DOT 49 CFR USA
Alternative Ways to Ship Perfume Under 49 CFR

Different bottle of perfume on a wooden table

Shipping Perfume: The Regulations

Every so often our regulatory team is asked a question that on the surface seems funny but in reality, has some interesting facets upon review. For example, can a perfume ever be shipped as anything but a perfume under the 49 CFR regulations? It sounds like a basic question. The short answer is yes. However, when you move through the intricacies of the regulations it can be a quite complex answer dependent on many factors.

Exceptions

Most of us familiar with the regulations would immediately think about the exceptions for small quantities, excepted quantities, de minimis, limited quantities and consumer commodities. However, before we can look at any of those, you need a clear indication of what you are actually shipping. 

For perfume the shipping description is UN1266, Perfumery products, Class 3, Packing Group II or III. There is one special provision that applies for ground shipments on this entry. It is SP-149 that allows the inner container limit to be 1.3 gallons or 5 L when shipped as limited quantity or consumer commodity.

Let’s look at each exception and see if it would apply:

  1. 4 Small Quantity (§173.4). For this exception, we are limited to domestic highway and rail transport only. We also see that our Class 3 material is allowed. The maximum amount allowed per inner container for this exception is 1 oz. or 30 ml.
  2. Excepted Quantity Continue Reading…
Regulatory Helpdesk: February 5

Labels, Placards, Segregation, Documentation, SDSs & Emergency Response

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Here are the top 6 questions from last week.

SDS and Workplace Labels

Q. If I have a product like a concentrated cleaner which is corrosive to the eyes and skin that I water down at my facility, do I need a new SDS and workplace labeling?
A. You have 2 options. You can use the SDS as provided to create your workplace labeling. This may cause concern with your workers. However, it would be better for you to develop your own and re-evaluate the product using the hazards presented in the watered-down version. It is possible, depending on how diluted it is, to move into the irritation or non-hazardous range.

Listing Canutec or Chemtrec on Lithium Battery Marks

Q. Regarding the new battery mark, am I allowed to add “in case of emergency, contact Chemtrec”?
A. The regulations are pretty clear (DOT §173.185(c)(3) and IATA 7.1.5.5). What should be listed there is a phone number for “additional information”. There should be no extra phrasing other than phone number itself. As for listing Chemtrec, Infotrac or even Canutec, those are 3rd party Emergency Response Providers and would not be appropriate to include in that section of Continue Reading…
Safety Data Sheets (SDS)
GHS SDS Ingredient Disclosure

Young female Industrial Worker

Another SDS ‘Headache’

If you are supplying chemical products that require Safety Data Sheets (SDS’s) to multiple countries, you are also likely to know this headache well.

With the implementation of the Globally Harmonized System of Classification & Labeling (GHS) around the world progressing, issues are beginning to appear which emphasize points where…. Maybe requirements are not so ‘harmonized’. One such issue, is ingredient disclosure requirements on SDS’s for mixtures across different regions of the world.

The United Nation’s (UN’s) GHS system, does contain some standardized recommendations for SDS, including that SDS’s should be provided only for chemicals classified as ‘hazardous’, SDS’s should contain basic minimum information (e.g., 16 sections with specific headings), as well as more detailed recommended guidance on how to prepare each section of the SDS.

Ingredient disclosure recommendations, in particular, appear in Annex 4 of the GHS. In general, the GHS recommends that for a mixture classified as hazardous, the SDS should list all ‘hazardous’ ingredients, which are individually hazardous to health or the environment, when the ingredients are present above concentration cutoff levels. There’s several parts of that general requirement, which can be viewed as a ‘can of worms’.

Are the cutoff levels the same for each region of the world? How should one handle ingredient disclosure when you are in a region that doesn’t regulate environmental hazards on SDS’s? Are ‘non-hazardous’ chemical mixtures really not Continue Reading…

IMDG
How Do You Ship Bullets? (IMO)

shipping bullets by ocean

What to do when you are moving and need to ship a whole lot of bullets?

98% of our repackaging clientele are businesses, but there are 2% of our clientele that are regular people. At least, this is how I refer to them. These folks are a “Mr. or Mrs. Smith” who have absolutely no idea about the dangerous goods world, but what they wish to send is considered dangerous goods. These folks are referred to us from carriers, freight forwarders, and sometimes by internet search results.

Recently I had a Mr. Smith call us to ask about packaging cartridges as recommended by his freight forwarder. He is moving to Europe and is packing up his entire house, which includes his firearms and the cartridges that go with them. He already had all his ducks in a row meaning his export/import documentation and certification for the firearms and whatever else was needed to ship the firearms and cartridges, but he needed to get the cartridges packaged up for transport. That’s where ICC comes in.

What Are We Really Dealing With?

Mr. Smith didn’t have any transport information such as UN number or shipping name. So, I asked him to email me pictures of the cartridges, because he mentioned they were all in their original retail packages. I was able to call the manufacturer directly and ask for the shipping info. Continue Reading…

Regulatory Helpdesk: January 29

WHMIS Labels Format, How ICAO and IATA are Related, Shipping Residues, and IATA Documentation

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

WHMIS Labels Format

Q. Is there a specified format for WHMIS 2015 workplace labels?
A. No. The information is specified but not the format. Pictograms may assist employees in quickly identifying the hazards/precautions; and may simplify employer creation of substitute “supplier” labels.

This is especially true when employees have been trained in the GHS-based WHMIS 2015 system. Employers must ensure training has been provided if GHS pictograms are used on workplace labels during the transition period.

ICAO/IATA Relationship

Q. Is a risk of non-compliance in using IATA DGR given that government regulations specify compliance with ICAO Technical instructions?
A. IATA DGR states in §1.14 that they contain all of the ICAO TI requirements and add additional restrictions. Thus, complying with IATA DGR will ensure compliance with ICAO TI. As with all regulations, it is important to keep aware of amendments/corrigenda between publication dates.

Shipping Residues (TDG)

Q. When we are shipping residues…. Can we and how do we indicate ‘Residue last contained’ on the transport document.
A. If the quantity of dangerous goods in a means of containment is less than 10 per cent of the Continue Reading…
Excepted Quantities
UPS Excepted Quantities Update

Red semi truck on highway

UPS Makes Changes to its International Special Commodities (ISC) Program

UPS has announced it will be making changes to its International Special Commodifies (ISC) Program which enables selected customers under contract to ship certain prohibited articles.

This initiative has added more than 50 countries that can ship biological substances, shipments utilizing dry ice, and goods in excepted quantities internationally.

What does this Include?

UPS will now pick up and deliver packages containing UN3373 (Biologic Substances, Category B, Diagnostic Specimen and Clinical Specimen) as well as UN1845 (Carbon Dioxide, solid or dry ice) to 51 added countries and territories bringing the total number of countries to over 100.

In addition, the countries that were added to the list can now ship dangerous goods in excepted quantities internationally if authorized by the regulations.

The full list of approved countries can be found here:
UPS – Approved Countries

What is an Excepted Quantity?

Dangerous goods shipped in excepted quantities allow relief from certain regulations in small quantities outlined by IATA in §2.6. Be sure to check IATA for specific details and to use the label below when shipping in excepted quantities.

Excepted Quantity Label
Excepted Quantity Label (LB-USL350N)

Where can I find packaging for UN3373 Category B Specimens and dry ice shipments?

At ICC we have a wide variety of packaging specifically designed for biological packaging as well as dry ice shippers for international shipments similar to the kit below:

[caption Continue Reading…

TDG
Standard TP14850 Pre-Canada Gazette (CG) I Consultation

Truck Driving on highway at sunset

Updated TDG Packaging Standard – Small Containers for Classes 3, 4, 5, 6.1, 8, & 9

In addition to expanding the title to reflect the various types of containers contemplated in the Transportation of Dangerous Goods regulation (TDGR) §5.6, 5.12 (and cited within other referenced standards), this “final draft” reflects the penultimate result of a review that’s been active since the adoption of the current edition in 2015.

Anatomy of Development

The 2nd Edition of TP14850, published October 2010 was adopted into the Canadian TDGR in July 2014, replacing CGSB-43.150-1997 and becoming the mandatory standard for packaging the “common” classes of dangerous goods in Canada in January 2015.

The 16th Edition (2009) UN Model was the primary basis for the 2010 TP14850 standard, so it was time to move forward in the spirit of harmonization.

Transport Canada began the process of forming a consultative committee in mid-2015. A public notice regarding the consultation was published in early 2016 with provision for general public input. The committee, formed in April 2016, consists of about 3 dozen participants.

The committee includes a core group of 6–8 from Transport Canada with the remainder representing a variety of industry associations, individual manufacturers, users, provincial/US regulatory interests, and labour organizations.

The draft presently open for general comment was developed by consensus following discussions, including face-to-face meetings and a series of web/teleconference sessions, between April 2016 and June 2017. Continue Reading…

Compressed Gas
Shipping Root Beer to France

Soda cans, pop cans

Arsenio Hall, Root Beer, & Transport Regulations

Television talk shows have been around forever. Back in the 1950s there was Joe Franklin who moved over from talk radio and the emergence of “The Tonight Show” with its first host Steve Allen. In the 1970s and 1980s the formatting changed to include more tabloid type themes. Eventually shows became more about interviewing celebrity guests, comedy skits, and musical performances.

After all, where else could you see Tom Cruise jump around on a couch or see a presidential candidate play a saxophone? In case you didn’t catch the references, Tom Cruise’s antics were on the “Oprah Winfrey Show” and Arsenio Hall had Bill Clinton playing his saxophone.

What’s This Have to do with Dangerous Goods?

Speaking of Arsenio Hall, a part of his show included the skit called “Things That Make You Go Hmmm“. While quite funny, most aren’t appropriate for company blog. I mention this because of a recent regulatory inquiry that made it’s way to me.

A customer of ours wanted to ship a can of root beer from the US to a client in France. They wanted to know if the root beer would be considered a hazardous materials shipment. Good question if you think about it. Root beer could be considered hazardous because of the compressed gas (carbon dioxide) in solution which is hazard class 2.2.

The Regulations

Since this customer is in the US, the regulations Continue Reading…

Regulatory Helpdesk: January 22, 2018

Shipping Alkaline Batteries, IBC Pressure Gauges, and SDS Expiry Under WHMIS 2015

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Shipping Spent Alkaline Batteries (49 CFR)

Q. Can spent alkaline batteries (Duracell) be shipped to a recycling facility by ground without being declared dangerous goods?
A. Assuming that these are dry alkaline batteries that are used or spent for recycling, they are not required to be shipped as dangerous goods by ground in the USA per 172.102 Provision 130 (d) provided they are rated under 9 volts per below.

Ground Transport (US DOT): 49 CFR 172.102 SPECIAL PROVISION 130

Used or spent battery exception. Used or spent dry batteries of both non-rechargeable and rechargeable designs, with a marked rating up to 9-volt that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal are not subject to this special provision or any other requirement of the HMR.

Pressure Gauge Requirements for IBCs

Q. What are the pressure gauge testing requirements for 31A IBCs?
A. I referred the customer to 178.814 d (1) (2) which lists 2 consecutive tests that must be administered with a rating of 65kPa first followed by 200kPa.

Can You Use Capital Letters (TDG)?

Q. Do Continue Reading…
United Nations Logo
20th UN Model Recommendations for Dangerous Goods Transport (Orange Book)

UN Model Regulations (Orange Book)

2017 (20th Edition) – Highlights Changes

Those who follow the IATA DGR will have an idea of many of the changes resulting from the UN Recommendations expected to result from the changes in the 20th Edition of the commonly titled “Orange Book”.

Those who work with other modal/government regulations may not be familiar with changes that will likely follow in those regulations as all or part of the amended Model become incorporated.

Changes in Terminology

As often happens, terminology changes were introduced to this edition to clarify or technically improve concepts covered by the regulations. Throughout the document the term “risk” has been replaced by “hazard” to reflect the intent of referring to a danger.

Similarly, most references to “devices” now refer to “articles” which is defined in 2.0.5.1 as including “machinery, apparatus or other devices”.

New UN Numbers

UN3535 to UN3548 have been added to the collection:

  • UN3535 refers to “TOXIC SOLID, FLAMMABLE, INORGANIC, N.O.S.”
  • UN3536 is a new “LITHIUM BATTERIES INSTALLED IN A CARGO TRANSPORT UNIT” applicable to either ion or metal-based batteries.
  • UN3537 through UN3548 cover a sequence of listings for “ARTICLES CONTAINING…, N.O.S.” applicable to a variety of Class 2-5, 6.1, 8 and 9 dangerous goods.

The additional entries result in related changes to classification sections and special provisions.

Lithium Everywhere

As we’ve seen over the last few years regulation of lithium battery regulations continues to evolve.

The concept of “equipment” in the sense of lithium Continue Reading…