Regulatory Helpdesk: March 5

Batteries, 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.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…
Why You Need the Most Updated Regulatory Texts

The Bible, Shakespeare and Transport Regulations

“Woe is me” is a phrase heard by many. It basically means someone is unhappy or distressed. The Bible uses this phrase in several locations including Job 10:15, Isaiah 6:5 and Psalms 120:5. Shakespeare later used this same expression when writing for his tragic character Ophelia in “Hamlet”. Existing and operating in the world of regulations can also bring on this feeling. It is difficult enough learning the basics of any regulation, but to truly “know” it takes time, patience and work. This process is complicated by the fact that many regulations change. Is it really necessary to have the newest, latest regulation? To answer that question it is time to look to the regulations.

International Air Transport Association (IATA):

For many, these are the Air Regulations. In this instance, the regulation is updated YEARLY. A new edition goes into effect on January 1st of any given year and ends on December 31st of that same year. The Regulation is currently on its 56th Edition. To showcase some of the changes that could apply to a variety of shippers, please read the following:

  1. The List of Dangerous Goods has new entries and/or updates to existing substances
  2. Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
  3. Section 7 – Marking and Labeling for Limited Quantities has new information

Continue Reading…

IATA Posts Addendum II to 55th Edition

IATA has released the second addendum to the IATA Dangerous Goods Regulations 55th Edition.

Click here to view the PDF.

IATA Posts Addendum I to 55th Edition

pdf Addendum I to the 55th Edition (PDF) download

In keeping with past practice, IATA has issued a late year 2013 (December 26) Addendum I to the 55th Edition of the DGR, in effect January 1, 2014.

Some significant changes in the DGR include:

  • Section 3.9.2.6 conditional extension of shipping lithium batteries tested according to Rev. 3 of UN s.38.3
  • Section 1.4.3.1 regarding passenger awareness is now mandatory (“must” replaces “should”)
  • SP A807 excludes hay, straw or (UN1327) from regulation if it’s dry & uncontaminated
  • PI-101, 562, 953, 965, and 968 have had revisions for content and editorial changes – e.g.

    (Note that the page reference in Addendum I regarding PI-953 should read “page 546…”!)

  • Section 7.1.5.5 clarifies the use of ground/sea Limited Quantity marks in relation to the LQ requirements of IATA
  • Colour requirements are modified for 5.1 (removes “black-on-red” option) and 5.2 (permits black-on-red” option for upper flame portion) labels

In addition there are so some editorial changes (e.g. correcting the reference to Package Use Markings- 7.1.4.1 found in various packaging instructions and sections 10.7.1.3.1 & 2; options for locating “IB” on the Shipper’s Declaration – Section 8.1.6.9.

There are also changes to State and Operator variations as reviewed below.

FedEx to extend edit checking software requirement:

One of the most significant changes for non-US shippers will be the elimination of FX-12 and the simultaneous extension of FX-18 to shipments originating anywhere. As of May 1, 2014 Continue Reading…

Changes for IATA & IMDG Code for 2013

Based on the information available to date, the following are some of the changes that will be in the 2013 editions of the IATA Dangerous Goods Regulations and the IMDG Code.

  • lithium ion batteries > 100 Wh but < 160 Wh may be carried as spare batteries in carry-on baggage
  • portable electronic devices containing batteries should be in carry-on baggage and be protected to prevent short circuits
  • medical devices or equipment that contains or may contain infectious substances are not subject to the regulations provided that the item is packed so that there will not be any leakage
  • packages containing medical devices or equipment must be marked “Used Medical Device” or “Used Medical Equipment”
  • lithium cells and batteries must be of a type proved to meet the UN Manual of Tests and Criteria
  • dangerous goods list additions:
    • UN3496 batteries, nickel metal hydride
    • UN3497 krill meal
    • UN3498 iodine monochloride, liquid
    • UN3499 capacitor
    • UN3500 chemical under pressure, n.o.s.
    • UN3501 chemical under pressure, flammable, n.o.s.
    • UN3502 chemical under pressure, toxic, n.o.s.
    • UN3503 chemical under pressure, corrosive, n.o.s.
    • UN3504 chemical under pressure, flammable, toxic, n.o.s.
    • UN3505 chemical under pressure, flammable, corrosive, n.o.s.
    • UN3506 mercury contained in manufactured articles
  • dangerous goods list deletions:
    • UN3492 toxic by inhalation liquid, corrosive, flammable, n.o.s.
    • UN3493 toxic by inhalation liquid, corrosive, flammable, n.o.s.
  • the excepted quantity code for the various silanes has changed to E0
  • special provision 240 applies to vehicles powered by batteries, such as, scooters, e-bikes, wheelchairs, etc. Hybrid vehicles must be consigned under one Continue Reading…
Ready or not…

As we approach the start of another new year, we also approach the start of new regulatory requirements. Both the IATA Dangerous Goods Regulations and the IMDG Code have new editions for 2011. The IATA regulations go into effect on January 1, while the IMDG Code has a 1 year transition period before becoming mandatory. If you ship using either of these regulations, you must ask yourself “Am I ready?”

IATA has made significant changes for 2011, and as a regulatory specialist, I am expecting A LOT of panicked phone calls from shippers (and carriers) who were unaware of the changes. In addition to the typical minor changes that happen on a yearly basis, IATA has completely revamped the limited quantity requirements as well as the packing instructions in section 5. The limited quantity requirements even have a new section number assigned to them. I can’t even begin to imagine how much confusion there is going to be with the new packing instructions!

The IMDG Code changes are not as drastic as IATA’s, but that doesn’t mean there won’t be questions. The limited quantity changes have made their way into the IMDG Code, so people who deal with those shipments are going to have to brush up on both regulations.

If you haven’t already checked out the new regulations, make sure that you do so as soon as possible. And don’t Continue Reading…

Must vs. May

In the regulatory world, things are not always as clear as they seem at first glance. One example of this is the use of the words must, may, shall and should. They seem pretty straightforward, but if interpreted incorrectly, they could lead you down the road of non-compliance, or leave you scrambling to comply with something that is not actually required.

Let’s imagine we are shipping an urgent package containing a sample of a virus that is included in division 6.2. We are shipping it by air according to the IATA Dangerous Goods Regulations. We have packaged the sample according to the regulations but when we go to label the package, we find that someone used the last label on the roll. We go hunting around the office to see if we can find more labels. The only 6.2 labels we can find are some that look similar to the ones we have always used, but they are not exactly the same. The labels that we normally use have text referring to notification to the public health authority in case of damage printed in the center. The labels we just found don’t have the text. Can we use them? Let’s see what the regulations say…

Section 7.3.15 of IATA shows a 6.2 label without the text. Below the picture of the label it states: "The Continue Reading…