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• The plenary session noted the outcome of discussions by the Working Group on Explosives relating to the use of the Manual of Tests and Criteria in the context of GHS. As a result, a note will be added to 1.1.1 in the Manual to explain that wherever the term “substance” appears it includes substances and mixtures, unless specified otherwise. The issue of replacing transport-specific
classification flowcharts in the Manual should be considered further to try to determine an acceptable solution. The Working Group was also asked to continue work to add guidance about how to address changes in physical state but recommendations concerning references to packing group and/or category in Part III of the Manual was accepted. • The Dangerous Goods Advisory Council (DGAC) continued to press for a definitive means of prohibiting the use of separate GHS
ICAO REPORTED ON RULE CHANGES INVOLVING INFECTED ANIMALS, LITHIUM BATTERIES AND CATECHOLBORANE
“IBCS ARE NOT INTENDED TO
CONTAIN ARTICLES AND CANNOT THEREFORE BE APPROVED FOR USE AS SALVAGE PACKAGINGS”
pictograms in transport. The Sub-committee agreed to adopt language as used in GHS in a new Note at the end of 5.1.1: In accordance with the GHS, a GHS pictogram not required by these Regulations should only appear in transport as part of a complete GHS label and not independently (see GHS 1.4.10.4.4). • Another paper from DGAC drew attention to the practical problems caused during transport when authorities require the GHS labelling of transport packages (i.e. outer packagings of combination packagings) that contain chemicals which are not subject to transport of dangerous goods regulations. This paper was also submitted to the GHS Sub-committee. • The Council on Safe Transportation of Hazardous Articles (COSTHA) reported that industry is often asked to supply safety data sheets (SDSs) for certain articles containing dangerous substances, even though GHS is not supposed to apply to articles. In such cases it is not clear how to complete the SDS, since section 14 applies to the article as offered for shipment while the rest of the SDS applies to the substance contained in the article.
The Sub-Committee recognised the
problem and felt it would be useful if both Sub-committees could develop joint guidance. The secretariat suggested that the list of articles subject to the Model Regulations be submitted to the GHS Sub-committee to seek their advice as to whether or not the GHS, including SDS, is applicable. • France reported on problems encountered in trying to determine the physical hazards of nanomaterials when using the usual test methods of the Manual. This issue will be submitted to the GHS Sub-committee working group dealing with nanomaterials. • The Working Group on Explosives had found the text proposed by Sweden for precautionary statement P502 hard to comprehend. It recommended that a separate precautionary statement for explosives be developed, as originally proposed by Sweden. HCB
The 49th session of the TDG Sub-committee was held between 27 June and 6 July 2016; a report on this meeting, the third of four in the current biennium, will be included in a forthcoming issue of HCB Monthly.
HCB MONTHLY | SEPTEMBER 2016
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