ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 25

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.

Carrier Variations

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 §8.1.6.1 and §8.1.6.2 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 §8.1.6.14. 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. In this case, you will need to display placards for both hazard classes. You cannot use a “DANGEROUS” placard instead of the Class 3 and Class 8 placards, since the provisions for these placards only address non-bulk packagings (see 49 CFR 173.504(b)). In addition, you’ll need to display the identification numbers for each different type of hazardous material on the outside of the vehicle, as per 49 CFR section 172.331(c). Let’s say you had two flammable liquids (UN1993 and UN1090), and one corrosive (UN1805).

You can display the “1805” on a white rectangle in the center of the Class 8 placards. For the two flammable liquids, you can either (1) put up two Class 3 placards per side, each displaying a different identification number in the center, or (2) put up one Class 3 placard per side, containing one identification number in the center, and put the other identification number beside the Class 3 placard on an orange panel. If you have additional non-bulk Class 3 or Class 8 material in the same shipment, you will not require additional Class 3 or Class 8 placards.

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”.

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2 thoughts on “Regulatory Helpdesk: June 25

  1. I don’t agree with the response to the question about placards with UN numbers.
    IBC’s are bulk packaging therefore my understanding is that UN Numbers unique to each must be displayed on both ends and both sides of the transport unit. This can be accomplished by affixing as many different UN numbered placards as needed or or by affixing the appropriate class placard with separate orange panels indicating UN numbers.
    No additional placards are required for the material that is packaged in non-bulk containers if it is of the same hazard class as that contained in any of the IBC’s.
    The appropriate placards and markings must be affixed to the transport unit prior to loading the hazardous material.

    1. Hello Roger,

      Thank you for the response. Our team has looked over the original question and we have updated the article with a more encompassing answer.

      In this case, you will need to display placards for both hazard classes. You cannot use a “DANGEROUS” placard instead of the Class 3 and Class 8 placards, since the provisions for these placards only address non-bulk packagings (see 49 CFR 173.504(b)). In addition, you’ll need to display the identification numbers for each different type of hazardous material on the outside of the vehicle, as per 49 CFR section 172.331(c). Let’s say you had two flammable liquids (UN1993 and UN1090), and one corrosive (UN1805). You can display the “1805” on a white rectangle in the center of the Class 8 placards. For the two flammable liquids, you can either (1) put up two Class 3 placards per side, each displaying a different identification number in the center, or (2) put up one Class 3 placard per side, containing one identification number in the center, and put the other identification number beside the Class 3 placard on an orange panel. If you have additional non-bulk Class 3 or Class 8 material in the same shipment, you will not require additional Class 3 or Class 8 placards.

      Thanks again,
      -ICC Regulatory Team

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