Regulatory Helpdesk: January 8, 2018

3 Questions from our Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Check back weekly, the helpdesk rarely hears the same question twice.

Disclosing Concentration Ranges Under WHMIS 2015

Q. Do I have to indicate “Proprietary” on a WHMIS (M)SDS when masking actual concentrations with ranges?

A. It depends. WHMIS 1988 accepted the use of concentration ranges on MSDS to mask confidential business information (CBI) without requiring any indication.

WHMIS 2015 does not currently allow the use of ranges other than the concentration range actually present for a variable substance (also, unlike WHMIS 1988, ranges cannot be used to allow a single SDS for a series of different but similar products).

Products subject to an approved masking under the HMIR Act do have to, in both versions, reference the exemption authorization on the (M)SDS.

A CBI amendment under consideration may re-introduce the permissible use of ranges to unilaterally mask actual concentrations. This proposal as currently written requires a statement in the SDS when a range is used that’s wider than the actual concentration range, to protect CBI. We’ll have to wait for the final amendment to answer the question going forward…

IMDG or TDG?

Q. Does a shipment within Canada by vessel from Newfoundland require placarding according to the IMDG Code or do the provisions of the TDGR apply?

A. That depends on destination and route of the Continue Reading…

Repacking Dangerous Goods
Shipping Dior … Perfume, not Christian

Shipping Perfume

Shipping Perfume as Dangerous Goods

A freight forwarder contacted me to get some help on shipping perfume to Hong Kong. I asked him how he is sending it and he replied, “Air.” I said, “That’s simple.” It would fall under ID8000, Consumer Commodity. Explained to him what that actually meant. Basically, it’s goods that are “packaged and distributed in a form intended or suitable for retail sales for purposes of personal care or household care”; however, there are a few restrictions such as only certain hazard classes and packing groups are permitted. Perfume definitely falls within the criteria.

He came by our office and dropped off 8 decent sized boxes of these goods. I asked the forwarder if he plans on shipping the boxes individually or will be consolidating them (e.g, on a pallet). He said his plan was to take the boxes back to the office once I prepare the boxes and he will palletize it. I advised him he can’t do that, because that would be considered an “overpack” and would require marking and labeling on the outside of the shrink wrap (assumed it would be shrink wrapped). He said “Oh”. I told him we could help him. We will provide the shrink wrap and prepare the shipment completely at our location. He said he already had a heat-treated pallet (all wooden pallets must be heat-treated Continue Reading…

Lithium Battery
Lithium Battery Placarding and Segregation

Lithium Batteries, Laptop battery

Lithium Battery Segregation

It is January and all of the new or updated transport regulations are in full swing. This includes the new IATA addendums and IMDG Code corrigenda that were recently published. That leaves many tracking down what changed in and how those changes could impact business. Add to that dealing with the complexities that come with shipping lithium batteries and many people end up feeling confused like Vincent “Vinny” Barbarino on “Welcome Back Kotter”. Check out that memory.

Here is my attempt to simplify the placarding and segregation requirements as they now stand for lithium batteries. Let’s take a look at each topic and regulation to sort things out.

49 CFR – US Ground

Placarding (§172.504): Class 9 materials are found on Table 2. This indicates that when the gross aggregate weight of the materials in the transport vehicle reaches 1001 pounds (454 kilograms) placards would be needed. In Paragraph (f)(9) there is an exception. The exception tells us that placards are not needed for Class 9 materials shipped domestically. Easy right? Now this paragraph also tells us that should you use a bulk packaging of batteries, we would be required to mark the identification number on an orange panel, a white square-on-point configuration or a Class 9 placard.

Segregation and Separation Chart of Hazardous Materials (§177.848): There is currently nothing in this section of 49 CFR to indicate batteries should be segregated or Continue Reading…

Regulatory Helpdesk: January 1, 2018

3 Questions from our Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Check back weekly, the helpdesk rarely hears the same question twice.

Location of the To/From Address

Q: Can the name and address of the shipper and/or receiver be on top of packages of hazardous materials?

A: For 49 CFR only 1 address is needed and for air you would need both. Ocean doesn’t specifically mention addresses but we tend to include one since most carriers are going to ask for it. None of the regulations actually state where they MUST go. In some of our older trainings it was indicated that the addresses had to be near the name and number. I’ve tried to correct that.

For AIR – Section 7.1.4.1(b) – both addresses “located on the same surface of the package near the proper shipping name mark, if the package dimensions are adequate

49 CFR – Only one address is required per 172.301(d)

IMDG – There are no set guidelines for including addresses in Section 5.

New Segregation of Lithium Batteries

Q: Do lithium batteries have to be segregated?

A: It depends on the mode of transport.

In 49 CFR and IMDG 38-16, there are no segregation requirements for batteries. There could be information on a batteries SDS that should be followed.

For Air, in the new 59th edition of IATA or as some call it the 2018 version, there is some Continue Reading…

Airplane Icon
My Suitcase is Following Me! Can I Take it on the Airplane?

luggage at an airport

Smart Luggage: Regulations and Technology

In the world of dangerous goods regulations, frequent changes are the norm. These changes may happen for a variety of reasons. With technology constantly moving forward at a fast pace, the dangerous goods regulations often times have to update accordingly. Within the last 40 years or so, we have been introduced to a variety of new products that contain lithium-ion batteries. From laptops to smartphones, the introduction of these products into society has caused dangerous goods regulators to be in a constant foot race to keep up with the newest lithium battery powered electronics. The newest craze we see in the electronic world is the introduction of battery powered smart luggage.

What is smart luggage?

If you have ever watched The Jetsons, When George arrives at work in the introduction, his car folds down into a briefcase for him to carry inside. 

While smart luggage isn’t exactly what George Jetson used, they do have many amazing features. Built-in features in smart luggage include GPS locators, weight scales that prevent over-packing, USB ports to charge your devices, and remote lock systems. Smart luggage is a game-changer in the travel industry, as they can help you navigate the airport and let you know where it is if it did not follow you to your destination. They even have the ability to follow you around the airport like a robot, which I’m Continue Reading…

Danger Placard
DG on the Other Side of the World

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What’s wrong with these photos?

Well, nothing, if you consider where it was taken (a remote town in Thailand).

Even while on vacation, someone in the Dangerous Goods field is always on the lookout for dangerous goods in their environment. I know when I first joined ICC, I never noticed placards on trucks, but soon after it seemed like they were on every transport that passed by. Those blessed to be in our line of work have a heightened awareness for the dangers around us.

As we all know, regulations concerning dangerous goods differ around the globe. As much as we would like to think the regulations are harmonized, they’re really not. Enforcement is the same. There are only so many inspectors available compared to the number of shipments each day.

One has to wonder what training these workers have. Where are the transport labels, the Hazcom labels, and the blocking and bracing?

I feel a lot more comfortable knowing that shipments of gases in the US and Canada will be properly secured when transported, and they will always have proper labels. Regulations are in place for one reason, and that is to protect workers and the community.

ICC is your source for products, services, and training – all under one roof. Call us today.

Repacking Dangerous Goods
Shipping Laptops to Australia

Lithium Batteries, Laptop battery

Shipping Laptops Means Shipping Lithium Batteries

If you were to ship a laptop 5 years ago, all you would need to do was pack it up and ship it. Like shipping socks. But now that same laptop is considered a dangerous good due to the lithium battery it contains.

The Situation

I had a customer drop off 2 laptops going to Australia. He wanted me to prepare the shipment for air transport as he isn’t certified to ship dangerous goods via air. He said he received about 6 pallets of marine vessel equipment returning from Canada to Australia and he said someone put these 2 laptops in one of those pallets thinking it can all go as general cargo. He knew that there are restrictions on shipping lithium batteries via air so he knew he had to call in the expert!

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The Solution

I removed the battery from the laptop to see the watt hour rating. It was 41-watt hour and the total net quantity of lithium was below 5 kg (well below). Which meant these laptops are classified as Section II for UN3481, Lithium ion batteries contained in equipment; therefore, does not require a shipper’s declaration. It’s always good news for the client when it falls in Section II as it saves the client money.

I placed both laptops inside a good strong box (each laptop was initially Continue Reading…

Regulatory Helpdesk: December 25

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Due to the Holiday week, we have only 2 FAQ’s worth sharing.

Check back weekly, the helpdesk rarely hears the same question twice.

More Lithium Batteries

Q. We want to ship a 63 W-hr lithium ion battery.  Are there any issues with packaging 2 or more together in the same container under IATA 2018 and 49CFR?  If 2 or more are ok what is the limit?

A. Under IATA you have 2 options and it will be up to you as the shipper to make the decision as to how to handle your shipment.  As you know the 65 w-h battery falls into the excepted type. Now, for IATA that puts you in either Section II or Section IB.  By the way, be sure to grab the recently published Addendum!

For Section II batteries there is a change for this year. As per usual, there are several changes to the operator regulations. Also, these batteries cannot be packed in the same outer packaging as any other dangerous goods.  The rest of the section still applies in PI 965. You are not allowed to offer more than 1 package prepared under Section II in any single consignment or shipment. If you are using an overpack, you can only have one package of these batteries in the overpack. The overpack cannot have Continue Reading…

IATA
IATA 59th Edition Addendum No. 1

2018 IATA Addendum

The 59th IATA Dangerous Goods Regulations were not even in effect when the first Addendum was sent. This Addendum was posted on Dec 22, 2017, and is effective January 1, 2018.

To view the full Addendum click here

Highlights of the Addendum include:

  • A new state variation was added for Ethiopia. This new addition includes 4 variations including mandatory requirements for the shipper’s declaration form and a mandatory inclusion of an (M)SDS.
  • UPS Airlines (5X), Air Canada (AC), Air France are some of the others who have operator variations. Check these carefully, as there are several pages dedicated to these changes.
  • Table 2.3A – Provisions for Dangerous Goods Carried by Passengers or Crew has been regarding Lithium Batteries. This section is not only important for shippers, but also for travelers.
  • Section 2.3.5.9 has been completely revamped.  There isn’t an easy way to go in and make the changes they have listed.  As a courtesy to our customers, you can download a revised section with all the changes, deletions and additions.  It fits on one page and can be printed for adding into IATA.
  • A change was added for Dangerous Goods in Excepted Quantities. The number of packages must now be shown on in the Nature and Quantity of Goods box on the waybill, unless they are the only thing being shipped.

There are a few other typographical changes in Section 4, Section Continue Reading…

Repacking Dangerous Goods
Shipping Different Dangerous Goods in One Package

Man preparing shipment

Q Value!

Now doesn’t that sound interesting. When you want to ship different dangerous goods in one outer packaging, you have to calculate something called a “Q value” using a formula. The Q value ordeal is only applicable to air shipments and seldom used as most prefer to put the dangerous goods in separate packaging.

Last week a customer requested to have 2 different dangerous goods packaged and shipped to Brazil via air. Since the quantities for each product was less than 200 ml I thought I might be able to apply the “Q” value and besides it’s always better to consolidate your shipment if you can to prevent loss/delay of packages. Especially this time of the year.

I ensured the dangerous goods met all the requirements of Section 5.0.2.11 of the IATA Regulation. I calculated the “Q” value and it was less than 1.0. So, everything seemed to be a go. For packaging, I used a 4GV box and lots of vermiculite to:

  1. separate the two dangerous goods and
  2. more than enough absorbent in case there was a leak (only one product was liquid)

Applied all the labels and markings, created the shipper’s declaration and added the Q value as required per Section 8.1.6.9.2(f), then shipped it out with Fedex.

I like to throw in a knuckleball once in a while and keep things Continue Reading…