Review and Revision Policies for Transport Regulations

DS543; SSR-6 (Rev. 2); IAEA Regulations for the Safe Transport of Radioactive Material (20XX Edition) Step 7 Agenda Item 3.3 TRANSSC 47 Eric H. Reber, Transport Safety Unit

Presentation Overview Review/Revision Policy Review Cycle Decision to revise SSR-6 (Rev. 1) Revision Cycle Step 6: First internal review of the draft publication Step 7: First review of the draft publication by the Review Committees A1/A2 Values WNTI-02 to -05 Rejection of new proposals Comments received in response to resolution table & its addendum Request for approval (Step 7) Overview of activities in 2024

Policy for reviewing and revising the Agencys Transport Regulations [Board of Governors (GOV/2005/31)] Transport regulations reviewed every two years the decision on the revision and publication will be made based on the assessment of TRANSSC/CSS If TRANSSC considers that a proposal for change stemming from a review cycle is sufficiently important for safety to necessitate publication as soon as possible, the Secretariat will initiate the revision process

Graphical Overview of the Review Process Proposals for change received by the Secretariat Initial review of proposals for change by TTEGs Recommendations by TTEGs to TRANSSC: accepted rejected impact on safety comments Recommendation / Decisions process for each individual proposal for change using the secondary set of questions in Annex 1 TRANSSC decisions: accepted rejected impact on safety Decision based on whether the aggregate of the accepted proposals would amount to a change in requirements that is important in terms of safety using the primary set of questions in Annex 1 TRANSSC decision on whether to revise SSR-6 (Rev. 1)

Review Cycle Schedule Overview

Overview of Proposals for Change 306 comments received from Australia(3), Belarus(5), Belgium(1), Canada(10), France(70), Germany(11), IATA(12), ISO(3), Italy(7), Japan(17), Morocco(7), Oman(3), Pakistan(2), Russia(11), Sweden(15), Switzerland(28), WNTI(79), TIC(5), UK(8), USA(6) 294 unique comments assigned to primary TTEGs: TTEG Primary TTEG-C TTEG-OM TTEG-PPA TTEG-RP 37 177 62 18

TRANSSC 45 Decisions: Number of proposals/grouped proposals accepted or accepted, but modified ; safety significance is yes accepted or accepted, but modified ; safety significance is no rejected 10 7 9 2 28 7 30 7 2 46 10 45 16 3 74 TTEG C TTEG OM TTEG PPA TTEG RP Total

Decision at TRANSSC 45 to enter a Revision Cycle Based on the presentations and understanding of the TTEG recommendations to TRANSSC for each change proposal, coupled with the outcomes from the moderated discussions, roughly 75 change proposals were identified that would be addressed/acted on during the revision process. In summary, there was nearly unanimous support from the Member States to move into the revision of SSR-6 (Rev. 1).

Revision Cycle Revision Cycle will follow the 14 Steps of the SPESS process. 2021 Transport Regulation Revision Quality Plan (Rev. 1) provides the details of the Revision Cycle. Current version is available in the Revision Cycle of SSR-6 (Rev.1) folder.

Activity Start End 18 August 2022 STEP 1: Preparation of DPP July 2022 STEP 2: Internal review of the DPP (Approval by the Coordination Committee) 11 August 2022 18 August 2022 STEP 3: Review of the DPP by the Review Committees 26 August 2022 2 December 2022 STEP 4: Review of the DPP by the CSS (approval by CSS) 23 March 2023 23 May 2023 Revision Cycle Overview STEP 5: Development of revised manuscript of SSR-6 (Rev. 2) December 2022 24 July 2023 STEP 5*: Development of modified text for proposals that were designated as Accepted, but modified during T-45 December 2022 20 April 2023 STEP 5**: Review of revised text at TRANSSC 46 5 June 2023 9 June 2023 STEP 6: First internal review of SSR-6 (Rev. 2) (Approval by the Coordination Committee) 24 July 2023 24 August 2023 STEP 7: First approval of the draft publication by the Review Committees 31 August 2023 December 2023 STEP 8: Soliciting comments by Member States December 2023 April 2024 STEP 9: Addressing comments by Member States (including activities at TRANSSC 48) April 2024 July 2024 STEP 10: Second internal review of the draft publication (Approval by the Coordination Committee) August 2024 August 2024 STEP 11: Second review of the draft publication by the review Committee(s) (Approval of the draft) STEP 12: Editing of draft in MTCD and endorsement of the draft by the CSS, establishment by the Publications Committee and editing September 2024 November 2024 December 2024 April 2025 STEP 12*: Silence approval of the final edited text by TRANSSC STEP 13: Approval by the Board of Governors STEP 13*: Submittal of SSR-6 (Rev. 2) to UNECE STEP 14: Publication May 2025 June 2025 October 2025 October 2025 May 2025 September 2025 March 2026 January 2026

Overview of Activities from TRANSSC 46 (June 2023) until Step 6 At TRANSSC 46, current text for proposals was discussed by TTEGs and in plenary; for revised text, some text was rejected, improved and identified as needing improvement. Details of the discussions at TRANSSC 46 and details of the development of proposals after TRANSSC 46 were recorded in the four TTEG resolution tables. Modified text was submitted to the Secretariat with a deadline of 24 July 2023 for various proposals. Modified text was incorporated into the draft SSR-6 (Rev. 2)

Step 6: First internal review of the draft publication Comments received from Division of Nuclear Security (NSNS): Para. 109, first sentence: replace theft or damage with unauthorized removal and sabotage - Accepted Para. 109, second sentence: add and coordinated after integrated Rejected References to Annex I: Add NSS No. 14, Nuclear Security Recommendations on Radioactive Material and Associated Facilities Accepted Draft was approved at the meeting of the Coordination Committee on 24 August 2023 Standards Specialist carried out a review of the draft; comments and queries were resolved

Step 7: First review of the draft publication by the Review Committees Draft SSR-6 (Rev. 2) posted for consideration by Review Committees on 31 August 2023 197 Comments received from: Argentina/RASSC (1) Bangladesh/NSGC (4) Belgium (5) Canada/EPReSC (2) Canada/TRANSSC (5) China (4) France (35) Germany/NUSSC (4) Iran/NUSSC (18) Iran/TRANSSC (8) Iraq (6) Israel (3) Japan/RASSC (1) Japan/TRANSSC (14) Pakistan/TRANSSC (20) UK/TRANSSC (4) USA/TRANSSC (18) USA/EPReSC (2) USA/NSGC (5) WNTI (38) Secretariat developed resolution table and revised draft during consultancy meeting on 17 20 October 2023 Resolution Table and revised draft SSR-6 (Rev. 2) uploaded for consideration by Review Committees on 23 October 2023 Addendum to Resolution Table uploaded on 26 October 2023 (F-12 and WNTI-29 to -38) Secretariat recommendations on proposals: Accepted (43%); Accepted, but modified (6%); Rejected (51%)

Changes to A1/A2 values Issues raised in comments [ARG/RASSC-01, JPN/RASSC-01, JPN/TRANSSC-05, JPN/TRANSSC-06, PAK-18, and ISR-02 & -03]: Explanation for new values should be provided RASSC should have a common understanding of the values including their impact on key radiation protection values in safety standards Proposal is not mature Values inconsistent within the A1/A2 WG Interim Report and incorrect values in proposed table Justification for the new 10-day rule is not understood Changes of text in the current SSR-6 and SSG-26 due to changes of A1/A2 are not fully discussed Options to establish new Q system proposed by the WG have not been agreed or instructed by TRANSSC A1/A2 values should not be changed in this revision cycle, and forwarded to the next revision cycle certain proposed A1 values are unlimited ; there is no LSA classification available for radionuclides where A2 is a specific value and A1 is unlimited .

Changes to A1/A2 values (cont) Information Version 1.0 of the Report of the WG A1/A2 was posted to the TRANSSC 47 web folder on 16 October 2023 and a link was included in the resolution table. An interim version of this report was posted in advance of TRANSSC 45 (November 2022). Version 1.0 of the Report of the WG A1/A2 addresses essentially all of the issues that have been raised by the commenters. A1/A2 values are stand-alone values in SSR-6 and have no corresponding values in other IAEA safety standards Any remaining issues with the revised A1/A2 values including coordination/cooperation with RASSC should be able to be accomplished in the next year before approval by the Review Committees of SSR-6 (Rev. 2) in Fall 2024 (Step 11). Table 2 in draft SSR-6 (Rev. 2) has been updated with values in Version 1.0 of the Report of the WG A1/A2 Path forward proposed by the Secretariat The A1/A2 values of Version 1.0 of the Report of the WG A1/A2 should be included in the draft of SSR-6 (Rev. 2) that is circulated to Member States at Step 8. Concerning transitional arrangements and the new A1/A2 values, based on the concept of a 10-year transitional period for no new manufacture of packagings [see para. 821A of SSR-6/para. 820.7 of SSG-26] and the comments of Canada and WNTI, the Secretariat proposes a 10-year transitional period.

WNTI-02 to -05; Maritime Terminology; IMO; Tables 10 and 11 Information At TRANSSC 46, it was agreed that input from IMO would be sought concerning proposals WNTI-02 to -04 about the use of new maritime terminology At TRANSSC 46, it was stated that WNTI-05 is not related to WNTI-02 to -04 A simplified information paper prepared by WNTI was considered at the 21 September 2023 meeting of the CCC9/IMO. Advice was sought on a proposal to use the term bay in Tables 10 and 11. The proposal was rejected by CCC9. Furthermore, during the plenary discussion, various issues were raised concerning, e.g. existing terms in SSR-6, i.e. defined deck area and exclusive use , and the safety basis for the modifications in Table 11. For details, see report: The Relevant Outcomes of CCC 9 and E&T 39 of IMO in the web folder for TRANSSC 47. In WNTI-31 (Step 7), it was proposed to include a footnote in Tables 10 and 11 with a description of a space on board ships that is similar to the definition of bay that was submitted to IMO. Path forward proposed by the Secretariat Revised text related to WNTI-02 to -04 was removed from the draft of SSR-6 (Rev. 2) WNTI-31 (Step 7) should be rejected based on the discussions at CCC9/IMO Revised text related to WNTI-05 should remain in the draft of SSR-6 (Rev. 2)

Rejection of new proposals 24 new proposals were rejected Review Cycle began with a Note verbale issued on 5 November 2021, which set a deadline for submitting proposals of 18 March 2022; >300 proposals were submitted The 2021 Transport Regulations Revision Quality Plan indicates that only proposals that were submitted during the Review Cycle would be developed further The fact that new proposals would not be considered during the Revision Cycle was discussed during plenary in TRANSSC and it is the common understanding of this committee

Comments Received in response to Resolution Table & Addendum Comments received from Belgium, Pakistan, and WNTI Some issues raised in comments by Pakistan were resolved through correspondence with the Secretariat Proposal for a path forward: Remaining comments will be addressed at TRANSSC 47 Comments were classified by the Secretariat: Secretariat proposes to accept: 8 Secretariat proposes to reject: 2 TTEG-C: 4 TTEG-OM: 2 TTEG-OM/TTEG-RP: 2 TTEG-PPA: 5 TTEG-RP: 2 Plenary discussion: 5 Overview of proposed process: 1. Presentation of an overview of the comments in plenary (this presentation) 2. Discussions/development of recommendations ( Accepted , Accepted, but modified or Rejected ) by TTEGs 3. Discussion in plenary of all new comments including recommendations by TTEGs; decision by TRANSSC on disposition of comments

Comments Received in response to Resolution Table & Addendum Resolution table practicalities The resolution table (posted 23 October) and its addendum (posted 26 October) were combined into one table for use at TRANSSC47 New comments were added to this combined table and highlighted in yellow The identifiers for the new comments include TRANSSC47 For the new comments, in the right-hand column of the resolution table, a proposed next step has been entered, i.e. discussions in plenary or by a specific TTEG, Secretariat proposes to accept this comment or Secretariat proposes to accept this comment The TRANSSC 47 resolution table has been uploaded to the TRANSSC 47 web folder

Comments Received in response to Resolution Table & Addendum

Comments Received in response to Resolution Table & Addendum

Comments Received in response to Resolution Table & Addendum

A goal for the TRANSSC47 is to agree on a draft of SSR- 6 (Rev. 2) that can be distributed for official Member State comments. Assuming that we are successful (and keeping in mind that there will be two more chances to comment on the draft, i.e. Step 8 and Step 11.) Action requested (Step 7) TRANSSC will be kindly requested to approve the submission of DS543 for official Member State Comments

Overview of Activities in 2024 (if DS543 is approved by all review committees at Step 7) Step 8 - Soliciting comments by Member States: January April 2024 Step 9 Addressing comments by Member States: If needed, discussions during TRANSSC 48 (June 2024); TTEG involvement Step 10 Second internal review of the draft publication: July August 2024 Step 11 Second review of the draft publication by the Review Committees: Fall 2024

Thank you!

Overview of Activities from TRANSSC 46 (June 2023) until the end of 2023 At TRANSSC 46, current text for proposals was discussed by TTEGs and in plenary; for revised text, some text was rejected, improved and identified as needing improvement. Details of these discussions and details of the development of proposals after TRANSSC 46 are recorded in the four TTEG resolution tables. Modified text was submitted to the Secretariat with a deadline of 24 July 2023 for various proposals. Modified text was incorporated into the draft SSR-6 (Rev. 2) e from Review Committees by 9 October 2023 Revised draft and resolution table in which the Secretariat proposed resolutions of comments were posted on 23 October 2023 Addendum to resolution table posted on 26 October 2023 TRANSSC 47: 6 10 November 2023 (SPESS STEP 7 first approval) Resolution of outstanding issues in plenary and by TTEGs, if necessary Approval of resolutions of comments by TRANSSC Approval of other Review Committees (30 Oct. 14 December 2023) Preparation of NV for 120-day comment period