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 It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently.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…
United Nations Logo
2018 United Nations Regulatory Updates
Palais des Nations in Geneva

What’s New at the UN for Transport?

At this time of year all the regulatory updates start. Every time a notation comes across my desk or email I can’t help but think about a famous line in the movie “Sixteen Candles”. That particular line is “What’s happening hot stuff?” Click here to see the actual movie clip. One of these days, I want a presentation to start with this. It would sure break the ice on some rather detailed subject matter.

Having prepared you for thinking about what’s happening or changing, we have to start at the UN level specifically. Much of this information comes from a presentation by Duane Pfund at the Pipeline and Hazardous Materials Safety Administration. We need to focus on is what changed from the 2015 – 2016 biennium. That biennium gave us Revision 20 of the UN Model Recommendations for the Transport of Dangerous Goods. Revision 20 is what will drive the changes starting in January 2019.

What’s Happening or Changing for 2019?

  • Class 8 Corrosive Materials:
    • A new alternative method for classifying these mixtures is being introduced. It revolves around using the GHS Purple Book bridging principles and calculation methods. Note that flammable gases and explosives are on the list for this same concept in the current biennium.
  • Dangerous Goods in Articles:
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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…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 4

Variation packaging cushioning material, excepted quantity packaging, UN packaging testing, distributor deadlines for WHMIS 2015, Mexico GHS, and compatibility

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.

Variation Packaging (4GV) Cushioning Material

Q. Can I substitute a different cushioning material in a variation box?
A. In general: “No.” When a UN-standardized package is specified. The various regulations (49 CFR, IATA DGR, IMDG Code, and TDGR), or the standards referenced within them, restrict the user to assembling the package according to the manufacturer’s instructions. These instructions are based on the components used in the submitted test/design reports on which the approval is based. 49 CFR §178.601(g)(4)(iv) even goes to the point of specifically requiring the same type of cushioning as was used in the submission.

Excepted Quantity Packaging

Q. Is it always necessary for the shipper to have performance test results on packaging used to ship “excepted quantities”?
A. This depends on the mode or jurisdiction of transport. 49 CFR [§173.4a(f)], IATA DGR (§2.6.6) and IMDG Code (§3.5.3) all require that the shipper ensure that testing has been done and documented. This doesn’t need to be externally certified or approved. TDGR [§1.17.1(3)] does not require specific testing, only that packaging is “… designed, constructed, filled, Continue Reading…
Lithium
How to Ship Damaged or Defective Lithium Batteries

Swollen lithium polymer batteries. Dangerous and harmful electronic waste

Regular Damaged or Defective or Dangerous Damaged or Defective?

There is a fair amount of interest in the topic of preparing Damaged or Defective (DoD) lithium batteries for transport and how to make a determination of the degree of hazard they present.

The current (20th) 2017 Edition of the Recommendations on the Transport of Dangerous Goods (UN Model) Regulations have addressed the former (packaging for transport) aspect, but the documents currently posted have not yet established firm protocols for the latter.

The situations involving recalls of defective, unsafe batteries and incidents during transportation has sustained the efforts to find better ways of dealing with them. The topic has been under discussion at the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods (TDG) in most sessions over the last several years.

For this discussion we’ll refer to cells/batteries that do not meet the UN Manual of Test criteria due to damage or defect, without specific safety hazards, as “regular” DoD; and those that “are liable to disassemble rapidly, react dangerously, produce a flame or a dangerous evolution of heat, or produce a dangerous emission of toxic, corrosive or flammable gases or vapours” as “dangerous” DoD.

This distinction is proposed for clarification in the next version (21st Edition) of the UN Model. See, for example, working document ST/SG/AC.10C.3/2018/51:
http://www.unece.org/fileadmin/DAM/trans/doc/2018/dgac10c3/ST-SG-AC.10-C.3-2018-51e.pdf

Batteries or Reactive Substances?

As a technicality, we should pause to consider the basic Continue Reading…