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…

Airplane Icon
My Suitcase is Following Me! Can I Take it on the Airplane?

luggage at an airport

Smart Luggage: Regulations and Technology

In the world of dangerous goods regulations, frequent changes are the norm. These changes may happen for a variety of reasons. With technology constantly moving forward at a fast pace, the dangerous goods regulations often times have to update accordingly. Within the last 40 years or so, we have been introduced to a variety of new products that contain lithium-ion batteries. From laptops to smartphones, the introduction of these products into society has caused dangerous goods regulators to be in a constant foot race to keep up with the newest lithium battery powered electronics. The newest craze we see in the electronic world is the introduction of battery powered smart luggage.

What is smart luggage?

If you have ever watched The Jetsons, When George arrives at work in the introduction, his car folds down into a briefcase for him to carry inside. 

While smart luggage isn’t exactly what George Jetson used, they do have many amazing features. Built-in features in smart luggage include GPS locators, weight scales that prevent over-packing, USB ports to charge your devices, and remote lock systems. Smart luggage is a game-changer in the travel industry, as they can help you navigate the airport and let you know where it is if it did not follow you to your destination. They even have the ability to follow you around the airport like a robot, which I’m Continue Reading…

Danger Placard
DG on the Other Side of the World

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What’s wrong with these photos?

Well, nothing, if you consider where it was taken (a remote town in Thailand).

Even while on vacation, someone in the Dangerous Goods field is always on the lookout for dangerous goods in their environment. I know when I first joined ICC, I never noticed placards on trucks, but soon after it seemed like they were on every transport that passed by. Those blessed to be in our line of work have a heightened awareness for the dangers around us.

As we all know, regulations concerning dangerous goods differ around the globe. As much as we would like to think the regulations are harmonized, they’re really not. Enforcement is the same. There are only so many inspectors available compared to the number of shipments each day.

One has to wonder what training these workers have. Where are the transport labels, the Hazcom labels, and the blocking and bracing?

I feel a lot more comfortable knowing that shipments of gases in the US and Canada will be properly secured when transported, and they will always have proper labels. Regulations are in place for one reason, and that is to protect workers and the community.

ICC is your source for products, services, and training – all under one roof. Call us today.

Regulatory Helpdesk: December 25

Lithium Batteries & Hazard Communication

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Due to the Holiday week, we have only 2 FAQ’s worth sharing.

Check back weekly, the helpdesk rarely hears the same question twice.

More Lithium Batteries

Q. We want to ship a 63 W-hr lithium ion battery.  Are there any issues with packaging 2 or more together in the same container under IATA 2018 and 49CFR?  If 2 or more are ok what is the limit?
A. Under IATA you have 2 options and it will be up to you as the shipper to make the decision as to how to handle your shipment. As you know the 65 w-h battery falls into the excepted type. Now, for IATA that puts you in either Section II or Section IB. By the way, be sure to grab the recently published Addendum!

For Section II batteries there is a change for this year. As per usual, there are several changes to the operator regulations. Also, these batteries cannot be packed in the same outer packaging as any other dangerous goods. 

The rest of the section still applies in PI 965. You are not allowed to offer more than 1 package prepared under Section II in any single consignment or shipment.

If you are using an overpack, you can only have one package of these batteries in the overpack. The overpack cannot 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

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 same 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…

Single Packaging
UN Specification Packaging Mystery

UN Specification Packaging Mystery

We Got a Mystery to Solve

One of my favorite childhood shows was “Scooby-Doo, Where Are You?”. How he and his group of friends could solve all those crazy hauntings and monsters always amazed me. Nothing made me happier than when the culprit was discovered and he uttered the words, “If it weren’t for you pesky kids, I would have gotten away with it.” After all I was only a kid and catching the bad guys was a big deal.

Occasionally during a training class odd questions or little mysteries arise. In those times I can feel like Thelma from my childhood show tracking down the clues and getting an answer. Here is one from one mystery from a recent training. It came about after our discussion on United Nations (UN) Specification Packaging. We had just finished reviewing all the parts of the packaging codes and discussing the manufacturer’s packing instructions as they apply to 49 CFR – US ground regulations. This lead to talking about their actual facility. Below is a picture of a box they have on site for use. They wanted to know if it was in compliance.

Ah, a mystery I can solve.

UN Specification Packaging Mystery 2

In case you didn’t catch why they asked about this particular box and compliance, take a look at the FOUR package specification codes on the box. For most boxes, there is only one code derived from the 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.

Lithium Battery Label Hash Marks

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

Shipping by Road
UN3363 Dangerous Goods in Machinery or Apparatus

Red semi truck on highway

When Can I Use UN3363?

What does one do when there is device or piece of equipment (“apparatus” or “machinery”) that is not intended to consign dangerous goods or hazmat (DG) specifically, but requires a certain quantity as part of its function or as a residue from earlier use or testing?

Many consignors can take advantage of UN3363, Dangerous Goods in Machinery (or Dangerous Goods in Apparatus), Class 9 – with (depending on the mode) a potential relaxation of packaging, marking, and documentation requirements.

Restrictions

There are basic conditions that must be met, however, to use this entry. Restrictions on using this entry exist in special provisions (SP) or packaging requirements in national and modal regulations.

Function – Not “Deus EX Machina”

This term is derived from the classical theatre world- but could represent an effort to use a “loophole” or take advantage of an unintended provision – for a discussion of the term see:
https://en.wikipedia.org/wiki/Deus_ex_machina

The apparatus or machinery’s primary function cannot be to “deliver” the DG in question. That is the item must have a purpose other than solely to act as a container to get the DG to the destination; and it must not be intended that the DG is discharged from the item.

Exclusions – Wisdom Begins in Calling Things by Their Proper Name

… with apologies to Confucius

Any article which has an appropriate UN number/shipping name already assigned must be shipped Continue Reading…