Can someone ship hazardous materials/dangerous goods without using regulatory publications?
This is often a question we ask ourselves when assisting customers. There are so many if’s, and’s, and but’s in the regulations, it’s hard to imagine someone shipping hazardous products without them. The regulations are just large instruction manuals on how to safely ship dangerous materials. We often have customers call and question why their shipment was rejected. After listening to their story, we can usually find the answer right in the regulations. When we tell a customer why their shipment may have been rejected, customers normally see why having a copy of the current regulations is so important. Every company shipping hazardous materials/dangerous goods should have all the regulatory manuals for the modes of transportation which they ship.
“That’s how we have always done it.”
This is something we hear very often, actually.
Just because that’s how you have always done it doesn’t mean it is compliant. The regulations are updated often for a reason – to ensure safety for everyone involved with shipping hazardous materials/dangerous goods. Recently, many of the regulations have been updated to include new UN numbers. The new shipping names and UN numbers will affect the way that companies label and document these products. This could easily become a scenario where “we’ve always done it this way” may lead to penalties or fines.
As the start of a new year approaches, it’s time for parties, resolutions – and to check our dangerous goods/hazmat procedures, and see what’s changing. If you are a shipper of non-bulk packagings, one thing to watch out for is the new size limit for identification numbers that will be introduced in many regulations for 2014.
Identification numbers (which cover UN numbers, NA numbers and ID numbers) are the main way for packages to be identified as to their contents, in a format that does not depend on language. In the past, incidents have occurred because these numbers were marked on dangerous goods packages, but were not large enough to be seen easily. Therefore, the United Nations has, in the UN Recommendations for Dangerous Goods, established minimum size requirements.
The size minimums are:
- For packages with a capacity of 5 Litres or net mass of 5 kilograms or less, the size should be “an appropriate size,” based on the size of the container.
- For packages containing more than 5 Litres or kilograms, up to a maximum capacity of 30 Litres or net mass of 30 kilograms, the letters and numbers of the marking must be at least 6 millimeters (1/4 inch) tall.
- For packages exceeding 30 Litres capacity, or 30 kilograms net mass, the letters and numbers of the marking must be at least 12 millimeters (1/2 inch) tall.
These size minimums will Continue Reading…
Update to UN Number Minimum Height
Are my eyes getting better with age or did something change? Something changed.
New to the regulations this year is a statement regarding the size of text on labels for dangerous goods. Both IATA (Air) and IMDG (Marine) have made changes to reflect the UN Model Regulation that become mandatory as of January 1st, 2014. Please reference “UN Model Regulations: 17th Edition; Section 18.104.22.168 (Vol 2. pg. 139)”, “IATA: 54th Edition; Section: 22.214.171.124 – Size (pg. 619)” and “IMDG Code: 2012 Edition; Section: 126.96.36.199 (Vol 1. pg. 244)” to find the following information.
As of January 1, 2014, mandatory size for “UN number” and letters “UN”:
Some things to note:
- The way this is written is such that the UN number and letters “UN” MUST be at least the size specified above whereas other package markings SHOULD be that minimum size.
- Other package markings include the proper shipping name, technical name, the word “Overpack”, and any other markings.
- For IMDG, cylinders marked in accordance with the 2010 version of IMDG are acceptable until no later than July 1st, 2018 (and only if marked by December 31st, 2013), otherwise the sizing requirements must be followed.
Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?
Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:
- A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
- Employees may not perform functions without appropriate training
- Training may be provided by the hazmat employer or other public or private sources
- A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered
Hazmat employee training must include the following:
- General awareness/familiarization training
- Function-specific training
- Safety training
- Security awareness training
- In-depth security training
Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.
For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.
Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.
Call 888.442.9628 for more information. Have a problem? We have a solution.
UN Packaging codes reveal necessary information about a package’s specifications. They provide concise answers to questions of:
what it can hold, how much, where it was authorized, when it was made, etc.
The UN packaging code, however, doesn’t always tell the whole story…
Although there may be other test levels achieved, these may not be reflected on the packaging itself. For example, take a steel drum that has successfully passed the most stringent tests (PG I), and is marked accordingly with the ‘X’ performance level. This package, in all probability, can/has also passed the less rigorous tests required to meet both the ‘Y’ and ‘Z’ performance level. (Referencing a testing certificate, a test report, or the registration of a successfully tested package, will confirm this.)
So what does this all mean?
Filling limits for single or composite packaging, containing less hazardous material for which they were tested & marked (e.g. PG III material in a PG I packaging), can be re-calculated as per below.
Provided all the performance criteria can still be achieved by the higher relative density product, the following will apply:
a. A packing group I packaging may be used for a packing group II material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.
b. A packing group I packaging may be used for a packing group III material with Continue Reading…
When shipping limited quantities (LQ), you do not need to use a UN specification package. But what specs should the package you want to use meet? IATA section 2.7.6 states that the shipper must do a series of drop tests and a 24 hour stacking load test before using the package. Does this then mean that the shipper is done?
Section 188.8.131.52 states that 5.0.2 through 5.0.4 must be met, except for 184.108.40.206, 220.127.116.11, 18.104.22.168(f), 22.214.171.124.(g) and 126.96.36.199.2. Section 5.0.2 is the general packing requirements. The performance test requirements for a package, also known as UN specification packaging, section 188.8.131.52 does not apply as well as 184.108.40.206. After reading these sections, does this mean the shipper can use their package? Not quite, there is another section to read – 220.127.116.11. Here it states that the outer packaging must meet the construction requirements of section 6.2. For combination packages, the most used outer packaging is the fibreboard box. In section 6.2.12, it states that the box must be subjected to the Cobb test. This is a test to determine the water absorbency of the fibreboard box, where the increase in weight cannot exceed 155 g/m2.
Are shippers aware of this requirement? And how are they to determine this when selecting a packaging to use? It might just be easier to use a UN specification package and send the shipment Continue Reading…
The International Air Transport Association (IATA), has recently published a summary of changes that will be seen in the 2012 edition of the IATA Dangerous Goods Regulations (DGR).
Some rather extensive changes to aspects such as packaging have been introduced this year in the DGR 52nd edition. The changes for the 53rd edition, that will take effect January 1, 2012 will be more limited, and are designed in most cases to refine or simplify requirements, rather than create new ones or change requirements significantly.
The expected changes include:
- Provisions for limited quantity packaging will be consolidated in section 2.7.5, moving some information from its current location section 5.0.
- Special provision A44 has been revised to clarify compatibility and packing group requirements for chemical and first aid kits.
- Special provision A802 has been created, to require that entries to the List of Dangerous Goods without packing groups, but with a requirement for UN specification packaging, must use packaging rated at least to the Packing Group II level.
- Special Provision A803 will require that all corrosives in Class 8, Packing Group III be packed in packaging that meets at least Packing Group II standards.(except for limited quantities).
- Special Provision A804 will reaffirm that Gallium and Mercury must be shipped in packaging that meets Packing Group I standards.
- Special Provision A805 will clarify that Dry ice may be packed directly into an overpack without an intervening packaging.
- For Continue Reading…
Many dangerous goods shippers in the United States are finding themselves using new software to complete their IATA shipper’s declaration for air shipments. A new operator variation for Federal Express (FX-18) requires shipper’s declarations be completed using an approved error checking software.
Most of these programs have rules built in to them that force the user to complete specific areas of the declaration with limited options, sometimes based on previous choices. the options given will always be ones that are authorized by the regulations, but the user must still consider their specific product when making choices. Just because the regulations (and software) allow something, doesn’t make it the best choice.
For example, when shipping hydrochloric acid, PG III on cargo aircraft, you must use IATA packing instruction 856. The packing instruction allows the use of metal single packagings. An error checking software will allow a declaration to show metal drums, but it will not, in most cases, alert the shipper that the metal drum must be corrosion resistant, as specified in the packing instruction.
If you find yourself using a new software system to complete your declarations, make sure you know the limitations of the program and make sure that you understand how to use the regulations. Error checking is not the same thing as fully automated!
Shipping lithium batteries has become a confusing issue. Let’s start by asking “what is a lithium battery?”. There are two types of lithium batteries – metal and ion (polymer). The lithium metal battery is also termed “primary” which means non-rechargeable. Typically you find these batteries in watches, calculators, cameras, etc. Lithium ion (and polymer) are “secondary” or rechargeable batteries. These are found in mobile phones, laptop computers, satellite navigation units, etc.
As most shippers are aware, ICAO/IATA rewrote the packing instructions for shipping lithium batteries by air for 2009. In the 51st Edition of the IATA Dangerous Goods Regulations for 2010, the packing instructions for lithium batteries have changed again.
First a quick review: the shipping name Lithium batteries is now either Lithium ion batteries or Lithium metal batteries. And for each of these shipping names are two (2) more: contained in equipment or packed with equipment. The shipping descriptions are:
- UN3090, Lithium metal batteries
- UN3091, Lithium metal batteries contained in equipment
- UN3091, Lithium metal batteries packed with equipment
- UN3480, Lithium ion batteries
- UN3481, Lithium ion batteries contained in equipment
- UN3481, Lithium ion batteries packed with equipment
The packing instructions in the 51st Edition of the IATA Dangerous Goods Regulations now consist of 3 sections. Packing instructions 965-970 each consist of:
- General Requirements: outlines the requirements for that battery type
- Section I: these batteries are fully regulated as Class Continue Reading…