PHMSA Modifies HMR Lithium Battery Provision

PHMSA modifies HMR Lithium Battery Provision — Harmonizing with UN Model Regulations, IATA, and IMDG Provisions

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a final rule establishing new standards for air cargo shipments of various types of lithium batteries, including packaging requirements and safeguards for power cells that have been damaged or are headed for recycling.

PHMSA, in conjunction with the FAA, is modifying the HMR regarding the transportation of lithium batteries. These changes with help to ensure that battery shipments are able to withstand transport conditions and are packaged properly to reduce the possibility of damage while in transit.

The intent of the rule making is to strengthen the current regulatory framework by imposing more effective safeguards, including design testing to address risks related to internal short circuits, and enhanced packaging, hazard communication, and operational measures for various types and sizes of lithium batteries in specific transportation contexts. The rulemaking would respond to several recommendations issued by the National Transportation Safety Board.

The final rule is expected be published in the Federal Register sometime in the next 10 business days. According to DOT, voluntary compliance is encouraged when the final rule is published, but compliance is mandatory beginning six months after publication, around in February, 2015.

The final rule will:

  • Enhance packaging and hazard communication requirements for lithium batteries transported by air
  • Replace equivalent lithium content with 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…
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…

Single Packaging
Minimum Height of UN Numbers on Packages

Anatomy of a Box - UN Packaging

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 5.2.1.1 (Vol 2. pg. 139)”, “IATA: 54th Edition; Section: 7.1.5.5 – Size (pg. 619)” and “IMDG Code: 2012 Edition; Section: 5.2.1.1 (Vol 1. pg. 244)” to find the following information.

As of January 1, 2014, mandatory size for “UN number” and letters “UN”:

UN Number Measurement

Some things to note:

  1. 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.
  2. Other package markings include the proper shipping name, technical name, the word “Overpack”, and any other markings.
  3. 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.

New UN Number Measurements

Re-Use of Shipping Containers

Isn’t it good to know that the shipping industry is playing a role in recycling natural resources? While the thought of reusing shipping containers for emergency housing after a natural disaster caught the imaginings of 8th graders I worked with in a recent “Future City” contest proposal, DeMaria Design has brought the concept into reality. DeMaria’s hybrid design for a Redondo Beach container house uses conventional stick-frame construction combined with eight repurposed steel shipping containers to form a two-story home.

“For me as an architect, the challenge has always been how to give my clients the highest level of design while still keeping the projects on budget,” says Peter DeMaria, one of the country’s first architects to incorporate steel cargo containers into residential designs. His Redondo Beach container house, located in Southern California, won the American Institute of Architecture’s Excellence in Design Innovation Award in 2007.

DeMaria tells me that the shipping containers were purchased locally from a Los Angeles area supplier with consideration given to original fabrication, age, condition, and even the previous cargo shipped within the container.

The containers were retrofitted off-site, before being assembled on-site to help further reduce labor costs during installation.

With the large number of shipping operations located around the New York/New Jersey area, this technique may be a worthy consideration in the re-building of the eastern sea board communities affected by Hurricane Sandy.

Redondo Continue Reading…

No Harmonization for Combustible Liquids in the US

On May 30, 2012, the DOT rescinded an April 2010 ANPRM regarding Combustible Liquids. The DOT was soliciting comments whether to consider harmonization of the Hazardous Material Regulations (HMR) applicable to the transport of combustible liquids with the international transportation standards as seen in the UN Recommendations.

The ANPRM was to invite public comments on the amendment to the HMR, and make recommendations on how to revise, clarify or relax requirements to facilitate transport and still ensure safety.

Under the HMR, when packaged in non-bulk packagings, a material with a flash point of 100 -140 oF may be reclassed as combustible liquids and are not subject to the HMR when transported by highway or rail. These materials ARE regulated as flammable liquids when transported by vessel under the International Maritime Dangerous Goods (IMDG) Code and by aircraft under the International Civil Aviation Organization’s Technical Instructions (ICAO Technical Instructions). In addition, there are some exemptions for combustible liquids when transported domestically in bulk quantities.

The classification system in the UN Recommendations has no combustible liquid category or hazard class. The domestic regulation of these materials is in conflict and may be confusing to both domestic and international shippers and carriers of flammable and combustible liquid shipments.

The Results are In

The majority of the commenters opposed harmonization and elimination of the combustible liquid classification and expressed support for the non-bulk and bulk Continue Reading…

IMDG Addendum

In May, 2012 the Dangerous Goods by Vessel (IMDG, 2010 Edition) was amended prior to the routine two year amendments. United States Department of Transportation (DOT) can add to 49 CFR in few months of this year. These updates fix some typing errors but a few regulations are being changed and these will likely become effective as soon as the DOT rulemaking process is completed. Review the items below to see if your activities are going to change:

VOLUME 1

Chapter 4.1 List of packing instructions (wording corrections)
Chapter 5.4 Documentation (dangerous goods documentation changed to container/vehicle packing certificate).

Chapter 7.9 Exemptions, in note 1 delete “(e.g. exemptions for limited quantities in 3.4.7)”
CHAPTER 3.1, Segregation Groups
Include in segregation groups 7 & 9, “3483” Motor fuel anti-knock mixture, flammable

VOLUME 2

DANGEROUS GOODS LIST

Chapter 3.2

For UN 2590, replace “0” with “5 kg” in column (7a)
Duplicate listing; delete first PSN, UN 2687, DESENSITIZED EXPLOSIVE, SOLID, N.O.S.
For UN 2949, insert “T7” in column “13”
For UN3132, packing groups II and III, insert “PP40” in column (9)
For UN 3319, insert “II” in column 5
SPECIAL PROVISIONS

Chapter 3.3

133 Replace “7.2.8” with “7.2.1.10”
181 Replace “7.2.8” with “7.2.1.10”

INDEX

Delete: Aviation Gasoline, see (UN 1863)
4-CHLORO-o-TOLUIDINE HYDROCHLORIDE SOLUTION (UN3450), replace “3450” with “3410”
Fishmeal, UNSTABILIZED (UN 1374), replace “9” with “4.2”
ISOPROPYL ISOCYANATE (UN 2483) replaces “3” with “6.1”
Delete: Trinitrotoluol, wetted, see” (UN 1356). Then insert the following:
TRINITROTUOL, WETTED, class 4.1, Continue Reading…

Transport Canada Publishes Proposed Amendment 11

On March 10, 2012, Transport Canada published a proposed amendment to the Transportation of Dangerous Goods Regulations (TDGR) in Canada Gazette 1. This amendment, called Amendment 11, will, when finalized, address a number of problematic points in the current TDG System.

The significant changes proposed in Amendment 11 include the following:

  • The definition of “person” will be changed for clarity, and a definition of “organization” will be added. This is to align with the meanings already established in the Transportation of Dangerous Goods Act (TDGA), in 2009.
  • Section 1.15, the “150 kg exemption”, is proposed to be changed allow for easier ransport of consumer-type aerosols. The proposed change will allow up to six aerosol containers to be transported in an outer packaging that is not UN specification. This fixes a problem introduced in Amendment 6; the current regulations allow most products transported under these provisions to be transported in non-standardized packaging, but does not exempt Class 2 materials. This was aimed at requiring cylinders to be tested and certified, but aerosols were not given an exception for their outer packagings. Companies that use section 1.15 to transport small, consumer-type aerosols are currently required to obtain a permit that exempts them from this requirement.
  • In Part 5, Means of Containment, the weight or filling limits on packagings will be clarified. For specification packaging, filling limits will be established under the specification. Continue Reading…