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TRANS/WP.15/AC.1/HAR/2005/2 Page 3 TRANS/WP.15/AC.1/HAR/2005/2*/ 20 May

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TRANS/WP.15/AC.1/HAR/2005/2
Page 3
TRANS/WP.15/AC.1/HAR/2005/2*/
20 May 2005
Original: ENGLISH only
ECONOMIC COMMISSION FOR EUROPE
INLAND TRANSPORT COMMITTEE
Working Party on the Transport of Dangerous Goods
Ad hoc Working Group on the Harmonization of RID/ADR/ADN
with the UN Recommendations on the Transport of Dangerous Goods
(Geneva, 2325 May 2005)
HARMONIZATION WITH THE UNITED NATIONS
MODEL REGULATIONS ON THE TRANSPORT OF DANGEROUS GOODS
Comments on document TRANS/WP.15/AC.1/HAR/2005/1
Transmitted by the European Industrial Gases Association (EIGA)

Special packing provision ‘n’ in P200
The wording of this provision has been the subject of correspondence
between EIGA and the Secretariat, but the proposal in HAR/2005/1 is
still not quite right. Since there has been some difficulty in
reaching a clear form of words, a rather long explanation is given as
background.
The basic requirement is that the two gases to which ‘n’ applies shall
never be packed in a single cylinder in a quantity exceeding 5 kg.
Since the valve on every cylinder in a bundle is closed during
carriage, bundles of these gases may be transported with up to 5 kg in
each individual cylinder in the bundle. In fluorine service several
cylinders may be grouped together served by one common valve and these
we have called assemblies. These assemblies are also obviously limited
to 5 kg. There are no assemblies of cylinders in a bundle carrying
oxygen difluoride.
EIGA’s proposal, based in minimised changes to the Secretariat text in
TRANS/WP.15/AC.1/HAR/2005/1, is as follows (new words underlined).
n For UN 2190, oxygen difluoride, compressed, cylinders and individual
cylinders and assemblies of cylinders within a bundle shall contain
not more than 5kg of the gas;
For UN 1045 fluorine, compressed, cylinders, individual cylinders
within a bundle and assemblies of cylinders within a bundle shall
contain not more than 5 kg of the gas. Bundles containing this gas may
be divided in assemblies (groups) of cylinders not exceeding 150
litres total water capacity (see special packing provision ‘k’).
EIGA is not convinced that the final sentence is needed since this is
explained in more detail in special packing provision ‘k’ and a simple
reference to ‘k’ would suffice. If this sentence is to remain,
however, it is more userfriendly to add the reference.
Our preference still remains to revert to the much simpler text
similar to that originally adopted in INF. 8 at the UN. For reference,
the text adopted at the December UN meeting was:
Insert in ‘k’
“Bundles containing UN 1045 Fluorine, compressed, may be constructed
with isolation valves on assemblies (groups) of cylinders not
exceeding 150 litres total water capacity instead of isolation valves
on every cylinder.”
Replace ‘n’
“n Cylinders and individual cylinders in a bundle shall contain not
more than 5 kg of the gas. Bundles containing UN 1045 Fluorine,
compressed, may be divided in assemblies (groups) of cylinders not
exceeding 150 litres total water capacity. The gas contents of such
assemblies shall be limited to 5 kg.”
It is clear (to EIGA at least and to Germany who proposed it) that the
first sentence of ‘n’ applies to both gases and the second and third
to fluorine only.
EIGA’s preferred proposal then becomes:
"n: Cylinders and individual cylinders in a bundle shall contain not
more than 5 kg of the gas. Bundles containing UN 1045 Fluorine,
compressed may be divided into assemblies (groups) of cylinders (see
special packing provision 'k') and such assemblies shall contain not
more than 5 kg of the gas."
Additional note by the secretariat:
The secretariat reproduces hereafter the amendment of P200 (n) as
adopted by the Committee of Experts on the Transport of Dangerous
Goods and on the Globally Harmonized System of Classification and
Labelling of Chemicals at its second session (Reference Document:
ST/SG/AC.10/32/Add.1).
This amendment was adopted by the SubCommittee of Experts on the
Transport of Dangerous Goods at its 26th session on the basis of a
proposal from Germany (Informal document UN/SCETDG/26/INF.8) as
amended by the SubCommittee. This proposal was amending the text
which was approved by the SubCommittee at its 23rd session and which
was reflected in document ST/SG/AC.10/C.3/2004/80.
"P200 Special provision "n": Amend to read as follows:
"Individual cylinders and assemblies of cylinders within a bundle
shall contain not more than 5 kg of UN 1045 Fluorine compressed.
Bundles containing UN 1045 Fluorine, compressed, may be divided in
assemblies (groups) of cylinders not exceeding 150 litres total water
capacity.".".
For information: The modifications to UN/SCETDG/26/INF.8 agreed by the
SubCommittee are highlighted below:
"Cylinders and individual cylinders inIndividual cylinders and
assemblies of cylinders within a bundle shall contain not more than 5
kg of the gasFluorine.
Bundles containing UN 1045 Fluorine, compressed, may be divided in
assemblies (groups) of cylinders not exceeding 150 litres total water
capacity. The gas contents of such assemblies shall be limited
to 5 kg."
When drafting the final texts, the secretariat realized that the
SubCommittee had overlooked the fact that special provision "n" also
applies to UN 2190, and not only to UN 1045. The secretariat discussed
this issue with EIGA, but due to the long discussions on the subject
during the SubCommittee session, the secretariat did not feel that it
had the authority to change the text as proposed by EIGA.

*/ Informal document. Not issued as an official United Nations
document. Circulated only to delegations participating in the work of
the Joint Meeting of the RID Safety Committee and the Working Party on
the Transport of Dangerous Goods.

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