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Implementation of new UN 6(d)
Test for Certain 1.4S Candidates and Acceptability of 1.4S
Products for Transport by Air
Topics
Background
Implementation Schedule (updated
10/21/2009)
Suggested Course of Action
OOT
Compliance Status (updated
7/23/2009)
Other Resources (updated
10/21/2009)
Background.
In December 2008, the UN Sub-committee on the
Transport of Dangerous Goods (UNSCETDG), completed work on and
accepted a new test to be applied to certain candidates for 1.4S
classification. The new test, called the UN 6(d) Unconfined
Package Test, is intended to evaluate whether hazardous effects
occur outside the 1.4S package as a result of accidental
functioning. The test only applies to the following 1.4S
entries that must pass the test or be assigned to a different
classification:
|
ID No.
|
Description
|
Class
|
|
UN0323
|
Cartridges,
power device
|
1.4S
|
|
UN0366
|
Detonators
for ammunition
|
1.4S
|
|
UN0441
|
Charges,
shaped
|
1.4S
|
|
UN0445
|
Charges,
explosive, commercial
|
1.4S
|
|
UN0455
|
Detonators,
non-electric
|
1.4S
|
|
UN0456
|
Detonators,
electric
|
1.4S
|
|
UN0460
|
Charges,
bursting, plastics bonded
|
1.4S
|
|
UN0500
|
Detonator
assemblies, non-electric
|
1.4S
|
"The Eight"
Entries to which UN 6(d) Test applies
The 6(d) test will be published in a new Section
16.7 of the UN Manual of Tests and Criteria. Until
an amendment to the 4th Rev. of the test manual is released (or
until a 5th Rev. of the test manual is published), the full text
of the 6(d) test can be found on pages 7 - 9 of UN document
ST/SG/AC.10/36/Add.2. This document is available at: http://www.unece.org/trans/main/dgdb/dgcomm/ac10rep.html#36a2.
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Implementation Schedule.
(updated
10/21/2009)
The UNSCETDG expected that the 6(d) test
would be implemented through regulatory channels, most likely by
2011.
Implementation in
the USA. At present, USA implementation is as
follows:
1. The 6(d) test
will be used for all new classifications of "the
8" beginning July 1, 2009. Authorized labs have been
advised of this requirement.
2. Self-evaluation of already
classified members of "the 8" is authorized.
This evaluation should include:
-
Review of 6(a) data to determine if that
data conclusively indicates that there are no hazardous
effects outside of the package.
-
Performance of 6(d) tests to determine if
members of "the 8" are packaged so that there are
no hazardous effects outside of the package.
-
Preparation of report(s) describing the
evaluations completed to support decisions as to which
members of "the 8" are eligible for passenger air
transport, and which are not. Although not presently
required, OCS recommends sharing this information with PHMSA
(see Suggested Course
of Action below).
3. (10/21/2009)
PHMSA issued an Advanced Notice of Proposed Rulemaking (ANPRM)
on 10/21/2009 (click here
for a copy). In this ANPRM, PHMSA is announcing Docket
HM-215K which will implement changes to the U.S. Hazardous
Materials Regulations (HMR) to harmonize the HMR with various
international standards including the UN, ICAO, and IMO.
In the ANPRM, PHMSA is asking for:
-
comments regarding possible safety
impacts and compliance costs associated with implementation
of the 6(d) test and
-
comments/recommendations as to whether
the 6(d) test should be applied to already approved explosives.
The comment deadline is January 19, 2010 and
instructions for filing comments are contained in the ANPRM.
Implementation in
International Modal Regulations. At present,
the 6(d) test has only been implemented for air transportation
by ICAO. ICAO implementation is via a new Special
Provision A165 that is now in effect as follows:
1. 1/1/2009 - 12/31/2009:
"The Eight" are prohibited from shipment by passenger
aircraft unless UN 6(a) data indicates no hazardous effects
outside the package. This is a transitional measure to
allow use of existing test data for evaluation until 6(d)
testing can be obtained. If 6(a) data indicates no
hazardous effects, shipment by passenger aircraft is
authorized. If 6(a) data indicates hazardous effects,
shipment on passenger aircraft is prohibited and is restricted
to cargo aircraft only. In this case, the packages must be
labeled with the Cargo Aircraft Only label and the appropriate
notation made on shipping documents.
2. Beginning 1/1/2010: "The
Eight" are prohibited from shipment by passenger aircraft
unless UN 6(a) data and 6(d) data indicate no hazardous
effects outside the package. If 6(a) and 6(d) data
indicate no hazardous effects, shipment by passenger aircraft is
authorized. If 6(a) and 6(d) data indicate hazardous
effects, shipment on passenger aircraft is prohibited and is
restricted to cargo aircraft only. In this case, the
packages must be labeled with the Cargo Aircraft Only label and
the appropriate notation made on shipping documents.
3. Beginning 1/1/2011: It is
expected, although not yet documented, that "The
Eight" may no longer be offered for any mode of
transportation as 1.4S unless 6(d) data indicates no hazardous
effects. In this case, new items that cannot pass the 6(d)
test will be assigned to a class other than 1.4S and existing
1.4S items that cannot pass the test will have to be reclassified
to something other than 1.4S.
Implementation in
other National Regulations. At the June
2009 UNSCETDG meeting, most countries advised that they expected
implementation beginning in 2011. However, in addition to
the USA (see #1 under Implementation in the USA),
Canada and the UK have indicated that they expect implementation
in advance of 2011. Actually, Canada has been using a form
of the 6(d) test for many years, so implementation in that
country may be almost complete.
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Suggested Course of Action.
1. Now:
check 6(a) data for "The Eight" and determine if
negative 6(a) effects exist.
a. If negative data exists, cease
offering for passenger air shipment, place "Cargo
Aircraft Only" labels on packages and identify the cargo
aircraft only restriction on air shipping documents.
b. If negative data does not exist,
continue shipments by passenger air. Take no further
corrective action.
2. Before
1/1/2010: Submit a letter to the Deputy Associate
Administrator, OHMS/PHMSA/DOT describing:
a. Currently approved members of
"The Eight" that have previously passed the 6(d)
test or equivalent. Provide copies of test data to
substantiate claim.
b. Currently approved members of
"The Eight" that have not been subjected to the 6(d)
test, but that you believe will pass the test and the basis
for that belief.
c. Currently approved members of
"The Eight" that have failed the 6(d) test or have
not been subjected to the 6(d) test and that you believe would
not pass that test.
In the letter, seek
guidance from the Deputy Associate Administrator regarding
proper disposition of the above. Address the letter to:
Mr. Robert A. Richard
Deputy Associate Administrator
U.S. Department of Transportation
PHMSA/OHMS, PHH-2
1200 New Jersey Avenue, SE
East Building, 2nd Floor
Washington, DC 20590
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Owen Oil Tools Compliance
Status. (updated
7/23/2009)
1. Products manufactured by Owen Oil
Tools under entries UN0323, UN0455, and UN0456 have been tested
and pass the requirements for assignment to 1.4S. No
changes in classification or shipping modes are anticipated.
Click here to
obtain a copy of the report.
2. Products manufactured by Owen Oil Tools under
entries UN0441 and UN0445 will not pass the "no hazardous effects"
requirements for assignment to 1.4S. For transportation by
air, these products are restricted to cargo aircraft only.
On 4/8/2009, OOT began affixing a Cargo Aircraft Only (CAO) label
on packages containing UN0441 items and began appropriately
noting the CAO restriction on air shipping documents.
In July 2009, OCS provided formal notification to OOT regarding
its labeling obligations pertaining to packages containing
UN0441 or UN0445 products. Click
here to obtain a copy of that notification.
3. Owen Oil Tools currently does not
manufacture products under enter entries UN0366, UN0460,
or UN0500.
4. Owen Oil Tools manufactures other
products under 1.4S entries that are not part of "The
Eight" and are not subject to testing under UN Test 6(d).
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Other
Resources.
(updated 10/21/2009)
Links to other resources on this topic will
be posted here as they become available.
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