ICC Compliance Center
Looking Forward to 2019

At the start of each new year lots of things are said about changes to make in order for the next year to be better. Many make resolutions about losing weight or getting healthy. Others decide to be nicer to people, spend more time with family or volunteer. It doesn’t mean the previous year was bad, but things can always get better. Let’s look at this from a regulatory compliance point of view, and see if things will be better in 2019.

Changes to Regulations:

Starting January 1, 2019 there is a new version of the IATA Dangerous Goods Regulations. You must now be using the 60th edition. Luckily, IATA does a great job of giving advanced notice about what is changing late in 2018 so people can start to prepare before the new version takes effect. You can see the list of “significant” changes here. The IMDG Code was also updated for 2019. The new version is the 39-18 Amendment. You are allowed to use the 39-18 starting in January 2019, but the older 38-16 version is still viable for the rest of this year. Again, a summary of the changes for that regulation was published as well. You can find them here. The US ground regulations of 49 CFR had a few amendments throughout 2018, and there is a large one looming for 2019. To stay up-to-date Continue Reading…

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 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…

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…