UN3171

I:\DSC\11\3-15.doc For reasons of economy, this document is printed in a limited number. Delegates are

kindly asked to bring their copies to meetings and not to request additional copies.

INTERNATIONAL MARITIME ORGANIZATION

IMO

E

SUB-COMMITTEE ON DANGEROUS

GOODS, SOLID CARGOES AND

CONTAINERS

11th session

Agenda item 3 DSC 11/3/15

20 July 2006

Original: ENGLISH

AMENDMENTS TO THE IMDG CODE AND SUPPLEMENTS, INCLUDING

HARMONIZATION OF THE IMDG CODE WITH THE UN RECOMMENDATIONS

ON THE TRANSPORT OF DANGEROUS GOODS

Amendment (34-08) to the IMDG Code and supplements

Comments on the use of UN 3166 and UN 3171

Submitted by the United States

SUMMARY

Executive summary: This document provides comments on the paper DSC 11/3/4 to

include UN 3166 and UN 3171 in the dangerous goods list of the

IMDG Code. Furthermore, alternative technologies such as lithium

ion batteries and hydrogen fuel cells have been developed to power

vehicles and equipment. Dangerous goods within vehicles are not

subject to the tests specified in the UN Manual of Tests and Criteria.

Additional precautions may be necessary to safely transport these

types of vehicles and equipment.

Action to be taken: Paragraph 7

Related documents: CDG 42/4/1/22, CDG 43/3/1/39, CDG 44/3/1/10, DSC 1/3/1/Add.1

(paragraphs 15.10 to 15.18), DSC 1/3/2/6, DSC 1/3/2/19, DSC 1/27

(paragraphs 3.1.18 and 3.1.19), DSC 6/3/1, DSC 6/3/25, DSC 6/15

(paragraphs 3.35 and 3.36), DSC 7/3/1, DSC 7/15

(paragraphs 3.38 and 3.39), and DSC 11/3/4

Introduction

1 This document comments on paper DSC 11/3/4 and is submitted in accordance with

paragraph 4.10.5 of MSC/Circ.1099 and MEPC/Circ.405.

DSC 11/3/15 - 2 -

I:\DSC\11\3-15.doc Background

2 UN 3166 - ENGINE, INTERNAL COMBUSTION or VEHICLE, FLAMMABLE GAS

POWERED or VEHICLE, FLAMMABLE LIQUID POWERED and UN 3171 –

BATTERY-POWERED VEHICLE or BATTERY-POWERED EQUIPMENT are listed as

dangerous goods in the UN Model Regulations, ICAO Technical Instructions, ADR, RID

and 49 CFR; however, under the IMDG Code they are not listed. The United States regulates the

transport of UN 3166 and UN 3171 because they typically contain quantities of various types of

dangerous goods and certain safety conditions need to be generally imposed. Since UN 3166 and

UN 3171 are not listed in the IMDG Code, problems arise when vehicles that are regulated by

national, regional or other modal regulations are transported by sea. The entry for UN 3166 was

removed as a result of a previous decision on the part of the DSC Sub-Committee.

Discussion

3 In practice, when articles of this type are required to be shipped as dangerous goods under

49 CFR or other national regulations, there is confusion as to what UN numbers and proper

shipping names to use under the IMDG Code. For example, UN 3363 – DANGEROUS GOODS

IN MACHINERY or DANGEROUS GOODS IN APPARATUS, is frequently misused to

represent a vehicle or equipment powered by and containing dangerous goods. Furthermore,

UN 3334 and UN 3335 are listed as dangerous goods in the IMDG Code even though they are

regulated by air only. The following table has been included to illustrate this discrepancy and to

provide a reference for discussion on UN 3166 and UN 3171:

Dangerous Goods Appearing in National,

International, or Modal Regulations Modes Subject to Regulation

UN 3166 UN 3171 UN 3334 UN 3335 UN 3166

UN 3171 UN 3334

UN 3335

UN Model

Regulations X X X X air only air only

ICAO

Technical

Instructions X X X X air only air only

ADR/RID X X X X air only air only

49 CFR X X X X all modes air only

IMDG Code X X not listed air only

4 Alternative technologies have been developed to power vehicles and equipment by other

than traditional methods. These technologies utilize dangerous goods such as lithium batteries,

petroleum gases, liquefied (propane) and hydrogen fuel cells as power sources to provide

alternatives to traditional fossil fuel based sources. Vehicles and equipment of this type may

possess hazards that warrant the use of a dangerous goods description and the application of

appropriate safety precautions for transportation. For example, large prototype lithium ion

batteries (or battery packs), may be installed within vehicles without the batteries being subjected

to the tests specified in the UN Manual of Tests and Criteria. Similarly, vehicles powered by fuel

cells that operate using hydrogen may be transported as a vehicle without any regulation on the

hydrogen storage unit. The United States intends to submit additional information and invites

discussion and comments on this issue.