Advocacy & Lobbying

Transport of Dangerous Goods

Overview

Paint, and the products used to manufacturer paint can be considered dangerous in the wrong environments, e.g. we don't want them washing down rivers.

Because of this, the NZPMA pays special attention to ensure that all our members are aware of the rules and requirements for transporting goods around the country, and the world.

With this in mind, we need to keep up with the ever-changing requirements from the UN Subcommittee of Experts on the Transport of Dangerous Goods.

This is where being a member of the World Coatings Council is a major benefit to the NZPMA. We are too small an Association to be represented at the UN, however the WCC, and some of their member Associations do attend, and we receive summaries of all the meetings so we know what changes may be heading 'Downunder'.

Below are statements regarding Transport of Dangerous Goods from the WCC.

UN Subcommittee of Experts on the Transport of Dangerous Goods

December 2024

The UN SCE TDG ultimately agreed to our updated proposal in INF.61, taking into account minor changes to the text that were discussed in plenary (9-2 in support). WCC secured the following new special packing provision (PP99) to packing instruction P001 in Chapter 4.1 of the UN Model Regulations:

 “PP99      For mixtures assigned to UN 3082 containing less than 1 % of substances of highly toxic ingredients with an M factor of 10, 100, or 1000 (as described in 2.9.3.4.6.4), plastics drums with removable heads containing quantities of more than 5 litres and not more than 20 litres per packaging are not subject to the performance tests in chapter 6.1 for a transitional period until 31 December 2034, provided the packaging has successfully passed the stacking test in 6.1.5.6 for plastics drums intended for liquids and meets the general provisions of 4.1.1, except for 4.1.1.3, and 4.1.3.”

 A consequential amendment was also made in Chapter 3.2 to add the new packing provision (PP99) to column 9 of the Dangerous Goods List for UN 3082.

2023

In general, paint is a resinous product intended to provide a continuous protective or decorative film to a substrate, imparting desirable properties that last for a long time. Extensive efforts are made to ensure economical transfer efficiency and to minimize loss of paint product to the environment during application and subsequent clean-up of application equipment (i.e. brushes and rollers).

The paint industry stresses that all known mitigating factors need to be considered in any effort to quantify the potential release of microplastics from products. This is especially true for academic researchers, government agencies and advocacy groups as they work to address concerns regarding microplastics in the environment. For its part, the paint industry stands ready to advance its understanding of the issue and our commitment to product stewardship.

In order to ensure consistency between the regulatory systems in every country and every mode for the transport of dangerous goods, the United Nations has developed mechanisms for the harmonization of transport conditions for all modes for transport (TDG). This harmonization occurs in the Sub-Committee of Experts on the Transport of Dangerous Goods  (UNSCETDG). [https://unece.org/transport/dangerous-goods]. The result of this effort is the UN Model Regulations, which is used by many countries as the basis of the country’s TDG regulations. The UN Model Regulations is currently in the 22nd revision (2021).

The UNSCETDG meets twice a year, in June and December, always in Geneva, Switzerland, to consider proposals from governmental and non-governmental delegations that will be incorporated into the UN Model Regulations.

In 2005, the World Coatings Council was granted Non-Governmental Organization status by the United Nations and is permitted to attend and participate in these meetings.

The World Coatings Council delegation includes the transport staff of CEPE and ACA. Participation in the council delegation to the UNSCETDG is open to those participating companies or country trade associations of the council.

Previously, the World Coatings Council has submitted proposals, testified on other delegations’ proposals and participated in the working groups on a variety of papers, including:

  • Working Group on Explosives (nitrocellulose);

  • Informal working group on “chemicals under pressure”;

  • Informal working group on packing instructions;

  • The council’s proposal for a new UN entry for Class 9 paints;

  • Proposed changes to the use of Limited Quantities;

  • The council’s proposal for an exception to the requirement that closures be upright; among others.

Be a voice for our position on industry-critical regulations and developing the future regulatory environment.