Repacking Dangerous Goods
Everyone’s Favorite … Shipping Lithium Batteries!

Lithium Batteries, Laptop battery

Complying with the Regulations

Sometimes we try to find an economical solution to comply with regulations. If it works, great, but sometimes – actually most times – it comes back to bite us in the behind.

Last week a customer of ICC’s came in panicking to get help. He has previously used us a few times for our repackaging service. Let’s call him Bob. Bob told me he and his team took an online training course which certified them to ship lithium batteries via air. Bob’s shipper packaged up a lithium battery shipment and had sent it out. Bob just found out that it was rejected by the carrier. I asked Bob which UN# they used and he said UN3481. Asked him which (packing instruction) section and he said “what?”. I said, “In Packing Instruction 967, which section do you fall under?” He said, “What’s a packing instruction?”. I grabbed my IATA regulation and told him, “You guys used this book to do the course, yeah?” and he inferred that the course didn’t require use of a book and no, they didn’t use any books. I asked Bob if they took training with ICC and he said, “no”. Bob said they took training with another company and paid $50 as it was the cheapest training they could find. I told him that was his first mistake.

Carrier Conundrum

Bob said Continue Reading…

Regulatory Helpdesk: November 27, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

Lithium Battery Special Provision

Q. Why is only a reference to Packing Instruction Section IB required on a lithium battery Shipper’s Declaration – what about shipments made under Section I or IA?

A. Sections I and IA refer to fully regulated shipments so it’s redundant to indicate an authorization unless there’s a special provision deviation involved.

Although Section II shipments don’t require a Shipper’s Declaration document, if an airwaybill is used a notation must be made indicating the Section II status like ‘’Lithium ion batteries in compliance with Section II of PI— CAO’’.

This is particularly true for UN3090 or UN3480 where the document is required to indicate the CAO status.

Shippers also need to verify any listed state or operator variations that may require information over that mandate by IATA DGR.

Determining the Size of the Package

Q. I have a customer who wants a “portable tank” of product instead of our usual smaller sized containers, can I oblige?

A:

  • Characterize your product,
  • read the container supplier’s specification,
  • read the relevant regulation,
  • read the cited container standard; review 1. & 2. in the context of 3. & 4; decide on any required modifications.

Shipping Continue Reading…

Lithium Battery
Lithium Button Cell Air Exemptions

Cargo loading on aircraft

IATA DGR PI 967 & PI 970 Confusion

The wording in recent, current and upcoming editions of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) has some potential to confuse the regulated community, especially regarding shipping lithium batteries.

Exemptions Restricted or Not?

The paragraph providing an exemption from the lithium battery mark (pka “Handling Label”) is found in the last sentence of the second paragraph in Section II “Additional Requirements”, for the packing instructions (PI) for both UN3091 and UN3481 “contained in…” lithium battery entries:

This requirement does not apply to:

  • packages containing only button cell batteries installed in equipment (including circuit boards); XXX
  • consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.

The “XXX” is the key that led to this discussion.

2016 as the Baseline:

In the IATA DGR 57th (2016) Edition, both PI 967 and PI 970 (“contained in equipment”, ion and metal respectively), the “XXX” in each case read “or”.

In other words, whereas cells/batteries other than button cells were limited to 2 packages per consignment, the number of packages per consignment were not limited when there were only button cells (of course, the maximum net battery weight per package restrictions in Table II of each PI must also be met).

Looking Forward to 2017?

Things then look as though they’re changing when reading the Appendix H (Intended Changes for Continue Reading…

Regulatory Helpdesk: November 20, 2017

Top 5 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

Overpacks

Q. My shipment was refused even though I followed what the regulations and my training said for shipping an overpack. My drums were on a pallet and shrink wrapped. All of the information on the drums could be seen. I placed a sticker with the words “Overpack Used” on the shrink wrap and listed it that way on my paperwork. Can you tell me why my carrier refused it?

A. Per Section 7.1.7 the actual wording that must be used on your pallet is just the word “overpack”. It seems confusing to have different terminology used but that is how the regulations work and why you should be trained every 2 years for IATA.

Using Combustible Liquid, N.O.S. (USA)

Q. Since this product meets the combustible definition, can we use ‘NA1993 Combustible Liquids, n.o.s.’ to ship to Canada or does Canada only recognize the ‘UN1993 Flammable Liquids, n.o.s.’?

A. Basically, to me, she is asking what is the difference between NA1993 and UN1993 and how it impacts transporting into Canada. NA1993 is a US only identification number. It is used for transporting combustible liquids in the US.  Technically, a combustible liquid is NOT Continue Reading…

Regulatory Helpdesk: November 13, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

WHMIS Label Size Requirements

Q. Is there were size requirements for WHMIS labels?

A. No, the HPR does not mandate a size requirement other than saying it has to be legible. But, what does legible mean? As a general rule of thumb, which we have developed from reviewing many different labeling regulations is 10 mm for one side of the pictogram, and 2 mm for the font size (1.6 mm for a worst-case scenario).

IATA Special Provision

Q. What does  IATA’s Special Provision A191 mean?

A. It was determined that SP A191 means if you have a manufactured article with less than 5 kg of mercury in it (like a thermometer) then you don’t need the Class 6.1 label for mercury’s subsidiary hazard and you don’t have to list the 6.1 subsidiary hazard on the shipper’s declaration.   From what we can tell that only applies to UN3506 which is Mercury contained in manufactured articles.

Quantity Limits – TDG (Canada)

Q: What does the quantity limit in TDG Columns 8 & 9 represent in terms of Passenger conveyance restrictions- package, consignment, …?

A: Good point which many find confusing. The answer is in the often-overlooked Continue Reading…

Repacking Dangerous Goods
When the Finished Package Resembles Christmas Lights

A lot of Labels!

A Lot of Labels

It’s not often that you’ll see more than 2 hazard labels on a DG package, but the one I did this week had 5 hazard labels plus 3 handling labels. So a total of 8 labels on a package. Yes, that is a lot.

I received a panic call from a freight forwarder who picked up a rejected package from a passenger airline and didn’t know what to do with it. It was a rush shipment to get to Australia. I asked him what was being shipped and he said, “a fire extinguisher and some cans of glue”. I advised him to bring the package and all accompanying documents over to our office and I will get it packaged up properly for air transport. He showed up an hour later.

This is what the box looked like when it came in:

A lot of labels 2

I reviewed the shipper’s declaration which the shipper did complete and the markings/labels on the box and it was incorrect for numerous reasons. I told the freight forwarder that the person who prepared this shipment is not certified to ship via air. An air certified individual may make an error or two, but not 10. It was evident this person did not know what they were doing. I asked for the MSDS/SDS for the products. The fire extinguisher was obvious, but there were 4 small Continue Reading…

Repacking Dangerous Goods
Shipping Funky Looking Fire Extinguishers

Shipping aircraft fire extinguishers

Aircraft Fire Extinguishers

Have you ever seen an aircraft fire extinguisher? If not, they don’t look anything like a regular fire extinguisher. For most of us when someone says, “fire extinguisher”, we imagine some kind of red cylinder with a pin, nozzle, and trigger. But an aircraft fire extinguisher looks like a ball with antennas sticking out. That’s why I call them “funky looking fire extinguishers”.

I was asked if I can assist with shipping out an aircraft fire extinguisher via air for a client. Absolutely I can. The client dropped off the fire extinguisher which was wrapped in bubble wrap. As per the SDS it was classified as UN1956 but for those with equivalency certificates/special permits it can be classified as UN1044. Now since these funky fire extinguishers don’t exactly have the surface area to place the markings and labels, I used a strong tag to affix the label and markings as per Section 7.2.6.1 (d) of the IATA Regulations. I wrapped the fire extinguisher in more bubble wrap in such a way to prevent any accidental activation during transport. I used a strong outer packaging and filled the void space with packing peanuts. Placed all the labels and markings on the outside of the package and send it out the same day with FedEx. The package arrived at its destination nice and early at Continue Reading…

Repacking Dangerous Goods
Shipping Small Quantities of DG via Air

Shipping Sodium Hydroxide by air

Shipping Sodium Hydroxide

A gentleman called to ask if we can help him ship out a small sample (125mL) of sodium hydroxide via air. I said, “absolutely”! He then asked, “maybe you can send it out as limited quantity?”. He was trained to ship dangerous goods via ground but not air. Folks trained in both modes of transport will agree that sending something using the limited quantity exemption by ground is tremendously different from sending that same product using the limited quantity exemption by air.

Shipping Limited Quantities by Ground vs Shipping by Air

Let’s just say for ground, life is good when you can apply the limited quantity exemption to the shipment. It’s easy and cheaper. Yes, it takes a while to get wherever it is going but that’s what you pay for. Sending the same product for a quantity that falls within the limited quantity exemption for air transport may save you a couple of bucks, but that’s it. The only place to really save some money is on packaging. Sending a product using the limited quantity exemption for air exempts you from using a UN standardized package; however, there are some tests that are required for that package. That’s why I said, “may”.

Shipping Sodium Hydroxide UN1824 by air

If you ship this small of a volume on a regular basis then it may be worth doing the tests, but if you only Continue Reading…

Regulatory Helpdesk: October 30, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

WHMIS Labeling

Q. If a product is manufactured in Canada strictly for export into the US, does it require the French on the GHS label?

A. HPR (Hazard Products Regulations) section 5.14, subsection 3. These exemptions from labeling and SDS (safety data sheet) requirements apply to importation (subsection 5.14(2) of the HPR) and sale, for the purposes of exportation (subsection 5.14(3) of the HPR), of hazardous products that are not meant to be used in a work place in Canada. Such hazardous products do not require an HPR compliant label or SDS.

Lithium Battery Labels

Q. When does the 12 mm UN number height requirement start?

A. The IATA 59th edition states the UN number height should be 12 mm. Since IATA 59th edition becomes mandatory on January 1, 2018, the UN height change is effective then. Keep in mind however that IATA defines “should” as a recommendation, it is not mandatory.

Q. I have a question on the red slash marks all the way around the label – what is the requirement on that?

  • Do they have to be so many of the red slash marks? – is there a specific Continue Reading…
IATA
IATA Significant Changes to the 59th Edition

2018 IATA DGR Significant Changes

It’s that time of year, the IATA Dangerous Goods Regulations are released. This year marks the 59th Edition which includes the following significant changes:

  • Limitation have been adopted on the number of portable electronic devices (PED) and the number of spare batteries that may be carried by passengers or crew members.
  • Many operator variations have been added, changed, or deleted.
  • The classification sections now include all substances and articles in Class 9.
  • Several special provisions have been added, changed, or deleted.
  • There are new restrictions on packing lithium batteries (surprise, surprise).
  • Several packing instructions have been added, changed, or deleted.
  • The Lithium Battery label now has a recommended UN number height of 12mm.
  • Changes have been made to Appendix B, D, E, and F.

A new appendix has been added – Appendix I. This new Appendix provides details of what to expect in 2019. These changes are based on the changes arising from the UN model regulations, and agreed to by the ICAO panel.

Some of these changes include:

  • Replacement of the word “risk” with the word “hazard”.
  • Changes to the provisions for classification of corrosive substances. These changes will better align the classification with the GHS Subcommittee (or GHS recommendations).
  • A new requirement to make available the test data for Lithium Batteries (UN38.3 test).
  • New UN numbers: UN3537 and 3538, which are for Continue Reading…