Gafta and USSEC have been working on modifying and streamlining the UN entries for transport of seedcake since June 2024 within Transport of Dangerous Goods committee (and previously in IMO).
Today, Gafta presented two papers were presented during the 67th Session of the subcommittee on the transport of dangerous goods (UNTDG) on 25th November in Geneva.
Papers can be accessed at:
ST/SG/AC.10/C.3/2025/51 - Gafta proposal – amending special provision 142 - https://unece.org/transport/documents/2025/09/working-documents/amendment-special-provision-142-gafta
UN/SCETDG/67/INF.37– supplementary INF document including data - https://unece.org/transport/documents/2025/11/informal-documents/amendment-special-provision-142-supplement-document
In summary -
During the subcommittee discussion today, there was overwhelming thanks, acknowledgement of work and full support from all countries for Gafta proposals except NL (and DE). Canada/BE had one concern on wording in relation to Special provision to avoid future confusion but were supportive overall.
Canada supports the proposal and thanks Gafta. To avoid confusion between UN 3088 and UN1386, asked if appropriate to delete beginning of sentence Gafta proposes in SP142 amendment document in yellow below. Belgium intervened suggesting to leave it – regulatory drafting issue. To be resolved at coffee break meeting later in the morning, thanked Gafta and support in general.
USA -support and thanks to Gafta for following through over many sessions and working through in an elaborate way. Acknowledged that this is a very safe product, know that we don’t treat provisions on lack of incidences and acknowledge that Gafta has responded in good way and did testing to show what was asked for on limits and at what point product reacts so we’re not setting limits based on safe history alone but science and good testing. We see the testing results and proposed thresholds are well within the safe limits which was what we were expecting. Good procedure adopting provisions and will be further taken up in IMO. No hard opinion on Canada comments, will work through it.
Australia – thanks to Gafta for work on this issue and happy to support. Work done to incorporate concerns following last session has been very useful to help Australia support the proposal. Proposal to add UN entry 3308 to Special Provision is reasonable. Happy to work out wording with US/Canada if any edits need to be made.
Argentina – intervened and acknowledged that work ongoing since June 2024, reiterate their support for proposals in 51/2025, solid technical basis provided, evidence is there and when parameters are limited, there no risk of self heating and this has been demonstrated.
United Kingdom – thank Gafta for all work and testing to ensure safety – very happy to support proposal.
NL appreciate efforts still some questions on document 57 from previous session re 4% and 13% - need to consider if now dealt with in INF paper 37. Experts in NL questioned why Gafta carried out the latest testing in INF 51 on soybean meal and rapeseed meal and not on cotton seed meal and sunflower seed meal. They also requested to see the daily and hourly data over the 60 days and not just the summary and charts. Also have reservations about N4 testing on small volumes. Would like more time to consider the paper – cannot support present proposal.
Russia – thanks Gafta for all the work, the data provided in paper 51 is sufficient and they fully support. This solution will have possibility to provide greater impact and economic cooperation asked of this committee by UN. This should be encouraged.
Germany - thank you Gafta, time, effort on testing data, echol NL comments. Possible way forward throguh energetics working group in the summer where experts on self heating can be invited.
As a reminder - Canada /Belgian comments refer to this sentence below:
Gafta proposal:
Working document 51
“Regardless of the moisture and oil limits within the description in column 2 of the dangerous goods list, seedcake of soybean, rapeseed, sunflower seed and cotton seed containing not more than 1.5 % oil and 11 % moisture, 4 % oil and not more than 13 % moisture which is substantially free of flammable solvent, is not subject to these Regulations.”
INF paper 37 - Prior to drafting of this informal document, Gafta received a comment from the experts from Canada, expressing concern that because the description of UN 1386 has a limit of 11% moisture within the dangerous goods list, then it might lead to confusion if a seedcake has a moisture content of greater than 11% but less than 13%. Considering this concern, we would propose that special provision 142 also be assigned to the entry for UN 3088, Selfheating solid, organic, n.o.s., 4.2, PGIII, which would be the best-fitting generic description of seedcake that exceeds the moisture limit of 11% within UN 1386. ( UN 3088 is a generic entry that would allow for product higher than UN 1386 ie 12% and 13% to avail of our Special Provision exemption, this is a regulatory drafting issue to fit with the approach of using the UN handbook)
Chairs conclusion - As there was overwhelming support with only NL and DE opposing, the Chair advised organising a meeting during the morning coffee break to resolve these final issues and finalise the language to bring an end to this discussion which is ongoing since June 2024 and before that in IMO committees.
Coffee break discussions:
The discussions during the coffee break have been summarised in the attached INF paper which is also now available on the UNECE website at: Group conversation based upon document ST/SG/AC.10/C.3/2025/51 and informal document INF.37, sixty-seventh session TDG Sub-Committee (Gafta) | UNECE
Next steps – paper is likely to be mentioned tomorrow morning 26th November during committee meeting so all delegations are aware. There will be text drawn up by the Secretariat reflecting outcome to be referenced in the draft committee report likely next Tuesday. Gafta will continue to keep you updated.
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