This was the plastic drum used for shipping UN1760, PG II product.
I received a call from one of our clients to assist them with a rejected shipment. They are air certified but they don’t ship via air that often; hence, why they had some issues and needed our expertise. For the folks that ship air regularly, we all know that if you don’t cross your “t” and dot your “i” it won’t go and it can be frustrating for those shipping via air infrequently.
1H2 or 1H1?
The shipment consisted of 2 plastic pails which was dropped to our location by the carrier as directed by our client. First thing I look for is if the pails are UN standardized and yes, they were. Based on the quantity limit per package, it had to go cargo aircraft only and must follow packing instruction 855. Looked at PI 855 and sure enough a “1H2” is not permitted to be used as a single packaging. Our client mainly ships ground and this pail is acceptable for ground shipping but since it’s going via air and it’s PG II, it must be a closed head drum, a 1H1.
Yes, it’s very frustrating. Called our client back and advised him it can’t go the way it’s currently packaged. Must be transferred into a 1H1 or another closed head single Continue Reading…
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 Battery Label (Ion/Metal)
Q: On the old lithium battery handling label, can I use an Avery address label for the words ion and/or metal?
A: What you propose is not the best option for lithium battery label. However, if it is your only option, then you most definitely will need to cover the Avery label with strong, clear packaging tape. Regular old scotch tape won’t do as it won’t stand up to the durability requirements.
Adding an SDS to Your Shipment
Q: Do I have to put the SDS on each one of my hazmat boxes?
A: Technically, an SDS is not required to be attached to any packages. Your carrier may request this though. If the SDS is being used as the “written emergency response information” required under 49 CFR and the US variation in IATA, then it should be with the shipping papers/declaration and not on the packages.
How Many Lithium Batteries Can Go in a Box?
Q: I have 4 pieces of equipment that are being shipped. Each has its own lithium metal battery inside a plastic bag. So, this is UN 3091 packed with equipment. The lithium content on each battery is 0.28 grams and Continue Reading…
Sometimes I feel behind in the regulatory world. It is just a fact that regulations often change faster than one has time to process. A good case for this is California’s Proposition 65. Not only are there multiple changes for how to represent substances that are on the list, but the list itself changed in May 2018. For more information on “how to represent” and the August 30, 2018 changeover date, take a look at ICC’s blog found here
To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Prop 65. The list has to be revised and republished at least once per year. California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for Prop 65 implementation. They consider adding chemicals to the list when some other “authoritative body” makes a determination regarding a substance’s ability to cause cancer, birth defects or other reproductive harm. Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity and Chemical Abstracts Service Registry Number (CAS).
Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.
In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX‐81 (PK-NGAL, PK-NGALC).
The clear tape required for closure of this packaging has changed from 3M #305 48mm wide clear tape to 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.
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.
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…
What do you do when your shipment involves two air carriers, but they are not interline?
It is common for one shipment to travel with multiple air carriers; however, almost all are interline which means they will coordinate and transfer shipments among themselves without issues. It helps when there is a freight forwarder involved who will take on this task for us, as we would expect them to take on all the coordination of a shipment. In some cases when the shipper is doing it all themselves, it can be challenging … like last week.
Let Me Set the Scene
The shipper is in Vancouver, BC and is shipping a variety of products (DG and non-DG) to 2 different communities in Northern Canada. They decided to do the logistics themselves. Since they don’t have air certification they asked for our repackaging services for the DG. The DG included some compressed cylinders, batteries, and life saving appliances. All commodities are acceptable for air transport. There would be 3 pallets leaving from Vancouver; 2 pallets are destined for one community and 1 pallet is destined for another community.
Here is the Issue
All 3 pallets are going to Ottawa, ON first. From there 2 of the pallets are going to one community and 1 pallet to another. All 3 pallets are going on Air Canada from Vancouver to Ottawa, from Ottawa the pallets Continue Reading…
Safety Data Sheets (SDSs) have been an important tool for worker safety for decades. In Canada, they became mandatory for hazardous materials in 1988, and although their basic format has been modified by WHMIS 2015 (the Workplace Hazardous Materials Information System 2015), one constant has always been a heading for “emergency telephone number.”
This brings up the question of what number should be on the SDS. Yes, it’s possible to run the emergency number internally, but most companies don’t use this solution. First, if you’re using it for transportation purposes, the law requires that the number be staffed 24 hours a day. Even if you have staff to do that, they must be trained to give effective advice over the telephone. That can be a difficult job, and requires professionals with both technical knowledge and the ability to remain calm in emergencies. Therefore, most companies these days outsource this function to specialist services.
Having a direct line to a live, knowledgeable person can be a true lifesaver in an emergency. Early in my training days, a customer told how he’d been given the job, late at night, of cleaning out a tank of chemicals by siphoning them into a waste container. In those days, safety standards were sometimes lax, and he was taught to start the siphon by mouth. Unfortunately, he was distracted during the procedure and ended Continue Reading…
In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX-21CA (PK-MT-134 and PK-MT136) and BX-5G (PK-GKF32, PK-GKF16, and PK-GKF8).
The clear tape required for closure of the BX-5G and BX-21CA packaging has changed from 3M #305 48mm wide clear tape to 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.
The BX-21CA maximum gross weight is changing from 12.4KG to 12.7KG
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 Compliance Center constantly evaluates our courses to be sure they are the most up-to-date with current versions of the regulations. Our Regulatory Team works hard to make sure the information we get you is complete and correct. In that regard, I am in the process of revising and updating our course on shipping reduced amounts of materials. It will focus on the options outlined in the US 49 CFR and the IATA regulation. We are talking about a focused course on the topics of small quantities, excepted quantities, limited quantities and consumer commodities.
During the course of the update, I came across an odd word in regards to drums under the Excepted Quantities exception. It was one not familiar to me at all even after 10 years of being in the “business.” Of course, my first thought was to look in the definitions or glossary section of the regulations. It wasn’t there. Then I tried to Google it. No luck. At this point, it was time to reach out to the Team. Sure enough, within minutes there was the answer and even where I could find it for future reference.
What was the word? It was the word “chime.” In both 49 CFR and IATA for Excepted Quantities is the package test requirement that must be met for drums. It says that when the package is in the shape of Continue Reading…