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…

Airplane Icon
IATA Lithium Battery Update for January 1, 2019
AA sized lithium battery cells

Welcome to the ever-changing world of transporting lithium batteries. It feels like just yesterday we were discussing the introduction of the new Class 9 hazard label dedicated to just batteries and the new handling “mark”. Would you believe that started at the end of 2016? In an attempt to clarify things, here is the first of several blogs dedicated to one of the new versions of a transport regulation. The focus will be what changed in regards to lithium batteries for that mode. My first choice, only because it is my favorite regulation, is the 60th edition of the International Air Transport Association or IATA as many of us know it. By the way, ICC will be hosting a training on lithium batteries on January 24th and 25th. Call us today to get registered today.

Listed below are the specific sections, paragraphs, packing instructions and the like that had changes for lithium cells and batteries. If you aren’t overly familiar with shipping batteries, what is below can be a bit overwhelming. You can access our “cheat sheet” for required labels by ground, ocean, and air.

IATA 60th Edition Changes for Batteries:

  • New classification criteria – As part of 3.9.2.6.1 there are 2 new paragraphs around the classification of lithium batteries. One paragraph talks about “hybrid” batteries, which are those that contain both ion and metal while the other is about Continue Reading…
Airplane Icon
FedEx DROPS “V-PACK” REQUIREMENT

IATA DGR 2019 and FX-02

IATA SIGNIFICANT CHANGES

In keeping with the standard practice of alerting users to modifications in the new edition of the Dangerous Goods Regulations (DGR) for air transport, the list of Significant Changes and Amendments to the 60th Edition (2019) were released several months ago, and are incorporated into the recently published copies of the DGR.

An overview of these changes was the subject of blogs issued by ICC on August 28th and September 26th of this year.

Typically changes in the State and Operator Variations, in s. 2.8, are not outlined in specific detail in the Significant Changes document, but are referenced as a general reminder. This contrasts with amendments issued between publications which illustrate the actual details of changes.

Which leads us to FX-02…

FX-02 DROPS “V” RATED PACKAGING

A rather significant operator variation in s. 2.8.4 of the IATA DGR was the common application of FX-02 (f) to liquids in specified classes. This limitation, which existed as FX-17 prior to the 57th Ed., required shippers to use the heavy duty UN-standard “V-Pack” (“variation” commonly noted by UN code 4GV) package even though it wasn’t mandated by the Packing Instruction (PI) or other provisions of the DGR.

The limitation was invoked when FedEx customers were choosing to ship under the “International Economy” or “International Freight Economy” designations. Not only was it required in place of PI-required UN standardized Continue Reading…

Repacking Dangerous Goods
Authorization column in the shipper’s declaration
Shipping by Air Declaration form authorization column

Almost always the authorization column in the shipper’s declaration is left blank, but when you need to add something in there, you must add it in there. Section 8.6.1.9.4 of the IATA Regulations provides when and what to add when required. Now sometimes we forget to read the “notes” in the Regulations.

Here’s my story

A customer called in first thing Monday morning to get help on shipping an engine. It was an urgent shipment, and he had to get it out ASAP. I said, “No problem. We can help.” It’s what we do. It was going via air, and since it was a domestic shipment he can drop the shipment off to the airline directly for it to leave later that day.

Packaging for an engine

Engines vary in size, clearly. I asked our customer if his engine was packaged, and he said no, but it was strapped on a wooden pallet with 2×4 lumber on corners of the pallet for support. So, I asked him to email me a picture to understand what he meant by that. The picture showed the engine was visible, and the corners with the lumber in upright position did not affect the identification of the engine. I told our customer that all he needed was the shipper’s declaration. We created the declaration, he picked up the colored copies from our office and dropped Continue Reading…

IATA
IATA Creates Digital System – DG AutoCheck

Cargo loading on aircraft

IATA is Going Digital with DG AutoCheck

When receiving inbound calls at our regulatory help desk, one of the most popular inquiries involves filling out various types of paperwork when shipping dangerous goods.

If you are looking to ship dangerous goods by air, you could now be facing a different type of compliance check involving your shipper’s declaration in the near future. The International Air Transport Association (IATA) unveiled a digital product allowing air cargo providers an easier way to verify that a shipper tendering dangerous goods has met the industry’s standards for transporting hazardous goods. Their new product is called Dangerous Goods AutoCheck (DG AutoCheck).

What is this new Digital Product?

This new Dangerous Goods Auto Check system is designed as a digital means of checking the compliance of goods designated under the Shipper’s Declaration. This tool will allow direct receipt of electronic consignment data and will automatically check the information contained in the Shipper’s Declaration against the relevant language in the IATA regulations governing the handling and transport of the goods.

Simply scan or upload the dangerous goods declaration into the tablet-based tool. That’s it!

-IATA’s Webiste

The tool will simplify a ground handler’s or airline’s decision to accept or reject a shipment during the physical inspection stage by providing a visual representation of the package with the correct marking and labelling required for transport based on the information electronically provided Continue Reading…

Toxic
The Zika Virus — Public Health Crisis and Regulatory Puzzle

Zika virus – the name itself sounds exotic and dangerous. It is believed to be a serious risk for pregnant women. And it’s due to arrive in North America. Just how great a danger is this virus, and how should research and medical facilities prepare for the regulatory burden?

First of all, Zika is not a new virus. It has been known since the 1950s in equatorial Africa and Asia, but only recently has it appeared to migrate to new territories, including South and Central America, the Caribbean and Mexico. It is primarily a mosquito-borne illness, transmitted by the Aedes genus of mosquitos. Possibly climate change has increased the populations of these mosquitos in the areas where Zika is spreading. Aedes mosquitos are found in some parts of the U.S., and although they are not currently believed to be in Canada, they may spread as the climate warms. Person-to-person transmission by body fluids is possible, but this would be relatively rare compared to the mosquito vector.

Zika is classed in the Flaviviridae family of viruses, along with dengue fever, West Nile virus and the notoriously dangerous yellow fever. However, compared to these, Zika is usually a mild affliction. According to the Centers for Disease Control (CDC), only one in five persons infected with the virus shows any symptoms at all. For those who do fall ill, the symptoms Continue Reading…

Lithium
Back to the Future – Interim ICAO/IATA 2016 Lithium Battery Changes

In addition to changes documented in the IATA 2016 (57th Edition) DGR, and the anticipated 2017 changes outlined in Appendix H (“Impending Changes” to ICAO Technical Instructions), recent incidents with lithium batteries and lithium battery-powered small vehicles (e.g. “Solowheels”, hoverboards, mini-“Segway”, etc.) have caused regulators to re-examine changes and deadlines.

Specifically ICAO intends to require that, in 2016 (date to be confirmed, April 1 proposed):

  1. Lithium ion cells and batteries (UN3480, PI 965) must only be offered for transport when their “state of charge” (SoC) does not exceed 30 % of the rated capacity, as determined by the UN Manual of Tests & Criteria (Section I cells/batteries are only allowed to exceed 30% if the States of Origin & Operator approve in writing).
  2. Not more than 1 package prepared under Section II of PI 965 (UN3480) or PI 968 (UN3090) may be placed in an overpack
  3. Overpacks prepared as above must have both the lithium caution label and “overpack” mark visible.
  4. Packages prepared as above must be offered separately from other cargo and not be loaded into a unit load device (ULD) before being offered to the carrier.

These are interim measures while performance-based standards are developed for lithium batteries; and until changes to UN3481 andUN3091 (packed with/in equipment) take effect in 2017. Some or all of these interim measures may be retained in the future editions of Continue Reading…

Overpack Label
“OVERPACK” Markings – Overdone?

The Issue

The formalization of the overpack concept into the Canadian TDG regulations has been the subject of concern for domestic shippers of dangerous goods due to the wording for fully regulated (TDGR 4.10.1) products. The wording implies that even when the DG safety marks for packages within the overpack are visible, the overpack must still have an “OVERPACK” mark displayed. This leads to some additional labelling requirements, particularly for shippers of stretch-wrapped pallet loads.

Definition

We’ll pause to review the concept of an overpack, consistent among the various regulations (e.g. TDG, UN Model Recommendations, IMDG, IATA, & 49 CFR).
An overpack is non-standardized packaging that:

  1. Is used for handling convenience (e.g. to reduce multiple handling- I.e. 4 drums on a skid, allowing loading 4 at once rather than 4 trips, or 6 small containers in a “non-spec” master carton, or 48 small boxes stretch wrapped on a skid; a keg (small drum) in a non-spec box for stability, etc. )
  2. Cannot be used as a replacement for inadequate, required “standardized” packaging
  3. Is to be unopened between consignor and receiver
  4. Cannot interfere with the integrity of the standardized packaging (e.g. banding cutting into boxes on a pallet)

The common principle requires that the description of DG that cannot be seen once the overpack is in place will be reproduced on the outside of the overpack.

However, this could be misleading in that Continue Reading…

Danger Placard
Remembering Placards

Mnemonic Devices

How do you remember the meaning of something? Do you try to KISS it where KISS stands for – Keep It Simple Silly? Do you use mnemonics from elementary school and even through college to trigger your memory? I do, and boy how they make things easier. I bet you can remember ROY G BIV, the colors of the rainbow from art class. Music class they gave us easy ways to remember the treble clef with Every Good Boy Does Fine for the lines on the staff and FACE for the spaces. One of my favorites however, is PEMDAS to help remember the order of operations in math!

I am always looking for a fun way to help reinforce my memory. In the hazardous transportation industry there are so many things to remember or define. Oh and the acronyms!

What is a Placard?

Let’s take a look at placards. What is a placard? As defined in the Merriam – Webster dictionary a placard is defined as:

a large notice or sign put up in a public place or carried by people

Placards provide pertinent information about an area, a specific instruction, or a hazard. Placards are used in work places to communicate to people of special operating procedures. Placards are also used in transportation to warn of hazards that are present in a truck on the road, in a rail 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…