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 ?? ??? ? ? ?? ?   ?      ? ? ? ?     ?  ? ???  ???  ?? ?? ??  ?  ?? ?   ?   ?  ?  ??? ??  ?  ? ?   ??  ????  ?? ?   ?   ?  ?  ?   ??  ?     ?  ? ? ?      ?     ?  ?  ?   ?? ?  ?  ?    ??    ?    ?    ??  ?      ?   ?     ?     ?     ??  ? ??  ??  ?    ? ??  ??     ? ? ?  ? ?    ?      ? ? ?        ? ??  ? ?      ? |  >  ?    ? ? ? ???  ?? @???  ?? ? ?? ??  ? ??    ??? ????  ? ?  ??    ?  ? ?     ?? ? ??? ?    ?  ?  ??     ?  ?          ?  ?~ x  p  ?  ?  ?  ?  ?   ?     ?     ?   ?? ???????????++`+?+ *? ?*? ?* * ****?(?(?((((''?(?()**?+?+?,?-.K(&%$$##"?  ?    q ???? !?"*) )( ?((''?&&?&%%$?$?$? ? ? ??   ?   . .? ?. - - ?- - --,,, ,? ,!+?!+"+ "+ #+ $+4*4*?4*4*4*?4*4*4*3)?3)3)3)?3)3)3)3)3)2)?2)2)2)2)2)2)2*π2B1B1B?1B?1B1B?1C1C2C2C2w* R  +? y Fdddyy GQdddjy 1  1 #p?7t-# !!!yddE  #}p?7#STUNITED  Z NATIONS yAn?22 dd#UNLOGO.WPG>nya   :,dd:-   d # p?7X #Secretariat#d6X@8;z@#+b >uQ!?+?  X #Xw P7[hXP#? Distr. ?RESTRICTED ? ?ST/SG/AC.10/R.523 ?17 September 1996 ?Original : ENGLISH  ?+ COMMITTEE OF EXPERTS ON THE TRANSPORT OF DANGEROUS GOODS  4(Nineteenth session, Geneva, 211 December 1996  X\ agenda item 6 (a)) NPERIODICITY OF AMENDMENTS TO THE RECOMMENDATIONS )Note by the secretariată ?+? sO?+  Y_ 1.+? sO+k ++The question of the periodicity of amendments to the Recommendations on the Transport of Dangerous Goods was raised by the International Maritime Organization (IMO) in a letter addressed by the SecretaryGeneral of IMO to the SecretaryGeneral of the UnitedNations. This letter was submitted to the Economic and Social Council at its 1996 substantive session (24 June to 26 July 1996) (see annex 1).  Y! 2.As the question of periodicity of amendments had already been raised during the eighteenth session of the Committee of Experts on the Transport of Dangerous Goods (28November7December1994), the SecretaryGeneral presented a document (E/1996/66) to the Council summarizing the status of discussions at the Committee level (see annex 2). GE.96 (R523.EN)  RN  +# ,---RRԌ Y .cST/SG/AC.10/R.523 page .d\r Y 553((;AccFccFST/SG/AC.10/R.523  Y 553((;AccFccFpage 3.PPDocument E/1996/15 was also brought to the attention of the United Nations Economic Commission for Europe Working Party on the Transport of Dangerous Goods (WP.15) at its fiftyninth session (610 May 1996), before the Council's session, and the comments made by WP.15 at that session (TRANS/WP.15/142, paras 96103) were brought to the attention of the Chairman of the Council (see annex 3).  Yv 4.PPSeveral organizations wrote to the SecretaryGeneral commenting on the letter from the SecretaryGeneral of IMO. These comments were brought to the attention of the Council as follows:  Y E/1996/63@ (Letter from the DirectorGeneral of the International Air Transport Association (IATA) to the SecretaryGeneral)Ɵ#  Y E/1996/84@ (Letter from the SecretaryGeneral of the International Civil Aviation Organization (ICAO) to the SecretaryGeneral)Ɵ#  Y E/1996/NGO/1@ (Statement of the Hazardous Material Advisory Council (HMAC)).Ɵ# These comments and statements are reproduced in annex 4.  Y4 5.PPThe issue was discussed by the Council and the following decision 1996/301 was taken: "At its fiftysecond meeting, on 26 July 1996, the Economic and Social Council took note of the note by the SecretaryGeneral, indicating that the Committee of Experts on the Transport of Dangerous Goods would examine, at its forthcoming session, the periodicity of amendments to the Recommendations on the Transport of Dangerous Goods, invited the Committee to take fully into account the views expressed by delegations during the substantive session of 1996 of the Council, and invited Member States that had not yet done so to submit to the Committee their views on the matter."  Y7 6.PPThe Committee is invited to consider Council's decision 1996/301 and to take action as deemed appropriate. `5, ă+((  X cd6\ ST/SG/AC.10/R.523 page  Annex 16] y Y 553((;AccFccFST/SG/AC.10/R.523  Y 553((;AccFccFpage   Y0 553((;AccFAnnex 1 50ANNEX 1 ă Letter dated 21 July 1995 from the SecretaryGeneral of the International Maritime  Y Organization addressed to the SecretaryGeneral of the United Nations (E/1996/15, 22February 1996) The Economic and Social Council, in paragraph 3 of its resolution 1993/50 of 29July1993 on the work of the Committee of Experts on the Transport of Dangerous Goods, invited, interalia, the specialized agencies to transmit to the SecretaryGeneral of the United Nations their views on the work of the Committee, approved by the Committee for inclusion in its existing recommendations together with any comments they might wish to make on the amended recommendations. In response to that invitation I wish to refer to the difficulties encountered by the International Maritime Organization in the implementation on a biennial basis of the numerous changes in the recommendations. As a consequence of these changes, bulky amendments to the IMO International Maritime Dangerous Goods (IMDG) Code become necessary, although it is generally recognized that their impact on safety is somewhat limited. The frequency of these changes undermines the credibility of the Code, as it is difficult for ships and ports to keep up with the everchanging requirements and for the provisions of the Code to be enforced. The problems associated with the frequent changes in the Code have been emphatically illustrated by random inspections of container cargoes in North European ports. I am advised that these have shown that, in some cases, dangerous goods are being carried under versions of the Code that date back a good many years. Another fact to be borne in mind is that nowadays a considerable proportion of the world fleet is registered in developing countries which find it even more difficult to keep abreast of the frequent changes. The need to restrict amendments to IMO instruments has been a subject of consideration by this Organization for many years. A first attempt was the adoption by the IMO Assembly in1981 of resolution A.500 (XII) in which the Assembly recommended that the Committee should entertain proposals for amendments only on the basis of a clear and welldocumented demonstration of compelling need and having regard to the costs to the maritime industry and the burden on the legislative and administrative resources of member States. Further discussions on the subject have led to the decision that, in principle, amendments to IMO instruments should be adopted in periods of not less than four years, to give member Governments and the industry time to incorporate the provisions into their national legislation and to ensure that ships comply with any new measures. I appreciate that industrial developments cannot be halted to accommodate the concerns I have mentioned above and that continuous updating of the rules might be necessary. However, I am also acutely conscious of the fact that unless the workload associated with amendments to instruments regulating the transport of dangerous goods is reduced to manageable proportions,;&+'' our aims of increasing maritime safety and protection of the marine environment may be jeopardized. I therefore seek your cooperation in conveying to the Economic and Social Council the request made by the Maritime Safety Committee (MSC), IMO's most senior technical body, at its sixtyfifth session (917 May 1995), that the publication cycle of the Recommendations on the Transport of Dangerous Goods be expanded from every two to every four years so as to enable the smooth and timely harmonization among the different modes of transport. While the Committee of Experts did not support such a proposal at its eighteenth session in December 1994, the Committee stated that the question could be reconsidered in 1996. In this light, it is essential that the Economic and Social Council be apprised of the concerns of IMO and the recommendation of MSC. I should therefore be most grateful if you would bring theIMO position to the attention of the Council and, in due course, inform me of any decision made in this respect. `#B(Signed) W. A. O'NEIL `#JSecretaryGeneral    6^ST/SG/AC.10/R.523 page  Annex 26_ Y 553((;AccFccFST/SG/AC.10/R.523  Y 553((;AccFccFpage   Y0 553((;AccFAnnex 24+''  X  50ANNEX 2 ă  -!QS   Y Note by the SecretaryGeneral (E/1996/66, 12 June 1996)  Y 1.PPReference is made to the letter dated 21July1995 from the SecretaryGeneral of the International Maritime Organization to the SecretaryGeneral of the United Nations (E/1996/15) and to the letter dated 29April1996 from the DirectorGeneral of the International Air Transport Association to the SecretaryGeneral (E/1996/63) concerning the periodicity of amendments to the Recommendations on the Transport of Dangerous Goods.  Y 2.PPThis question was discussed by the Committee of Experts on the Transport of Dangerous Goods at its eighteenth session (Geneva, 28November7December1994). The discussion was reflected in paragraphs159 to 162 and 167 to 173 of the report of the Committee (ST/SG/AC.10/21), which are reproduced in the annex below.  Y 3.PPThe question will be discussed again at the next session of the Committee (2-11December1996) on the basis of a proposal made by the expert from Germany, which is referred to as informal document INF.45 in paragraph167 of the abovementioned report and which has now been issued as an official document (ST/SG/AC.10/R.501).  Y5 4.PPThe Recommendations of the Committee of Experts on the Transport of Dangerous Goods on this matter, together with the report of the SecretaryGeneral on the work of the Committee, will be submitted to the Economic and Social Council at its substantive session of1997 (see Council decision 1996/204 on the basic programme of work of the Economic and Social Council for 1997).  X  Annex:PPEXTRACT FROM THE REPORT OF THE COMMITTEE OF EXPERTS ON THE TRANSPORT OF DANGEROUS GOODS ON ITS EIGHTEENTH  X} SESSION (ST/SG/AC.10/21) Ɵ#P  YO 159.PPThe representatives of IMO and OCTI mentioned the difficulties experienced by their organizations every two years in updating the instruments for which they were responsible. Those difficulties were related to the considerable work involved in adapting the instruments to the new Recommendations, the need to translate the new texts into several languages, and the difficulty of ensuring the effective implementation of regulations which were too frequently amended, particularly in developing countries.  Y! 160.PPThe representatives of IATA and of ICAO, however, said that they wished to keep the present twoyear period so as to be able to reflect consignors' requirements and technical progress in the regulations. They stressed that approximately four years of procedures were currently required in the relevant United Nations bodies or organizations for a solution to a problem raised by industry to be reflected in the regulations and that a longer cycle could lead to a tendency to circumvent the regulations. The representative of ICAO further suggested;&+'' that a contributing factor to difficulties encountered by other modes in maintaining a twoyear cycle was the format of the regulations as ICAO successfully followed a biennium cycle.  Y 161.PPIn view of the improvement in harmonization between modal regulations based on the Recommendations, several experts expressed their support for the less frequent publication of the Recommendations; however, a procedure should be introduced for amendments related to urgent requirements of industry or particular instances requiring a rapid response. The Committee agreed to revert to the question during the discussion of item8 (Publication of the revised Recommendations) (see para.167) and in accordance with the decisions to be taken regarding the programme of work.  Y 162.PPThe representative of IRU suggested that, in order to improve harmonization, it would be useful to establish a recommended date for implementing new amendments which would appear in the resolution of the Economic and Social Council. ...  Yy 167.PPReferring to the discussion of the periodicity of amendments to the Recommendations (see paras. 159 to 161), the expert from Germany proposed (INF.45) that completely revised editions of the Recommendations after the 9th revised edition would be published every four years only, that a procedure for smallscale amendments to be adopted every two years should be established, and that no amendment to the Manual of Tests and Criteria should be adopted until the 1998 session of the Committee.  Y 168.PPThe representative from IMO indicated that IMO could agree to the timescales for amendments proposed by Germany in INF.45 since the IMO Maritime Safety Committee had already approved the time periods for amendments to the IMDG Code. She expressed the view that with the introduction of new technology, smaller amendments on a twoyear cycle would be easier to produce as an interim solution, leaving larger amendments for four years. She drew attention to the fact that when IMO raised this issue within the Committee two years ago, it was because IMO member Governments had expressed difficulties in implementing frequent amendments to the Code and often had to grant transitional periods before an amendment could be fully implemented. This had raised the question of what was the purpose of introducing frequent amendments if they could not be implemented.  Y 169.PPRecognizing that all member Governments present in this Committee are also represented in IMO, the IMO representative expressed concern that problems arise when Governments express different views in a different form. She suggested that such differences should be resolved on a national level to enable Governments to present a coordinated view in all forms. The representative from OCTI expressed the same concerns.  YQ% 170.PPThe Committee noted that, if the possibility of smallscale amendments every two years is retained, it is more convenient for the United Nations publication section to sell, at:&+'' least in English and French, a consolidated edition rather than to reprint the older edition and to sell it with a set of amendments published separately.  Y 171.PPNo decision could be made on this subject of periodicity of amendments. The difficulty experienced by international organizations and Governments to update their respective instruments was recognized, but it was recalled that the Recommendations have been developed and are kept up to date in the light of technical progress, the advent of new substances and articles and the exigencies of modern transport systems, and therefore there would be a risk for the Recommendations to become obsolete or not adapted to the technical progress if a fouryear interval period was adopted.  Y 172.PPThe expert from the United States of America said that Governments and international organizations may decide on the implementation date and that modal organizations should provide reasonable implementation schedules. He also felt that the industry should be allowed to use the new recommendations on a voluntary basis in the interim period. He also expected fewer amendments in the forthcoming period of global harmonization and restructuring.  Yb 173.PPThe expert from Germany requested that his proposal in INF.45 should be formally circulated as an official document for discussion in the next biennium and reiterated his views that neither the Recommendations nor the Manual of Tests and Criteria should be amended until the 1998 session of the Committee.  -!QU +''  X ^_67ST/SG/AC.10/R.523 page  Annex 367y Y 553((;AccFccFST/SG/AC.10/R.523  Y 553((;AccFccFpage   Y0 553((;AccFAnnex 3 50 77 Y 553((;AccFccFST/SG/AC.10/R.523  Y 553((;AccFccFpage   Y0 553((;AccFAnnex 3 ANNEX 3 ă  X  -!Qn   -!Qn Report of the Working Party on the Transport of Dangeous Goods on its fiftyninth  Y session (610 May 1996) -!Qn   -!Qn  (TRANS/WP.15/142, 21 May 1996) -!Qr paras. 96103:  Y` 96.PPThe Working Party had before it documentE/1996/15, which was a letter from the Secretary-General of the International Maritime Organization to the Secretary-General of the UnitedNations, proposing to amend the current periodicity of amendments to the UnitedNations Recommendations on the Transport of Dangerous Goods from two years to four years. This letter had been submitted to the Economic and Social Council which would consider it at its July1996 session, although the Committee of Experts on the Transport of Dangerous Goods was scheduled to discuss the question in December 1996 on the basis of a document submitted by Germany (ST/SG/AC.10/R.501). Since road transport was also affected, the Chairman asked the Working Party to take a decision so that its views could also be transmitted to the Economic and Social Council.  Yc 97.PPThe representative of the United Kingdom said that he was not in favour of a decision of this nature, particularly in view of the ongoing process of restructuring both of RID/ADR and of the Recommendations on the Transport of Dangerous Goods. He said that the adaptation of national regulations in Europe to the Annexes of ADR would bring to the fore many new problems to be settled in the next few years for which a twoyear periodicity of amendments would be preferable. Once the ongoing restructuring for all transport modes was completed and the national regulations adapted, it would be possible to envisage a periodicity of four years. This viewpoint was supported by the -!Qurepresentative of Norway.  Y 98.PPSeveral delegations (Spain, Netherlands, Germany, Finland, Hungary, Belgium, Sweden and Austria) said that they would be in favour of a periodicity of four years in the future so as to ensure more stability in the regulations and avoid current problems of the time required for translation, informing the professional categories concerned, etc.  Y! -!Qw499.PPThe representative of the European Commission stressed the greater importance of the role which the Committee of Experts on the Transport of Dangerous Goods was required to play in the future. Once the process of harmonization on the basis of the Recommendations on the Transport of Dangerous Goods and the various ongoing restructuring processes were complete, it was probable that the regulations on the transport of dangerous goods would have become more stable and a periodicity of four years could then be envisaged. He stressed the importance of the simultaneous entry into force of amendments to all the modal instruments and thus of consultation among the organizations concerned with a view to defining a joint position on the -!Qwperiodicity issue. R%+''Ԍ Y -!Qw4100.PPThe representatives of CEFIC and IRU said that the professional associations which they represented were in favour of a periodicity of four -!Qwyears.  Y -!Qw4101.PPThe representative of France said that she had no objection to a periodicity of four years but she pointed out that the proposals submitted by Governments were generally the result of pressures from the transport, packaging or chemical industries which hoped to obtain a swift response to their practical and technical problems as a result of the regulations. She hoped that all delegations would sound out the representatives of their -!Qwcountry's industry very carefully before a final decision was taken.  Y -!Qw4102.PPThe representatives of Italy, Portugal and Poland said that it would not be desirable for the Economic and Social Council to take a decision in July1996 since it was essential for all the aspects mentioned to be considered carefully; the body competent to assess them was the Committee of Experts on the Transport of Dangerous Goods which could take a decision in -!QwDecember1996 after the necessary consultations had been made at all levels.  Y -!Qw4103.PPThe Working Party took a unanimous stand on this position and requested the Executive Secretary of ECE to ask the Economic and Social Council to wait until the Committee of Experts on the Transport of Dangerous Goods had considered the problem of the periodicity of amendments before taking a decision on the request contained in the letter of the Secretary-General ofIMO. The Executive Secretary was also asked to attach to this request a document reflecting the above discussion. +''  Y 776IST/SG/AC.10/R.523 page  Annex 46 Iy Y 553((;AccFccFST/SG/AC.10/R.523  Y 553((;AccFccFpage   Y0 553((;AccFAnnex 4 -!QU  50 ANNEX 4 ă  X  Letter dated 29 April 1996 from the DirectorGeneral of the International Air Transport  Y Association to the SecretaryGeneral (E/1996/63, 22 May 1996) I refer to the letter dated 21 July 1995 from the SecretaryGeneral of the International Maritime Organization (IMO) to the SecretaryGeneral of the United Nations (E/1996/15).  -!Q   -!Q The International Air Transport Association (IATA) represents over 230airlines from about 140 countries. These airlines transport dangerous goods on a daily basis, and IATA therefore considers the carriage of dangerous goods an issue of extreme importance. IATA fully supports the work of the United Nations Committee of Experts on the Safe Transport of Dangerous Goods. The effective functioning of the regulatory process depends on implementation of the required changes quickly and efficiently. IATA therefore believes that the current twoyear publication cycle for the Recommendations on the Transport of Dangerous Goods, known as the "United Nations Orange Book", is essential for maintaining flexibility and improving safety. Under the present process, a proposal to the Committee takes up to two years to be adopted and a minimum of two more years to be implemented by the various transport modes. The shipping industry has indicated that the current system is sometimes too slow to react to its needs. Changing the publication cycle from two to four years, as proposed, could result in delays of up to eight years before changes are implemented by all transport modes. Under such conditions, the various modal transport organizations will find themselves under industry pressure to implement changes unilaterally. This would result in the disintegration of all of the valuable work that has been done by the Committee towards producing a harmonized regulatory structure for all transport modes. IATA feels strongly that lack of compliance with regulations, as mentioned in the IMO letter, is not a valid reason to delay implementation of required changes. Through the International Civil Aviation Organization (ICAO) and IATA, the air mode implements the Recommendations quickly, faithfully and globally, using proactive training, awareness and enforcement. The air mode's success is the result of close cooperation between the Committee, ICAO, IATA, industry and national Governments. The Committee (in December 1994), ICAO (in October 1995), IATA and other organizations representing the industry have clearly stated their strong support for maintaining the twoyear publication cycle for the Recommendations. The benefits of maintaining this periodicity, and the grave negative consequences of a change to four years, must be seriously considered. I would therefore appreciate IATA's position, and the issues raised here, being brought to the attention of the Economic and Social Council at its substantive session of 1996. `#?(Signed) Pierre J. JEANNIOT  Y& `-#KDirectorGeneral Ã& +''Ԍ X ԙ Letter dated 26 June 1996 from the SecretaryGeneral of the International Civil Aviation  Y Organization addressed to the SecretaryGeneral (E/1996/84, 9 July 1996) I wish to refer to the letter dated 21 July 1995 from the SecretaryGeneral of the International Maritime Organization (IMO), addressed to the SecretaryGeneral of the United Nations, which has been submitted to the Economic and Social Council at its substantive session of 1996 as document E/1996/15, and, more specifically, to the suggestion of IMO concerning the periodicity of the publication of the United Nations Recommendations on the Transport of Dangerous Goods. At the 15th meeting of the International Civil Aviation Organization (ICAO) Dangerous Goods Panel (DGP/15, Montreal, 1726 October 1995), the members discussed this issue and the consequential periodicity of the Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc. 9284). The Panel confirmed its opinion that the present twoyear cycle should be the maximum period between amendments to the United Nations Recommendations, noting that the issue of the transport of dangerous goods was a dynamic subject and that, for industry, changes needed to be reflected as quickly as possible. Without encountering any of the difficulties mentioned in document E/1996/15, ICAO has published the Technical Instructions from 1984 to 1986 on an annual basis and biennially since1987. Therefore, as the Dangerous Goods Panel has strongly advised, the present twoyear cycle will be maintained.  Y1 `H#B(Signed) Philippe ROCHAT Ã1 +'' Statement of the Hazardous Materials Advisory Council with respect to document  Y E/1996/15 (E/1996/NGO/1, 17 June 1996) The Hazardous Materials Advisory Council (HMAC) is an international, educational organization devoted to promoting safety in the domestic and international transportation and handling of hazardous materials, substances and wastes. We represent shippers, carriers of all modes of transportation, and a variety of other companies and trade associations involved in the field of dangerous goods transportation. HMAC has consultative status with the International Maritime Organization (IMO), the International Civil Aviation Organization (ICAO) and the Economic and Social Council. Document E/1996/15, which contains a letter from the SecretaryGeneral of IMO to the SecretaryGeneral of the United Nations, seeks support for increasing the time between successive amendments of the United Nations Recommendations on the Transport of Dangerous Goods from two to four years. It cites the workload associated with amendments to instruments regulating the transport of dangerous 0goods as a major reason why a change to four years would be justified. While we recognize the administrative burden in preparing amendments to international instruments, we strongly believe that four years is too long a time period for updating international dangerous goods regulations. The United Nations Recommendations are amended principally to incorporate technological advances in packagings and other aspects of dangerous goods transport as well as to modify current transport requirements for individual substances on the basis of new data, ensuring that the shipping requirements are neither too restrictive nor too lax. The amendment process thus facilitates the safe and costeffective movement of dangerous goods. It is in the best interest of both the hazardous materials industry and the public to ensure that the regulatory regimes that control the movement of dangerous goods are up to date. In our view, this would not be the case if the amendment cycle for the United Nations Recommendations were changed to four years. There is already a lag of two to three years from the time the United Nations Recommendations are amended until they are incorporated and implemented in the various transport modes. Increasing the United Nations amendment cycle to every four years will only further delay this process. HMAC supports IMO's ongoing efforts to reformat the International Maritime Dangerous Goods (IMDG) Code. Presently the Code is contained in four lengthy volumes and a supplement which, understandably, is very difficult to amend. We believe that discussions within IMO will soon lead to a publication that is much smaller in size and more amenable to detail changes resulting from the amendment process. We would expect that much of the administrative problem within IMO and member States referred to in document E/1996/15 would be alleviated when the Code is reformatted. Q# +''ԌHMAC strongly recommends retention of the current amendment cycle for the United Nations Recommendations at twoyear intervals. As a minimum, we further recommend that discussion on this issue in the Economic and Social Council be deferred until after the United Nations Committee of Experts on the Transport of Dangerous Goods meets in December 1996 so that the entire matter can be thoroughly examined and the Committee has the opportunity to suggest appropriate action. H5$