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A New Year, New Requirements for Identification Numbers

As the start of a new year approaches, it’s time for parties, resolutions – and to check our dangerous goods/hazmat procedures, and see what’s changing. If you are a shipper of non-bulk packagings, one thing to watch out for is the new size limit for identification numbers that will be introduced in many regulations for 2014.

Identification numbers (which cover UN numbers, NA numbers and ID numbers) are the main way for packages to be identified as to their contents, in a format that does not depend on language. In the past, incidents have occurred because these numbers were marked on dangerous goods packages, but were not large enough to be seen easily. Therefore, the United Nations has, in the UN Recommendations for Dangerous Goods, established minimum size requirements.

The size minimums are:

  • For packages with a capacity of 5 Litres or net mass of 5 kilograms or less, the size should be “an appropriate size,” based on the size of the container.
  • For packages containing more than 5 Litres or kilograms, up to  a maximum capacity of 30 Litres or net mass of 30 kilograms, the letters and numbers of the marking must be at least 6 millimeters (1/4 inch) tall.
  • For packages exceeding 30 Litres capacity, or 30 kilograms net mass, the letters and numbers of the marking must be at least 12 millimeters (1/2 inch) tall.

These size minimums will be mandatory for shipment under the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, the IATA Dangerous Goods Regulations, and the International Maritime Dangerous Goods Code (IMDG), starting January 1, 2014. So, make sure that your packages transported by international air and ocean are properly marked. Shipments with smaller markings will run the risk of being refused transport, or even cited as violations.

While the US Hazardous Materials Regulations (HMR) of Title 49 of the Code of Federal Regulations (49 CFR) contain the size minimums, section 172.301(a)(i) indicates that, for domestic shipment within the United States, these minimums will not be mandatory until January 1, 2017. Of course, some carriers may prefer that you meet these minimums before that date.

Canada, however, has not yet put these requirements into the current Transportation of Dangerous Goods (TDG) Regulations. Even so, designing your markings with these minimums in mind can indicate due diligence in ensuring your hazard communication is up to the highest standard.

If you have any questions that ICC The Compliance Center Inc. can assist you with regarding the changes to the marking requirements, please contact us at 1-888-977-4834 (Canada) or 1-888-442-9628 (US).

Barbara Foster

Barbara Foster graduated from Dalhousie University with a Master’s degree in Chemistry and a Bachelor’s degree in Education. As one of ICC Compliance Center’s most senior employees, she has worked in the Toronto office for the past three decades as a Regulatory Affairs Specialist and Trainer. She is fluent in various US, Canadian, and international regulations involving transportation, including TDG, 49 CFR, ICAO, IMDG, and the ADR/RID. She also specializes in the hazard communication standards of OSHA, WHMIS, CCCR, and the Globally Harmonized System for Classification and Labelling (GHS). Barbara is the author of ICC’s TDG Clear Language Driver and Handler’s Guide. Currently, she is a participant on the Canadian General Standards Board committee where she creates training standards for transportation of dangerous goods in Canada and is a past Chair of the Dangerous Goods Advisory Council.

2 Comments

  • ARUN MOHILE says:

    May I know what are ‘NA Numbers’ and ‘ID Numbers’?

    I would very much appreciate if you could educate me on these.

    Best Regards,

    Arun Mohile

    • As mentioned, identification numbers encompass several things (UN numbers, NA numbers, and ID numbers).

      NA numbers are used domestically in the United States of America according to the 49 CFR.
      In the past, different ID numbers were used in the ICAO Technical Instructions and are found in the IATA book. Actually there is only one ID number that is currently still used and that is ID 8000, CONSUMER COMMODITY, CLASS 9. It is specific to air transport. We do not see it in TDG or IMDG regulations. In the 49 CFR, there is mention of it, but ORM-D is used for Consumer Commodity by surface in the United States of America.

      Good question Arun.
      Thank you,
      Jonathan

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