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.
Q. Section 188.8.131.52.1 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 of the letters must now be “not less than 65 mm” unless the portable tank has a capacity of “not more than” 3000 Liters.
Generic Shipping Names
Q. In the TDGR, how do you know to use a chemical name when you have an NOS? In the USA there is a G beside the entry in the table.
A. In the TDGR the technical name is required when Special provision 16 applies (under column 5 in Schedule 1). Also, in the IMDG the technical name is required by Special Provision 274 and in IATA it is required when the symbol of the star appears beside the shipping name in the list of DG. All 4 regulations do it a bit differently. In addition, keep in mind that not all N.O.S. have a technical name.
Using an Overpack
Q. My air carrier’s checker said that my overpack type (e.g. boxes) needs to be indicated on the Shipper’s Declaration, not just the type of package (e.g. multiwall paper bag) within. Does IATA require this?
A. No. IATA DGR 184.108.40.206.2 “Step 7” makes no mention of a requirement to list the type of overpack (e.g. box, master carton, stretch-wrapped skid, etc.)- only the type of packages within the overpack.
See also illustrations- Fig. 8.1J-8.1L, etc. in the 58th IATA DGR – different types of inners without describing the type of overpack used.