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:
- The List of Dangerous Goods has new entries and/or updates to existing substances
- Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
- Section 7 – Marking and Labeling for Limited Quantities has new information
By the end of this year, the International Maritime Organization (IMO) will publish the next revision to the International Maritime Dangerous Goods Code (IMDG). This revision, to be known as Amendment 37-14, will be optional to comply with starting on January 1, 2015, and will become mandatory on January 1, 2016.
What changes will we expect to see in this new revision? Perhaps not as many as in previous amendments, but there will be a number of significant issues addressed. These include:
- A clarification that lamps and light bulbs are not to be considered dangerous goods
- Significant revisions to the requirements for Class 7 radioactive substances
- Addition of shipping descriptions and packaging instructions for adsorbed gases
- Clarifications on classifying viscous flammable liquids
- Clarification on the design and dimensions of various marks, such as the marine pollutant and limited quantity markings, as well as the design and dimensions of labels and placards
- The lettering of the OVERPACK marking must be at least 12 mm high (Mandatory January 1, 2016)
The Dangerous Goods List, Chapter 3.2, will be altered by dividing column 16 (Stowage and segregation) in two, creating column 16a, Stowage, and 16b, Segregation. Codes for appropriate stowage and segregation will be assigned for each shipping description (these codes will be explained in Chapter 7.2).
There will be a number of revisions to shipping descriptions. One important one affects the automotive industry – the shipping names Continue Reading…
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…
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…
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…
Transport Canada published in Canada Gazette, Part I, the amendment titled “Part 4 Dangerous Goods Safety Marks”. Notable changes include:
- introduction of overpacks
- modifications to the use of the DANGER placard
- introduction of new safety marks (3)
- new proposal for placarding large means of containment
Let’s start with the overpacks. Currently under TDG, overpacks are not recognized although they are being used. And this is causing enforcement issues. TC considers an overpack to be a large means of containment. The definition for overpacks will be added to section 1.4 of TDG. Safety marks for overpacks is covered in section 4.10.1. As part of this section, when the overpack has a capacity ≥ 1.8 m3, then safety marks must appear on two opposite sides of the overpack.
The new safety marks to be introduced are:
All the safety marks are in the UN Model Regulations, ICAO Technical Instructions, IMDG Code and 49 CFR.
The requirements for placards will undergo a major change. The table in TDG section 4.15 is replaced. Placards will be required on both ends and sides of a large means of containment. The subsidiary placard requirements do not change. UN numbers on a placard or orange panel will be required when an ERAP is required, or the dangerous goods are liquids or gases in bulk. IBCs (intermediate bulk containers) will be permitted to only have 2 placards with UN Continue Reading…
Transport Canada published Amendment 11 in the Canada Gazette, Part II on December 5, 2012. In Amendment 6 (February 2008), a number of errors were introduced. This amendment corrects those errors, and brings others into line with some changes to the Act (June 2009).
The changes in this amendment are:
- definition of “person” now aligns with the definition in the Act, including the addition of “organization”,
- section 1.15 150 kg Gross Mass Exemption has been changed to allow up to 6 aerosols to be transported without complying with Part 5 Means of Containment. However, the aerosols must have a valve protection cap; in addition, special provision 80 has been changed to provide consistency,
- section 5.5 Filling Limits goes back to the wording prior to Amendment 6 so as to remove any confusion and misinterpretation regarding standards or safety requirements,
- the placarding provisions of the IMDG Code have been placed in Part 9 Road and Part 10 Rail; this allows for the placarding under the IMDG Code which means that placarding requirements are simpler and will reduce if not eliminate confusion,
- other changes are of an editorial nature or typo:
- in section 2.29(2)(c), 0.2 g/L now reads 0.2 mg/L
- in the restricted paragraphs of section 1.15 and section 1.16, the title for Class 4 has been corrected
- in section 1.32.1, the shipping name Liquefied Petroleum Gas now reads Liquefied Petroleum Gases
- table of contents for Part 2 Continue Reading…
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…
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…
I am beginning to feel like Peter Mackay of Hazardous Cargo Bulletin (HCB) – doing this in two parts. Cheers Peter!
The Thursday session continued with Richard Bornhorst, USCG, on Amendment 35 of the IMDG Code. This amendment is at the 16th Edition of the UN model regulations, but does not include the revised EHS/GHS criteria. Some of the new issues with this Amendment are:
- the new limited quantity mark
- new Chapter 5.5 on fumigated containers, including a fumigation certificate
- UN3166 Engines, has two new special provisions 961 & 962
- new TIH n.o.s. entries UN3488 – 3494, such as sour crude oil
- training record retention
- monitoring equipment as part of a CTU does not need to be declared
Some proposals for Amendment 36 are:
- revised EHS/GHS criteria
- adopt the 17th Edition of the UN model regulations
- revision of Chapter 7 – simplified stowage and packing requirements for Class 1 based on vessel type
- books to be published every 4 years with amendments every two years
- new illustrations
- new guidelines for packing CTUs
- revised circular on CTU inspections that contain dangerous goods; 56,000 CTU inspected worldwide in last year with 51,000 in the US alone
Bob Richard then continued the presentation on:
- DSC 16 (Sub-committee on dangerous goods, solid cargoes and containers) on fibre bulk containers (FBCs) – these will be restricted to a stacking height of 3, and restricted on long distance roll on, roll off (RoRo)
- batteries tested prior to 2014.01.01 will be grandfathered
- there Continue Reading…