UN/SCETDG/16/INF.6

COMMITTEE OF EXPERTS ON THE TRANSPORT

OF DANGEROUS GOODS

Sub-Committee of Experts on the

Transport of Dangerous Goods

(Geneva, 5-16 July 1999,

agenda item 5(d))

MISCELLANEOUS DRAFT AMENDMENTS TO THE MODEL

REGULATIONS ON THE TRANSPORT OF DANGEROUS GOODS

Packagings

Comments on ST/SG/AC.10/C.3/1999/42, Reconditioned packagings

Transmitted by the International Confederation of

Container Reconditioners (ICCR)

The International Confederation of Container Reconditioners (ICCR, formerly ICDR), hereby comments on the paper (ST/SG/AC.10/C.3/1999/42) transmitted by the Expert from Italy, on the subject of reconditioned packagings.

We agree with the Expert from Italy that national and international laws on the environment are resulting in more reprocessing of packaging for dangerous goods, through reuse, reconditioning, and remanufacturing. In the name of ICDR, several years ago we proposed and the Committee adopted new definitions and requirements intended to bring clarity and control to the reconditioning process. Set forth were specific new marking requirements, testing and retesting criteria, etc. These changes have been implemented worldwide by industry and are accepted by fillers of dangerous goods packaging. Approximately 100 million reconditioned steel drums are shipped globally each year, with a superb safety record. In the U.S., where accident data are recorded, reconditioned steel drums have a safety record in excess of 99.9% annually. For these reasons, we strongly disagree with the suggestion that today's reconditioning requirements in the Model Regulations are inadequate.

Although the Italian paper is correct that under 6.1.3.2 the fate of some packaging is left to the knowledge and discretion of the manufacturer who must decide whether his product is liable to undergo a reconditioning process, this is not the case with metal drums of a capacity greater than 100 liters. The vast majority of reconditioned packagings are metal drums of this size. Under 6.1.3.2.1, every new metal drum of a capacity greater than 100 liters shall be marked permanently on the bottom with their original performance capability and date of manufacture, as well as the nominal thickness of the metal.

A permanent mark is one that can withstand the reconditioning process, which is defined in 1.2.1 as cleaning to the original materials of construction and removal of labels. A printed mark covered with tape absolutely cannot withstand this cleaning process and is not permanent.

The paper from Italy says that the general requirements on reconditioning are only in 4.1.1.9, but this ignores the extensive definition of the reconditioning process in 1.2.1, including cleaning to original materials of construction, removal of labels, removal of all contents, replacement of all non-integral gaskets, and inspection after cleaning. In addition, every reconditioned drum used for liquid dangerous goods must be leakproofness tested under 4.1.1.12(b). Ultimately, the provision in 4.1.1.9 declares unambiguously that every new, remanufactured, reused, or reconditioned packaging shall be capable of passing the tests prescribed in 6.1.5.

The paper from Italy says that reconditioners are unknown to the competent authority. This is not accurate. Every packaging reconditioned for use in transport of dangerous goods must be marked with "the name or registered symbol of the reconditioner." This is the same as for makers of new packaging under 6.1.3.1(g).

The paper from Italy would impose a quality assurance program on reconditioners, but remove it from applicability to manufacturers of new packagings. If the quality of a packaging is not assured from the time of new manufacture, then imposing quality assurance on its reconditioning cannot add quality. We think adoption of this proposal would be a serious error.

The paper from Italy would require the reconditioner to mark the information shown in 6.1.3.1(e) on reconditioned packagings. This is the date of original manufacture of the packaging. The reconditioner now is obligated to mark the year of reconditioning, under 6.1.3.4(j). On metal drums over 100 liters capacity, the original date of manufacture remains marked permanently in the bottom head. Therefore, when the reconditioner's mark was clarified a few years ago, it was considered unnecessary to repeat the date of original manufacture on the top head or side because it already appears on the bottom, and because it could be confused with the year of reconditioning marked by the reconditioner.

In conclusion, ICCR believes the proposals in the paper from Italy are based upon a misunderstanding of the existing obligations of reconditioners under the Model Regulations and regulatory codes based on the UN model. No changes to the existing requirements are needed. If any reconditioners are not meeting the existing requirements, then we recommend vigorous enforcement, not the adoption of new requirements.

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