PHMSA Amendment HM-259

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule on October 18th. As you know, the only way to amend or change Title 49 for Transportation in the Code of Federal Regulations is through a rule making process. This particular docket number is HM–259. Its goal is to “align the U.S. Hazardous Materials Regulations with current international standards for the air transportation of hazardous materials”. It has an effective date of October 18, 2018. While the published rule is 23 pages long, I have attempted to hit the highlights here.  If you wish to read the entire final rule with the discussion on comments received, you can go to https://www.phmsa.dot.gov/regulations-fr/rulemaking/2018-22114.

Highlights of HM-259

  • 172.101 – Removal of A3 and A6 from Column 7 for multiple entries in the HMT. Provision A3 will be removed from all Packing Group I entries. Provision A6 will be removed from all liquid entries to which it is assigned.
  • 172.102 – A3 revised and now reads as follows: “For combination packagings, if glass inner packagings (including ampoules) are used, they must be packed with absorbent material in tightly closed rigid and leakproof receptacles before packing in outer packagings.” There is no longer a mention of using “tightly closed metal receptacles”.
  • 175.10(a)(18)(i) – Revised portable electronic devices by passengers and crew. This section has been expanded to include portable medical electronic devices with lithium metal Continue Reading…
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FedEx DROPS “V-PACK” REQUIREMENT

IATA DGR 2019 and FX-02

IATA SIGNIFICANT CHANGES

In keeping with the standard practice of alerting users to modifications in the new edition of the Dangerous Goods Regulations (DGR) for air transport, the list of Significant Changes and Amendments to the 60th Edition (2019) were released several months ago, and are incorporated into the recently published copies of the DGR.

An overview of these changes was the subject of blogs issued by ICC on August 28th and September 26th of this year.

Typically changes in the State and Operator Variations, in s. 2.8, are not outlined in specific detail in the Significant Changes document, but are referenced as a general reminder. This contrasts with amendments issued between publications which illustrate the actual details of changes.

Which leads us to FX-02…

FX-02 DROPS “V” RATED PACKAGING

A rather significant operator variation in s. 2.8.4 of the IATA DGR was the common application of FX-02 (f) to liquids in specified classes. This limitation, which existed as FX-17 prior to the 57th Ed., required shippers to use the heavy duty UN-standard “V-Pack” (“variation” commonly noted by UN code 4GV) package even though it wasn’t mandated by the Packing Instruction (PI) or other provisions of the DGR.

The limitation was invoked when FedEx customers were choosing to ship under the “International Economy” or “International Freight Economy” designations. Not only was it required in place of PI-required UN standardized Continue Reading…

Repacking Dangerous Goods
Authorization column in the shipper’s declaration
Shipping by Air Declaration form authorization column

Almost always the authorization column in the shipper’s declaration is left blank, but when you need to add something in there, you must add it in there. Section 8.6.1.9.4 of the IATA Regulations provides when and what to add when required. Now sometimes we forget to read the “notes” in the Regulations.

Here’s my story

A customer called in first thing Monday morning to get help on shipping an engine. It was an urgent shipment, and he had to get it out ASAP. I said, “No problem. We can help.” It’s what we do. It was going via air, and since it was a domestic shipment he can drop the shipment off to the airline directly for it to leave later that day.

Packaging for an engine

Engines vary in size, clearly. I asked our customer if his engine was packaged, and he said no, but it was strapped on a wooden pallet with 2×4 lumber on corners of the pallet for support. So, I asked him to email me a picture to understand what he meant by that. The picture showed the engine was visible, and the corners with the lumber in upright position did not affect the identification of the engine. I told our customer that all he needed was the shipper’s declaration. We created the declaration, he picked up the colored copies from our office and dropped Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 1

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.

Placarding Bulk Truckloads

Q. My truck has 4000kgs of drums of Class 3 UN1993 in it. Truck has Class 3 UN1993 placard on it . We pick up 1 empty tote (IBC) which is Class 3 UN1993 also. Can we keep the same placard on the truck or do we need to add Class 3 only? Same with empty drums. We just need to add primary CLASS card? All transported via ground within Canada.
A.Well the drums don’t need UN numbered placards since drums are considered small means of containment. A plain class 3 placard will do to represent the drums. It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently. Totes, even empty with residue, requires UN numbered placards for liquids in direct contact with the means of containment. You don’t need to add plain class 3 placard for the drums as both the drum and tote content is hazard class 3. So technically the truck displayed the correct placard (UN1993). If the drums were empty and less than 500kg gross mass then no placard will be required; however, if you Continue Reading…
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IATA Electronic Dangerous Goods Declaration INFr8 (eDGD)
Unloading an airplane

Another Step in the Digital Direction

For the most part, the dangerous goods world is one of the few industries that still relies heavily on using paper documentations, specifically when it comes to shipping declarations. In one of my previous blogs, we talked about DG AutoCheck which is simply a system IATA unveiled that digitally checks the compliance of a shipper’s declarations by simply uploading or scanning the paperwork into the system. As a part of IATA’s e-freight initiative, the digital process is being taken one step further with the implementation the INFr8 (eDGD) digital system.

What is INFr8 (eDGD)?

Unlike DG Auto Check which is intended for use by airlines, ground handlers, and freight forwarders, this digital platform is intended to include shippers as well to digitally create and send electronic Dangerous Goods Declarations (eDGD) through the entire air cargo supply chain. The dangerous goods process has traditionally been paper-based due to the lack of digital standards. The eDGD validation module ensures that the information on the shipper’s declaration is correct against IATA regulations and the specific airline’s requirements as well. Currently, airlines can only begin checking the documentation after handover. Thanks to the new electronic system, errors in accompanying documentation can be detected and ironed out before the airline even receives the shipment. This means documentation errors can be detected and eliminated at an early stage, reducing Continue Reading…

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Significant Changes and Amendments to the 60th Edition Published

Airplane in Flight

Change is in the Air – IATA DGR 2019

In keeping with past practice, IATA (International Air Transport Association) has released the summary of significant changes to the IATA Dangerous Goods Regulations (DGR) that will appear in the upcoming 60th Edition effective in January 2019.

This useful summary appears in the “Introduction” section of the IATA DGR and allows users to check for items that may affect their procedures that have changed since the previous edition. There are a variety of changes highlighted that comprise revisions to existing provisions, addition of new items and deletions. While some changes are based on updates to the United Nations Recommendations for model regulations (UN Model), typically adopted in other modal regulations, some are specific to the IATA DGR.

Get your copy of the IATA from ICC.

General UN Updates

There are some editorial changes that relate to the clarification of terminology regarding “risk” versus “hazard”. This mainly affects the designation of subsidiary classifications which will now be referred to as “subsidiary hazards”. This is more logical and conforms to protocols in safety and considers “hazard” as the danger inherent to a substance; compared to “risk” as an indication of the possibility/probability of harm from the danger.

Other UN Model-based changes include adding UN numbers, qualifying ammonium nitrate fertilizer classification, adding additional provisions for classification/packaging group assignment for corrosives and expansion of classification of articles Continue Reading…

Lithium
How Can a Laptop Bring down an Airplane?

Airplane in Flight

Cell Phone Fire Aboard Airplane

If you have seen the news, recently a cellphone aboard an airplane caught fire before take-off, leading to an evacuation (FOX News).

When I first saw this story, I was grateful that this event took place before the airplane took off and they were able to get everyone off of the airplane safely. But a few questions arose, what if it happened in the air, and what if it happened to a laptop computer in cargo?  Well, regulators had previously believed that a flame-retardant gas required in airliner cargo holds would be able to suppress any type of single lithium battery fire. This gas, called halon is a liquefied, compressed gas that can stop the spread of fire by chemically disrupting its combustion.

However, recent tests conducted by the Federal Aviation Administration found the halon gas suppression systems can’t put out a battery fire once it combines with other highly flammable material, such as the gas in an aerosol can or cosmetics. The potential dangerous combination can cause flames to spread, overwhelming the fire suppression systems in airplane cargo holds, meaning it is possible under the right circumstances that a single laptop battery could catch fire and cause an airliner to crash. The possibility is such a concern that the Air Line Pilots Association (ALPA), the biggest pilot union in North America, is now thinking Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: July 30

IBC Residue, Choosing Placards, IATA Special Provisions, and Hazard Class Label Size

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. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Residue in IBCs (TDG)

Q. Under TDG, do Intermediate Bulk Containers (IBCs) such as tote tanks that contain residues still have to be transported as dangerous goods? Should the placards remain or be removed?
A. Under TDG, packagings or containers that still contain enough residue to pose a hazard during transportation should still be treated as dangerous goods. Unfortunately, the regulations do not give a specific way of judging this, so they should be considered hazardous unless you are absolutely sure they are not. (There is some misinformation that you may come across about how to make this decision. TDG does not specify “triple-rinsing” as a standard for cleaning or declare that an inch or less of residue can be considered non-dangerous. These references may come from other regulations or industry guidelines, but do not apply to TDG.)

So, if your IBC contains a dangerous residue, it should be clearly identified as such for transportation. If it was originally placarded or labelled correctly, just leave those Continue Reading…

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National Aviation Day – Aug 19th

Celebrate the History and Development of Aviation

Airplanes are a great way to reach far away locations. This wouldn’t be possible without Wilbur and Orville Wright’s first powered flight in Kitty Hawk, North Carolina in 1903. To honor this great accomplishment President Franklin Roosevelt declared August 19th as National Aviation Day in the United States. Many use this day to honor other pioneers in aviation and space exploration. It also happens to be Orville Wright’s birthday.

National Aviation Day can be celebrated in any number of ways. Schools dedicate lessons to air travel. Discussions focused on the Wright brothers, Amelia Earhart or Charles Lindbergh and their accomplishments is another. People interested can explore the history of the National Aeronautics and Space Administration (NASA) which started as the National Advisory Committee for Aeronautics (NACA). Visits to museums that have dedicated exhibits to aviation and aeronautics are another possibility. Build a model airplane. If you are stuck in an office, make a paper airplane and fly it around the office during your next break or lunch.

You could also take advantage of our pre-sale for the 60th edition of the IATA. This new version goes into effect on January 1, 2019. While that sounds far away from August 2018, it bears thinking about now. This 60th edition will incorporate the changes from Revision 20 of the UN Recommendations on the Transportation of Continue Reading…

OSHA Labeling
Can you ship DG and non-DG Together in One Package?

Can you ship DG and non-DG Together in One Package?

Surprisingly this is pretty common. Normally the answer is, “Sure.”

However, that’s not always the case. Sometimes a dangerous goods commodity can react with a non-dangerous goods commodity. I do come across this type of situation occasionally.

Shipping from Canada to USA via Air

Earlier this week a client dropped off 2 different product samples going to USA via air transport. He provided the SDS for both products, one was DG and the other not. He asked if both samples can go together in one package. I told him, “Maybe.” Without consulting the SDSs and gathering more information I couldn’t be sure. If they are compatible, then I can package them together.

I used to work in the carrier industry so I know it’s better to consolidate than to have a multiple piece shipment. Most times all the pieces will arrive together, but there is a chance they may not. So for me, personally, I prefer to minimize the number of packages, which means using a bigger box if I need to.

Determining Compatibility

So back to this. I checked the SDS for both and the one that was DG was a corrosive material.

The non-DG product requires a more thorough read-through to see which material this material was incompatible with and in Section 10: Stability and Reactivity it said incompatible with oxidizing materials Continue Reading…