dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
How to Document Weights on DG/HazMat Transport Paperwork

Dangerous goods and hazmat forms

IATA, IMO, 49 CFR, & TDG Documentation

No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.

Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.

Definitions:

Package
The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
Packaging
A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
Means of containment
(in TDG) a container or packaging or any part of a means of transport that is or may be used to contain goods.
Means of transport
(in TDG) a road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used Continue Reading…
Regulatory Helpdesk: March 12

Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork

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.

DG Documentation on Overpacks

Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.

Combustible Liquids

Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 Continue Reading…
Regulatory Helpdesk: February 19 & 26

Shipments to Puerto Rico, Non-hazardous substances, the Overpack label, and Aviation Regulated Liquids or Solids

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.

Shipping to Puerto Rico

Q.  If 49 CFR is used to make a vessel shipment of limited quantities from the mainland US to Puerto Rico is a shipping paper required? I’m asking because limited quantities don’t require shipping papers.

A. Technically that is true. Shipping papers are not needed for US GROUND shipments. You have to read the fine print in paragraph 173.150(b) which is the section on limited quantities for flammable and combustible liquids. It that paragraph it says, ” … is not subject to the shipping paper requirements of subpart C of part 172 of this subchapter, unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and transported by aircraft or vessel, and is eligible for the exceptions provided in §173.156 of this part“.

Non-hazardous substances under WHMIS 2015

Q.Customer called and asked if SDS’s were required for non-hazardous substances and where to find this in the WHMIS 2015 Regulations?

A.The answer to your question can be found below in WHMIS 2015, which states that safety data sheets only pertain to a hazardous product, therefore Continue Reading…

IATA
How Do You Ship an Engine? (IATA)

Diesel Engine Close Up

How should you provide quantity on a shipper’s declaration for an engine?

Generating a shipper’s declaration for an engine isn’t exactly new to me. I have been creating shipper’s declarations for engines since the very first time I stepped into the DG packaging world, and that was a long time ago. Therefore, it hit me pretty hard when a client’s shipment, containing an engine, was rejected by their air carrier.

Engines and UN Numbers

For many years the UN number for engines and vehicles were the same and it was classified as hazard class 9. Just recently it was changed so that each type of engine has their own UN number and hazard class. Therefore, internal combustion engines containing flammable liquid is classified as UN3528 and falls under hazard class 3.

My client said there was a small amount of diesel fuel inside (it wasn’t drained). Based on this I classified his engine as UN3528. He provided me with the completed shipment detail form which provided me with all the details of the shipment including net weight of the engine and the amount of fuel inside the engine.

Quantity of the Engine on the Shipper’s Declaration

I started to work on the shipper’s declaration and had to stop at the “Quantity and type of packing” section. There wasn’t an immediate measurement I could use for the engine. As per column “J” and Continue Reading…

Lithium
Lithium Batteries Section 1B & IATA Shipper’s Declaration

Lithium Batteries, Laptop battery

Lithium Batteries on IATA Shipper’s Declaration

One of my favorite cartoons growing up was “Scooby Doo”. Nothing made me laugh more than when Scooby would say, “Ruh roh, Raggy” when he was trying to say, “Uh oh, Shaggy”. This was usually in situations where things had gone terribly wrong. I had one of those moments recently and it was in regards to lithium batteries.

In one of my recent training classes, we were digging into the IATA Shipper’s Declaration and how to complete it. Anyone that handles these knows there are lots of things to include. As the discussion moved to the “Nature and Quantity of Goods” section, we were cruising. Everyone understood the process and how great IATA is about explaining what goes where. The examples in Chapter 8 are awesome!

The “Ruh roh” moment came as we were discussing the inclusion of the Packing Instruction number. Most of us are familiar with the first part of that step. It tells us that for all of our shipments, we add the number of the Packing Instruction we followed for said shipment. In Section 8.1.6.9.3 of IATA, it says the following:

Step 8. Number of Packing Instruction or Limited Quantity Packing Instruction (with its “Y” prefix) (Columns G, I or K). For lithium batteries prepared in accordance with Section IB of Packing Instruction 965 or Packing Instruction 968 the letters “IB” must be added Continue Reading…