ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 11

Segregating Flammable Gas and Explosives, WHMIS/OSHA Labeling, Lithium Batteries, Orientation Marks, and Net vs Gross

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.

WHMIS/OSHA labeling

Q. Is a WHMIS 2015 compliant label going to be compliant within OSHA HazCom2012?
A. Maybe. While both the Canadian and US version of the GHS are very similar there are some differences in phrases used in regards to precautionary phrases. Also, WHMIS 2015 has the additional possibility of classifying something as a biohazard that is not found in the US standard. The best course of action would be for ICC to review your label for compliance within the 2 regulations.

Segregating Flammable Gas and Explosives (TDG)

Q. Is it okay to ship a class 2.1 dangerous good with a class 1.4 explosive in the same box shipping ground in Canada?
A. While the TDG and TP14850 do not have a segregation table, TP14850 12.89 states that Dangerous goods must not be offered for transport together with other dangerous goods or non-dangerous goods in the same container or overpack if the combining of those goods could:

  1. result in an evolution of heat or gas, or produce a corrosive effect or the formation of unstable substances that could endanger the integrity of the package or overpack; or
  2. cause a discharge, emission or escape of the dangerous goods from the container or overpack that could constitute a danger to public safety.

With that being said, the segregation table located at 49 CFR §177.848 says that class 1.4 explosives and 2.1 materials are not allowed to be shipped in the same package together due to the fact that the table lists an “O” which means these materials may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that, in the event of leakage from packages under conditions normally incident to transportation, commingling of hazardous materials would not occur.

Net vs Gross Weight (IMO)

Q.What is the difference between Net Weight and Gross Weight when filling out an IMO declaration?
A. The Net Weight is referring to the total weight of the dangerous goods alone, and Gross Weight is referring to the total weight of the dangerous goods along with the packaging together.

Orientation Mark

Q. For the orientation mark and label is the line underneath the arrows required?
A. While there is nothing in any of the transport regulations outlining that specific part of the mark and label, the 49 CFR, IATA, and IMDG do have it shown in their representation figure of it.

Lithium Batteries (IATA)

Q. I am trying to ship some lithium metal cells by air. Each cell has a lithium content of 0.22 grams. I am putting 800 of these in a box. The total weight of the cells in the box is 10.6 kg. Which part of Packing Instruction 968 am I’m supposed to use?
A. At 0.22 grams of lithium in the cell this would fall into Section II of the packing instruction. However, because the net quantity weight is 10.6 you have exceeded the limits allowed in Table 968-II. That net weight also pushes you beyond the limits for a Section IB as listed in Table 968-IB. Your only option if you must ship all 800 cells in one package is to ship them as fully regulated following Section 1A. This means you will now need UN Specification Packaging rated to performance level II as well.

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2 thoughts on “Regulatory Helpdesk: June 11

  1. Regulatory Help Desk:
    I have a question regarding IATA Packing Instruction 967 page 617 Section II. I am shipping 10 identical boxes containing a lithium ion battery installed in equipment (UN 3481) having a watt hour rating less than 100Wh. The PI Section II states that each package must be marked with the lithium battery mark unless the consignments consists of two packages or less where each package contains no more than two batteries installed in equipment.

    Do each the ten packages need to be marked with the lithium battery mark as there is only one lithium ion battery installed in the equipment in each box?

    Thank you,
    Richard J. Lloyd
    dickchar@rcn.ocm

    1. Hi Richard!

      Thank you for your question.

      It will depend on the type of batteries inside your equipment. This particular part of Packing Instruction 967 says, “The application of the lithium battery mark does not apply to: packages containing only button cell batteries installed in equipment or consignments [shipments] of 2 packages or less where each package contains no more than 4 cells or 2 batteries installed in the equipment.

      If your equipment has only button cells installed in the equipment, then you are not required to use the mark.

      If your packages contain other than button cells, you will be required to mark all of them. This is because you have 10 packages in your consignment (shipment).

      All the best,
      -ICC Regulatory Team

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