggests that the new special provision can be allocated to Dangerous Goods List entries (existing or new) at any time as required, based on a proposal to the UNSCETDG. ACA and IPPIC maintain that this avoids both the need to establish a complete list immediately, as well as the risk of inadvertently allowing names that would not be appropriate in the context of UN 3077 or UN 3082.
ACA staff will be attending the upcoming UNSCETDG meeting in Geneva where the IPPIC proposal will be considered.