SAFEX Newsletter No.35 - EU-Excert

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SAFEX Newsletter No.35, 4 th Qtr. 2010 12 Our Explosives Regulatory World Update on the 6 (d) Test Ben Barrett Ben Barrett, an Expert Panel member, is an independent consultant specializing in regulation of explosives. DG Advisor, Ben’s consultancy, is dedicated to participation in the development and modification of international dangerous goods regulations and helping clients comply with US and international regulations. Ben also provides training in the handling of dangerous goods including that required by ICAO. Background The 6(d) test was adopted in December 2008 by the UN for the purpose of removing certain products from Division 1.4 Compatibility Group S classification to Division 1.4 other than S. It examines addresses part of the definition of 1.4S that previously was evaluated using the 6(a) test: Substance or article so packed or designed that any hazardous effects arising from accidental functioning are confined within the package [Note: 6(d) test] unless the package has been degraded by fire. [Note: 6(c) test]. The 6(d) test method is based on the existing 6(a) single package test that determines whether inner packages or articles propagate one to the next when confined by surrounding material. The 6(d) is different in that it does not include surrounding material. The test measures the effects outside the package which can’t normally be discerned when confined. It was implemented by adding a special provision requiring the test for eight out of the approximately 32 existing 1.4S UN numbers, which include the following: Cartridges, power device, UN 0323 Charges, bursting, plastics bonded, UN 0460 Charges, explosive, commercial without detonator, UN 0445 Charges, shaped without detonator, UN 0441 Detonator assemblies, non-electric for blasting, UN 0500 Detonators, electric for blasting, UN 0456 Detonators for ammunition, UN 0366 Detonators, non-electric for blasting, UN 0455 The Issues The implementation of this test is a problem for all products in these UN numbers because it is retroactive. Existing products which would clearly pass still have to undergo the re-approval process. Products which would fail the test but obviously fit into Division 1.4 must undergo approval into 1.4 other than S since selfclassification is not allowed. Until recently the only impact of the 6(d) test has been for air shipments. In Spring 2009, the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air were amended by adding a new paragraph 1.4.2.1: “1.4.2.1 Certain Division 1.4S explosives, identified by Special Provision A165 in Table 3-1, are subject to Test Series 6 (d) of Part I of the UN Manual of Tests and Criteria (see ST/SG/AC.10/36/Add.2) to demonstrate that any hazardous effects arising from functioning are confined within the package. Evidence of a hazardous effect outside the package includes: a) denting or perforation of the witness plate beneath the package; b) a flash or flame capable of igniting such as a sheet of 80 ± 3 g/m2 paper at a distance of 25 cm from the package; c) disruption of the package causing projection of the explosives contents; or d) a projection which passes completely through the packaging (a projection or fragment retained or stuck in the wall of the packaging is considered as non hazardous). The appropriate national authority may wish to take into account the expected effect of the initiator when assessing the results of the test, if these are expected to be significant when compared to the articles being tested. If there are hazardous effects outside the package, then the product is excluded from Compatibility Group S.” A new Special Provision A165 was also added by ICAO: “A165 This entry must not be used for transport on passenger aircraft when testing in accordance with the UN Manual of Tests and Criteria Test Series 6 (a), upon which classification was based, has shown evidence of a hazardous effect outside the package. This includes denting or perforation of the witness plate beneath the package. From 1 January 2010, for transport aboard passenger aircraft, this entry may only be used if the results of Test Series 6 (d) of Part I of the UN Manual of
SAFEX Newsletter No.35, 4 th Qtr. 2010 13 Tests and Criteria have demonstrated that any hazardous effects arising from functioning are confined within the package (see 2;1.4.2.1). Note.— If the 6 (d) test is successfully completed before 1 January 2010, this entry may be used for transport on passenger aircraft.” Developments in the USA These provisions only existed in the ICAO regulations and not in national or regional regulations or rules for highway, rail or vessel. On August 24th, 2010 the DOT Pipeline & Hazardous Materials Safety Administration (PHMSA) issued a notice of proposed rulemaking to implement their bi-annual harmonization of the US regulations with the latest versions of regulations of the UN, IMO and ICAO. This provides the first clear picture in the US of the impact of the 6(d) test adopted by the UN in 2008 and expedited into the ICAO regulations in 2009. The essence of the requirements is contained in the new US special provision 347, assigned to the same eight UN numbers: “347 Effective April 1, 2011, for transportation by aircraft this entry may only be used if the results of Test series 6(d) of Part I of the UN Manual of Tests and Criteria (IBR, see § 171.7 of this subchapter) have demonstrated that any hazardous effects from accidental functioning are confined to within the package. Effective January 1, 2014, for transportation domestically by highway or rail, this entry may only be used if the results of Test series 6(d) of Part I of the UN Manual of Tests and Criteria (IBR, see § 171.7 of this subchapter) have demonstrated that any hazardous effects from accidental functioning are confined to within the package.” The impact of this proposed rule on the eight affected UN numbers carries through all modes of transportation. Since industry can’t self-classify explosives, companies may not simply self-classify these products as Division 1.4 with the correct compatibility group such as B or D. After these deadlines the products may not be shipped at all without a revised EX number from the DOT. It typically requires 120 days to perform the review and fitness evaluation, but can take substantially longer. The resulting PHMSA workload is significant. Thus, according to the proposed rule, in the US the 6(d) test must be performed by April 1, 2011 for a product to be transported by air (cargo too, not just passenger), whether as 1.4S or 1.4 other than S. PHMSA gives themselves a much more reasonable time frame of January 1, 2014 to implement the 6(d) test for shipments by highway or rail. From a practical standpoint this would include vessel, as one must use highway at some point to get to the port. I estimate that this proposed rule will be finalized by the end of the year at least with respect to this issue. Further developments in the UN As stated above, the 6(d) test was created to move products from Division 1.4 Compatibility Group S into Division 1.4 in compatibility groups other than S. The UN is considering expanding the 6(d) test criteria to impact “1.4 other than S” classifications. Thus the 6(d) test could be used to remove products from Division 1.4 and assign them into Divisions 1.1, 1.2 or 1.3. An informal paper UN/SCETDG/37/INF.40 presented the issue and discussion ensued at the 37th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods, as paraphrased below. It is suggested that the expanded criteria could be based on 6(c) test criteria, for instance the energy of projectiles measured by witness screens or the massdistance table. Some experts note that articles with a significant content of energetic substances may be packaged in such a way that a mass explosion of the whole content will not occur in the 6 (c) bonfire test, but they would generate significant effects if accidentally initiated. Examples were presented which include: “3. Shaped charges with UN 0440 (Hazard Division 1.4D) are limited to an NEQ of 25 grams per unit by some competent authorities, otherwise are classified with UN 0059 (Hazard Division 1.1D); 4. Explosives welding articles that contain a significant NEQ (e.g. 500 grams) may be packaged in such a way that a mass explosion of the whole package does not occur and end up being classified with a UN 0444 (1.4D); however the accidental initiation of a single charge may result in a significant blast which is not consistent with the definition for a 1.4 article; the appropriate classification may be UN 0442 (1.1D) to better reflect potential 5. articles containing smokeless powder used for blasting applications may be classified as UN 0323 (Cartridges Power Device, 1.4S) or UN 0276 (Cartridges Power device, 1.4C) based on series 6 testing including 6(d); note that this classification may be achieved with a product design feature that would prevent a potential deflagration if the article is unconfined rather than special packaging to contain hazardous effects; should such an article with a similar quantity of powder be assembled without an igniter this would be packaged propellant and classified as UN 0161 (1.3C);”
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