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…
Regulatory Helpdesk: December 11, 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.

UN Numbers on Explosive Placards

Q.Can the UN number be added to a class 1.4 placard shipping UN0323 ground in the U.S?

A. 49 CFR 172.334(a) States no person may display an identification number on Explosives 1.2, 1.2, 1.3, 1.4, 1.5, or 1.6. In this case 0323 is classified as a 1.4, So it cannot display the ID number.

IMDG Corrigenda

Q. Section 5.3.2.0.1 has changed with the Dec 2017 Corrigenda to the IMDG. Why would you need to put a proper shipping name on a CTU when a placard is all that is really required?

A. First of all that section speaks specifically to 3 situations where information beyond a placard is required. The 3rd one really doesn’t exist anymore, but the first 2 do. The first is when you have a TANK cargo transport unit. Tanks as defined in Section 1.2 are those that are portable tanks, road tank-vehicles like gasoline highway trucks, and rail tank-wagons which are those rounded rail cars that you see. The second is when you have bulk containers. For either of these situations a placard is needed as well as the PSN. Given the corrigenda the height Continue Reading…

Regulatory Helpdesk: December 4, 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.

IMDG Editions

Q. What edition of the IMDG should I be using?

A. The customer would still need the 38th edition to get him through all of next year. The new 39th edition will be published at the end of 2018 but it can’t be used at all until Jan 1, 2019. Even then the 38th is still a viable option.

IMDG Transition Timeline
IMDG Transition Timeline

Placement of the Consignor’s Certification Statement

Q. Can the Consignor’s certification appear on a second page or on the back of the shipping document?

A. Yes, if there is no other non-DG information intervening when using the phrase in TDGR 3.6.1(1)(a). This phrase requires that the certification appear below the information specified in 3.5. The Transport Canada FAQ page indicates that the “consignor’s certification may appear on the back of the shipping document as long as it is after the information required under Section 3.5“.

Limited Quantities Under IMDG

Q. Can limited quantity provisions be used to ship under the IMDG Code?

A. Yes, but you should have IMDG Code training or consider a re-packing service if you are not trained, since the requirements are not the Continue Reading…

Regulatory Helpdesk: November 6, 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.

Equivalent Exemption (Canada & US)

Q. What is the  US “equivalent” to TDGR Part 1 Special Case 1.33?

A. The reference is found in 49 CFR§173.150. Essentially the US says that, with conditions, a low risk flammable liquid may be “reclassified” as a combustible liquid; & combustible liquids may be exempted when in non-bulk packaging. Before using the exemption, also check the following:

  1. Verify that the actual ingredients don’t trigger the (US only) “RQ” requirement to classify as “hazardous substance” or “marine pollutant” designation which will negate the exemption under (f)(2).
  2. Verify that there is no subsidiary hazard class which would negate the exemption (US (f)(1) & TDG 1.33(a)).

Organic Peroxide Shipped by Ocean

Q. Can you confirm the packing group for UN3104 with Dibenzoyl Peroxide for IMDG?

A. UN3104 is Organic Peroxide Type C, solid. This is a class 5.2 material that does not have a packing group. However, Chapter 2.5 should be reviewed as well as Packing Instruction P520 and packing methods OP6.

A Spill Involving a Limited Quantity

Q. If I have a product being shipped in Limited Quantity, it’s not considered as being dangerous any more? So if there is Continue Reading…

Regulatory Helpdesk: October 9, 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.

#4. Why is My Product X when it should be Y? (USA)

Q. Why is my product listed as a Flammable Liquid Category 4, when the product is combustible?

A. Under OSHA Hazcom 2012, a product that has a flashpoint >140°F and <199.4°F is considered a Flammable Liquid Category 4.

This is illustrated in the table below:

Table B.6.1: Criteria for flammable liquids

Table B.6.1: Criteria for flammable liquids
Category Criteria
1 Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F)
2 Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)
3 Flash point ≥ 23°C (73.4°F) and ≤ 60°C (140°F)
4 Flash point > 60°C (140°F) and ≤ 93°C (199.4°F)

Once you have the classification, then you can apply the label phrases. The Flammable Liquid Category 4 hazard statement is Combustible Liquid. This is outlined in the table below.

C.4.19 Flammable Liquids (Continued)
(Classified in Accordance with Appendix B.6)
Hazard Category Signal Word Hazard Statement
4 Warning Combustible Liquid

 


#3. Does my Class 6 placard need to show Class 6.1? (International)

Q. I have a customer who is saying that it is the regulation to have the 6.1 on the bottom of the placard … and not just the 6 in order to ship overseas. Is Continue Reading…