Learning a new transport regulation is tough. Even if you are familiar with other modes, learning the intricacies of a new one is difficult. In our courses, we spend a good deal of time going over a basic shipping description (ISHP) and breaking down each part of it.
Time is also spent on UN versus ID numbers, proper shipping names, hazard classes, and packing groups. We also bring in the Dangerous Goods List (DGL) and talk about where to find the ISHP. This leads to a discussion on technical names, aircraft types, and other symbols shown in the DGL. Eventually we land on the topic of Special Provisions in Column M.
We explain these are additional requirements for any given entry or as I like to call it – the curve balls. Some are helpful and relieve parts of the regulation while others complicate it.
Note – If you ship dangerous goods and are having some trouble with the terms used above, you may need training.
New Special Provisions
IATA added some new Special Provisions a few years ago that cause additional stress for new shippers. I am referring to the A800 series. There are 5 special provisions there starting with A801 and going up to A805. So, what is the big deal with these and new shippers? If we take a moment to look at each one, you’ll see why Continue Reading…
Every country has superstitions. Those beliefs or notions that while irrational and not scientific seem to persist in society. They can impact how people respond to situations at home and even at work. In honor of Friday, April 13th, let’s take a look at a few and how they might impact safety.
Superstition #1: Fear of Friday the 13th
People cite multiple reasons for being afraid of this date every year. Some trace it back to the Christian religion and the belief Jesus died on a Friday and there were 13 guests at the Last Supper. Others say this day coincides with the arrest of so many Knights Templar. Those skilled fighters tasked with escorting people to and from the Holy Land. Some still have nightmares from Jason in his hockey mask from the movies around this date.
Regardless of the history, there is nothing in any of the safety or transport regulations that says this date should be avoided. If you need a day off, follow your company policy and do it by the book. For those trivia buffs out there, the fear of the number 13 and/or this date is known as paraskevidekatriaphobia and friggatriskaidekaphobia. One is of Greek derivation the other is Norse.
Superstition #2: Do Not Walk Under Ladders
This one stems from either the Christian religion and the idea of the Holy Trinity or ancient Egyptian and the shape of Continue Reading…
No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.
Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.
The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
Means of containment
(in TDG) a container or packaging or any part of a means of transport that is or may be used to contain goods.
Means of transport
(in TDG) a road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used Continue Reading…
As an avid reader and science nerd, the author Dan Brown is a different type of read. His lead character, Dr. Robert Langdon, is a professor of symbology. This means he studies and understands various symbols found in history and codes. Sometimes in transportation, we must be our own Dr. Langdon to decipher what the regulations are trying to tell us.
■ The square: This symbol tells us new material has been added to the regulation or edition.
▲ The triangle: Here it indicates some part of that section of the regulation changed in some way. It could be as simple as one word, sentence, or entire section that was reworked or clarified.
∅ The crossed-out circle: This one is a space holder showing some part or section has been removed, deleted or cancelled from the current edition. A very useful symbol, because it will keep you from looking for something that you knew was there but now can’t find.
☛ The pointing finger: Here is a symbol found only in IATA. It signifies this section or statement is more Continue Reading…
Occasionally our Regulatory Helpline is asked a question by a customer that stretches our knowledge of the regulations. The most recent one was a call regarding shipping spaceship batteries. Apparently, they were visiting another planet in their system and got stuck due to a dilithium crystal ion battery that would no longer hold a charge. Their home planet of Nibiru wants to send some replacement spaceship batteries and asked if there were any regulations with which they should comply and any areas with which they needed to be concerned.
To show you how great our helpline is, let’s review the process we used to get them the answer they needed.
Step 1: Is the planetary nation a current customer of ICC?
It turns out they actually are a current customer.
This means they have ready access to our helpline anytime they should need it.
Step 2: By which mode of transport will these be transported?
To start, the Area 51 CFR Ground regulations for the home planet must be reviewed. This is necessary as the spaceship batteries would be transported by hovercraft from the home planet’s office to the intergalactic air and space launch facility.
George Carlin will always be a favorite comedian for people of a certain age. One of his best-known bits is on oxymorons. An oxymoron, is basically a set of contradictory terms that work together. While not the greatest of explanations, let’s have George give you some examples to make the point.
This concept came to mind on the heels of the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and the DOL’s Occupational Safety and Health Administration’s (OSHA) joint video on labeling. Those two organizations are just that, 2 different organizations, yet they released a joint video? It sounded like a setup to a bad joke. Turns out I was wrong.
The video does a great job of explaining the focus of each organization and goes a long way to clearing the air. There are references to the regulations used by each, but not a lot of time is spent on “regulatory language” or the details of either one.
Comparing PHMSA vs OSHA
Here is my version of the comparisons between the two and how closely the align based on the video.
Regulates hazardous materials in transport
Regulates hazardous chemicals in the workplace
Both want people to be safe.
Uses the Hazardous Materials Regulation
Uses the Hazard Communication Standard
Both have a set of “rules”.
Defines Hazardous Material as those that pose an unreasonable risk to health, safety and property when transported in commerce
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.
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:
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.
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.
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…
Here we are at the end of 2017 and the best word to summarize it is “change”. Every transport regulation had some sort of change this year. The most recent one is to the IMDG Code. A Corrigenda was published earlier this month that makes some changes to the 38-16 version. Note that this version becomes mandatory for use starting January 1, 2018.
Here are a few of the highlights:
The words “fishmeal” and “seedcake” are now divided into separate words throughout the regulation. You now have “fish meal” and “seed cake” throughout the code.
The words “marking” and “markings” have all been replaced with “mark” or “marks” through the entire code.
Several chapters in the regulation have been renumbered such as the subheadings under 5.1.1, 7.8.6 and 7.8.7.
Packing Instruction P002 has a change to Special Packing Provision PP11 to include 5H1, 5L1 and 5M1 bags.
Special Packing Provision PP40 has been deleted from several UN numbers including 1396 (PG III), 1398 (PG III), 1402 (PG I) and 3132 (PG III) to name a few.
For the new Lithium Battery mark there is now the allowance that it can also be a “suitable contrasting background” rather than just black and white.
The new Class 9 Hazard Label for Lithium Batteries also received some clarification in Chapter 126.96.36.199.1.3 in that the number of vertical stripes Continue Reading…