ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 2

How to determine if a product is regulated, SAPT on a SDS, Shipping a drone, and using a UN package

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.

Is my product regulated?

Q. I have 2 products I distribute to various stores to sell. The SDS files say my product is not regulated under DOT and TDG in Section 14. Since this is sold as a consumer product, doesn’t that mean it is regulated for IATA should I ship it via air? (the SDS were emailed to me)
A. Nothing in your SDS files leads me to believe either one would meet any of the 9 hazard classes in IATA. This is further confirmed by neither SDS classifying the products for DOT and TDG. Basically, what you have are containers of non-regulated liquids.  There is no need for UN Specification packaging or paperwork for IATA or any other transport regulation.

SAPT on my SDS

A. Since the addition of UN numbers for polymerizing substances, we’ve been told we must include the Self-Accelerated Polymerization Temperature (SAPT) on our SDS documents in Section 9. Is this a new requirement?
Q. There is no requirement in OSHA HazCom 2012 to include that particular data point in Section 9. All of the Continue Reading…
dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
How to Document Weights on DG/HazMat Transport Paperwork

Dangerous goods and hazmat forms

IATA, IMO, 49 CFR, & TDG Documentation

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.

Definitions:

Package
The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
Packaging
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…
Square on point with x marked out
Symbols in Transportation Regulations

Symbols in the IATA, IMDG, and 49 CFR

Solving the Mystery of the Regulation Symbols

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.

Here are some of the common symbols you could see with their meanings. Also included is where in each regulation you can find further information. By the way, have you purchased the March 2018 version of 49 CFR?

Symbols in IATA and IMDG:

  1. ■ The square: This symbol tells us new material has been added to the regulation or edition.
  2. ▲ 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.
  3. ∅ 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.
  4. ☛ The pointing finger: Here is a symbol found only in IATA. It signifies this section or statement is more Continue Reading…
Regulatory Helpdesk: February 12

Lithium Batteries, Placards, and SDS in the Workplace

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.

Lithium Batteries (Air)

Q. For PI 967 in IATA is the weight limit the weight of the equipment and battery inside of it or just the battery.
A. For all battery packing instructions in IATA it is always the weight of the battery itself.

Lithium Batteries (IMDG)

Q. Do “excepted” batteries require segregation from limited quantity packages under IMDG?
A. Under IMDG §3.4.4.2 it tells you that segregation requirements in Chapters 7.2 – 7.7 plus any information on Stowage in column 16b of the table do not apply to goods in limited quantity packages. Lithium ion batteries do not yet need segregation under IMDG either. It is only IATA that has implemented segregation this year as part of the packing instructions for shippers. IATA has also added batteries to the segregation table for operators, but it isn’t mandatory until next year and only applies to those in Section 1A and 1B not Section II.

Placards (TDG)

Q. Customer asked if his Class 8 material (UN 1830) needed to have a UN number on the placard if shipping 1 liter per package and 7 per tote for a total of 17 Liters for the shipment in Canada. Continue Reading…
IMDG
How Do You Ship Bullets? (IMO)

shipping bullets by ocean

What to do when you are moving and need to ship a whole lot of bullets?

98% of our repackaging clientele are businesses, but there are 2% of our clientele that are regular people. At least, this is how I refer to them. These folks are a “Mr. or Mrs. Smith” who have absolutely no idea about the dangerous goods world, but what they wish to send is considered dangerous goods. These folks are referred to us from carriers, freight forwarders, and sometimes by internet search results.

Recently I had a Mr. Smith call us to ask about packaging cartridges as recommended by his freight forwarder. He is moving to Europe and is packing up his entire house, which includes his firearms and the cartridges that go with them. He already had all his ducks in a row meaning his export/import documentation and certification for the firearms and whatever else was needed to ship the firearms and cartridges, but he needed to get the cartridges packaged up for transport. That’s where ICC comes in.

What Are We Really Dealing With?

Mr. Smith didn’t have any transport information such as UN number or shipping name. So, I asked him to email me pictures of the cartridges, because he mentioned they were all in their original retail packages. I was able to call the manufacturer directly and ask for the shipping info. Continue Reading…

Regulatory Helpdesk: January 15, 2018

Here are the top 4 questions last week:

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.

Worded Label Requirements

Q. Are worded labels required for use in US transport?
A. Based on 172.405(a), except where prescribed, wording is optional on US hazard class labels.

Placement of UN Number, Shipping Name and Hazard Class Label

Q. Can you put the “ISH” information (shipping name, UN number and hazard label) on the top of a package (e.g. box)?
A. That depends. Different regulations express it differently, but the key message is that the information must be easily located and read; and with few exceptions in proximity to each other on the same surface of the package. All common regulations (49 CFR, Canadian TDGR, IATA DGR, IMDG Code) have a general requirement for legibility.

49 CFR requires the information to be clearly visible on a surface other than the bottom [172.304(f) and 172.304(a)(i)]- so the top could be allowed if the configuration resulted in it being clearly visible.

IATA DGR and the IMDG Code do not specify top/bottom but only require the information to be “readily visible” [IATA 7.2.6.1(a); IMDG 5.2.1.2.1, 5.2.2,1.6].

TDGR, however, is a little more prescriptive- requiring the information to be “on any side … other than the side on Continue Reading…

Regulatory Helpdesk: January 8, 2018

3 Questions from our Regulatory Helpdesk

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.

Disclosing Concentration Ranges Under WHMIS 2015

Q. Do I have to indicate “Proprietary” on a WHMIS (M)SDS when masking actual concentrations with ranges?
A. It depends. WHMIS 1988 accepted the use of concentration ranges on MSDS to mask confidential business information (CBI) without requiring any indication.

WHMIS 2015 does not currently allow the use of ranges other than the concentration range actually present for a variable substance (also, unlike WHMIS 1988, ranges cannot be used to allow a single SDS for a series of different but similar products).

Products subject to an approved masking under the HMIR Act do have to, in both versions, reference the exemption authorization on the (M)SDS.

A CBI amendment under consideration may re-introduce the permissible use of ranges to unilaterally mask actual concentrations. This proposal as currently written requires a statement in the SDS when a range is used that’s wider than the actual concentration range, to protect CBI. We’ll have to wait for the final amendment to answer the question going forward …

IMDG or TDG?

Q. Does a shipment within Canada by vessel from Newfoundland require placarding according to the IMDG Code or do the provisions of the TDGR Continue Reading…
Lithium Battery
Lithium Battery Placarding and Segregation

Lithium Batteries, Laptop battery

Lithium Battery Segregation

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…

Regulatory Helpdesk: January 1, 2018

3 Questions from our Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Check back weekly, the helpdesk rarely hears the same question twice.

Location of the To/From Address

Q: Can the name and address of the shipper and/or receiver be on top of packages of hazardous materials?
A: For 49 CFR only 1 address is needed and for air you would need both. Ocean doesn’t specifically mention addresses but we tend to include one since most carriers are going to ask for it. None of the regulations actually state where they MUST go. In some of our older trainings it was indicated that the addresses had to be near the name and number. I’ve tried to correct that.

  • For Air – Section 7.1.4.1(b) – both addresses “located on the same surface of the package near the proper shipping name mark, if the package dimensions are adequate
  • 49 CFR – Only one address is required per 172.301(d)
  • IMDG – There are no set guidelines for including addresses in Section 5.

New Segregation of Lithium Batteries

Q: Do lithium batteries have to be segregated?
A: It depends on the mode of transport.

In 49 CFR and IMDG 38-16, there are no segregation requirements for batteries. There could be information on a batteries SDS that should be followed.

For Air, in the new 59th edition of IATA or as some call it the 2018 version, there is some Continue Reading…

IMDG Logo
All Transport Regulations Updated – Even IMDG

IMDG Code Updates

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:

  1. 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.
  2. The words “marking” and “markings” have all been replaced with “mark” or “marks” through the entire code.
  3. Several chapters in the regulation have been renumbered such as the subheadings under 5.1.1, 7.8.6 and 7.8.7.
  4. Packing Instruction P002 has a change to Special Packing Provision PP11 to include 5H1, 5L1 and 5M1 bags.
  5. 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.
  6. 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.
  7. The new Class 9 Hazard Label for Lithium Batteries also received some clarification in Chapter 5.2.2.2.1.3 in that the number of vertical stripes Continue Reading…