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…

Lithium Battery
Lithium Button Cell Air Exemptions

Cargo loading on aircraft

IATA DGR PI 967 & PI 970 Confusion

The wording in recent, current and upcoming editions of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) has some potential to confuse the regulated community, especially regarding shipping lithium batteries.

Exemptions Restricted or Not?

The paragraph providing an exemption from the lithium battery mark (pka “Handling Label”) is found in the last sentence of the second paragraph in Section II “Additional Requirements”, for the packing instructions (PI) for both UN3091 and UN3481 “contained in…” lithium battery entries:

This requirement does not apply to:

  • packages containing only button cell batteries installed in equipment (including circuit boards); XXX
  • consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.

The “XXX” is the key that led to this discussion.

2016 as the Baseline:

In the IATA DGR 57th (2016) Edition, both PI 967 and PI 970 (“contained in equipment”, ion and metal respectively), the “XXX” in each case read “or”.

In other words, whereas cells/batteries other than button cells were limited to 2 packages per consignment, the number of packages per consignment were not limited when there were only button cells (of course, the maximum net battery weight per package restrictions in Table II of each PI must also be met).

Looking Forward to 2017?

Things then look as though they’re changing when reading the Appendix H (Intended Changes for Continue Reading…

Regulatory Helpdesk: November 20, 2017

Top 5 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.

Overpacks

Q. My shipment was refused even though I followed what the regulations and my training said for shipping an overpack. My drums were on a pallet and shrink wrapped. All of the information on the drums could be seen. I placed a sticker with the words “Overpack Used” on the shrink wrap and listed it that way on my paperwork. Can you tell me why my carrier refused it?

A. Per Section 7.1.7 the actual wording that must be used on your pallet is just the word “overpack”. It seems confusing to have different terminology used but that is how the regulations work and why you should be trained every 2 years for IATA.

Using Combustible Liquid, N.O.S. (USA)

Q. Since this product meets the combustible definition, can we use ‘NA1993 Combustible Liquids, n.o.s.’ to ship to Canada or does Canada only recognize the ‘UN1993 Flammable Liquids, n.o.s.’?

A. Basically, to me, she is asking what is the difference between NA1993 and UN1993 and how it impacts transporting into Canada. NA1993 is a US only identification number. It is used for transporting combustible liquids in the US.  Technically, a combustible liquid is NOT 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: November 13, 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 Label Size Requirements

Q. Is there were size requirements for WHMIS labels?

A. No, the HPR does not mandate a size requirement other than saying it has to be legible. But, what does legible mean? As a general rule of thumb, which we have developed from reviewing many different labeling regulations is 10 mm for one side of the pictogram, and 2 mm for the font size (1.6 mm for a worst-case scenario).

IATA Special Provision

Q. What does  IATA’s Special Provision A191 mean?

A. It was determined that SP A191 means if you have a manufactured article with less than 5 kg of mercury in it (like a thermometer) then you don’t need the Class 6.1 label for mercury’s subsidiary hazard and you don’t have to list the 6.1 subsidiary hazard on the shipper’s declaration.   From what we can tell that only applies to UN3506 which is Mercury contained in manufactured articles.

Quantity Limits – TDG (Canada)

Q: What does the quantity limit in TDG Columns 8 & 9 represent in terms of Passenger conveyance restrictions- package, consignment, …?

A: Good point which many find confusing. The answer is in the often-overlooked Continue Reading…

Repacking Dangerous Goods
When the Finished Package Resembles Christmas Lights

A lot of Labels!

A Lot of Labels

It’s not often that you’ll see more than 2 hazard labels on a DG package, but the one I did this week had 5 hazard labels plus 3 handling labels. So a total of 8 labels on a package. Yes, that is a lot.

I received a panic call from a freight forwarder who picked up a rejected package from a passenger airline and didn’t know what to do with it. It was a rush shipment to get to Australia. I asked him what was being shipped and he said, “a fire extinguisher and some cans of glue”. I advised him to bring the package and all accompanying documents over to our office and I will get it packaged up properly for air transport. He showed up an hour later.

This is what the box looked like when it came in:

A lot of labels 2

I reviewed the shipper’s declaration which the shipper did complete and the markings/labels on the box and it was incorrect for numerous reasons. I told the freight forwarder that the person who prepared this shipment is not certified to ship via air. An air certified individual may make an error or two, but not 10. It was evident this person did not know what they were doing. I asked for the MSDS/SDS for the products. The fire extinguisher was obvious, but there were 4 small Continue Reading…

Birthday truck
Happy Birthday DOT!

Truck Driving on highway at sunset

Happy 50th Birthday DOT!

Birthdays are important milestones and should be celebrated. One important one for parents is a baby’s first birthday. This is often followed by apprehension when a child reaches their teenage years. Many people in the United States enjoy turning 21 because that means alcohol is legal for us to consume. After that there are the “round” birthdays – those dreaded ones that have a zero after them. You know, turning 30, 40, 50, etc. We also celebrate the birth of nations. In the US it is every July 4th. For Canada the celebration is on July 1st. Many religions celebrate birthdays too. Christmas in the Christian faith is the birth of Jesus. Buddhists celebrate Buddha’s birthday on the 8th day of the 4th month in the Chinese lunar calendar.  Companies also follow this same practice. In fact, ICC Compliance Center just turned 30 last month.

What does all of this birthday talk have to do with the transport of hazardous materials? January 12, 1966 saw then President Lyndon B. Johnson declare in his State of the Union address his plans to create a Department of Transportation (DOT). It was on April 1, 1967 the DOT was open for business. Think about that for a moment. That means in the 1940s when the first atomic bomb was created, there were no regulations around the transport of Class 7 radioactive materials. Other materials such Continue Reading…

ICC Trade Shows and Events
Speaking at DGAC Summit in DC

Trade Shows and Events

DGAC Summit 2017

One of the highlights of the year, at least for those of us involved in dangerous goods regulations, is the annual summit meeting of the Dangerous Goods Advisory Council (DGAC). This year, it was held in Crystal City, just outside of Washington, DC, and as always had many speakers from both government and industry. Of course ICC attended, and I was graciously invited to give a couple of talks on the Canadian Transportation of Dangerous Goods (TDG) Regulations, and to take part in a fun closing activity known as “speed-dating the regulators”.

Speakers

The introductory talk was given by Brigham McCown, former deputy administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA). As a longtime political insider, he discussed the state of the department under the new administration, and how the once “sleepy little agency” was moving forward. He identified top trends in transportation such as infrastructure investment, autonomous (self-driving) vehicles, drones, and of course reducing unnecessary regulatory burden while still ensuring public safety. He mentioned that the new Secretary of Transportation, Elaine Chao, was experienced and would help the department adapt.

Other speakers representing PHMSA included Shane Kelly, who provided an overview of upcoming changes to hazardous materials regulations, and a report on the United Nations Transport of Dangerous Goods Sub‐Committee by Steven Webb, Aaron Wiener, and Lindsey Constantino. Amy Parker of the U.S. Coast Continue Reading…

Single Packaging
Change Notice: BX-30CA

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-30CA (PK-N2QTC/N2QTCA)

  1. 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.

Click here to view our packing instructions and certificate downloads »

If you have any questions or concerns, please contact our customer relations center in the US at 888‐442‐9628 or in Canada at 888‐977‐4834.

Thank you,
Michael S. Zendano
Packaging Specialist

Repacking Dangerous Goods
Shipping Funky Looking Fire Extinguishers

Shipping aircraft fire extinguishers

Aircraft Fire Extinguishers

Have you ever seen an aircraft fire extinguisher? If not, they don’t look anything like a regular fire extinguisher. For most of us when someone says, “fire extinguisher”, we imagine some kind of red cylinder with a pin, nozzle, and trigger. But an aircraft fire extinguisher looks like a ball with antennas sticking out. That’s why I call them “funky looking fire extinguishers”.

I was asked if I can assist with shipping out an aircraft fire extinguisher via air for a client. Absolutely I can. The client dropped off the fire extinguisher which was wrapped in bubble wrap. As per the SDS it was classified as UN1956 but for those with equivalency certificates/special permits it can be classified as UN1044. Now since these funky fire extinguishers don’t exactly have the surface area to place the markings and labels, I used a strong tag to affix the label and markings as per Section 7.2.6.1 (d) of the IATA Regulations. I wrapped the fire extinguisher in more bubble wrap in such a way to prevent any accidental activation during transport. I used a strong outer packaging and filled the void space with packing peanuts. Placed all the labels and markings on the outside of the package and send it out the same day with FedEx. The package arrived at its destination nice and early at Continue Reading…