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…

dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
Inner quantities on the IMO declaration…do you need to add it?

For many of us who have been preparing international ocean shipments for sometime now we know that the requirements of what needs to be included on the IMO declaration hasn’t changed all that much.   

One of the biggest frustrations is when carriers or agents of carriers reject the IMO declaration because the inner quantity information is not provided on the actual declaration. I know carriers need to enter information in their internal system for acceptance of shipments (DG or not), and perhaps the system requires the breakdown of inner packaging but why is the IMO declaration being rejected? This information can be provided on an alternate document (i.e., packing list).

As per section 5.4.1.5.1 of the IMDG Code “The number, type and capacity of each inner packaging within the outer packaging of a combination packaging is not required to be indicated.” The Code never asked for it; however, a few editions back, “they” clarified it by adding the above quoted note. And I for one am grateful for it because now when someone comes back stating the declaration is incorrect, I just scan, highlight this section from the Code, and email it to them. I am not trying to be a smart-ass, but for me it’s about educating others. They can read that specific section to avoid future hindrance with others. This goes for me as well. I appreciate it 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…

IMDG Code Updates

Amendment 36-12 of IMDG code finalized
Just in time for the Holidays

The IMO’s Maritime Safety Committee has adopted Resolution MSC.328(90) finalizing Amendment 36-12 which updates the Volumes 1 and 2 of the 2012 IMDG version. These changes become mandatory January 1, 2014. Implementations can be made in part or in whole on a voluntary basis from January 1, 2013 thru December 31, 2013. Amendment 36-12 includes revisions, and additions required for shipping specific substances. In particular, Part 7- Transport Operations has the most substantial changes.

Some of the key changes are as follows:

  • Stowage and segregation provisions including rules separating Cargo Transport Units (CTU) and Vessel Types (7.3, 7.4, 7.5, 7.6, and 7.7)
  • Foodstuffs segregation rules have eliminated the categories “away from” and “separated from” and now have specific storage distance requirements (3.0 meters) when Class 8 or Class 6.1 substances are being transported in the same CTU. (1.2.1)
  • Keep away from heat has now been changed to “Protected from sources of heat” (7.1.2). Specifically this indicates a distance of 2.4 meters away from heated ship structures.  Also there is mention of protecting CTU’s stored on deck, from direct sunlight requiring them to be shaded.

10 new UN Numbers have been added to the Dangerous Good List and include:

  • UN 3498 Iodine Monochloride Liquid (a red liquid that reacts violently with water)
  • UN 3499 Capacitor (articles intended to store electrical energy)
  • 6 new substances under UN Continue Reading…
A New Year, New Requirements for Identification Numbers

New shipping name labels sizes are required as of January 1, 2014

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…

Shipping Something Less Familiar — Bromine

What does one do when the need to ship something outside the realm of “ordinary” arises?

Last month I had to ship a couple of small bottles of bromine for a client. It was more involved than I originally expected.  Before even getting close to the bottle, I wanted to know what was so bad about it. Why is bromine hazardous?

I read through the MSDS to get an idea of what I was about to work with. This shipment was going by ocean so I also had a look at the IMDG code. According to IMDG, it has an extremely irritating odour, is a powerful oxidant, and is highly corrosive to most metals. Also, it is toxic if swallowed, by skin contact or by inhalation. Furthermore, it can cause burns to skin, eyes and mucous membranes. To say the least, it is pretty nasty stuff.

Here is the classification:
UN 1744, BROMINE, CLASS 8(6.1), PG I

As you can see, it is Packing Group I material. I went to IMDG packing instruction P804 to see what was required for packaging and found that it read completely different than the normal P001 and P002 that one frequently sees. This instruction lists four possible ways that this material can be packaged, all varying depending on what type of inner package is used to contain the actual liquid. To give you an idea, Part 1 refers to using Continue Reading…

UN Performance Packaging – Filling Limits

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:

For liquids:

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…

DGIS VI (Part I)

I attended the sixth Dangerous Goods Instructor Symposium (DGIS VI) hosted by LabelMaster in Memphis TN last week.
Things started on Tuesday evening with the Dangerous Goods Trainers Association (DGTA) meeting. The changes concerning NESHTA, BCSP, IHMM and others were discussed. Bob Richard has suggested the DGTA make application at the UN for consultative status. This would allow DGTA to attend the UNSCOE on TDG as observers or as a NGO (non-governmental organization). The website has been updated, see www.dtga.org/. There was also discussion on which trade shows that DGTA should attend.

Later that night some of us boarded buses to go the the FedEx world hub. Here we were given a tour of the FedEx Memphis Hub (night-side) facilities.

Some interesting points of interest:

  • handles approx. 1.3 million packages daily
  • averages 140 landings per night (every 90 seconds)
  • averages 140 takeoffs per night
  • aircraft unloaded in under 30 minutes
  • fleet of more than 366 aircraft (727s to A300s to 777)
  • 7,000 employees at the hub
  • covers 863 acres
  • approx. 42 miles (68 km) of conveyor belts

Thanks to David Jones of FedEx for arranging the tour.

The Wednesday morning session on the ABCs of Training Objectives. This workshop covered the basics in making brief, concise, clear learning objectives. After lunch, Howard Skolnik of Skolnik Industries did a hands-on session on Writing of packing and closure instructions: an exercise in authorship. Howard gave each table an exercise on writing Continue Reading…