Carrier Variations, WHMIS vs. OSHA, Placarding, Lithium Batteries and More Lithium Batteries
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. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.
- Q. Can you help me understand what I did wrong or how to respond to them?
DHL is the carrier for my product. It is UN3077 and it is packaged 25 kg per fiberboard box. They sent me the following comments regarding my shipment.
They told me the country of USA must be a part of my address on the shipper’s declaration. They also said I had to use PI 956 even though it is marked and labeled as a limited quantity shipment. Finally, they told me I had to include the place and title on the shipper’s declaration.
- A. First of all, carriers can ask for things beyond what is in the regulations. Sadly, you must comply with their requests if you want your shipment to proceed. Having said that there are a few things about your points that I can provide some regulatory framework for should you choose to push the issue with them. As to the country of USA being required, the IATA regulations never specifically state that you have to include the country.
It only says in §184.108.40.206 and §220.127.116.11 to “enter the full name and address of the shipper“. For the packing instruction, I believe they are incorrect. Limited Quantity shipments under IATA must meet the maximum net quantity per package amounts listed in column H of the blue pages. For UN3077 that means 30 kg G which translates to 30 kilograms GROSS weight is allowed as an LQ.
You say you had 8 boxes of 25 kg. My guess is the gross weight with the inner packagings, the outer box and material all together would not hit the 30 kg GROSS weight. This means you have a LQ shipment and the PI is Y956. Technically, the place is no longer needed on a shipper’s declaration per Note 1 under §18.104.22.168. That note says, “The place of signing the declaration is optional and may be left blank.” Again, carriers can request odd things so this is probably one of them.
When Do I Need to Use UN Numbered Placards?
- Q. My shipment going by US ground has some Class 8 and Class 3 materials in it with multiple UN numbers. Each hazard class is packaged in either fiberboard boxes or IBCs. The IBCs are placarded appropriately with the UN number and hazard class placard. For the placards on the outside of the truck given to the driver, do they need UN numbers?
- A. Because you have a mixed load of UN numbers for each hazard class it is not feasible to try and list each UN number on the hazard class placard for each class. Each placard is only designed to hold 1 UN number. You should use “generic” hazard class placards for the driver.
WHMIS 2015 vs. OSHA Hazcom Labeling
- Q. Is a WHMIS 2015 compliant label going to be compliant within OSHA HazCom 2012?
- 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.
Lithium Batteries Packaging
- Q. What do I need to package lithium batteries?
- A. Well that depends on a number of factors. Mode of transport, how you plan to ship the batteries (as only batteries, contained or packed with), and carrier variations if going by air. Determine the mode of transport then go to that regulation to determine packaging requirements. And yes, they do vary with air being the most stringent.
Lithium Battery Marks
- Q. We’re shipping ten identical packages containing equipment, each piece of equipment containing a lithium-ion battery (UN3481). The batteries each have a watt-hour rating less than 100 Wh. Do each of the ten packages need to be marked with the lithium battery handling mark, seeing as there is only one lithium ion battery installed per piece of equipment, and only one piece of equipment in each package?
- A. It depends on the mode of transport. If you’re shipping by ground under TDG or 49 CFR, you will not require a lithium-ion battery handling mark when packages contain no more than two exempted lithium batteries per package. (See TDG Special Provision 34(c)(4) and 49 CFR §173.185(c)(3).)
However, if you’re shipping by air, Packing Instruction 967 will only extend this provision to two packages per shipment. In this case, when there are ten packages, they would require the lithium battery handling mark, and a notation on the Air Waybill as follows: “Lithium ion batteries in compliance with Section II of PI967”.